214 In March 2015 the IPCA released a review of Police custodial management119 that identified systemic and organizational deficits that contributed to recurring problems in Police detention. Specifically, the IPCA noted that discussions with Police and Area Mental Health Services staff have clearly shown that the problems with the way Police respond to vulnerable and mentally impaired persons are commonplace. The report highlighted the absence of appropriate alternatives to Police detention for dealing with vulnerable people, including those who have not committed an offence, and the lack of a timely response by Mental Health Services to mentally impaired persons in Police custody. The IPCA considers that, unless they are violent or pose an obvious and immediate threat to the safety of others, all practicable steps should be taken to avoid having mentally impaired people detained in Police cells solely for the purpose of receiving a mental health assessment.120 215 Police have developed new training packages for both recruit and frontline officers based on feedback from Mental Health Service User (“MHSU”) groups, and acknowledged the importance of having MHSU involved in future thinking around mental health crisis response. Police watch houses with on-site mental health nurses have also resulted in better monitoring and continuity of care during police custody. The SPT recommended this practice be applied nationally. 216 The Commission recommends that the Committee urge the Government to take steps to develop a national strategy and agree a set of actions to ensure the provision of mental health care in places of detention which includes mechanisms to ensure the timely and appropriate sharing of individuals’ health information across Government agencies. D Disproportionate representation of people with intellectual or learning disabilities 217 The WGAD heard testimonies when it visited New Zealand that people with intellectual or learning disabilities are at a particular disadvantage in the criminal justice system. Police officers, lawyers and officials are inadequately trained in relation to intellectual and learning disabilities. This has meant that in some cases, an individual may be questioned by the police without the presence of a lawyer, and is subsequently convicted and sentenced without or with inadequate legal representation. 218 It is estimated that 60-70% of people in New Zealand prisons are disabled people. The disabilities include intellectual or learning disabilities, foetal alcohol syndrome and poor mental health. 119 120 IPCA, Review of Police Custodial Management, Wellington (March 2015). Ibid. Page 58 of 93 Human Rights Commission submission to the Human Rights Committee in relation to New Zealand’s 6th periodic review under the ICCPR