managers. Similarly, senior managers should satisfy themselves that prisoners are being treated in the way which they intend. ■ Where prisoners feel that the prison system is failing to meet its obligations, they should have access to a body which is independent of the prison system. In some countries, prisoners may complain to a general ombudsman. In other countries, there is a prisons ombudsman. The European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment recommends that systems for airing grievances should have two levels, one within the prison and one outside it. ■ The prison authorities should maintain comprehensive records of all complaints. TOPICS FOR DISCUSSION How may a prison director ensure that prisoners who make complaints to the director about staff conduct are not then harassed by staff? If first-line prison staff are bypassed in the complaints procedure they may lose confidence in their own authority and may develop irresponsibility in taking decisions. How can the director ensure that the authority of these staff is not undermined by the complaints procedure? If a large number of complaints are received from prisoners about the allocation of prisoners' work, what steps should the prison director take? CASE STUDIES 1. A prisoner complains to the prison director that a member of staff has been illegally bringing goods into the prison and selling them to prisoners. The complaint is investigated by a senior member of staff, who can find no evidence. The prisoner wishes to take his complaint further. According to the international instruments, what should he be able to do? 2. The prison director instructs you to draw up a procedure to ensure that all complaints made by prisoners are properly recorded. What would you include in such a procedure? 3. A prisoner is delivered to the prison by the police with obvious bruising. The prisoner complains that he has been beaten by police. What action should prison staff take? 133