Part I: Basis for an effective follow-up adversarial one and there is an established culture among the HMIP inspectors to be open to ‘challenge’ on their findings. A similar process of constructive dialogue and analysis of findings among inspectors has also been established by one of the bodies of the Dutch NPM, the Inspectorate of Security and Justice (IVENJ), as a tool to enable the inspectors to be able to explain and justify to the authorities, if necessary, why they have come to a particular conclusion with the authorities. Furthermore it has been suggested that a focus group approach could be used in some circumstances in order to test recommendations that NPM staff might not be sure about. In such cases the NPM could, for example, seek practical input from former prison officials, while fully observing security and confidentiality considerations.107 These examples suggest that if the NPM adopts a systematic process of constructive and robust ‘testing’ of findings, this can strengthen the actual and perceived legitimacy and credibility of the NPM recommendations and enable the NPM members to justify and explain the recommendations in discussions on implementation. In addition, the number of recommendations made may have an impact on the extent to which they are implemented. As the UK NPM has noted, the number of recommendations its individual member institutions made per report varied significantly (from 3 – 63) and it has noted that ‘large numbers of recommendations are unrealistic for inspected/monitored organisations to implement’, with some suggestion that there should be no more than ten per report.108 4.3 Development and maintenance of an information management system Monitoring bodies will gather a large amount of data during the course of their work and it is essential that this information is collected systematically and filed in such a way that it can be used effectively to inform future activities and strategies. In order to assist follow-up and effectively track progress made to implement recommendations NPMs should hold information on the recommendations they have made, information whether they have or have not been implemented and the reasons for this response.109 To ensure consistency and a set reference point for monitoring particular aspects of detention some NPMs have developed standardised forms and questionnaires to aid the process of data collection and evaluation. For example, the UK HMIP has developed a range of tools to help gather and assess information such as detailed inspection criteria; prisoner surveys (see also Part II, Chapter 1.2); and a guide for inspectors containing a number of standardised forms.110 However, a common problem encountered by torture monitoring bodies in the collection of data is the lack of information and accurate records kept by the authorities. Therefore it is essential that officials and authorities in charge of places of detention keep an accurate and full record of information relating to a wide range of aspects of deprivation of liberty and conditions of detention, such as records of arrest, complaints, the use of disciplinary sanctions, the use of restraint, medical treatment requested and received, time spent in detention; as well as fundamental data on the number of places of detention, their location and the number of persons deprived of their liberty, including statistical information on gender, age, ethnic background etc.; as well as information on staff and personnel. Many would consider an essential tool for following-up on the implementation of recommendations to develop and maintain a database of the recommendations made. It is acknowledged that a good record of recommendations results in a better follow-up visit and facilitates the process of follow-up. As well as being a practical record of the various recommendations that have been made, such databases can also keep track of time-limits for responses to recommendations; the prioritisation of recommendations; status of implementation; and also collate or enable searches of recommendations according to issues Comments provided by Mari Amos, April 2015. UK, NPM, Making Recommendations (2014) para 4. 109 See UK NPM and HRIC, ‘The UK NPM at Five Years’ 16. 110 See UK, HMIP´s website under ‘About our Inspections’: <http://www.justiceinspectorates.gov.uk/hmiprisons/about-ourinspections/#.VTIzpSHBzGe > accessed 12 June 2015. 107 108 - 42 -