Further Consultation on the Draft Public Services Reform (Inspection and Monitoring of Prisons) (Formerly Prison Visiting Committees) (Scotland) Order 2014 - Analysis of Written Responses

Section 2: Titles and Roles of Independent Prison Monitor and Prison Monitoring Co-Ordinator

2.1 This section presents the findings relating to the titles; and the nature of the roles and functions of IPMs and PMCs in the revised draft Order (Questions 1-4).

Summary of Section 2

At Question 1, there was a high level of support for the change of role titles from "Lay Monitor" to "Independent Prison Monitor" (IPM) and from "Prison Monitor" to "Prison Monitoring Co-ordinator" (PMC). All of those who expressed a "yes" or "no" view answered "yes", and none answered "no". The most common comments related to positive aspects or benefits of the change (e.g. to reflect the roles better; and emphasise the impartiality of IPMs and the co-ordinating role of PMCs). The most common issues or concerns were: that monitors would be less independent than currently; and that the terminology in the titles was misleading.

At Question 2, "yes" or "no" views were evenly split about whether the revised draft Order provided greater detail on the functions to be carried out by the IPMs. There were differences by type of respondent, with those who answered "no" comprising VC respondents and individuals. The most common comments related to issues or concerns (e.g. the lack of detail or omission of specific issues; the nature of the IPM role; a lack of independence; and the impact of these issues). Positive comments were made about the greater detail (generally and on specific issues).

At Question 3, the highest number of respondents (13, or 45%) answered "no" to whether they supported the clarifications made to the role of the PMC to explain their administrative role in relation to prison monitoring. A slightly lower number (10, or 34%) answered "yes", with views overall mixed. Those who did not support the proposals comprised almost all of the VCs, along with half of the individual respondents and one local authority. The most common comments related to issues or concerns (particularly the view of the PMC role as directive and managerial, with a limited administrative element; and the link to HMCIPS and blurring of the distinction between inspection and monitoring). Positive comments included improved clarity and its benefits, as well as some views of the PMC role.

At Question 4, there was a high level of support for the inclusion of the requirement for the PMC to provide support to, and arrange for the training of IPMs. All of those who expressed a view answered "yes", while none answered "no". The most common comments were positive (e.g. the importance and benefits of support and training). A small number of issues and concerns were raised, related to the discretion of the PMCs; and the requirement for IPMs to attend all training.

Question 1 Change of role titles

2.2 Question 1 asked:

"Do you support the change of the role titles from 'Lay Monitor' to 'Independent Prison Monitor' (IPM) and from 'Prison Monitor' to 'Prison Monitoring Co-ordinator' (PMC)? Please give reasons for your answer."

Overall pattern of views

2.3 Most respondents (79%) addressed the quantitative part of Question 1^[10] and there was a high level of support for the change of role titles. All of those who expressed a view answered "yes", while none answered "no". Six respondents (21%) did not express a specific "yes" or "no" view, although two of these made additional comments relevant to Question 1.

2.4 By type, all of the Visiting Committee; local authority; individual; and health and well-being respondents answered "yes". A small number of respondents (from the criminal justice; inspection, monitoring or complaints; professional or representative; and human rights organisation categories) did not express a "yes" or "no" view (but those who did so expressed agreement). The pattern of quantitative views is summarised in the table below.

Table 2. Support change of role titles?

	Number	%[11]
Ticked or stated "yes"	23	79
Ticked or stated "no"	0	0
Did not express a "yes" or "no" view	6	21
Total	29

2.5 Most respondents made additional comments relating to Question 1 (including two who did not address the quantitative part of the question). Only four respondents did not address this question in some way.

2.6 The most common theme for additional comments was the identification of positive aspects or benefits of the change of role titles. Also common, however, were comments identifying issues or concerns. A few respondents identified specific suggestions, perceived requirements or developments.

Positive comments or benefits

2.7 Most respondents, including respondents of all types, made positive comments at Question 1. These included overall comments in favour of the changes (e.g. welcoming these; expressing general agreement; or suggesting that they were an improvement on the previous proposals).

2.8 Comments were also made on specific benefits of the change of titles, and several respondents stated that these were appropriate or reflected the roles, duties and functions of the IPMs and PMCs more accurately. One local authority respondent stated that the changes modernised the terminology.

2.9 Several respondents made specific comments on the benefits of the change of role title from Lay Monitor to Independent Prison Monitor, particularly the importance of inclusion of "Independent" in the title, to emphasise the impartiality of the role. One IMCO stated that the prison monitoring function would be a separate arm of HMIPS, with HMIPS itself independent of the Scottish Government. One VC respondent stated that the changes recognised who would actually be undertaking independent monitoring, while another stated that IPM was a much more meaningful title. It was also argued that the previous term "Lay Monitor" did not give appropriate weight to the role.

2.10 A few respondents made specific comments on the benefits of the change of role title from Prison Monitor to Prison Monitoring Co-ordinator. For example, it was argued that the changes highlighted their role in administering, co-ordinating and supporting the work of the IPMs. It was also argued that the change provided a more robust description of the role, clarifying the distinction between the roles of IPM and PMC.

2.11 Some respondents, however, qualified their comments with additional concerns, and these are discussed below, along with other issues or concerns raised.

Issues or concerns

2.12 As noted, around half of the respondents raised additional issues or concerns. These were raised most commonly by VC respondents (almost all of which made such comments), as well as by a small number of others.

2.13 The most common theme in relation to issues or concerns related to specific concerns about the independence of the Monitors. For example, some respondents questioned how "independent" the Monitors would be, or argued that they would be significantly less independent than was the case currently. Related to these issues, it was also argued that the terminology used was misleading.

2.14 Several respondents raised specific issues which they considered would hinder or compromise the independence of Monitors, and these were seen to be:

• Recruitment of PMCs by HMCIPS.
• The means of reporting concerns (with a lack of mechanism for IPMs to go directly to the relevant Governor or to Scottish Ministers).
• A lack of independence of monitoring from inspection.
• A hierarchical structure.
• IPM visits to prisons in accordance with a rota agreed by the Co-ordinator and Governor.
• Appointment and management of IPMs by the PMCs, and compliance with instructions issued by them.
• Prisoners' access to IPMs being reliant on the co-operation of the SPS.
• Abolition of the duties of VCs to hear and investigate complaints.

2.15 One VC expressed general disagreement with the PMC title, while a few respondents noted that the revised draft Order still empowered PMCs to carry out monitoring functions, suggesting that this was obscured by the title. A small number of VCs also argued that it was misleading in terms of the primary functions of the PMC.

2.16 A few VC respondents stated generally that the changes did not resolve concerns raised in previous consultation responses, and a few made specific references to the differences to the current situation for VCs, or to the situation in other parts of the UK. One VC respondent stated that they were more concerned with the change of roles than the name changes themselves. Another stated that the proposals did not constitute a "gold standard" of prison monitoring.

Suggestions or requirements

2.17 A small number of respondents made additional suggestions or identified perceived requirements (although clearly some of the issues and concerns highlighted above also imply these).

2.18 Specific additional suggestions which focused on independence included to:

• Maintain the level of independence currently available to VCs.
• Ensure priority for independence in the guidance.

2.19 Suggestions in relation to the role of the PMC included to ensure that:

• The role is made clear.
• The role is only in support of IPMs.
• The role is purely administrative and not managerial.

2.20 One respondent suggested more generally that a case could be made for strengthening the ties between prisons and local communities.

Question 2 Functions of the IPM

2.21 Question 2 asked:

"Does the revised draft Order provide greater detail on the functions to be carried out by the IPM? Please give reasons for your answer."

Overall pattern of views

2.22 Most of the respondents (83%) addressed the quantitative part of Question 2 and there were mixed views of whether the revised draft Order provided greater detail on the functions to be carried out by the IPM. Amongst those who expressed a view, these were split evenly between those who answered "yes" and "no". Five respondents (17%) did not express a specific "yes" or "no" view, although two made additional comments relevant to Question 2.

2.23 There were clear differences of view by type of respondent. Those who answered "yes" included: all of the local authority respondents; the professional or representative organisations; and the health and well-being organisation; as well as half of the individual respondents and those criminal justice organisations and IMCOs who expressed a specific view. Only one VC respondent answered "yes". Those who answered "no" comprised almost all of the VC respondents, along with half of the individual respondents. The pattern of quantitative views is summarised in the table below.

Table 3. Greater detail provided on the functions of the IPM?

	Number	%
Ticked or stated "yes"	12	41
Ticked or stated "no"	12	41
Did not express a "yes" or "no" view	5	17
Total	29

2.24 Most of the respondents made additional comments relating to Question 2 (including two who did not address the quantitative part of the question). Only three respondents did not address this question in some way.

2.25 The most common theme for additional comments in this case was the identification of issues or concerns. A less common theme (although identified by a number of respondents) related to positive comments or benefits of the proposed changes. Several respondents also identified specific suggestions or requirements.

Positive comments or benefits

2.26 Positive comments or perceived benefits relating to the revisions to the functions to be carried out by the IPMs were identified only by respondents who expressed agreement with Question 2 (thus reflecting the general pattern identified at paragraph 2.23 above).

2.27 These included expressions of general agreement that greater detail had been provided, and / or comments that this represented an improvement. One respondent stated that the level of detail was helpful in considering the proposals, and one local authority respondent suggested that the previous consultation had clearly guided the revised draft.

2.28 Amongst issues identified as being clearer (or specifically welcomed) were:

• The role of IPM.
• How the functions fit with the responsibilities of the PMC.
• Assignment of an IPM to a specific prison.
• The primary role of an IPM as being monitoring.
• The IPM's role in the complaints process.
• Recognition of the need for rotas alongside unannounced visits.
• The requirement for formal training.
• Recognition of evaluation.

Issues or concerns

2.29 As noted above, the largest number of comments at Question 2 related to issues or concerns. Although these were made primarily by those who expressed disagreement (VCs and individual respondents), some respondents who answered "yes" or who did not express a specific "yes" or "no" view to the quantitative element of the question also raised issues or concerns.

2.30 A common theme was a perceived general lack of clarity, or insufficient detail in relation to the functions, profile and role of IPMs, particularly (in the view of some respondents) when compared to existing legislation relating to VCs. It was argued, for example, that the current legislation set out the key duties and tasks for lay volunteers, while the revised draft Order contained only limited information on their detailed functions. It was also stated that there was no job description available for IPMs.

2.31 A number of respondents raised concerns about the omission of particular issues. These included:

• The number and composition of IPMs required; the number per prison; a formula for calculation of the minimum number for a prison; or a mechanism for establishing a minimum number.
• The frequency and regularity of visits to each prison, or a minimum number of visits.
• Appointment criteria, or the circumstances in which an individual may become ineligible.
• A duty to hear and investigate complaints; the requirement to produce a written report and inform the prisoner of the findings; and the duty of the Governor to provide a confidential setting to hear complaints.
• Provision for regular IPM group meetings to share information, ensure continuing professional development (CPD), and discuss issues with the Governor and other staff.
• Requirement to produce an annual report on a prison.

2.32 A few respondents argued that previous comments on the need for detail in the legislation (or particular aspects of the detail) had not been taken into account, or that the changes made may be insufficient.

2.33 Concerns were also raised with the actual nature of the IPM role, including the view that the functions were limited in scope and authority compared to current VCs. It was also argued that the new monitoring arrangements appeared less robust. In terms of additional comments on specific aspects of the IPM role, one VC respondent argued that a term of three years was not sufficient. The same respondent stated that the achievement of a good cross-section of people to be IPMs would not always be possible. Another VC respondent expressed disappointment that the annual reporting requirement did not specifically demand IPM input.

2.34 Some concerns also reflected issues raised at Question 1 relating to factors which were seen to compromise independence, such as:

• IPM visits to prisons in accordance with a rota agreed by the Co-ordinator and Governor.
• Appointment and management of IPMs by the PMCs, and compliance with instructions issued by them.
• The requirement on IPMs to investigate specific matters referred by the PMC.
• Evaluation of the performance of each IPM by the appointing PMC.
• The proposal to remove the need for the Governor to respond timeously to any circumstances which concern IPMs.

2.35 Other concerns about the impact or implications of the issues raised included views that:

• The omissions would weaken monitoring generally.
• The lack of detail about the scope and authority of the role of the IPM may have a negative impact on the ability to recruit suitably qualified volunteers.
• The lack of specification of the number of IPMs or frequency of visits may make the voluntary aspect of the role "onerous".
• Less frequent visits by IPMs could lead to less visibility to prisoners and staff.
• The lack of regular meetings would undermine the establishment of a robust system and lead to a loss of influence of IPMs.
• The complaint-handling arrangements would be less robust than current arrangements and a retrograde step for prisoners.
• The quality of reporting may be reduced.
• The ability to call the Governor to account would be weakened and ineffective.

2.36 One VC respondent, while supporting the recognition for evaluation, stated that this would require the determination of quality standards, and expressed concern about who would devise these and how they would be applied.

2.37 One respondent stated that there was confusion over terminology in relation to what was meant by "function", "role", "independence" and "monitoring". Another raised a specific concern about a wording issue in the revised draft Order (Section 7D [3]) relating to the inclusion of the word "may". It was argued that this did not accord with the wording in the consultation paper [page 5 Section 7D]).

2.38 Several VC respondents expressed concern about the high level of reliance on guidance rather than legislative provisions, arguing that this could be written and altered without parliamentary scrutiny.

Suggestions or requirements

2.39 Fewer comments focused on particular suggestions or perceived requirements (although clearly some of the concerns highlighted above again imply suggestions and perceived requirements). Where specific additional suggestions were made, some of these related to the areas of concern identified above.

2.40 For example, one respondent argued that the revised Order should include the frequency and regularity of visits and that this should be in accordance with current practice as specified in Part 17 (Section 151) of the Prisons and Young Offenders Institutions (Scotland) Rules 2011.

2.41 The same respondent argued that the number and composition of IPMs would follow the need to meet the specified frequency and regularity of visits, and should therefore be included in the Prison Monitoring Guidance documents rather than being a matter for legislation.

2.42 One human rights organisation respondent made comments relating to the composition of members and staff for independent monitoring of prisons, stating that they should not only be independent, but should be knowledgeable and have the relevant professional expertise. They stated that there should be a multidisciplinary approach, with the required variety of different fields of professional knowledge, as well as being representative of wider society (e.g. in terms of gender and being representative of BME and other groups). The same respondent argued that any limitations on Monitors visiting prisons should be set out clearly.

2.43 One of the VC members stated specifically that Monitors must be allowed to investigate complaints. Suggestions were also made about meetings, including that: there should be at least bi-monthly meetings; and that the meeting dates should relate to quarterly reports from Governors. It was also argued by a human rights organisation respondent that annual reporting on individual prisons was highly desirable (a view also expressed by a VC respondent, who also argued that there was a need for a regular report from the Governor to the IPMs).

2.44 A small number of additional suggestions were made about wording. One respondent stated that the wording (and the order of the wording) could be improved and made specific suggestions relating to Sections 6A and 7G of the revised draft Order (which are not set out here, but are available to the Scottish Government).

2.45 Some additional suggestions or perceived requirements were also highlighted in relation to guidance. For example, one criminal justice organisation respondent suggested that practice guidance for the IPM could complement the detail in the Order. One of the VC respondents argued that, if guidance was used to set out duties, then a detailed mechanism for reporting changes to Parliament should be set out within the Order. The same respondent stated that any guidance should be developed in partnership with current members of VCs.

2.46 One respondent stated that some of the specific details could not be "set in stone" at this stage. They argued that the "building blocks" were in place, and the fine details could be established once the scheme was operational and evolving.

Question 3 Clarifications to explain the administrative role of the PMC

2.47 Question 3 asked:

"Do you support the clarifications that have been made to the role of the PMC which seek to explain their administrative role, in relation to prison monitoring? Please give reasons for your answer."

Overall pattern of views

2.48 Most respondents (79%) responded to the quantitative part of Question 3. Views were mixed, but the highest number of respondents (13, or 45%) answered "no", and did not support the clarifications to the role of the PMC as outlined in the question. A slightly lower number (10, or 34%) answered "yes" while six respondents (21%) did not express a specific "yes" or "no" view (although one of these made additional comments relevant to Question 3).

2.49 There were differences of view by type of respondent. Those who did not support the proposals comprised almost all of the VCs, along with half of the individual respondents and one local authority. By contrast, only one VC answered "yes" in support of the clarifications, along with the three remaining local authorities; the other individual respondents; and small numbers of respondents of other types who expressed a view. The pattern of quantitative views is summarised in the table below.

Table 4. Support clarifications to explain the administrative role of the PMC?

	Number	%
Ticked or stated "yes"	10	34
Ticked or stated "no"	13	45
Did not express a "yes" or "no" view	6	21
Total	29

2.50 Most respondents made additional comments relating to Question 3 (including one who did not address the quantitative part of the question). Only five respondents did not address this question in some way.

2.51 The most common theme for additional comments at Question 3 was the identification of issues or concerns (largely by respondents who did not support the changes). A number of respondents (all of whom supported the changes) identified positive comments or benefits. A small number of specific suggestions or requirements were also highlighted.

Positive comments or benefits

2.52 Positive comments included overall agreement or satisfaction with the clarifications made in the revised draft Order relating to the administrative role of the PMC. It was suggested, for example, that the definition and role purpose was clearer in the Order, including, for example, the addition of responsibility for rotas, recruitment and training.

2.53 A few additional comments were made about the impact or benefits of the clarification, including that this would:

• Help identify the PMC administrative role, as well as contributing to the overall responsibility of monitoring prison conditions and treatment of prisoners.
• Help remove confusion about who is responsible for the day to day work of monitoring.

2.54 Positive comments were also made about the PMC role (e.g. in relation to this becoming more administrative and supporting). One respondent stated that the additional responsibility to report annually in relation to the monitoring of each prison to which the PMC was assigned would provide good performance information about prisons, and enable accurate annual reporting to Scottish Ministers. Another stated that the changes of role of the employed staff in relation to administration, training and support introduced a note of realism into the plans. They suggested that it was clear that most monitoring work would be undertaken by lay persons who would need administrative input, training and support.

Issues and concerns

2.55 The issues and concerns raised related to two main issues:

• The nature of the PMC role.
• The link to HMCIPS.

2.56 In terms of the nature of the role, it was argued that the role of the PMC was not administrative, or that it contained only a small administrative element. Some of the respondents detailed or summarised the main functions identified in the revised draft Order, and suggested that this meant that the administrative role of the PMC was a very limited one.

2.57 Several respondents argued specifically that the role was directive and managerial (involving managing the IPMs on behalf of HMCIPS), rather than being administrative.

2.58 Linked to these issues, several respondents expressed concerns about the link to HMCIPS. Comments included that the PMCs would:

• Act in accordance with the wishes of the Inspectorate, and be required to comply with instructions.
• Report to HMCIPS on investigations referred to the IPMs.
• Effectively be agents of HMCIPS and managers of IPMs.

2.59 A few VC respondents stated that the emphasis on following instructions from the Chief Inspector suggested that a major part of the PMC role would be to ensure that IPMs followed up on inspection findings. It was also suggested that the PMC role pointed more to inspection than monitoring.

2.60 A few respondents expressed a specific concern that the distinction between inspection and monitoring would be blurred or lost, with monitoring becoming ongoing inspection or a "tick box" exercise. One VC respondent argued that this concern (raised previously) had not been addressed by these clarifications. It was also argued that these arrangements would compromise the independence of monitoring, and reduce the time available for this.

2.61 A few respondents made other comments about the PMC role. One VC, for example, expressed concern that the PMCs seemed to be responsible for supporting individual IPMs, rather than coherent teams. Another contrasted the proposed system to that of Independent Custody Visitors (ICVs), within which, it was said, police Co-ordinators administer, but do not manage.

Suggestions or requirements

2.62 A small number of specific suggestions or requirements were also highlighted.

2.63 At a general level, one professional or representative organisation respondent stated that the PMC should facilitate the role of IPMs rather than diminish this. One local authority argued that the role crossed several functions and would require to remain transparent, given that it would engage with prisoners, prisons and the IPMs. One of the VC respondents also emphasised the importance of talking with staff and prisoners.

2.64 One respondent expressed the view that details on recruitment processes; how rotas would work; and training requirements should be included in the Prison Monitoring Guidance Document.

2.65 As at Question 2, one respondent stated that some of the specific details of the system could be established once it was up and running.

Question 4 Role of the PMC in support and training

2.66 Question 4 asked

"Do you support the inclusion of provisions in the draft Order whereby the PMC is required to provide support, and arrange for the training, of IPMs? Please give reasons for your answer."

Overall pattern of views

2.67 Most respondents (83%) addressed the quantitative part of Question 4, and there was a high level of support for the inclusion in the revised draft Order of the requirement for the PMC to provide support, and arrange for the training of IPMs. All of those who expressed a view answered "yes", while none answered "no". Five respondents did not express a specific "yes" or "no" view, although one of these made additional comments relevant to Question 4.

2.68 By type, all of the VC; local authority; individual; professional or representative; and the health and well-being organisation respondents expressed agreement. A small number of criminal justice; inspection, monitoring or complaints; and human rights organisations did not express a specific view, but those who did expressed agreement. The pattern of quantitative views is summarised in the table below.

Table 5. Support requirement of PMC re support and training of IPMs?

	Number	%
Ticked or stated "yes"	24	83
Ticked or stated "no"	0	0
Did not express a "yes" or "no" view	5	17
Total	29

2.69 Most respondents made additional comments relating to Question 4 (including one of those who did not address the quantitative part of the question). Only four respondents did not address this question in some way.

2.70 The most common additional comments related to the identification of positive comments or benefits of the requirement for the PMC to provide support, and arrange training for IPMs. A further common theme was the identification of suggestions or requirements relating to these provisions. A small number of issues or concerns were also raised.

Positive comments or benefits

2.71 Almost all of the respondents who made additional comments at Question 4 made positive comments or identified benefits relating to support and training. Among these, some respondents welcomed the provision, or expressed their general agreement or support (although a few VCs qualified their comments, and these issues are discussed below). One local authority respondent welcomed the clarification that the PMC role would include providing support to the IPMs and arranging the training of the IPMs, but also arranging a meeting with the IPMs every six months and evaluating the performance of the IPMs.

2.72 Many respondents made comments on the importance of both support and training, or the need for this. One individual respondent expressed the view that the scheme would only be successful if proper support and training were provided.

2.73 One IMCO respondent stated that responsibility for training had been omitted from the previous Order, and had been identified in the previous consultation analysis. They stated that this provision clarified responsibility and placed a requirement on the IPMs to attend as part of their role. One criminal justice organisation and several VCs stated that requests for training had previously been made, and that this provision was overdue. One VC respondent stated that training provision was currently "haphazard" and that they undertook a lot of their own training.

2.74 A few respondents identified particular benefits of the proposed changes, in terms of providing clarity of role and preventing duplication. Several respondents identified the benefits of support and training per se, and these included to enable:

• Effective monitoring.
• Sharing of practice information.
• Consistency of practice and processes.
• Development and maintenance of further knowledge, information and competence.
• Consistency of skills and knowledge.
• Credibility in the process.
• Maintenance of the integrity of the IPM role.

Issues or concerns

2.75 A small number of issues or concerns were raised by some of the VCs and one of the individual respondents. The most common related to the approach to support and training, and the exercise of these functions being at the discretion of the PMCs. A few VC respondents expressed concern that there was no guarantee that training would cover all of the important topics, and that this could lead to inconsistencies across Scotland. It was also suggested that the support provided may not be appropriate to the needs of IPMs.

2.76 Some of the VCs and one individual respondent raised a concern relating to the requirement for IPMs to attend all training arranged by the PMC. It was argued that this could leave the IPM in breach of the Order if, for reasons outwith their control, they were prevented from attending a training session on a particular date. It was also argued that it seemed "overly prescriptive".

2.77 A small number of other issues were raised. One VC expressed the view that it would be difficult to meet the specific needs of individual IPMs if these were a cross section of the community. A few VCs stated that very little of the PMC role related to support and training. One VC raised an issue relating to who could provide the training. The same VC respondent expressed concerns about the demands the requirements would place on a small number of staff with a broad remit.

Suggestions or requirements

2.78 A number of respondents made suggestions or identified requirements relating to support and training. The two most common themes related to: the provision of additional detail; and suggestions about the actual nature of the provision.

2.79 In terms of additional information, one local authority respondent, for example, suggested generally that more information about the support and training that would be available would be helpful. Some respondents argued that more a detailed specification (and, for example, a definition of "support") should be provided, in order to avoid inconsistency and to ensure that each IPM received the same advice and level of input. Related to this, it was argued that it should not be at the discretion of the PMCs, but should be standardised across Scotland.

2.80 A number of suggestions were made about the nature of training, including that this should be:

• Of a high standard.
• Focused and relevant to the current legislative landscape.
• Tailored to the needs of IPMs.

2.81 Suggestions were also made about issues to be covered in training, and these included:

• Mental health.
• Suicide awareness.
• International requirements.
• Human rights legislation.
• Necessary personal safety.
• Familiarisation with the role of the IPM.

2.82 It was also suggested that the issues to be covered in training could be set out in guidance. Additionally, a few respondents argued that attendance requirements for training would best be detailed in guidance. It was also argued that there should be some flexibility in the attendance requirement, in order to ensure that suitable candidates were not excluded as a result of occasional limited availability. Another respondent suggested that it should be made clear that training would take account of individual circumstances, and that there may be a need to give IPMs choices of dates and times to attend.

2.83 One VC respondent expressed the view that the proposed resources available for the "paid" Monitors (the PMCs) could be more usefully directed to providing a funded training programme for the "lay" Monitors (the IPMs).