2013 Annual Report of the Interception of Communications Commissioner

7.21

Figure 13 shows the breakdown of the 2013 recommendations by category.

Figure 13 2013 Prison inspection recommendations by Category

induction &
prisoner
awareness
10%
monitoring of prisoners
mail and
telephone calls
76%

legally privileged
calls & mail
8%

storage, retention & destruction
of intercepted material
5%
police disclosures <1%
translations <1%

7.22 76% of the recommendations fell into 1 key category – procedures for the
monitoring of prisoners telephone calls and mail. There are four distinct areas of failings
in this category.
7.23 First, failings were identified with the authorisation and / or review procedures.
In a large number of instances our inspectors concluded that the interception risk
assessments were not robustly or properly completed. In these instances the necessity
and proportionality justifications for invoking or reviewing the monitoring had not been
sufficiently made out. In these cases it was difficult to understand how the Governor had
been able to make an informed judgement as to whether the monitoring was necessary
and proportionate on the basis of the information contained on the risk assessment,
authorisation and review documentation. In a number of cases the inspectors examined
other relevant documentation in the prisoner’s files and / or reviewed the minutes from
risk management meetings where the particular prisoner had been discussed in an
attempt to satisfy themselves that there was sufficient evidence to support the decisions.
7.24 Second, failings were identified in relation to the actual monitoring. Our inspectors
randomly interrogate the system used for the monitoring of prisoners telephone calls
and the prisoners accounts are compared against the monitoring logs completed by the

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