administration at the Klagenfurt correctional institution.
This problem was already described in the NPM’s reports to the
National Council and the Federal Council in 2013 and 2014. The NPM
advocated systematic recording and evaluation of complaints in light
of the major inequalities in punishments for administrative offenses
(see NPM Report 2014, p. 101 et seq.).
The Federal Ministry of Justice reiterated that there is still no technical
means of implementing the “complaint register” module in the
integrated prison administration. A “complaint book” similar to the
appeals book cannot be reasonably maintained because complaints
can be raised in the most diverse manner (internally and externally).
However, for the NPM, the importance of complaint management as a
source of information regarding deficiencies and opportunities for
improvement is still undisputed.
It is positive that, since the end of 2014, petitions for administrative
review and legal appeals at the Klagenfurt correctional institution
which cannot be remedied within the institution’s own purview are
provisionally being recorded in an index in the form of an Excel file.
The Federal Ministry
implementation of a
correctional institution
2015. All incoming
management, which
number.
First aid
of Justice also gave its assurance that the
complaint register at the Vienna-Simmering
has been accomplished at the beginning of
complaints are now forwarded to the
registers the complaint with a consecutive
With respect to the implementation of an appropriate module in the
integrated prison administration, the Federal Ministry of Justice states
that the available resources of the prison administration and the ITprovider for Federal Departments in Austria will likely be needed until
the summer of 2015 for the nationwide expansion of the integrated
prison administration module for administrative penalty proceedings.
Consequently, the IT experts will not be available to analyse and plan
the “complaint register” module until mid-2015 at the earliest.
Analysis and planning
of “complaint register”
by mid-2015 at earliest
The Federal Ministry of Justice was unable to estimate the scope of the
project and the necessary implementation period. However, the
Ministry predicted that it will not be possible to place the “complaint
register” module into operation in the integrated prison administration
at the beginning of 2016.
The NPM emphasises that an effective complaint procedure is a basic
precaution against mistreatment in prisons. In accordance with the
CPT standard, prisoners should have channels for pursuing
complaints. These channels should be open to them inside and
outside of the prison system [CPT/Inf/E (2002) 1 – Rev. 2010, p. 19]. The
NPM reiterates that implementation of the “complaint register” module
in the integrated prison administration must be pursued with the
utmost vigour.
The systematic recording of complaints in a register is a prerequisite for the correctional
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