box which can only be accessed by a nominated member of staff, preferably someone who is not part of the treatment or custody team. People with disabilities and anyone who may have difficulties in accessing the complaints system should be provided with assistance to enable them to do so. ■ O  versight mechanisms need to be strengthened, in particular with regard to placement in, and ways out of, seclusion and segregation units. These should be made proportionally more exacting as time in seclusion/segregation progresses. In the case of the ‘chronic’ stays in solitary confinement (in prisons and in health and disability settings), a national multidisciplinary oversight body which includes expertise from outside the detaining agencies, should be considered. ■ D  ata on the use of seclusion/segregation/secure care units and the application of restraints should be recorded more fully and analysed for trends and protected characteristics such as age, gender and ethnic origin. The apparent overrepresentation of ethnic minorities, in particular Mäori, in seclusion and segregation units in prisons and health and disability units should be investigated further as a matter of urgency.49 Similarly, the apparent overrepresentation of women in prison segregation units needs to be investigated and addressed. ■ R  ecords should clearly and prominently: indicate the reason for the placement in solitary confinement or the application of restraint; the start and end times of the application of seclusion or restraint; record efforts to use less restrictive practices, and; record any injuries sustained in the process (to both detainees and staff), and any other interventions and observations regarding the person.50 ■ D  etaining authorities should consider cross-sectoral collaboration aimed at the reduction of seclusion and restraint practices, sharing learning and good practice identified across other detention contexts. For example, the Ministry of Health’s seclusion reduction policies could be adapted to the prison context, and the Department of Corrections’ Minimum Entitlements could be adapted for use in health and disability units and in police custody suites. 49 As noted earlier, Te Pou, the Mental Health Foundation and others are already engaged in work to analyse discrepancies in the use of seclusion across DHBs and the over-representation of Mäori in seclusion, and to develop culturally sensitive alternatives. Such strategies could be expanded and adjusted to other detention contexts. 50 These and other recording requirements are helpfully listed in NZS8134.2.2: 2008 Standard 2.3 Criteria 2.3.4 of the Restraint Minimisation and Safe Practice Standard (2008), and could be adapted from health and disability settings to other detention contexts. 58