Reconfiguring the EstateThe Review reconfigures the estate down to 10 prisons, including a trial Strategic Hubclustering three prisons: HMP Drake Hall, HMP Foston Hall and HMP Styal. The aim is toimprove proximity to home, reduce the number of transfers between prisons andincrease access to interventions intended to reduce reoffending. For example, the CAREProgramme is currently only delivered in HMP Foston Hall, so women must be transferredthere to complete it regardless of what part of the country they come from. The Reviewalso proposes close cooperation between HMP Eastwood Park and HMP Styal withregard to the detention of Welsh women. The review recommends that essential facilitiesand interventions must be available in every region. The table below outlines the keyfacilities or programmes that will be available in each region under the proposals in theReview.Region Prisons Specialist Provision(proposed provision in italics)North East HMP Low NewtonRestricted StatusPrimrosePIPEProposedcapacity344NorthWest andWestMidlandsTrialStrategicHubHMP Drake Hall 340(up by 25)HMP Foston HallHMP StyalCARECAMEO (PIPE)MBURestricted Status (currently used forcourt appearances)Open Unit344(up by 34)485(up by 25)Yorkshire HMP New Hall MBURestricted Status (currently used forcourt appearances)PIPECARE442(up by 17)East ofEnglandHMP PeterboroughMBURestricted StatusForeign national hub384SouthWestHMP Eastwood Park(with links to HMP Styal)MBUPIPE457(up by 94)Londonand SouthEastHMP BronzefieldHMP HollowayRestricted StatusMBUThe Review notes the specialist andhigh intensity provision for womenwith severe mental health problemswhich is not available elsewhere in thesystem.527578(down by13)HMP SendTherapeutic CommunityPIPE281
Other Key RecommendationsResettlement PrisonsAll Closed women’s prisons will become Resettlement Prisons and the Open Prisons willbe shut, leaving just one category of prison for women. There is a lack of clarity as tohow this type of multi-function Resettlement Prison will operate. We strongly believe thatin becoming Resettlement Prisons there must be a change in culture as well as practices.If resettlement functions are not provided effectively in each of the prisons thisrecommendation will condemn all women to serve their entire sentences in ClosedPrisons. The Open Prisons must not close until the resettlement functions areestablished and shown to be working.The Open UnitThe Review proposes the creation of an Open Unit attached to but outside the perimeterof HMP Styal. This Unit, to be set up in an existing building, will hold 25 women who willhave greater access to work and support outside of the prison. This is a significant stepand the closest that the government has come to trialling small custodial units since theywere proposed in the Corston Report. The Unit is intended to be a pathfinder and should,if shown to be successful, lead to the development of similar Units in every region.Reduction in CapacityWhen the review began the operational capacity of the women’s custodial estate was4,583 places. The re-roling of HMP Downview to a men’s prison in September means thecurrent operational capacity is 4,228. The proposals would result in an overall reductionto 4,182 with the loss of 228 open spaces almost balanced by the creation of additionalplaces.Case Management of Women with Complex Needs and Restricted StatusThe Review introduces a case management system for women with Complex Needs andwomen with Restricted Status. The assessment by specialist mental health professionalsof women with complex needs and the resulting care plans should identify women whoare too unwell to be held in prison and improve the level of care women receive whilst inprison. Better care planning is in the interests of the prisons and the staff who work withthe women as well as the women themselves. Reducing the women’s prison populationrequires a reduction in the number of women being sent to prison but also animprovement in the possibilities for women to progress through their sentence planstowards release. These proposals should help to ease the bottle neck caused by the lack
of access to programmes required to meet conditions for release.ContextTransforming RehabilitationWomen in Prison has deep concerns about the impact on women in the criminal justicesystem of the changes taking place under the Transforming Rehabilitation agenda. Thiswill necessarily impact on the effectiveness and potential benefit of the reformscontained in the review. In particular we are concerned that by including Through theGate services as part of the Transforming Rehabilitation contracts these will fail to bewomen-specific and will not effectively link in with women’s services across the wholecountry.Offender Rehabilitation BillWomen in Prison believes that measures contained in the Offender Rehabilitation Billcurrently before Parliament risk increasing the women’s prison population. This isbecause the possible numbers of recalls to prison for breach of the proposed mandatory12 months supervision for all prisoners serving between one day and two years.Communication to Women Currently in PrisonWomen in Prison has an ongoing concern about the failure to communicate proposedchanges to women currently in prison. Without clear communication of proposedchanges rumours spread quickly, especially in relation to the closure of prisons causingunnecessary distress. Women currently held in HMP Askham Grange and HMP EastSutton Park are anxious about being sent back to closed conditions and the lack of atimeframe is exacerbating this anxiety.Key ConcernsOur key concerns are:There are currently too few Open Prison spaces, removing Open Prison for womenis not the right reduction in prison capacity.The good theory behind some of the proposals is going to struggle to become goodpractice due to the practical implications.The proposals should deliver positive long-term change but women are going to becaught up in the disarray caused in the short- and medium-term and there is noguarantee that some of the potential benefits will be delivered.Monitoring and Next StepsReviews only become valuable when implemented and the full risks and benefits may notbe known until the measures outlined are in place. Women in Prison will be working toensure that this review is implemented. We will be monitoring the progress of therecommendations and will publish updates on implementation.
Recommendation 1 – Proximity to home locationNOMS and other criminal justice partners should work together to ensure that womenprisoners can, wherever appropriate, be held as close as possible to their home location(while taking into account wider criminogenic need).Recommendation 2 – Strategic HubsNOMS should provide strategic hubs for women prisoners, reconfiguring court alignmentand making flexible use of custodial capacity to keep women as close to home aspossible for as much of their sentence as possible. This should be achieved by:re-roling Downview from a women’s to a men’s prison. This recommendation hasalready been accepted and it was announced on 4 September 2013;increasing capacity at Foston Hall through upgrading current buildings;formation of a strategic hub between Foston Hall, Drake Hall and Styal to facilitatecloseness to home and progression;refurbishment of mothballed places at Eastwood Park;giving priority to keeping Welsh women in Eastwood Park and Styal;creating additional places at Drake Hall to facilitate the progression of midlandswomen;working with all women’s prisons to develop community employment regimes,subject to appropriate risk assessment, while maintaining closeness to home; andgiving priority to keeping Welsh women in Eastwood Park or Styal for as much oftheir sentence as possible. It is proposed that Eastwood Park focuses on meetingthe needs of Welsh women, and that the two prisons work closely together toensure that they are responsive to their needs.ProgressAs outlined in the Review, proximity to home location is of great potential benefit interms of family and community connections and the maintenance anddevelopment of links to the community and services to which women will bereturning. We hope that this restructure will also lead to far fewer transfersbetween prisons which are highly disruptive for women and for their sentenceprogression.ConcernsThis is a reduction in the women’s prison estate but we would like to seeplanning for an even smaller women’s prison population as there continue to befar too many women unnecessarily sentenced to imprisonment. This Reviewlays out a reduction in the capacity by 401 places despite a there being a 700 placeoversupply at the time the Review began.QuestionsWill the reorganised women’s prison estate be open to further (i.e.. will it bepossible to reduce capacity in each region whilst maintaining services whenfurther reductions in the women’s prison population make this possible)?
Recommendation 3 – HMP Styal Open UnitAn open unit, possibly on the site of Styal, should be established for women from theregion to work in the community and test the impact on reoffending. The unit will providea pathway from prison to employment in their local community.ProgressWomen in Prison has advocated for a radical rethink of how women are held andfor the exploration of the viability of small custodial units. This Open Unit is anopportunity to trial a very different form of custody.QuestionsHow long will this be trialled for and is there an intention (or any budget) to rollthis out in the other regions if successful?What would success look like for the Open Unit?On what grounds could women be transferred back into custody within HMP Styal’sperimeter?Recommendation 4 – Closure of Open Prison for WomenFollowing the successful implementation of community employment regimes in strategichubs, which enable women to prepare for release and progress in their sentence closerto home, closure of the two open prisons should be considered as they will no longeroffer the best option for the majority of women due to their location.ConcernsWomen in Prison believes that there is a need for more open prison spaces notfewer at this stage and would prefer to see an open prison or open unit in eachof the regions rather than a move to holding yet more women at a securitycategorisation above that which is necessary.Stating that all women’s prison will be resettlement prisons and that there will thereforebe increased employment opportunities for women in those prisons is not enough. Thedifference between an open and closed prison is not limited to work opportunities. Thereare also opportunities to be Released on Temporary License (ROTL), subject to riskassessment, for work in the community and for family time. There is a significantdifference in the facility itself and in the culture of the prison. It is not clear how theincreasing level of trust and responsibility provided by open prisons will be replicated ina closed environment. We would question whether it ever can be.No timescale is given for this proposal but we believe that if these prisons are to closethen they must not close until the systems are fully functioning in the resettlementprisons to enable the same level of opportunity for work and family visits outside theprisons. We also believe the closure should not come until the questions about impact onwomen’s sense of sentence progression and preparation for release through more openconditions have been answered. This is a particular issue for longer sentencedprisoners.It is an ongoing concern that too many women held at a higher security level thannecessary, subjecting them to greater control and more punitive regimes than areproportionate to any risk they may pose.
The review later makes reference to the importance of ROTL in enabling community andfamilies ties, but there is no recommendation on this. The systems to process largenumbers of ROTLs in every prison must be in place prior to the closure of the openprisons. Women transferred from the open prisons at the time of closure should maintainthe same opportunities for ROTL. Preparedness to deliver this effectively will includeconsideration of transport arrangements for women to get to work and family,development of relationships with potential employment and volunteering opportunities.The news of this probable closure has caused distress and anger to the women currentlyheld in HMP East Sutton Park and HMP Askham Grange who fear that they will bereturned to closed prisons, something which feels like a significant step backwards forthem.QuestionsWhen will the closed prisons be judged to have sufficient resettlement processesand support for the two open prisons to be closed?Recommendation 5 – Learning from the Offender Personality DisorderPathway: joint commissioningForthcoming evaluation of the Offender Personality Disorder pathway should be used toinform further development of joint commissioning and delivery of services to those withthe highest levels of need.ProgressJoint commissioning is essential for coherent services and to recognise thatmental health interventions as well as or instead of) criminal justice responsesare more appropriate for many women in prison.ConcernsThis section of the review speaks about “whole system approach” but a moreholistic approach is needed for tall women in the system not just for women withpersonality disorders and complex needs.QuestionsHow will the privatisation approach of Transforming Rehabilitation fit with thisintention for joint commissioning? What commissioning responsibilities willNOMS retain in order to enable joint commissioning once the TransformingRehabilitation contracts are in place?Recommendation 6 – Women with complex needs: central casemanagement systemA central case management system for women with complex needs should start work assoon as possible to provide direction for the care and management of these womenensuring that they benefit from the most appropriate interventions and regimes availablefor their particular needs.ProgressThis is a much needed development. It has been an ongoing concern for Womenin Prison that for some women prison is causing further damage to their mental
health and well being and that the complexity of their needs presents a barrier toparticipation in interventions that would enable them to progress through their sentenceplans towards release. Women in Prison has been told that the assessment and reviewprocess will be carried out by a specific, specialist board including mental healthprofessionals. The process of individual assessment by independent professionalsshould identify those women for whom prison is an inappropriate place of detention(facilitating transfer to secure psychiatric settings). The sentence/care plans and regularreview should ensure that women with complex needs can access relevant interventionsand progress through their sentence towards release.ConcernsIn order to have the positive impact intended this will need to be linked toimproved access to relevant interventions, offending behaviour programmesand training and education opportunities (as detailed in recommendation 12).QuestionsWhat is the threshold to be classified as having complex needs?How many women will be case managed in this way?Will women have access to independent advocacy support? This is beneficial both to thewomen prisoners and for prison management (as has been shown with the CAREProgramme advocates)?Recommendation 7 – Women with Restricted Status: central casemanagement systemRestricted Status (RS) women should be included in the central case managementsystem for women with complex needs which will ensure their access to the mostappropriate regimes and interventions taking into account their security status.Recommendation 8 – Women with Restricted Status: review reportsRS review reports should focus on reporting behaviour and progress made by the womenin the context of their risk factors and offending.Recommendation 9 - Women with Restricted Status: access tointerventionsRS women should be assessed for their suitability to access relevant interventions toenable them to evidence a reduction in risk, where this has been the case.ProgressWomen with Restricted Status are often the hardest women prisoners to talkabout due to the nature of their offences and this means that their treatment andneeds have often been overlooked in discussions about the women in the criminaljustice system. Therefore, we welcome the attention paid to this group. The smallnumbers of women (11 at present) present a problem for NOMS in terms of management.However, the commitment to have capacity to hold women with Restricted Status in morelocations should enable more women to be held closer to home.ConcernsWomen will only be able to benefit from the case management system if theinterventions/programmes are available in the prisons they are held in. A case
management system alone will not progress women through their sentence. If a woman isassessed as being unsuitable to participate in relevant interventions then prisons mustidentify what steps could be taken to work towards the woman being able to participate.QuestionsWill there be access to independent advocacy for women with RestrictedStatus?Are suitable interventions available? Will they be available in all of the prisonsthat will hold women with Restricted Status?Recommendation 10 – All Women’s Prisons to be ResettlementPrisonsAll women’s prisons will be resettlement prisons under the Transforming RehabilitationProgramme.ProgressThis should enable more women to prepare for release closer to home, so long asall the systems are in place.ConcernsThe Review refers to through the gate support and the mandatory 12 monthsupervision for all short-sentenced prisoners provided for in the OffenderRehabilitation Bill. Women in Prison are deeply concerned about the potential impact ofthis supervision and believe it is punishment not support.Women in Prison have delivered and championed through the gate support for womenleaving prison, but this is based on our model of voluntary support provided by anindependent, specialist organisation. What is proposed in the Offender Rehabilitation Billwill be mandatory supervision with the possibility of recall to prison for breach ofwhatever conditions are put in place. In effect this is the creation of a 12 month licenseperiod for every prisoner serving between one day and two years. The government hasidentified that they believe this will lead to a significant increase in the prison population.Desistance theories all talk of the importance of willingness to change and theimportance of choosing to access support at the point that a person wants to makechanges.Women in Prison has received assurances that measures are being put in place toensure that this will be provided by specialist women-specific services. This is essentialin order to reduce the likelihood of breech and recall to prison.Women in Prison strongly believes in the value of through the gate support but not in thisform. We are also concerned that by describing the mandatory supervision as a Throughthe Gate service there we be no space for support services which women can choose toaccess and which we have found to be effective in reducing reoffending.QuestionsWhat measures are in place to ensure that there will be women-specific throughthe gate support, linked into women’s support services across the country?What possibilities will there be for independent through the gate support services tooperate?
Recommendation 11 – Increased provision of family daysProvision of family days in women’s prisons should be increased and other methods ofmaintaining contact between visits should be explored.ProgressThis is a positive development and we would support the proposal in the Review toappoint (and resource) a Family Engagement Worker in each prison. The Reviewalso states that technology should be used to enable families to better stay intouch and we would strongly support the use of video calling to enable morefrequent contact, especially for families for whom visits are not possible.QuestionsAre there any plans for the development of “family houses” just outside theperimeter to facilitate family visits?How will good practice from the family stays at HMP Askham Grange bemaintained when the prison is closed?Recommendation 12 – Interventions to be more widely availableacross the estateInterventions should be commissioned more widely across the women’s estate to ensurethat strategic hubs meet the needs of their populations. Holding women closer to homeand reducing the need to transfer between prisons will support the development ofappropriate and supportive relationships with staff and other prisoners. This can reducefeelings of isolation, distress and the risk of self-harm.ProgressAs noted above the provision of high quality effective interventions across theestate is essential to enable women to progress through their sentence . It is alsoessential in order to halt some of the disruption caused by transfers and problemsresulting from prisons offering programmes that are not consistent in theirmethodologies.ConcernsThere is a possible risk to innovation. We would encourage there to still beopportunities for interventions to be trialled on a small scale first with thepotential to be rolled out if effective (as happened with the CARE Programme).QuestionsHow will this work in practice, will there be national commissioning ofinterventions for the whole women’s estate?To what extent will prisons get to pick and choose what interventions they offer?Will there be a requirement to ensure all prisons offer certain interventions?Recommendation 13 – Explore women-specific substance misuseservices with a focus on relationshipsNOMS will explore with NHS commissioners responsible for commissioning substance
misuse services in custody, whether substance misuse services provided to womenshould include a focus on relationships as a core element of encouraging futureabstinence.ProgressWomen in Prison advocates for women-specific substance misuse programmesbecause the root causes of women’s substance misuse are different from men’sand therefore the responses need to be gendered too.ConcernsThe quality and efficacy of the programmes will depend on who delivers themand their knowledge and experience of delivering women-specificinterventions.Recommendation 14 – Consistent services for survivors of domesticviolence and women involved in prostitutionProvision of services to women who are survivors of domestic violence or who have beensex workers should be of a consistent quality and should meet the relevant NOMSframework.ProgressHigh quality, safely delivered interventions provided by independent specialistorganisations should be available in all women’s prisons and links should be madewith organisations that may be able to support women on release. Women inPrison has repeatedly stated that there needs to be training, resources and support forthe Domestic and Sexual Violence and Prostitution Leads, so we are pleased to see thisrecommended in the Review.QuestionsWill these services be available in all women’s prisons?Recommendation 15 – Expansion of peer-led life skills trainingExisting provision of life skills training should be increased and expanded so all prisonsoffer peer led services in the following areas:independence skills classes;classroom assistant roles;self-harm support and prevention; andadvice giving in other settings, including induction, pre-release, motivational workand preparation for other regime activities or interventions.ProgressLife skills training is useful in prisons and peer-led projects offer opportunities forwomen to use and develop skills as advisors, facilitators and mentors. Whendelivered well there are clear benefits for those giving the advice as well as thosereceiving it.
ConcernsThe quality of training, advice and support delivered and the confidentiality andsafety of the service depends on the quality of training and support received by the peertrainers and peer mentors.This recommendation presumably ties in with the changes to Incentives and EarnedPrivileges which require prisoners to “help other prisoners or prison staff” to earnEnhanced Status. Women in Prison has concerns about this high threshold for earningprivileges and the impact this will have on women who for their own well being and metalhealth have chosen not to undertake such activities.QuestionsWho will be training and supervising the delivery of these courses and services?Will external supervision be available for the mentors and advisors?Recommendation 16 – Closure of the Mother and Baby Unit at HMPHollowayThe mother and baby unit at Holloway should close in order to reduce over-supplywithout affecting closeness to home. There would be a further reduction of ten placesshould Askham Grange close.ConcernsWomen in Prison is concerned that there is not an oversupply of places but anunderuse of them. Women in Prison believes that in the last 5 years fewerpregnant women have been passing the risk assessment for the Mother andBaby Units. We believe that there has been an increased risk aversion rather than anincreased risk. Therefore, there should be a review of the criteria for suitability forMother and Baby Units and greater efforts to ensure that more women who give birthwhilst in prison are provided with the opportunities and support to enable them to use theMother and Baby Unit facilities.Whilst HMP Bronzefield is within the same region as HMP Holloway it is significantly moreexpensive and more difficult to access from most London boroughs which will impact onvisiting families members and access to support services.QuestionsWhat support is being provided to women who give birth in prison who are not ona Mother and Baby Unit?Recommendation 17 – Foreign national women: Hub at HMPPeterboroughWork should be undertaken with the Home Office to develop a hub at Peterborough forforeign national women who are likely to be deported, taking into account best practicefrom the male hub and spoke system. This will allow for more effective decision makingby the Home Office while providing clarity earlier in their sentence for these women.
ProgressForeign national women are not a homogenous group and there are many differentcircumstances within this category, therefore we welcome the commitment toprovide women who are unlikely to be deported with services which arecomparable to those available to UK national women.ConcernsSpecialist support should be available to foreign national women in the hub atHMP Peterborough and wherever they are held across the estate.Many foreign national women have family in the UK and therefore closeness to homeshould be a consideration for them, there is a risk that by creating a specific hub at HMPPeterborough women will be held further from their families.Road to Reduction?Response to the Women’s Custodial Estate ReviewThe Review of the Women’s Custodial Estate was commissioned by the Secretaryof State for Justice because the “female estate should be organised as effectivelyas possible to meet gender specific requirements whilst also delivering best valuefor the public.”This short response highlights progress, raises concerns and identifies questionsthat Women in Prison has regarding the delivery of the recommendations in thisUnit 10, The Ivories, 6 Northampton Street, London, N1 2HYwww.womeninprison.org.uk