CAT/OP/UKR/3 presence at or absence from that institution. The system is one in which it is easier to lose persons rather than to find them. It is inefficient, incoherent and, from a preventive perspective, wholly inadequate, as it fails to allow easy independent oversight of the movement of individuals by external mechanisms. 63. The Subcommittee also observed that, in State Security Service facilities, individuals could be deprived of their liberty for periods lasting from several hours to several days before they were considered to have been officially detained. Although the detainees were already under the control of investigate units and processes, there was no systematic recording of their whereabouts or well-being available for scrutiny. 64. The Subcommittee recommends that the State party review and reform its system of record-keeping in order to ensure that records are, at all times, comprehensive, accurate, precise and up to date. It is recommended that registers be uniform and accessible to detainees’ authorized representatives and next of kin, as well as to the national preventive mechanism. Furthermore, the Subcommittee recommends that the system to be introduced is such that a third party may easily follow the movement, location and well-being of a person in detention without the need to locate and examine numerous files, papers or slips. 65. The Subcommittee recommends that the State party keep such records for all persons deprived of their liberty, regardless of whether they are kept in a location officially registered as a place of detention by the State party. Contact with the outside world 66. The Subcommittee remains concerned that, for persons in pretrial detention, visits by family members and others are only allowed with the express permission of investigating officers (see CAT/OP/UKR/1, paras. 105-106). In practice, such permissions are rarely granted, resulting in detainees’ isolation from the outside world. Policies for telephone calls vary among SIZOs and ITTs, with some places allowing video calls so long as a guard is present and others restricting calls entirely. Given the lack of mail service in many areas affected by the conflict in eastern Ukraine, restrictions on the use of telephones can completely disconnect detainees seeking to communicate with individuals in those areas. Authorizations to send letters to relatives and others also vary, with some SIZOs restricting that right. It has also been reported that institutions may excessively limit contacts so that, in practice, visits and telephone calls are more restricted than what is required by law. 67. The situation is exacerbated for detainees accused of crimes in connection with the armed conflict in eastern Ukraine who undergo lengthy investigations and therefore face protracted periods of pretrial detention, a situation which prolongs the period during which their outside contacts are restricted. 68. The Subcommittee recommends that the State party enable family members and others to visit and communicate with persons in pretrial detention centres as a matter of both law and practice. It also recommends that any restrictions imposed on contacts are made only in exceptional circumstances and that the State party ensure that its policy on outside contacts applies equally in all similar institutions, such as in all SIZOs. Complaint and oversight mechanisms 69. As mentioned in paragraphs 18, 37-38 and 43 above, the mechanisms currently in place to respond to procedural concerns, for example about conditions and allegations of torture and ill-treatment, could be strengthened. Detainees have asserted that the complaints mechanisms that exist, including those within the Prosecutor General’s Office, the courts and the national preventive mechanism, have proven ineffective since they fail to provide complainants with substantive hearings or meaningful remedies. 70. The Subcommittee is also concerned that an apparent fear of reprisals precludes some detainees from seeking protection through such mechanisms. Detainees have stated that if they submit a complaint they may be accused of “disobedience” (Criminal Code, art. 391) and subject to disciplinary sanctions. They have also cited fear of abuse from detention personnel and from other detainees as additional deterrents. Furthermore, the 12