CAT/OP/GBR/ROSP/1 102. Furthermore, the Subcommittee endorses the concern expressed by the national preventive mechanism that the access of immigration detainees to legal aid at Heathrow Immigration Detention Centre and the quality of the legal aid available are suboptimal.54 103. The Subcommittee recommends that the State party: (a) Ensure that immigration detainees are detained only as a last resort and for the shortest possible time, consider replacing the current practice of removals and implement a time limit on immigration detention;55 (b) Ensure that all immigration detainees (including those in short-term holding facilities) have access to good quality, free legal advice, and ensure that all detainees have effective access to fair and accessible procedures to challenge the decision to detain and/or deport; (c) Provide effective oversight, monitoring and complaints policies and procedures in the immigration detention estate to ensure that any ill-treatment is immediately identified and guarantee the effectiveness of investigations into allegations of ill-treatment; (d) Introduce independent processes, both when a decision to detain is made and during detention, for the identification of people who may face a particular risk of harm in detention. E. Court custody 104. The Subcommittee shadowed a visit of lay observers to a temporary detention facility of the Westminster Magistrates Court in London. In its role as an observer, the Subcommittee was able to assess the situation at this facility and shared key concerns identified by the national preventive mechanism. 105. For example, the Subcommittee observed that the person escort records were incomplete. The purpose of the person escort record is to ensure that all staff transporting and receiving detainees are provided with all necessary information about them, including any risks or vulnerabilities. The lay observers identified and showed to the Subcommittee a number of person escort records that were lacking the name of the receiving officer, information on detainee’s risk of self-harm and information on medication that the person was taking. Another issue brought to the attention of the Subcommittee referred to the lack of an interface between the three computer systems used by the police, the prisons and the courts, which led to inconsistent and incomplete information that could put at risk both the person deprived of liberty and the escorting officer, in cases involving previous assaults on staff. Reportedly, the escort staff treat any person in their custody as a possible risk, which often leads to the unnecessary use of means of restraint.56 For example, the Subcommittee observed during the visit that a child was being handcuffed and escorted by three officers. The custody officer explained that this was a standard procedure for all, which meant that children and adults were treated in the same way. 106. The Subcommittee calls on the State party to implement the recommendations of the reports of the national preventive mechanism member (lay observers) and to ensure that: (a) Accurate and complete records, in particular of person escort records, are maintained; 54 55 56 18 Independent Monitoring Boards, Annual Report of the Independent Monitoring Board at Heathrow Immigration Removal Centre for the Reporting Year January to December 2019 (April 2020). CAT/C/63/4, paras. 47–51. Her Majesty’s Inspectorate of Prisons, Report on an inspection visit to court custody facilities in North and West Yorkshire by HM Chief Inspector of Prisons: 6–16 August 2018. See also Her Majesty’s Inspectorate of Prisons, HM Chief Inspector of Prisons for England and Wales Annual Report 2017–18, p. 88; and Her Majesty’s Inspectorate of Prisons, HM Chief Inspector of Prisons for England and Wales Annual Report 2016–17, p. 86.