cold; prison staff can be rude or insensitive; property can be lost; there can be delays in visits or correspondence; and so on. Very often, all that is sought by the prisoner is the recognition by someone in authority that things have gone wrong and an apology. Prison officials need to ensure that such complaints are given proper consideration and that investigations which arise out of them are thorough and frank. Inadequate investigation of minor but justified complaints often leads to a far greater level of grievance than that which arose from the original complaint. While it is often the case that judicial investigation of such complaints will not be merited, the underlying principle is that prison authorities should not seek to prejudge the issue and should allow unhindered access to legal advice. ■ Appeals against the content of decisions: Not surprisingly, prisoners are liable frequently to seek recourse to a more senior authority when the content of an official response to a request or complaint is not the one they wanted. The same conditions apply to such appeals as to complaints about poor practice. ■ Appeals against disciplinary findings: The procedure for disciplinary hearings and punishment was dealt with in chapter 17 of this Manual. Prisoners who feel that the proper procedures were not followed in their case or who feel that they have been punished unjustly should have the right of appeal to a higher authority. PRACTICAL RECOMMENDATIONS ■ It is always better to develop good decision-making procedures than to concentrate on elaborate mechanisms for managing the consequences of inadequate decisionmaking procedures. ■ At the heart of any system of remedies there must be a desire and a willingness on the part of all concerned to tackle issues positively. ■ The aim should be to develop a culture which is based on prevention rather than cure; which seeks to avoid requests becoming complaints and to prevent complaints developing into deep-seated grievances. ■ If prisoners are given proper reasons for any decision which materially and adversely affects them there will be fewer complaints and deep-seated grievances. ■ It is inevitable in the coercive environment of a prison that there will be complaints. These should not be discouraged but should be welcomed as positive contributions to the discharge of responsibility by the prison authorities. ■ Decision-making processes should be accompanied by effective processes for hearing appeals, complaints, allegations and grievances against the decisions made by the prison administration. ■ Requests and complaints should be resolved as close as possible to the point at which they originate, rather than being passed up the administrative chain. ■ It is always preferable that the group of staff with responsibility for reaching decisions on complaints be given the opportunity to reconsider or to explain those decisions to the individuals they affect before any complaint is considered elsewhere. ■ Prisoners should have regular access to senior members of staff who, in turn, should have the opportunity to satisfy themselves that decisions taken by junior members of staff are in accordance with the rules and regulations and the spirit of the rules and regulations. ■ Where prisoners feel that the objectives of senior management are not being implemented by first-line staff, they should be able to discuss this with senior prison 132

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