on equality and diversity. As a consequence, religious, gender identity, and physical and intellectual disability needs that fall outside established norms are not being routinely met. While efforts have been made to reduce Mäori offending, it is difficult at this stage to measure the effectiveness of these initiatives. Complaints handling Prisoner confidence in the effectiveness of prison complaints processes is currently very low. The ability of prisoners to raise concerns effectively, by accessing processes that are clear, robust, responsive, and consistently applied across the prison estate, is vital to maintaining and safeguarding the integrity and accountability of the prison system as a whole. In addition, poor record keeping by prison staff, and an inability at times to readily retrieve complaint-related information in response to information requests, serve to undermine the effectiveness of the complaints processes. Meal times Meal times across the prison estate do not reflect standard meal times, with breakfast being served between 8.30 am and 9.00 am, lunch at 11.30 am and the evening meal as early as 3.15 pm in some prisons. The intervals between some meals is not optimal and is in breach of the Mandela Rules. Health and disability facilities • Use of long-term seclusion for clients considered to be complex and difficult to manage. • Lack of step-down beds in both mental health and I.D services resulting in bed blocking and least restrictive practices. • Use of night safety procedures (locking someone in their room between certain hours i.e. 8pm to 8am. This is not considered seclusion by the Ministry of Health and is being used by some DHB’s to reduce their seclusion hours. • Increase in environmental restraint. • No minimum entitlements for patients i.e. patients don’t automatically have access to daily fresh air and telephones. • Youth being held in adult services. 21