When oversight retreats: IMBs, women’s prisons and the monitoring-gap

The Independent Monitoring Boards (IMBs) exist to provide a vital check on the treatment of people in custody. Every prison in England and Wales must have an IMB, composed of volunteers appointed to monitor whether prisoners are being treated fairly, humanely and in accordance with rules.
Yet today the IMBs in women’s prisons are under serious pressure: from understaffing; from changing instructions about how they handle individual prisoner concerns; and from a justice system undergoing regime change. The consequence: a weakening of independent scrutiny at precisely the time when the women’s custodial estate is under heightened stress.

The IMBs’ own remit includes receiving prisoners’ applications or concerns and making sure they are addressed. Yet commentary in reform-journals has suggested that IMBs are being told they must rely solely on aggregated data or periodic visits rather than individual complaint-handling, thereby diluting their role as an independent redress channel.

If this shift becomes formal policy, or is implemented via new internal instructions, the ramifications are severe: women prisoners who raise concerns — about safety, mental health, staff-conduct, segregation or healthcare — may lose access to a crucial independent voice.

Monitoring on the edge

IMBs are volunteer-led, unpaid, and each prison board covers visits, reports, scrutiny of treatment and conditions, as well as engagement with prisoners. The national IMB website describes over “a thousand unpaid volunteers operating in every prison in England and Wales”, and invites recruitment campaigns.

Independent commentary highlights “unprecedented staff shortage” within IMBs — not just prison-staff but volunteer monitors — creating what insiders call “an oversight gap”. One blog notes that “recruitment is improving but new recruits lack the experience of the officers they are replacing” and the IMB warns of a direct link between monitoring capacity and prisoner wellbeing.

The weight of evidence indicates a major volunteer-capacity crisis for IMBs — meaning fewer visits, less time in-cell, less follow-up of individual applications and more reliance on high-level auditing rather than responsive scrutiny.

How does this impinge on OPCAT duties?

The UK is a party to the OPCAT, meaning that prisons and detention-centres must be subject to a system of regular, independent oversight including unannounced visits and the ability to receive detainee concerns. IMBs form one vital component of that independent monitoring framework.
If IMBs are told not to respond to individual complaints, or are too under-resourced to engage properly, several OPCAT-related risks arise:

• Erosion of the “vulnerable detainee voice”: Individual complaints are often the first signal of mistreatment, self-harm, delayed transfers, or systemic neglect. Without a proper channel, those signals may go unheard until a crisis unfolds.
  
  
• Weakening of early intervention: OPCAT emphasises prevention of ill-treatment, not just reaction. IMBs working case-by-case help identify patterns early. If IMBs focus only on aggregated data or annual reports, they lose that early-warning role.
  
  
• Reduced independent access: One of IMBs’ strengths is their right to access any part of the prison and to talk confidentially to prisoners. If capacity falls, or if individual applications are discouraged, that access becomes less meaningful.
  
  
• Credibility and trust: For oversight to work, prisoners must believe that someone will listen when they raise a concern. If IMBs cannot credibly respond, trust declines and the entire oversight architecture is weakened.
  In short: undermining IMB responsiveness puts the UK’s OPCAT obligations at risk of being met only on paper, while functionally receding.
  
  

Why is government seemingly trying to take away this resource for prisoners?

There are several reasons that may help explain this worrying trend — though none justify it:

1. Cost-saving and resource pressures: In a climate of austerity and prison population strain, monitoring bodies may be seen as “nice to have” rather than essential. Volunteer recruitment is cheaper than paid staff — but that also implies less capacity.
2. Risk of scrutiny and adverse findings: Monitoring bodies like IMBs often publish reports which highlight systemic failures — overcrowding, delayed transfers, self-harm, poor mental health support. Some argue that institutional resistance may grow when oversight threatens reputation or budget.
   For example: a recent IMB report flagged that women at HMP/YOI Downview faced a 90% increase in delays awaiting psychiatric transfers.
3. Shifting to governance agendas: If the oversight model is altered to emphasise quantitative metrics or aggregated reviews, that reduces the emphasis on individuals’ rights and voice — easier to manage risk-wise, but much weaker on justice.
4. Volunteer burnout and lack of renewal: The IMB model depends heavily on volunteers – if recruitment, training and support are inadequate, boards age, membership falls, and the board cannot fulfil its role. That creates a “managed decline” of oversight without necessarily changing policy overtly.
   
   

Why this matters for women in prison

Women in custody often present different and more complex needs than the male estate: higher levels of trauma, mental-health challenges, self-harm, motherhood issues, dependency, and shorter sentences but often multiple remands. The independent voice of IMBs is especially vital here.

• For women who self-harm, who are acutely mentally unwell, or who face segregation or delayed care, the IMB can act as their independent advocate. For example: the IMB’s report for Downview highlighted acutely unwell women being held in segregation because of extended psychiatric delays.
  
  
• If IMBs cease taking individual complaints, these women may lose a mechanism of escalation when the prison’s own route fails.
  
  
• A short-staffed and overstretched IMB may visit less frequently or have fewer members with visibility into the wings. That means less oversight, more “blind spots”, and higher risk of harms going unreported.
  
  
• From a gender-justice perspective: women’s prisons are fewer, geographically dispersed and face distinct resettlement and mental-health challenges. The weakening of oversight in this estate disproportionately affects them.
  
  

What needs to happen?

1. Reaffirm IMB’s individual complaint role: The Ministry of Justice must clarify that IMBs retain responsibility for receiving and responding (or escalating) individual prisoner applications, especially for vulnerable groups.
   
   
2. Address the volunteer gap: A national recruitment and retention strategy must be resourced — 700 missing monitors require attention. Without them, oversight will continue to ebb.
   
   
3. Protect oversight under OPCAT: The UK Government must ensure that independent monitoring remains robust and capable of early-warning and intervention, not just annual audit.
   
   
4. Prioritise women’s custody oversight: Given the heightened vulnerability of women in prison, special attention should be given to boards in women’s prisons — ensuring they have sufficient capacity, training and resources.
   
   
5. Transparent reporting of changes: If instructions or guidance to IMBs are being changed (e.g., limiting individual complaint response), these must be publicly documented and consulted. Oversight cannot be weakened behind closed doors.
   
   

The IMBs — volunteer citizen-monitors — play a quiet but essential role in protecting dignity, safety and decency in our prisons. When their visibility fades, especially in women’s prisons, the consequences are not abstract: they are felt by real people who already carry the burden of trauma, ill-health and marginalisation.
If the institution is being told not to respond to individual complaints, if the volunteer ranks are hollowing out, and if monitoring is becoming less individual-focused and more “remote”, then what we are witnessing is not just a shrinking of oversight — it is a rollback of prisoners’ voice, of transparency and of early protection.
For women — whose journeys into and through custody already reflect systemic disadvantage — this retreat matters profoundly. The challenge now is not only to draw attention to the problem, but to insist on action: robust oversight, full monitoring capacity, and guardians in place for those who otherwise might have nowhere to turn.