CAT/OP/GBR/CNPMRO/1 completing a complaint form which is submitted to detention authorities. A complaint can be appealed. After this process has been exhausted, prisoners are able to contact the Prisons and Probation Ombudsman to make a formal complaint to be independently investigated. In Scotland, prisoners can make complaints to the Scottish Public Services Ombudsman. IMBs have a statutory duty to receive and respond to applications (requests and complaints) from prisoners and detainees. This direct feedback gives boards valuable qualitative and quantitative evidence which contributes to monitoring findings and helps identify themes and trends relating to conditions and treatment in individual establishments. 42. In response to the recommendation contained in 105 (e) ICVA acknowledges the challenges of a multidisciplinary approach with volunteer visitors. ICVA, as the representative of these locally administered schemes, has increased its work with HMI Prisons and HMICFRS. The result of this work has improved co-ordination exponentially between the inspectorates and the local volunteer schemes, with HMI Prisons and HMICFRS consulting with scheme managers during inspections, and ICVA passing back information of note for monitoring to schemes. ICVA also shares pertinent points from inspections with stakeholders. In addition, during COVID, HMI Prisons and the IMBs have been exchanging information more regularly in the course of the Inspectorate’s scrutiny visits and in presenting information to HMPPS and the UK Parliament. Paragraph 107 – The Subcommittee recommends that the national preventive mechanism always consider that there is a risk of intimidation, sanctions or reprisals, and therefore take steps to address that risk. In addition to the precautions mentioned above, the mechanism should clearly inform the authorities that reprisal of any kind is impermissible, will be reported to respective authorities and will be followed up by the mechanism. The manner in which the Subcommittee addresses the issue of reprisals and sanctions is set out in CAT/OP/6/Rev.1. 43. In response to the recommendation contained in paragraph 107, the NPM accepts the SPT’s recommendation that the risk of intimidation, sanction or reprisal for detainees is always considered by NPM members. It is the NPM’s view that this risk is clearly communicated to both authorities and people in detention and is guided by protocols on the issue.16 For example, HMI Prisons includes details of their process for dealing with sanctions on the surveys given to people in detention at the start of an inspection. Details of the sanctions protocol are included on posters put up by HMI Prisons during an inspection. HMI Prisons also work to regularly remind staff about sanctions and provide training on the issue to new staff. Furthermore, NPM members are currently discussing how to deal with allegations of abuse where the person in detention fears sanctions. 16 10 UK NPM, 2016, Protocol between HMI Prisons, IMB and PPO on sanctions, https://s3-eu-west2.amazonaws.com/npm-prod-storage-19n0nag2nk8xk/uploads/2016/02/Sanctions-protocol2.pdf ; UK NPM, 2016, Protocol between HMI Prisons and HMICFRS on sanctions, https://s3-eu-west2.amazonaws.com/npm-prod-storage-19n0nag2nk8xk/uploads/2016/03/HMICFRSHMIP-sanctionsprotocol-2017.pdf.