Niacro

NIACRO works to reduce crime and its impact on people and communities

                                                     

NIACRO’S RESPONSE TO THE CONSULTATION

 

“THE DRAFT STRATEGY FOR THE MANAGEMENT OF WOMEN OFFENDERS IN NORTHERN IRELAND”.

 

 

INTRODUCTION:

 

NIACRO works to reduce crime and its impact on people and communities and has been operating for the past 37 years. Our vision is to be acknowledged as making a unique contribution to the creation of a society in which communities can live without fear of crime and in which the rights and needs of everyone, including offenders, are equally respected.

NIACRO provides services for children and young people who offend, people in prison and their families and adult offenders in the community. NIACRO also seeks to influence policy and practices which impact on service users.

NIACRO has had particular focus on developing work with women since the transfer of the female prison population from Maghaberry to Hydebank Wood in 2003.

NIACRO provides a Welfare Advice Service to Ash House and assists individuals address problems with debt. During 2008/09, we dealt with 62 women in custody in relation to 190 issues. NIACRO’s Jobtrack Programme offers an individual needs-led intervention to towards gaining employment. Women also participated in a Personal Development ‘Transitions’ programme. We operate a weekly job club for women in the community, offer job placement opportunities as well as connection to a range of training courses. We currently have 7 women in training and 3 in work placements.

During 2007/08, APAC (Assisting People & Communities) ran a support group for a number of women experiencing difficulty in the community such as alcohol / drug abuse and isolation. APAC works with women across Northern Ireland – Portrush, Fintona, Coalisland, and Belfast. NIACRO recruits and trains volunteers from the community to work with offenders and during the past year, 5 have been involved as Mentors. The women have also been encouraged to participate in NIACRO’s adult user forum.

NIACRO also supports the visiting arrangements at Hydebank Wood and transports the children of some women prisoners to the visits. Through FamilyLinks – an information and support service for the families of people in prison – in 2008, we worked with the families of 76 women, carried out 54 home visits, made 86 referrals to other agencies, 314 phone-calls to families and 110 calls to other agencies on their behalf.

 

NIACRO is currently working with the Probation Board for NI and the Women’s Support Network to develop a model for work in the community and will be locating services at the new probation women’s centre, the ‘Inspire’ project, and providing connection to the range of Women’s centre Provision in local communities.

 

NIACRO goes where women are – in prison, the probation centre, etc.

We carry out assessments of reintegration needs and work to motivate and gain engagement. We can help with finances, accommodation, alcohol / drug dependency, relationships, and health and presenting problems.  We try to link women to services in the local community for sustainable support.

We welcome this draft strategy for working with women offenders and the opportunity it provides for comment and discussion. Our response has been produced in consultation with the Women’s Support Network (WSN).

 

CONSULTATION RESPONSE FORM

 

Chapter 5 – Strategic Strand

 

1: Providing Alternatives to Prosecution and Custody

 

Q.Do you think these proposals will be effective in diverting women offenders

from prosecution and custody?

The proposals for Alternatives to Prosecution (2008) fall short of what is required to keep women out of the formal Criminal Justice system.  It is important, particularly when discussing diversion, to have regard to what we recognise as the common factors which bring women into conflict with the law – ie they are more likely to be victims of abuse, experience poor health, difficult economic circumstances, have suffered exploitation. It would be more appropriate therefore to talk in the strategy about diverting ‘women who offend’ from prosecution.

Proposing an increase in the use of fines does not address the circumstances which give rise to women being involved in offending and indeed can lead to additional problems. As the Corston report states, “women prisoners are far more likely than men to be the primary carers of young children…..”

By the same token, women are more likely than men to have responsibility for managing household finances and can therefore be placed under particular pressure when faced with having to pay a fine. Anecdotal evidence suggests that a significant number of women will seek financial loans from “money-lenders” in the community thus adding to the difficulties that may have contributed to their offending.

Other “Alternatives to Prosecution” have been proposed for the general population – none specifically for women who offend.

Restorative Adult Cautioning – has been proposed only for 18-21year olds. Alternatives to prosecution such as informal warnings / adult cautions / restorative cautions would have merit in some cases but NIACRO is particularly concerned that the rehabilitation period for an adult caution to become spent is unnecessarily punitive. This has important implications for those seeking employment. Moreover none of these sanctions provide opportunity for women to address difficulties they may be experiencing which have led to their offending, as highlighted in the Corston report -

ie mental health problems / coercion by men /  relationship problems, etc.

It is NIACRO’s view that to be effective in diverting women away from prosecution any proposed scheme should also be focussed on diverting women from further offending and so activity must be responsive to the needs women have – particularly at the crisis time of arrest.

NIACRO would advocate that the Public Prosecution Service facilitate a Diversion scheme which could offer some form of (a) assessment and (b) voluntary referral to an appropriate service in the community.

Please see document “NIACRO’S RESPONSE TO NIO’S CONSULTATION

TO ALTERNATIVES TO PROSECUTION – A DISCUSSION PAPER – MARCH 2008”.

For those who are prosecuted, the penalty of fines is widely used by Courts because of its flexibility. The recent consultation on providing Alternatives to Custody for Fine Default (2008), suggested that introducing new arrangements for the payment of fines (reminder systems, better information on incomes for sentencers) would help those who can’tpay, and this would impact on the female population.

 Whilst these initiatives may well assist some people to complete their payments, NIACRO is concerned about those who default.  Completing a “Supervised Activity Order” is proposed as an alternative to custody and this is welcome. However, it is reserved only for those considered by the Court to be likely to default at a later stage. Others must face the pressure to obtain the money and deal with the implications for other financial responsibilities they may have.

 

It is NIACRO’s view that monetary penalties can be very appropriate disposals for certain types of offences, such as motoring, but a wider range of lower tariff penalties should also be available to the Courts as alternatives to fines.

 

Q.How best can we engage with sentencers and the community on the

effectiveness of non-custodial disposals for women offenders?

There is clearly an obligation on policy-makers to present Sentencers as well as Legal representatives with the full range of research information, including the findings of the Corston report, which provide strong arguments in favour of taking different approaches to dealing with women offenders. 

Engagement by the community directly with women offenders is likely to be a key factor in influencing attitudes. We believe that engagement with the community/voluntary sector in general, and the community based women’s sector in particular, is vital to meeting the underpinning aims of the Strategy, and NIACRO will work to ensure effective connection with these services for women in the criminal justice system.

NIACRO believes that there would be merit in inviting Sentencers to nominate key representatives to link closely with the development of the strategy.  They should be introduced to outworkings the strategy and meet with the community and voluntary sector engaged in taking initiatives forward.

Q.Are there further measures, which are not identified, which would further

improve the likelihood of diverting women offenders from prosecution and

custody?

Where diversion from prosecution is possible, the offender should be offered an opportunity to receive one-to-one support to address and change the circumstances which brought her to the attention of the Police and Public Prosecution Service.

There are models of such intervention available which provide a casework approach and brokerage to a range of other services in the community. NIACRO’s APAC project (Assisting People and Communities) offers an individual needs-led service, providing practical assistance with budgeting, dealing with debt, as well as help with addictions, with relationships and the impact of domestic violence.

In NIACRO’s view, referral to such a support service could be made conditional for the prosecuting authority concerned as part of the diversion process.  However, any further participation by the person should be on a voluntary basis. Otherwise, failure to participate would attract sanctions thus drawing the individual into the criminal justice system unnecessarily.

NIACRO believes that any diversion from prosecution must also be about providing opportunity for assistance and support.

 

NIACRO is also concerned at the number of women who are remanded in custody because there is no suitable alternative in the community. These women may be considered vulnerable by the courts or have forfeited their accommodation in the community as a direct result of their offending behaviour. They may have significant mental health problems but have not been assessed as appropriate for hospitalisation under the mental health act. They may be foreign nationals with few supports available to them.

It is NIACRO’s view that facility should be made for women so that bail can be considered by the courts as a realistic option. Such a “bail scheme” could include involvement in a support service such as that described (above) and/or access to suitable accommodation.

NIACRO believes the strategy should address the need for a “bail scheme” for women who appear before the Courts.

Chapter 6 - Strategic Strand 2: Reducing Offending

 

Pathway 1 – Accommodation

 

Q.What further actions could we take to address the issue of homelessness

and its impact on women’s offending/reoffending?

The number of women in the criminal justice system may be relatively small but the range of accommodation needs can be diverse – from shared accommodation offering a high level of support to independent accommodation which can facilitate children.

The current range of hostel accommodation is generally unsuitable for women – particularly those who are vulnerable and at risk of exploitation.

Relationship breakdown can be a significant feature of offending and getting accommodation is problematical.

The current proposal identifies voluntary hostels, Women’s Aid and dedicated Probation approved hostel provision. With the exception of Women’s Aid – whose accommodation and support would undoubtedly meet the needs of a number of women offenders – the proposal for dedicated hostel provision is not ideal and in NIACRO’s view, is likely to use up any available resources.

• NIACRO would propose a shared house facility where separate living units can be identified and where there is also an optional shared living area ie similar to some of the university accommodation currently available for students. The shared living area would have staff available at particular times, co-ordinating a programme of services (eg benefits advice) and social/creative activities.
• There is also a need for a lodgings scheme to be developed – particularly geared to meet the needs of younger women.
• In addition, a number of 2/3-bedroomed flats should be retained by the Criminal Justice system for women who have children and who are waiting to be offered social housing.
• Accommodation also needs to be addressed within the Strategy for dealing with Personality Disorder, where small units offering high levels of support will be available for those who cannot manage in the community.

Such a range of accommodation could be managed jointly by PBNI and NIHE. It also needs to connect closely to specialist floating support provision provided by the voluntary sector.

 

Having a range of suitable and safe accommodation available is preferable to investing heavily in only one model.

 

Pathway 2 - Education, Training and Employment

 

Q.Are there further opportunities, which are not identified in the strategy,

which could address the learning and skills needs of women offenders and

provide more effective pathways to employment?

The key factor here is how to best engage with women to encourage participation in learning. NIACRO’s own experience is that Personal Development courses can greatly assist women to gain the confidence they need to avail of mainstream provision.

?     There should be a greater focus at commencement of sentence on educational abilities and work history experiences to inform realistic and relevant educational/vocational/ and employment plans.

?     In doing so women must be provided with advice and guidance regarding the relevance of their convictions to career paths. This should be supported with advice and guidance on disclosing convictions – and developing the relevant communication skills to do so.

?     Opportunities available to gain work experience in prison should be broadened and should include non traditional vocational training  - there are a number of very effective training programmes available in this area within the community.  

?     The strategy must work to include proactive links with DEL programmes/services including Job Assist/ Steps to Work/ Personal advisors – women must have information on such and be afforded links to such.

?     Women must not be refused education/ training opportunities on the grounds of insufficient numbers. Provision should incorporate models of distance learning and one-one / small group work.

?     All education and training delivered should carry some level of certification / accreditation that allows for progression and recognition of prior learning.

?     Peer mentoring is an effective model which should be considered – though this may be severely affected by the introduction of the new Safeguarding Vulnerable Groups legislation.

Given NIACRO’s experience in working with employers it would be important to seek views and support of employers in developing this strategy.

 

NIACRO would welcome a commitment from DEL to working with and supporting the community and voluntary sector initiatives which  raise levels of employability amongst women.

 

Pathways 3 & 4 - Health, Alcohol and Substance Misuse

 

Q.Are there other measures which you think would improve co-ordination

between agencies to more effectively identify and meet the health needs of

women offenders, in particular those with mental health and addiction issues?

The current level of service provision gives limited opportunity for women to deal with their range of problems, eg admission to a residential facility for addiction will not necessarily address mental health problems.  NIACRO would argue the need for a small therapeutic mental health centre for women which would provide direct services for individuals and support other health professionals across Northern Ireland.

NIACRO believes there is a need for an holistic addiction service, a one stop shop, dealing with physical health problems (testing for communicable diseases), mental health services, counselling, family planning, offering group-work, child support, advice re benefits etc.  When women enter into treatment they find it difficult to enter into a range of services. A one stop shop enables them to access all services they need.  They cannot address their mental health until their addiction has been stabilised; if there are two separate services it can result on the women being passed between the two services and no effective work being completed.

 

NIACRO believes that a more joined-up approach to the health care needs of women would be advantageous and that the idea of a one stop shop should be explored.

Pathway 5 - Finance, Benefits and Debt

 

Q.Are there further actions that can be taken to provide an effective cross-departmental response to the impact of poverty and debt on offending?

NIACRO provides Specialist Benefit Advice Services for people in the Criminal Justice System, and in our experience, it is often through the offer of this practical service that we can make connection with them and begin to help them to identify their wider needs.

During the past year, NIACRO has developed a training course accredited by the Open College Network Northern Ireland (OCN NI) - Exploring Benefits & Tax Credits in the Criminal Justice System - which is specifically designed for people working in the criminal justice system. The course looks at the relationship between the social security system and imprisonment and examines and helps raise awareness of the issues, difficulties and obstacles faced by those entering the prison system as well as their families in the community. Its purpose is to enable participants to deliver a basic standard of advice to prisoners, their families, offenders in the community or released prisoners.

NIACRO will be seeking an opportunity to pilot a peer learning model for prisoners, similar to that developed by the Housing Rights Service in Maghaberry prison. NIACRO is developing proposal which would enable people in prison to be trained and supported to deliver a managed information and advice service within prison, focussing on benefits and debt. This programme could be a starting point on a career path for people in prison who wish to build on their training and qualifications to the extent they will be able to compete for jobs in the Advice Sector when they are released. Introducing  such initiatives to the women’s prison would greatly enhance the level of services available for women in custody as well as providing opportunities for individual skills development.

NIACRO is also able to deliver courses to assist Budgeting & Money Management, and can support staff or client groups with training to develop an awareness of debt and strategies to address it.

At a strategic level NIACRO has a productive working relationship with the Social Security Agency where issues affecting our service users, both female and male, are discussed, monitored and addressed. NIACRO contributes to good communication between the prisoner and the Agency, improved decision-making and timely intervention to avoid overpayment of benefit and delay in payment of benefits.

At a policy level NIACRO would like to see a strong cross-departmental effort from government to support Opening Doors, the strategy for funding the advice sector in Northern Ireland which is currently stalled due to a lack of resources. It is vital that advice services based within deprived communities, which exist to combat the causes and effects of poverty and unemployment, are properly funded and supported, especially given the present poor economic circumstances. Also of significance is the Anti-Poverty Strategy, especially in relation to training and employment opportunities for women and families with children.

 NIACRO’s believes that there needs to be cross departmental recognition of the need for resourcing the voluntary Advice Sector and its relevance to meeting the needs women face.

Pathway 6 - Children and Families

 

Q.Are these measures appropriate?

 

Q. What other measures would help women prisoners maintain family links?

 

Q.Is there more that could be done in the community, in liaison with the

statutory and voluntary sectors, to improve access to childcare for offenders

and those at risk of offending?

NIACRO’ Family Links currently work with families in the community to maintain contact with prisoners. We acknowledge that the needs of women are different and they are likely to have particular needs in respect of their families and children. Maintaining family contact can often present great difficulties when the mother of children is prison. The Assisted Prison Visits scheme does begin to address this issue by offering financial assistance to families as a contribution towards the cost of travel to the prison. This often works extremely well and is a welcome and vital service. However in more complex cases, it can often be the case for mothers that are in prison, the scheme falls short. For example, in order to qualify, the carer of children needs to meet strict criteria.

There are a number of women that are estranged from their partners who are often the father and carer of their children.  The partner may  not willing to visit the woman in prison (for a number of reasons) so the children are prevented from visiting their mother, because the Assisted Prison Visit Scheme does not extend this benefit  to the children  in their own right. 

In the case where partner are estranged and the children do not have access to transport from a person that meets the criteria for Assisted Prison Visits, they are then unable to take advantage of child centred visits at the prison because they are unable to get there in the first place.

In addition the children of women prisoners can often end up in the care system. They too are unable to access financial assistance towards transport to the prison because the Assisted Prison Visits Scheme does not apply to children in their own right.

NIACRO’ Family Links works closely with Assisted Prison Visits Scheme to provide volunteer drivers to families that qualify under this scheme, however we are unable to provide volunteer drivers to children that find themselves in this situation. 

NIACRO requests that changes are urgently made to the criteria for awarding Assisted Prison Visits so that children of women in prison can maintain contact with their mothers.

Pathway 7 - Attitudes, Thinking and Behaviours

 

Q.Are these measures appropriate? We would welcome your views on best

practice in this area.

Again it is NIACRO’s experience that helping women explore their own thoughts and feelings can have an impact on their confidence and ability to then gain insight into their offending behaviour.

The proposal to develop special gender-specific programmes for women has merit, and is long overdue, but their design should include the voices and experience of women offenders directly.

The Corston result suggested that we need to do different things with women to get the same results ie to reduce repeat offending.

Gender specific programmes should not therefore be based on adaptations of those used with men but should be responsive to the needs women have.

Consultation directly with women offenders should be an essential part of this process.

Pathway 8 - Supporting Women who have been Abused Raped or who have experienced Domestic Violence

 

Q.What more can be done to give effective support to women whose

offending behaviour is linked to sexual or domestic abuse?

There is clearly a need for a range of therapeutic interventions for women who have been victims of sexual or domestic abuse. The Tackling Sexual Violence Strategy proposes development of services for victims but there is an urgent need for greater recognition to be given to these issues for women facing prosecution and for therapeutic interventions to be identified.

The proposed SARC facility (Sexual Assault Referral Centre) will play an important role, once it is established. However, this is only one resource and women who are victims cannot easily access services without the necessary supports being in place.

If any real impact is to be made in meeting the needs of women then commitment must be made to providing adequate resources to the community and voluntary sector.

Pathway 9 - Supporting Women who have been involved in Prostitution

 

Q. What further actions can be taken to help women move away from

prostitution?

With few exceptions, women who are involved in prostitution do so because they do not believe they have any other choice. The proposal that the new criminal justice “women’s centre” will assist women who are involved in prostitution clearly suggests that prostitution is criminal behaviour on the part of the women concerned. It has long been recognised that this is not a useful approach and that such women are vulnerable to exploitation and need practical and emotional support to help to build an alternative lifestyle.

Those people who seek to gain financially from the exploitation of women should be the focus of the criminal justice system.

 

Helping women move away from prostitution will depend on offering packages of support addressing all pathways in the community.

 

Restorative Interventions

 

Q.What are your views on restorative interventions?

NIACRO has already stated that restorative approaches could be used effectively in some cases as alternatives to prosecution. We welcome the current pilot programmes with women on Probation supervision and the recognition that other services are also needed ie community mediation and re-integration. The voluntary and community sector already have experience in these areas.

Q.In the delivery of a formal service, how can we best engage with partner

agencies to deliver community mediation and re-integration?

NIACRO offers Base 2 services to women in the community who have been threatened / intimidated and the APAC reintegration service offers a casework approach and effective connection with a range of community resources – supporting women who are at risk of loosing their tenancy, for example, as a result of anti-social / offending behaviour.

 We recognise the stigma experienced by women who offend and the importance of ensuring that individuals are given the means by which to address this and build confidence and their ability to change their circumstances.

NIACRO advocates the development of restorative approaches within the community and voluntary sector and the avoidance of using complex court orders.

Gender-Specific Research

 

Q.Do you think these actions will provide sufficient information to assist in the

development of policy to reduce offending?

and

Q.Are there other areas we should be considering? If so, please outline.

NIACRO supports the need for gender-specific research specifically related to Northern Ireland and would emphasise the importance (1) of user involvement in that research and (2) taking on board what resources are working effectively with women – and not assuming that all examples of good practice are to be identified in other jurisdictions.

Whilst the Criminal Justice sector is just beginning to develop gender-specific approaches, the experience of women in communities in Northern Ireland has been quite unique over the past 30+ years and the learning from that experience comes from the community, should be taken on board and applied to work with women offenders.

Gender-specific research in Northern Ireland must take account of the broad spectrum of work in the community and current examples of good practice.

Chapter 7 - Strategic Strand 3: Gender-Specific Community Supervision

and Interventions

 

Q.Are the proposed measures appropriate?

NIACRO welcomes the proposal to develop gender-specific standards for Probation’s work with women and we hope that standards will reflect what individuals can expect from the experience of serving a probation-led community disposal. Whilst acknowledging that it is desirable that compliance and completion of such orders should be consistently achieved, it is hoped that the gender-specific approach will offer a flexible approach so that the ‘standards’ do not simply become a set of rules for the offender and that there is a suitable balance with individual needs.

Q.How can we best engage with external organisations and the wider

community on contributing to service provision to women offenders in the

community?

The establishing of the probation office specifically for women provides a real opportunity to progress models of work which effectively link women to the resources they need in the community. This must involve an individual-needs-led approach which can be resource-intensive.

Through our experience of working with women, NIACRO believes that there are a number of ways in which the community can be supported to engage with women who offend:-

?     by delivering training for the range of women’s services in the community to help them respond to the needs of offenders

?     by recruiting women in the community to become volunteer mentors with female offenders

?     through group-work approaches which have a positive focus and which contribute personal growth

?     by creating a structure which facilitates a bridging of statutory and voluntary services.

Q.What are your views on the provision of dedicated hostel accommodation?

A dedicated hostel for women is a costly proposal and should not be seen as the only solution to meet the emergency accommodation needs women have and most women would prefer not to live in a supervised hostel-type environment.  If such a hostel is to be provided, it should cater for the needs of those few women who have the greatest difficulty managing in the community, eg women with personality disorders, who are particularly vulnerable in other settings. As stated earlier, it is NIACRO’s view that a range of temporary accommodation should be available within the criminal justice system to meet individual needs more appropriately.

To be successful, NIACRO takes the view that we should use this opportunity to listen to women themselves, to pilot new initiatives and not be guided by making adaptations to the approaches currently designed for use with men.

 

Chapter 8 - Strategic Strand 4: Developing a Gender-Specific Approach

to the Management of Women in Custody

 

Q.Do you think these measures are appropriate for the development of an

effective gender-specific approach to the management of women in custody?

NIACRO’s believes that the need for a gender-specific approach is long overdue, but that there is, unfortunately, a real risk that this will not fully be achieved.  The approach is starting from the basis of what currently happens in prison – and what changes could be made to suit the needs of women better, such as better training for staff; changes in search procedures to take account of the impact on women, etc.

 It is NIACRO’s view that we now have a real opportunity to question who needs to go to custody and what can we offer those who do, to make it much less likely that they will re-offend when released.

We (the public) want people to take responsibility for their lives, but we remove responsibility from them in prison.  Why, for example, are we proposing to build a prison with institutional kitchen facilities, rather than domestic units where individuals have some control over the food they eat?

We are at risk of using the same “frame of reference” to determine future decisions as that we have had in the past and its emphasis on the needs of  the institution rather than of the people contained therein.

Q.Are there further opportunities, which are not identified, that could further

improve the response provided to the needs of women prisoners?

Research shows that the needs of women who offend are complex and any custodial regime must try and respond to that range of needs as far as possible. However, institutions do not by their very nature cater for individual needs and therefore only the few people who need to be in prison should be.

NIACRO would want women to have increased responsibility for managing their lives within the prison environment:

- access to a full range of support services (counselling; psychotherapy; etc)

- opportunities to maintain good levels of contact with children and families

- to train for employment and obtain employment in the community prior to release

Q.What are your views on the need for a purpose built women’s prison?

Within this society, we are likely to continue to put in prison people who have committed serious crimes as well as those who present a risk of serious harm to others. We therefore have an obligation to ensure that women are held in a suitable environment and this can only be achieved through a purpose-built and separate facility.

In reality, prison accommodation will be required and should not be

located in a Young (male) Offenders’ Establishment.

 

Chapter 10 - Equality and Human Rights Issues

 

Q.Do you consider that any of the proposals will have a positive equality

impact on groups within any of these nine categories? If so, what is it?

By trying to address the needs of women offenders specifically, and move from a system that was designed by and for men, these proposals should contribute to the equality agenda for women and for their dependents.

Q.Do you consider that any of the proposals will have an adverse equality

impact on groups within any of these nine categories? If so, what is it and how

might we mitigate against this adverse impact?

Unless the strategy fully takes account of the needs of women – and that proposals are followed through - then there is a risk that discrimination on the basis of gender could continue.

It is not clear from the proposals to what extent they will adequately take account of women who are foreign nationals and to do so effectively, the strategy needs to ensure that women are not imprisoned unnecessarily – because no other provision is available eg travel on a false passport.

Q.Will any of the proposals potentially affect the promotion of good relations

between persons of different religious belief, political opinion or racial group?

There is little in the proposals about the promotion of good relations and the strategy should make stronger commitment to addressing the needs of women who have children; women from minority racial groups etc.

Q.Do you have any other comments on the equality impact of the proposals?

Monitoring must ensure that gender-specific measures are implemented fully and not undermined by unnecessary security considerations.

Q.From the proposals are there any areas where you consider there to be a

potential human rights issue?

Yes. Where women are sent to prison for their own personal safety, or because there is no-where else suitable – not because they need to be there for any ‘Criminal Justice’ reasons. A most obvious example is where women are sent to prison because they have mental health problems.

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