In the United Kingdom, operational guidance to staff working with women in immigration detention facilities require that ‘staff must always knock and wait for an answer before entering detained individual’s rooms, unless an exceptional operational need makes this inappropriate. Additionally, prior to opening the door, officers should verbally announce their gender’.109 The guidance also states, that ‘[i]ssues of decency, the need for close observation and women’s safety and rights should be considered when deciding the gender balance of staff and managers’.110 Further, ‘[w]omen must have easy access to a range of hygiene products including sanitary provisions, reusable and sustainable products such as menstrual cups, period underwear and re-usable towels. These products should be freely available without the need to ask a member of staff’.111 The Commission’s own Human rights standards for immigration detention also state that ‘[f]eminine hygiene products are readily available free of charge to female detainees and never require a request to male security staff’.112 The United Nations Standard Minimum Rules for the Treatment of Prisoners (Mandela Rules) stipulate that ‘[n]o male staff member shall enter the part of the prison set aside for women unless accompanied by a woman staff member’.113 Additionally, they state that ‘[w]omen prisoners shall be attended and supervised only by women staff members. This does not, however, preclude male staff members, particularly doctors and teachers, from carrying out their professional duties in prisons or parts of prisons set aside for women’.114 The UN Special Rapporteur on Torture has affirmed that the separation of women and men and ensuring women are supervised by female officers and staff only are ‘key safeguards against abuse’.115 The UN CEDAW Committee has also stated that ‘[t]his important safeguard, based on non-discrimination against women in line with article 1 of the Convention, has been reaffirmed by the Committee in its concluding observations on the reports of States parties’.116 With respect to immigration detention specifically, the Committee has likewise emphasised ‘the use of female guards and warders should be promoted’.117 The UN SPT has however observed that it is ‘common to find male staff carrying out security duties because of a lack of female guards’.118 Following its visit to Australia in 2022, the UN SPT noted, ‘the prevalence of male guards in … women’s sections of immigration detention centres … and also noted information provided by staff indicating that male officers entered female living quarters without the presence of a female officer’.119 While the Commission observed that women were generally supervised by female officers, there were also male officers present at each of the facilities and compounds we visited. It was also apparent that the Emergency Response Team (ERT) presence at both BRP and VIDC were all males. The Commission was advised by ERT staff and Serco management they were having difficulty recruiting and retaining any female ERT officers due to the ongoing requirements of the role. In a differing approach to the above guidance, the CPT has stated that ‘[t]he presence of male and female staff can have a beneficial effect in terms of both the custodial ethos and in fostering a degree of normality in a place of detention’.120 The Committee does, however, note that there should be ‘a preponderance of female staff supervising such accommodation’.121 In support of ensuring a larger proportion of women officers in women’s accommodation, the Norwegian Parliamentary Ombudsman has stated in one of its reports that: The changed relationship of power that arises between people when someone is deprived of their liberty can, for various reasons, make women particularly vulnerable. For women who have suffered abuse or been involved in prostitution, the proportion of male staff can be particularly challenging.122 The Commission’s own Human rights standards for immigration detention do not preclude the presence of male officers in women’s compounds, but they denote that some situations and tasks require female-only staffing. They state that ‘female detainees should be attended and supervised only by female members of staff when in the bathroom and sleeping areas of the facility or when under observation (for mental health reasons, for example)’.123 Issues and concerns impacting women across the detention network 29