MONITORING PLACES OF DETENTION : A PRACTICAL GUIDE 131 3. Every prisoner shall be allowed to make a request or complaint, without censorship as to substance but in proper form, to the central prison administration, the judicial authority or other proper authorities through approved channels. 4. Unless it is evidently frivolous or groundless, every request or complaint shall be promptly dealt with and replied to without undue delay.” SMR, Rule 36 See also ACPR, A-7-a), b) and c), IDRCPDL, art. 50 para 1 and art. 54. Comments The visiting mechanism should examine whether prisoners have recognised means to discuss or contest aspects of their life in detention. The form and content of complaints procedures, or their absence, can be an important indicator of the level of respect accorded to the detainees. How many levels of complaint are available? The first level may be addressed directly to the director of the establishment. Does the detainee have the possibility of uncensored and confidential complaint to a higher instance? The mechanism should examine whether prisoners have uncensored access to an outside authority, independent of the prison system. The visiting mechanism should monitor the system of complaint. ■ Does the procedure meet standards of fairness and justice? ■ How accessible is it to prisoners? ■ Is confidentiality respected? ■ Is the procedure transparent? 2