3 | Key observations and concerns In terms of the qualifications and expertise of those conducting the review, the only information that has been provided is that the company commissioned to undertake the review ‘engaged appropriately qualified clinical professionals’ and that the specialist team involved included ‘a Specialist Psychiatrist with a special interest in psychodynamic psychotherapy and personality disorders; and a Senior Clinical Governance doctor in Australia, who is a Research Associate at a Department of Global Health and Population school within a University’.84 It is not possible to make an informed assessment of the expertise that underpinned this review without further information. Given both the lack of information available to allow for any assessment as to the adequacy of the 2020 Departmental Review, and the fact that the same issues that initially led to the Commission recommending a review continued to be raised during these inspections, the Commission considers that, as a priority, additional work needs to be done by the Department to review and improve the mental health care provided in immigration detention, including in hotel APODs. This includes both publicly releasing the 2020 Departmental Review to allow for a transparent assessment of work done to date, and also commissioning a group of independent mental health experts to conduct a comprehensive follow up review of the mental health care provided in immigration detention. 44 RECOMMENDATION 17: The Department should publicly release the 2020 Departmental Review into mental health care in immigration detention and as a priority commission a group of independent mental health experts to conduct a comprehensive follow up review of the mental health care provided in immigration detention facilities. 3.5 Management of the COVID-19 Pandemic At the time of the Commission undertaking these inspections, there were still active measures in place to manage the risks presented by the ongoing COVID-19 pandemic. It is acknowledged that the pandemic presented significant challenges for the management of Australia’s immigration detention facilities, including hotel APODs. The Commission has previously recognised that COVID-19 presents heightened risks to people in all forms of detention, including immigration detention, and that immigration detention facilities are high-risk settings for the spread of COVID-19.85 In these circumstances, it will be necessary to put measures in place to help address those risks and ensure the health and safety of both detainees and staff. These measures may, in some cases, limit the human rights of people in immigration detention, however in order to be compatible with Australia’s international human rights obligations, any such limitations must be necessary, reasonable and proportionate in the circumstances.86