Detainees described spending the majority of their time effectively confined to their rooms. Being confined in this way was consistently described by detainees as contributing to isolation, anxiety, loneliness, boredom, and depression. RECOMMENDATION 4: The Department should implement strategies to provide greater access to shared facilities and outdoor space for people detained in hotel APODs. The Commission has previously acknowledged that restrictions on freedom of movement within immigration detention facilities ‘may be reasonable in some situations if they are necessary to manage risks and are proportionate in the circumstances’.54 It is not clear that the significant restrictions placed on the movements of detainees in hotel APODs meet this criteria, particularly in light of the extended periods of time that individuals are being 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. The restrictions appear to be primarily due to the nature of the facilities, rather than any risk factors particular to the detainees themselves. This further highlights the unsuitability of hotel APODs as longterm detention options. (c) Freedom of movement Individuals detained at the Brisbane and Melbourne APODs were significantly more restricted in their movements than individuals detained at low security compounds in other immigration detention facilities. This is despite APODs generally (with some exceptions) being considered to be lower-security facilities. For example, at the Brisbane APOD detainees were not able to move freely within the hotel, being restricted to the same floor as their room, only being able to visit other rooms in accordance with the ‘buddy system’ described above, and not being able to leave their rooms without being escorted by security. This was particularly restrictive for those who did not have access to shared spaces on their hotel floor, which was the case for every single male detainee at the Brisbane APOD at the time of our inspection visit. 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. The Use of Hotels as Alternative Places of Detention (APODs) • 2023 • 31