Gender-responsive training and staffing The Bangkok Rules outline several obligations relating to the training requirements of staff working with women in detention. For example, Rule 31 stipulates that ‘[c]lear policies and regulations on the conduct of prison staff aimed at providing maximum protection for women prisoners from any gender-based physical or verbal violence, abuse and sexual harassment shall be developed and implemented’.100 Rule 33(1) notes that staff working with women shall ‘receive training relating to the gender-specific needs and human rights of women prisoners’.101 Rule 33(2) also necessitates basic training be provided to all staff on ‘the main issues relating to women’s health’.102 The UN CEDAW Committee, commenting specifically on immigration detention and referencing the Bangkok Rules, also affirm that ‘[a]ll staff assigned to work with women detainees should receive training relating to the gender-specific needs and human rights of women’.103 The UN Special Rapporteur on Torture has also emphasised that staff training ‘to identify specific physical and mental-health needs of female detainees, are key to preventing mistreatment’.104 Across all facilities visited, Serco, ABF and Department staff advised the Commission that gender-specific training had not been incorporated into their training and ongoing development. IHMS was able to evidence specific training for its staff and ongoing refresher training into the specific health needs of women. The Commission was advised that training provided to Serco, ABF and Departmental staff had an individualised focus and covered topics such as trauma-informed practice, understanding triggers (for example for domestic violence survivors), mental health and situational awareness. Training did not however have a specific gendered dimension to it. In the Commission’s discussions with these staff, it was evident that women were not considered a vulnerable cohort as such; instead, the emphasis was on exercising sensitivity on a case-by-case basis. The UN SPT however have categorised women in detention as suffering ‘particular vulnerability’.105 For the most part, interviews with women in detention demonstrated respectful and positive relations with staff. The Commission also observed positive interactions particularly with ABF leadership at both PIDC and VIDC. There were examples of very positive interactions with specific staffing groups, for example, many women at VIDC commented positively about IHMS staff with one stating they were ‘understanding people, they don’t rush you’. At PIDC, women spoke positively about Serco welfare staff with one woman saying, ‘welfare are great’. Some women did, however, raise concern about interactions with certain staffing groups. For example, at BRP some were concerned about ABF staff interactions with one woman stating they were, ‘patronising and they make you feel uncomfortable when they are around. I feel they look down at you’. The Commission found further evidence which reinforced the importance of staff being provided initial and ongoing gender-responsive training and policy guidance. For example, the Commission reviewed the Detainee Consultative Committee (DCC) Meeting minutes from BRP, VIDC and PIDC over the last 12 months. In the BRP DCC minutes, the following complaints were raised by women, demonstrating the need for such training: l l l 28 ‘detainees have advised officers knock before entering however do not wait for detainees to respond and come in right away. Detainees are requesting for DSOs to be reminded to wait for their response before entering’.106 ‘Female detainees would also like to have a female officer processing their undergarments, as they can relate and [provide] accurate assistance with sizes’.107 ‘BRP detainees advised male officers should be accompanied by females when entering the units. Female detainees also feel uncomfortable when discussing certain topics with the male staff (sanitary products, undergarments etc)’.108 Not just an afterthoughtThe experience of women in immigration detention