3 | Key observations and concerns (d) Privacy A number of detainees commented that they felt they had a greater degree of privacy in hotel APODs as compared with other immigration detention centres. However, others highlighted the continuous presence of security officers in close proximity and frequent checks that were conducted throughout the day and night. Detainees described being regularly woken in the middle of the night as headcounts were performed, and that they ‘feel that anyone can enter their room at any time with no warning. They feel there are no boundaries’. Staff advised that continuous line of sight monitoring of detainees within hotel rooms only occurred where it was assessed as necessary to ensure the safety of individuals in circumstances where heightened risks of suicide or self-harm were identified. While acknowledging that there may be limited circumstances where continuous monitoring is required to ensure safety and security, the Commission reiterates the recommendation from earlier inspection reports that continuous monitoring should only be used when it is demonstrated to be necessary, reasonable and proportionate in the circumstances.55 During the inspection visit to the Brisbane APOD, the Commission observed multiple security officers being stationed on each floor, with the stated intention that no individual would be able to open the front door to their room, or to leave their room, without being observed. Detainees were observed being escorted by staff whenever they left their room. Detainees stated that the presence of security officers during external medical and counselling appointments could frequently be intimidating and intrusive, as well as undermining the confidence that individuals have in the confidentiality of those appointments. A number of individuals raised 32 concerns with us about privacy during these appointments, particularly with regards to the proximity of security officers. It is essential that the policies, procedures and practices that inform the operation of hotel APODs respect the privacy of the individuals who are detained. The Commission recommends that all policies, procedures and practices relating to the supervision and monitoring of individuals detained at hotel APODs be reviewed to ensure they are necessary, reasonable and proportionate with regards to respecting the right to privacy. RECOMMENDATION 7: 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. (e) Communication and visits Most individuals at the hotel APODs had unrestricted access to personal mobile phones and laptops, had unlimited access to wireless internet, and were able to obtain phone cards using Individual Allowance Program points. There were also tablets and phones available for loan as needed. One concern that was regularly raised by both detainees and those working with them was the practical barriers that existed with respect to accessing legal advice and other assistance.