The Imprisonment Code129 provides for the possibility of exchanging a short visit for a telephone call at the written request of the untried or convicted person, but does not provide for the same possibility in relation to long visits. The European Committee for the Prevention of Torture emphasizes the need for a preferential approach in terms of visits and telephone calls for prisoners whose family members live far from the penitentiary facility (which makes regular visits virtually impossible). Such prisoners should be allowed to accumulate visit times and/or should be provided with improved conditions for telephone communication with their families.130 In contrast, the Special Preventive Group found during a visit to Establishment No. 3131 that there were instances when detainees transferred from eastern Georgia were restricted from making calls as a disciplinary sanction. 2.7. Requests/complaints Effective grievance and inspection procedures are fundamental safeguards against illtreatment in prisons.132 Prisoners should have avenues of complaint open to them both within and outside the context of the prison system, including the possibility to have confidential access to an appropriate authority.133 The Special Preventive Group, as a result of the monitoring carried out in Establishment Nos. 2, 8, 14 and 15 in 2019, found that prisoners face obstacles in the realization of their right to requests/complaints. The convicted/untried person has the right to send a sealed, confidential complaint to a desired addressee, while the penitentiary facility is obliged to ensure the protection of confidentiality of the complaint.134 However, facilities fail to ensure the above. During visits to Establishments Nos. 2 and 8, members of the Special Preventive Group received numerous reports about the censorship of confidential complaints sent to the Public Defender. According to them, in many cases, complaints are 129 Imprisonment Code, Article 17, parts 11 and 12. Report (CPT/Inf (2019) 16) of the European Committee for the Prevention of Torture on its visit paid to Georgia on September 10-21, 2018, para. 51, available in English at: <https://rm.coe.int/1680945eca> [last accessed: 17.02.2020]. 131 September 16-17, 2019, visit of the Special Preventive Group to Establishment No. 3. 132 Excerpt from the 27th General Report of the European Committee for the Prevention of Torture. Section: 1/8 | 19/04/2018, available at: <https://rm.coe.int/16807bc668> [last accessed: 17.02.2020] 133 European Committee for the Prevention of Torture, Standards, para. 54, available at: <https://rm.coe.int/16806ce96b> [last accessed: 17.02.2020]. 134 Article 104 of the Imprisonment Code of Georgia. According to Article 15 of the Organic Law of Georgia on the Public Defender of Georgia, “Applications, complaints and letters sent to the Public Defender of Georgia by persons placed in penitentiary establishments, places of detention and other places of restriction of liberty shall be confidential. They may not be opened or censored. They shall be sent to the Public Defender of Georgia immediately." 130 53