CAT/OP/KAZ/1 benches are provided, there are no windows and no ventilation and no food or water is provided. Some detainees indicated that the investigator gave them food. 59. The fact that all detention facilities are under the same ministry as the investigators is problematic. The Subcommittee recommends that the detaining authority be separate from the investigating officials, which allows for mutual control and excludes the possibility of using detention as a tool of the investigative process or a means to compel prisoners to confess. 60. The Subcommittee views with concern the many transfers between different institutions. Transfers of detainees should be kept to a minimum. As the default option, investigators should travel to the pretrial or temporary detention facilities to question detainees. If investigators consider transfers elsewhere strictly necessary, they should be required to justify those transfers. The Subcommittee recommends that movements of suspects be recorded accurately in order to track their whereabouts. 61. The Subcommittee recommends that the Government bring the conditions of detention in police stations into compliance with international standards, including the conditions of detention during transfers, by ensuring that cells have sufficient daylight, ventilation and space and by providing detainees with water and food. D. Complaints 62. The delegation noted that there were several formal complaints mechanisms in place, including “complaints boxes” in most places of deprivation of liberty. The national legislation in force describes relevant procedures and prohibits reprisals against complainants.9 63. While the legislation prohibits censorship of correspondence, and requires that all mail should be forwarded unopened, 10 many detainees interviewed reported that their correspondence was opened by the administration of the detention facilities. In some cases, they faced reprisals as a result of their complaints, despite the legal provisions prohibiting such reprisals. Meanwhile, nearly all the officials interviewed indicated that they had not received any complaints about misconduct by Ministry of Internal Affairs staff through those channels in recent years. Few detainees appeared to trust the complaints boxes system or other complaint mechanisms. The delegation was told that complaints often remained unprocessed and that detainees did not even receive a registration number for the complaint. Many interlocutors indicated that those who complained rarely received a response, or that they were told after lengthy periods that their complaints had been set aside without any further action. 64. The Subcommittee concludes that, in practice, there are no effective complaints avenues, which leads to a total absence of trust and, in combination with fear of reprisals, a low number of complaints. The Subcommittee therefore recommends ensuring that complaints reach relevant authorities and that the confidentiality of those complaints is respected.11 E. Inspections of places of detention and investigation of allegations of torture 65. The delegation met several oversight prosecutors, who are usually assigned to a particular detention facility. By law, they are tasked with an array of activities specifically aimed at preventing torture. The fact that they visit places of detention almost daily is laudable, but they mentioned that they never received complaints about conditions or treatment. At the same time, almost all detainees interviewed consider the prosecutors part 9 10 11 Criminal Execution Code, art. 14 and Law No. 353-I, art. 20. Law No. 353-I, art. 20. Nelson Mandela Rules, rule 57. 11