CAT/OP/GBR/RONPM/1 86. However, and with the caveat that the Subcommittee accompanied only a small portion of the Inspectorate visit to Cookham Wood, the Subcommittee notes that the prohibition on reprisals was not explicitly mentioned in the interviews conducted by Inspectorate staff. While concurring with the Inspectorate’s assessment that the risk of reprisals was quite low, the Subcommittee emphasizes that prevention of reprisals should be a standard procedure. (b) Independent Monitoring Boards 87. The Subcommittee accompanied three members of Independent Monitoring Boards and the Independent Monitoring Boards National Chair, Dame Anne Owers, during a oneday visit to Heathrow Immigration Removal Centre. 88. The Subcommittee notes with great appreciation the dedication and commitment of members of Independent Monitoring Boards, who are unpaid members of the community. Moreover, the Subcommittee welcomes: (a) The continued presence of Independent Monitoring Boards in the Heathrow Immigration Removal Centre and the unhindered access to all premises and persons; (b) The solid findings contained in the annual report of the Independent Monitoring Board at the Heathrow Immigration Removal Centre for 2018, and recommendations directed to the Home Office and the contractor in charge of the services that pointed at systemic issues, such as indefinite immigration detention, inappropriate use of detention for persons with acute mental-health issues, and concerns regarding the training of staff employed by the contractor. 89. However, the Subcommittee notes that the Independent Monitoring Board was often regarded as a body inspecting the material conditions of day-to-day life in the removal centre, rather than as an interlocutor working for the human rights of persons deprived of their liberty. During the visit to the removal centre, the Subcommittee noted that some persons deprived of liberty perceived members of the Independent Monitoring Board as insensitive to their concrete allegations (for example, a person alleging recent beatings and presenting injuries to his head, and a man reporting a risk of refoulement). Some went as far as alleging that the Independent Monitoring Board was part of the Heathrow Immigration Removal Centre administration. 90. While acknowledging that the members of Independent Monitoring Boards are not in a position to deal with individual complaints, and also noting the levels of anxiety and frustration of persons awaiting a removal, the Subcommittee suggests that a referral system be envisaged, so as to preserve the reputation of the Independent Monitoring Board as an impartial advocate for the human rights of persons deprived of their liberty. 91. The Subcommittee appreciates the continuing presence of the Independent Monitoring Boards in places of detention, which results in close (often daily) monitoring of a place of deprivation of liberty. However, given that only one or two persons carry out visits, it is challenging for the visiting teams to comply with the Optional Protocol requirement of multidisciplinarity. (c) Lay observers 92. Lay observers play a crucial role, by monitoring the treatment and conditions of detention of people when they are held in court custody and in vehicles when they are being brought to and from court. 93. The Subcommittee observed the visit of two lay observers to the Westminster Magistrates’ Court. It commends the professionalism, dedication and empathy demonstrated by the lay observers in the course of that visit. In particular, the Subcommittee notes with appreciation that the lay observers verified thoroughly the records of persons deprived of liberty at the Court. Inaccuracies detected were immediately brought to the attention of the custodial staff and it was explained why those might represent a risk of ill-treatment for detainees. Moreover, the lay observers raised appropriately the issue of a minor who was being transferred from the Court handcuffed and escorted by three police officers. When police officers stated that this was a routine procedure, the lay observers emphasized the need 16