During the COVID-19 pandemic the Commission conducted a targeted review of the management of COVID-19 risks in immigration detention.87 This review gave specific consideration to the use of hotel APODs and noted that ‘given the limited space and facilities available in hotel APODs, restrictions on offsite appointments and excursions introduced in response to COVID-19 would be especially harsh and restrictive for people detained in hotel APODs’.88 regarding measures such as quarantine requirements and visitor restrictions. The observations made in that report remain relevant in light of the issues raised with the Commission during these inspections. For example, during interviews individuals described the COVID-19 pandemic response measures as worsening the conditions within hotel APODs significantly, with visitor restrictions, increased isolation, treatment delays and a lack of communication and health information all being raised. Particular concerns were raised with us by a number of detainees regarding the impact of operational quarantine, which has been discussed above.89 and what did not. This applies to immigration detention just as it does to all other parts of Australian society. The Commission recommends that the Department conduct a comprehensive review into the management of the COVID-19 pandemic within the immigration detention network. While it is undoubtedly important for risk mitigation strategies to be in place to prevent and manage an outbreak of COVID-19 in immigration detention facilities, it is also essential that all pandemic response measures are consistent with international human rights law and standards. The Fault Lines Report – an independent review into Australia’s response to COVID-19 released in October 2022 – recognised that responses to any crisis will never be perfect. The report found that while Australia got many things right, ‘we also got some consequential calls wrong’.90 In order to be better placed for the next health crisis, we need to learn the lessons about what worked effectively, RECOMMENDATION 18: The Department should conduct a comprehensive review into the management of the COVID-19 pandemic within the immigration detention network. It is also critical that all measures introduced are clearly and effectively communicated to all detainees. For example, the interviews undertaken during these inspections left us with the impression that individual detainees often were not aware or were mistaken in their understanding of the measures that were in place at the time, and a number of individuals complained about being given inconsistent or incorrect information The Use of Hotels as Alternative Places of Detention (APODs) • 2023 • 45