National Preventive Mechanism Tenth Annual Report 2018–19 • • • • written and oral evidence, arguing that an automatic blanket ban on prisoner voting is a disproportionate measure. MWCS made detailed proposals to the Scottish Government in its response to a consultation on reform of incapacity law, highlighting the need to address obligations under the UN Convention on the Rights of Persons with Disabilities. Ofsted provided feedback to the Youth Justice Board consultation in November 2018 to develop and implement standards for children in the youth justice system. Ofsted also submitted written and oral evidence to the Independent Inquiry into Child Sexual Abuse (IICSA). In its evidence, Ofsted noted the marked difference in its inspections of secure children’s homes in comparison with secure training centres. Citing its Annual Report, published in December 2017, Ofsted stated that inspectors of STCs had ‘serious concerns’ about the safety of both children and staff, the rising levels of violence between children and young people, assaults on staff, and difficulties in staff retention.105 The CCE presented evidence to the Joint Committee on Human Rights on its inquiry into ‘Youth Detention: Solitary Confinement and Restraint’, highlighting the unacceptable time that some children are held in separation or segregation. The CCE has also been working with government officials on the development of new Liberty Protection Safeguards to discuss how these will ensure that the rights of children are respected. The IMB Secretariat provided evidence to both the Home Affairs Committee and the Joint Committee on Human Rights inquiries into immigration detention. It drew attention to the damaging effect of indeterminate and, in some cases lengthy, periods of immigration detention on the well-being and mental health of detainees, as evidenced in IMB reports. It also highlighted other issues, including: the use of separation units to house vulnerable detainees suffering from mental illness; the concerning levels of drug use and violence in some immigration removal centres; and overcrowding and unacceptable living conditions, caused largely by inadequate and delayed maintenance. The IMB provided evidence to the JCHR on the deleterious effects of detention policy on the people volunteers met in detention, and raised serious reservations about the effectiveness of the ‘Adults at Risk’ policy in keeping the most vulnerable out of detention. • The IMB also provided written evidence to the Justice Committee’s inquiry into the prison population, focusing on the impact of indeterminate sentences for public protection (IPPs), the inappropriate use of prison for those with a mental illness, and the vulnerability of the female prison population. • HMIPS gave evidence to the Equalities and Human Rights Committee inquiry into prisoner voting in Scotland, supporting the extension of voting rights to all prisoners. HMIPS also provided written evidence to the Justice Committee on the Management of Offenders (Scotland) Bill where it supported the greater use of electronic monitoring as an alternative to custodial sentencing. 105 Independent Inquiry into Child Sexual Abuse, February 2019, Sexual Abuse of Children in Custodial Institutions: 2009–2017 Investigation Report, https://www.iicsa.org.uk/key-documents/9560/view/sexual-abuse-children-custodial-institutionsinvestigation-report-february-2019.pdf [accessed 12/12/19] 48