Appendix 1 – List of Recommendations Recommendation 7 The Commission makes the following recommendations: Recommendation 1 The Department should ensure that hotels are only used as Alternative Places of Detention in exceptional circumstances and for the shortest possible time. The Department should review all policies, procedures and practices relating to the supervision and monitoring of detainees at hotel APODs to ensure they are necessary, reasonable and proportionate with regards to respecting the right to privacy. Recommendation 8 Recommendation 2 The Department should implement strategies to The Department should review emergency management procedures for each hotel APOD to ensure appropriate procedures are in place. Recommendation 3 Individuals detained in hotel APODs must be able to access fresh air in any rooms where they are required to reside. Recommendation 4 The Department should implement strategies to provide greater access to shared facilities and outdoor space for people detained in hotel APODs. Recommendation 5 Every individual detained in a hotel APOD should be able to access at least one hour of suitable exercise in the open air every day. Recommendation 6 The Department should implement strategies to provide greater freedom of movement, and to ensure that any restrictions on movement within hotel APODs are both necessary to manage risk and proportionate in the circumstances. ensure that people detained in hotel APODs are able to regularly access and engage with the legal assistance and other services they are entitled to, in a manner that respects the confidentiality of these services. Recommendation 9 Visits should routinely be facilitated at the detention facility in which the detainee is ordinarily held, other than in exceptional circumstances. Recommendation 10 The Department should establish a central contact point for all hotel APODs (including telephone and email details) to assist in facilitating visits. Recommendation 11 The Procedural Instruction relating to the use of force should be amended to require that the impact that not being escorted outside of the detention facility may have on the health or wellbeing of the individual detainee be considered as a mandatory factor in the risk analysis prepared when seeking approval for a planned use of force. The Use of Hotels as Alternative Places of Detention (APODs) • 2023 • 59