There is a clear approach to promoting equality and diversity, underpinned by processes to identify and address any inequality or discrimination. The distinct needs of women with protected and any other minority characteristics are recognised and addressed. Women are able to practise their religions. The multi-faith team plays a full part in centre life and contributes to women’s overall care and support.

Strategic management

39. Strong leadership delivers a coordinated approach to eliminating all forms of unlawful discrimination and promotes tolerance of difference.

The following indicators describe evidence that may show this expectation being met. They do not exclude other ways of achieving it.

  • The centre manager leads by example in promoting equality and diversity.
  • Policies and regime activities reflect the diverse needs of the population.
  • A local equality and diversity strategy outlines how the needs of all groups will be identified and addressed.
  • A named person has overall responsibility for equality and diversity.
  • Staff with specific equalities responsibilities are given sufficient time and support to fulfil their role, and have clear job descriptions and objectives. Women know who the equality and diversity staff are.
  • Equality and diversity issues are monitored regularly by a committee involving managers, staff and detainees.
  • There is regular and effective input by external community representatives, providing advice at a strategic level and support to women.
  • Awareness of the needs of people with protected characteristics is promoted by educational and celebratory events. The centre invites members of local minority nationalities and groups with protected characteristics to take part.

40. By employing fair processes the centre ensures that no detainee or group is unfairly disadvantaged.

The following indicators describe evidence that may show this expectation being met. They do not exclude other ways of achieving it.

  • The centre has clear systems in place to minimise all forms of unlawful discrimination or disadvantage.
  • There are effective monitoring systems to help identify discrimination in treatment and access to services.
  • Staff are trained and supported to identify and eliminate unlawful discrimination.
  • Staff are especially alert to possible tensions between different nationalities.
  • Data on discriminatory incidents and allegations are routinely analysed for patterns.
  • Potential adverse outcomes are investigated thoroughly. Remedial action is promptly taken and evaluated.
  • Monitoring data are made available in various formats so that they are accessible to all people with protected characteristics.

41. Discriminatory behaviour is challenged robustly and consistently.

The following indicators describe evidence that may show this expectation being met. They do not exclude other ways of achieving it.

  • All forms of discriminatory language and conduct are challenged.
  • Women and staff know what behaviour and language are acceptable.
  • Women, staff and visitors know how to report an incident, are supported to do so and are safe from any repercussions.
  • Responses to complaints are timely and based on a thorough investigation. Allegations and incidents are investigated thoroughly.
  • There are effective interventions to support victims of discrimination and to challenge perpetrators.

42. Women play an active role in eliminating all forms of discrimination and are consulted frequently to strengthen the support available.

The following indicators describe evidence that may show this expectation being met. They do not exclude other ways of achieving it.

  • Detainee equality representatives are used to support their peers.
  • Women have the opportunity to express their views about equality and diversity issues on a regular basis.
  • Women have access to staff and outside agencies on a regular basis to have queries answered and seek advice.
  • There is effective consultation on diversity issues, especially on matters relevant to race, nationality, culture and religion.

Protected characteristics

43. Women with protected characteristics and any other minority characteristics are treated equitably and according to their individual needs.

The following indicators describe evidence that may show this expectation being met. They do not exclude other ways of achieving it.

  • Women with protected characteristics are identified systematically on arrival and initial assessments take account of their specific needs.
  • Women with protected characteristics that would make them vulnerable to victimisation in detention, or who need assistance to complete everyday activities, are detained only in exceptional circumstances. When identified, they are referred to the Home Office for an immediate review of detention.
  • Any detainee who requires a personal care plan is identified quickly and an individual plan is put in place. Care plans are kept up to date and, where appropriate, are multidisciplinary.
  • Staff promote awareness of equality, anticipating and addressing the needs of women.
  • Staff are aware of women who may require extra support in the event of an emergency. Personal emergency evacuation plans are used.
  • Staff make reasonable adjustments to ensure that women with protected characteristics can participate in activities that meet their needs.
  • External support groups and networks are effectively promoted and women are helped to make contact with them.

44. The specific needs of women from all racial and ethnic groups are met.

The following indicators describe evidence that may show this expectation being met. They do not exclude other ways of achieving it.

  • Staff are aware of and respond appropriately to race and cultural issues.
  • Action is taken to identify and minimise racist bullying.

45. The specific needs of women from all nationalities are met.

The following indicators describe evidence that may show this expectation being met. They do not exclude other ways of achieving it.

  • Accredited interpreting services are used with women wherever accuracy or confidentiality are important.
  • Accurate records are kept of staff and women who are able to speak languages other than English.
  • Key information about the centre is available in foreign languages.
  • Regular group meetings are held with specific nationality and/or language groups, with the help of interpreters where necessary, to keep abreast of detainee issues.

46. The specific needs of women with disabilities are met.

The following indicators describe evidence that may show this expectation being met. They do not exclude other ways of achieving it.

  • Reasonable adjustments are made to ensure that women with disabilities, including those with learning disabilities/difficulties, have equitable access to a full regime and facilities.
  • Dedicated rooms adapted for use by women with disabilities are available. Ongoing adaptations are made if the needs of the occupant change.
  • Women have access to appropriate specialist support services and equipment, and receive information in a format and language they can easily understand.
  • Women with disabilities that affect their mobility are helped to move around the centre.

47. The specific needs of pregnant women are met.

The following indicators describe evidence that may show this expectation being met. They do not exclude other ways of achieving it.

  • Pregnant women are not normally detained. If there are exceptional circumstances that result in detention, they are clearly documented. Detention is for the shortest possible time.
  • Pregnant women are fully supported in detention by appropriately trained staff, and receive services equivalent to those provided in the community. (See ‘Health services’.)

48. The specific needs of women of all sexual orientations are met.

The following indicators describe evidence that may show this expectation being met. They do not exclude other ways of achieving it.

  • Staff training and development promotes equal respect for women of all sexual orientations and raises awareness of the discrimination faced by gay and bisexual women.
  • The centre fosters a climate of acceptance of different lifestyles.
  • There are clear guidelines for women on what behaviour is acceptable.
  • Women who are gay or bisexual are supported through specific means in the centre, and through referral to external support networks.

49. The specific needs of trans, gender non-conforming (including gender non-binary and gender fluid) and intersex detainees are met.

The following indicators describe evidence that may show this expectation being met. They do not exclude other ways of achieving it.

  • If trans, gender non-conforming and intersex people are detained, they are located in a centre appropriate to their expressed gender identity, following a multidisciplinary case conference involving the detainee.
  • Detainees who wish to begin gender reassignment are permitted to live permanently in their chosen gender identity and can access appropriate medical and other specialist support.
  • All detainees have access to the items they use to maintain their gender expression. Any restrictions are based on properly evidenced justifications.
  • Trans detainees are routinely addressed as, and referred to in the gender they identify with. Non-binary or gender fluid detainees are referred to using their preferred pronoun.
  • Detainees who are trans, gender non-conforming (including gender non-binary and gender fluid) and intersex are able to access support or counselling services where needed, including external support networks.
  • There are arrangements to educate staff, enabling them to adequately support detainees in transition and detainees who are gender non-conforming (including gender non-binary and gender fluid) or intersex.

50. The specific needs of women of all ages are met.

The following indicators describe evidence that may show this expectation being met. They do not exclude other ways of achieving it.

  • Older women are assessed on arrival and, where appropriate, have a regularly reviewed care plan.
  • All staff working with older women know how to recognise the signs of mental health problems and the onset of dementia.
  • The activities provided are appropriate for all age groups.
  • Staff are aware of the distinct needs of young adults, and recognise and respond to individual levels of maturity.
  • Local policies and practices draw attention to the distinct needs of young adults and older people in detention.
  • Young adults and older women are consulted about the range of age-appropriate activities offered.

51. The specific needs of women held in shared facilities are met.16

The following indicators describe evidence that may show this expectation being met. They do not exclude other ways of achieving it.

  • Female staffing ratios are appropriate to the size of the female population.
  • All staff have a clear understanding of the specific needs of women, including those who are separated from dependants and pregnant women.
  • Policies and procedures recognise the specific needs of women from the first point of detention.
  • Women in shared facilities have regular and equitable access to facilities and activities, such as the library, gym, shop and communications.
  • Women are provided with suitable hygiene and sanitary products.
  • Pregnant women are not normally detained. If there are exceptional circumstances that result in them being detained, they are clearly documented. Detention is for the shortest possible time and never for more than 72 hours.
  • Pregnant women have appropriate support. Force is never used against them simply to effect removal. It is only used to prevent harm.

16This is repeated in the Expectations for men in immigration detention.

Faith and religion17

52. Women are able to practise their religion fully and in safety.

The following indicators describe evidence that may show this expectation being met. They do not exclude other ways of achieving it.

  • All women have access to corporate worship and faith-based classes and groups each week, and to ministers of their faith.
  • Women know the timings of religious services, which are well advertised. Timings are appropriate to the different religions.
  • The composition of the multi-faith team is commensurate with the centre’s faith populations.
  • Multi-faith rooms and worship areas are equipped with facilities and resources for all faiths and are accessible for all women to allow contemplation, reflection and prayer.
  • Activities are arranged so that women are able to attend corporate worship.

53. Different religious faiths are recognised and respected.

The following indicators describe evidence that may show this expectation being met. They do not exclude other ways of achieving it.

  • Staff are aware of religious diversity and the way it interacts with cultural and racial identities.
  • Searches of staff, visitors, women and their property are conducted in a religiously and culturally sensitive manner.
  • Women can fulfil religious lifestyle requirements.
  • Women can learn about different faiths.
  • Monitoring of the different religions in the centre population is comprehensive, accurate and reviewed regularly to shape service provision.
  • Women are able to obtain, keep and use artefacts that have religious significance.
  • Women are able to celebrate all major religious festivals and the centre actively promotes them.

54. Women are fully supported by the multi-faith team, which contributes to their overall care, support and preparation for removal or release.

The following indicators describe evidence that may show this expectation being met. They do not exclude other ways of achieving it.

  • Religious leaders meet all new women in private within 24 hours of their arrival in the centre.
  • Religious leaders provide support at times of personal crisis, such as family bereavement, the death or serious illness of a detainee, and imminent removal.
  • Religious leaders demonstrate tolerance and cooperate with each other, working closely with other staff in the centre.
  • Religious leaders establish and maintain links with faith communities and places of worship according to the individual needs of women.
  • Religious leaders are consulted about care planning for women where appropriate, and are invited to assist in preparations for release, removal or transfer.
  • Women of no religion or belief are able to receive support from the multi-faith team and are no less favourably treated than women of faith.

17 The word ‘religion’ here should be understood to include ‘religion and belief’ as they are understood in the context of the Equality Act 2010 and related case law.

Human rights standards

Equality, diversity and faith
In relation to all equality, diversity and faith expectations above: Non-discrimination is a fundamental principle enshrined in human rights treaties and standards. See ICCPR 26; CERD 1, 2; CEDAW 1, 2; ICESCR 2.2; CAT 1; CRPD 5. Human rights standards relating to places of detention should be applied impartially and without discrimination. See SMR 2; EPR 13; BOP 5. See additionally in relation to women, BR 1.

Strategic management
In relation to expectations 39–42 above: See the general non-discrimination provisions set out above and standards relating to staff-detainee relationships (in relation to expectations 26 and 27 above). See additionally in relation to women, BR 30–33.

Protected characteristics
In relation to expectations 43–51 above: In addition to the general non-discrimination provisions set out above, there are specific human rights standards relating to some protected characteristics, including the following:

  • Detainees with disabilities: CRPD 2, 3, 5, 9, 14; SMR 5.2, 55.2, 109.2; UNHCR–DG 9.5.
  • Detainees from national, ethnic, cultural, religious or linguistic minorities: DRM 2; EPR 38. See additionally BR 54.
  • Sexual orientation and gender identity: UNHCR–DG 9.7; Yogyakarta Principles; Council of Europe Committee of Ministers, Recommendations on measures to combat discrimination on grounds of sexual orientation or gender identity.
  • Older detainees: UNHCR–DG 9.6.
  • Women: In relation to ensuring private accommodation for women. See UNHCR-DG 8[48(v)]; SMR 11; EPR 18.8.

Faith and religion
In relation to expectations 52–54 above: All persons have the right to freedom of thought, conscience and religion, see ICCPR 18; ECHR 9. Human rights standards require that there be no discrimination on the grounds of religion or religious belief and that prisoners belonging to religious minorities must be able to profess and practise their religion without any interference. See EPR 13, 29; SMR 2, 65, 66; BOP 5; UNHCR–DG 8 [48(ix)].