- 57 c. complaints procedures 95. There is no system of internal complaints available within the prison system. Prisoners may write a request to meet a member of the management team (for example, the director, deputydirector, chief guard or prosecutor). However, the procedure is totally informal with no register of the various complaints, the conversations that take place or of any action taken subsequent to the request. While at Alikarnassos Prison, the Director at least recorded for himself the date and nature of the request, at Nafplio Prison even this basic information was not available. The CPT considers that a proper internal complaints system needs to be put in place; for example, prisoners ought to be able to make written complaints at any moment and place them in a locked complaints box on a prison landing (forms should be freely available); all written complaints should be registered centrally within the prison before being allocated to a particular service for investigation or follow up. In all cases, the investigation should be carried out expeditiously (with any delays justified) and prisoners should be informed within clearly defined time periods of the action taken to address their concern or of the reasons for considering the complaint not justified. In addition, statistics on the types of complaints made should be kept as an indicator to management of areas of discontent within the prison. Of course, prison officers should be encouraged and empowered as far as possible to resolve complaints themselves and only where this is not possible should recourse to a written procedure be promoted. The CPT recommends that the Greek authorities introduce a formal system of complaints, taking into account the above remarks.

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