overcrowding on the detention conditions of those directly concerned, and pointed out that under no circumstances should detained juveniles be placed in such a situation in view of the specific provision they require - based on personalised and tailored educational efforts. The Prison Administration Department replied that the juvenile wings of the Paris Interregional Directorate for Prison Services (DISP) had indeed been experiencing high occupancy rates since the start of 2017, climbing from 87% in January to 104% in April. He included in his response a table of the occupancy rates of these institutions which shows that, since January 2017, institutions receiving children in the Parisian region have seen their occupancy rate go up and that all of them have reached a temporary occupancy rate of more than 100% at some point since the start of 2017, with the exception of Villepinte; the Nanterre juvenile wing was systematically overcrowded in 2017, its occupancy rate spiking at 128% in April 2017. He conceded that other DISPs had also seen the occupancy rates of their juvenile detention facilities steadily increase, especially the directorates in Lille, Lyon and Marseilles. He explained that these high occupancy rates were the result of a structural increase in detention by the courts, something over which the prison authorities do not have any direct control. He said that, to avoid facilities being stretched over-capacity, the DISPs organise administrative transfers to distribute the young offenders across their region. Regarding the Parisian region, he said that his departments were carrying out a transfer policy aimed at harmonising the occupancy rates of juvenile wings and prisons for minors in the Parisian region with those of the neighbouring interregional directorates for prison services with lower occupancy rates, and therefore provide young offenders with acceptable detention conditions and appropriate care. He indicated that 39 young people had thus been transferred since 1 January outside the Paris DISP, and emphasised the close attention his departments were paying to ensuring family ties could be maintained. Finally, he explained that the Prison Administration Department and Judicial Youth Protection Service Directorate were looking into the merits of a joint memo on detained juvenile transfers, so as to specify the specific coordination arrangements, ensure a joint assessment of individual situations prior to any transfer and guarantee the exchange of information between the professionals involved in the juveniles' provision and information for holders of parental responsibility. The Chief Inspector is continuing to keep a close eye on this issue and reiterates her misgivings over the procedures to reduce crowding in prisons via transfers, expressed in the thematic report that the CGLPL published in February 2018 entitled "Fundamental rights under threat from prison overcrowding". This is because such procedures, by nature, tend to disregard prisoners' rights to maintain family ties and their sentence enforcement pathway. 2.1.3 Prisoners' access to the telephone services of the International prisons watchdog (French section) (OIP) Following discussions with several heads of institutions who refused to include the number of the International Prisons Watchdog in the telephone lists for prisoners, the Chief Inspector referred the case to the Prison Administration Department. A range of reasons were given by the heads of institutions to justify their refusals: maintaining good order in the institution, not including this association in the list of automatically authorised associations, or the claim that the OIP is apparently not an association allowing, under the terms of Article 39 of the Prison Act of 24 November 2009, for "the preparation of prisoners' reintegration". In the letter she sent to the Prison Administration Director, the Chief Inspector particularly indicated that all of these arguments appeared questionable, and that denying prisoners the opportunity to ring the OIP amounted to a violation of their rights insofar as this association advocates precisely in favour of defending these rights. 84