ESSEX PAPER 3: INITIAL GUIDANCE ON THE INTERPRETATION AND IMPLEMENTATION OF THE UN NELSON MANDELA RULES Other good practice examples mentioned were telephone hotlines and confidential complaint boxes.457 Types of complaints and contact points Rule 56 (1) and (2) and Rule 57(1) read together suggest a complaints mechanism escalating through various stages, as described below, although the wording makes clear that there is no limitation or specific order for these different stages.458 The different stages envisaged are: 1. to the prison director (or the person appointed by him/her, each day, Rule 56 (1)) 2. to the inspector of prisons during his/her inspections (Rule 56 (2)) 3. to the central prison administration (Rule 56 (3)) 4. to a judicial or other competent authority, including those vested with reviewing or remedial power (Rule 56 (3)) 5. to an independent national authority in case of allegations of torture or other cruel, inhuman or degrading treatment or punishment (71 (1) and (2)).459 There are slightly different provisions depending on the type of request and complaint: 1. Complaints to the prison director (or the person appointed by him/her) must be available ‘each day’ (Rule 56 (1)). 2. Where complaints are raised with the inspector of prisons, the prisoner must have the opportunity to talk to the inspector in private, without the presence of the prison director or staff. (Rule 56 (2) notes that this Rule is equally relevant for external monitors, see Rule 84 (c)). 3 & 4. Rule 56 (3) enshrines the right to make complaints to the central prison administration and to ‘the judicial or other competent authority, including those vested with reviewing or remedial power’. The wording clarifies that such complaints can be made ‘without censorship as to substance’, implying that a) prisoners do not need to issue an internal complaint first, and b) complaints must be passed on as they are made. 5. Specific rules apply in case of allegations of torture or other cruel, inhuman or degrading treatment or punishment, in line with obligations under the Convention against Torture and the Istanbul Protocol.460 They must be dealt with immediately and shall result in a prompt and impartial investigation conducted by an independent national authority in accordance with Rule 71 (1) and (2). CAT SMR revision observations, CAT/C/51/4, para.54. 457  Further guidance can be drawn from Principle 33 of the UN Body of Principles for the Protection of All Persons under Any Form of Detention or Imprisonment, adopted by the UN General Assembly on 9 December 1988, A/RES/43/173. 458  The UN Committee against Torture has recommended establishing ‘a central and accessible mechanism to receive complaints of torture or ill-treatment’ (CAT SMR revision observations, CAT/C/51/4, para. 53). 459  UN High Commissioner for Human Rights, Manual on Effective Investigation and Documentation of Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (commonly known as the Istanbul Protocol), 1999, 2004. See also Principle V of the Inter-American Principles and Best Practices on the Protection of Persons Deprived of Liberty in the Americas. 460  Penal Reform International and the Essex Human Rights Centre | 115