- 42 84. There is still no proper system of internal complaints available within the prison system.44 In the prisons visited, inmates could make requests (or complaints) for various services by filling out a paper and placing it in a locked box on the wings. However, there was no clear policy regulating the complaints system, with timelines for responses and possibilities to appeal to a higher body if the complaint was rejected, or even who should be responsible for investigating a complaint, especially if it concerned the Director or Chief Guard. Nor were the complaints recorded or any attempt made to compile statistics on the various types of complaints which might inform prison policy. The CPT repeats 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.45 The CPT reiterates its recommendation that the Greek authorities introduce a formal system of complaints in all Greek prisons, taking into account the above remarks. 44 45 See, inter alia, CPT/Inf (2016) 4, paragraph 95. See also the section on complaints mechanisms in the 27th General Report of the CPT: CPT/Inf (2018) 4, paragraphs 68 ff.