There is a strategic focus on custody, including arrangements for diverting the most vulnerable from custody. There are arrangements to ensure custody-specific policies and procedures protect the well-being of detainees.


1.1 There is leadership which communicates a clear focus on protecting and diverting vulnerable people from custody, wherever possible, and promotes the safe and respectful delivery of custody.


  • There are objectives concerning the diversion of vulnerable adults and children away from custody. These are promoted and accessible to staff.
  • There is an effective management structure that ensures appropriate policies and procedures for the whole custody process are in place, fully implemented and reviewed regularly to ensure compliance with legislation and relevant human rights standards. Policies and procedures are accessible and staff understand them.
  • There are sufficient resources to carry out the custody functions to ensure the safety and well-being of detainees. Custody suites are staffed with personnel (including contracted staff) who are trained, with the right skills and security clearance, who understand how to respond to detainees and whose training needs are assessed, met and evaluated to perform the requirements of the role.
  • Services provided externally to support custody are monitored and scrutinised to hold providers to account.
  • There is a clear whistle-blowing procedure in place and all staff know how to raise concerns.

1.2 There is an evident and effective focus on the protection and welfare of children and vulnerable adults.


  • Safeguarding of children is embedded at a strategic level, supported by clear policies and procedures specific to the needs of children. Border Force staff are trained to recognise child abuse and to understand the need to safeguard and promote the welfare of children, and are supported to do so. Relevant authorities are notified if children are detained in custody (see section 3).
  • There is a robust safeguarding policy for vulnerable adults (see section 3).
  • Staff are provided with training in awareness of human trafficking, sexual abuse (including exploitation), extortion, grooming and smuggling. All staff are alert to the signs that a detainee has potentially been a victim of trafficking, sexual abuse or grooming, know how to report it and do so appropriately, including to the National Referral Mechanism.


1.3 Performance management data supports the safe delivery of custody.


  • Accurate data (including custody throughput, demographics, adverse incidents, strip-searching, use of force and complaints) are routinely collated and analysed to identify trends, and used to inform organisational learning and improve outcomes for detainees in Border Force custody.
  • The central custody directorate receives all relevant management information and data, including on the use of force and equality and diversity.
  • Border Force has mechanisms in place to assure itself and the public that the use of force in relation to arrest, detention and custody is strictly necessary, safe and proportionate.
  • Quality assurance processes promote the safe and respectful treatment of detainees and continuing professional development of staff. 
  • Effective mechanisms are in place to learn from adverse incidents and to identify and share good practice within and across Border Force and relevant partnerships.

1.4 Border Force staff demonstrate an understanding of their obligations under the Equality Act 2010, including the public sector equality duty. Border Force promotes respect for people from all backgrounds and with diverse needs and raises awareness of the discrimination that can be faced by particular groups.


  • There are effective monitoring systems to identify discrimination in treatment, including analysis of data on custody throughput.
  • Assessments are conducted across custody operations, including an element of external challenge to identify whether services deliver fair and equal treatment.
  • An equality governance and accountability framework is established, linked to the Border Force risk register.
  • Where staff come across unfair or discriminatory treatment, they are able and required to take action in challenging, eliminating and reporting it (see section 3).
  • Equality monitoring, and any other monitoring required for protected characteristics, are communicated to all staff and staff understand how they can implement and monitor appropriate action.
  • Staff have been trained to recognise and meet the needs of people who have one or more of the protected characteristics under equality legislation.
  • There are policies and procedures in place to ensure staff understand their obligations under the Equality Act 2010.

1.5 Border Force facilitates access as required for effective external scrutiny.


  • Border Force responds to issues and complaints raised by Independent Custody Visitors (ICV). This includes dealing with immediate complaints and issues raised during visits.
  • Feedback is used appropriately by Border Force and there are regular and formal opportunities for issues to be raised with senior officers.


1.6 Partnership arrangements effectively support the identification and management of risks to the welfare of vulnerable detainees (including children) in Border Force custody.


  • There is constructive engagement with all relevant partner agencies (including relevant safeguarding boards, ICVs, health care providers and commissioners, local authorities, youth offending services, criminal justice agencies, escort providers, immigration authorities, ambulance service, courts, etc) to protect and divert children and vulnerable adults from custody, where possible, and to support the safe and respectful delivery of custody. Outcomes can be clearly demonstrated.

Human rights standards

In relation to expectations 1.1–1.6: Human rights standards require that all places of detention are managed to ensure that detention is prescribed by law and that detainees’ human rights are respected, protected and fulfilled. That means that the humanity and inherent dignity of each and every detainee is recognised in policy and practice, that vulnerable detainees are identified and safeguarded and that managers ensure that all staff have the requisite knowledge, aptitude and skill to perform their duties so as to be human rights compliant. A child (any person under the age of 18 years) must be treated as vulnerable by reason of age and their best interests remain a primary consideration. See ECHR 2, 3, 5; ICCPR 10(1); ICESCR 12(1); CERD 2, 5, 6; CAT 2, 10, 11, 12, 13, 16; OPCAT 19, 20, 21, 22; BOP 1, 4, 5, 7, 9, 29; PPMI 1, 2, 20; CCLEO 2, 3, 6, 7; BPUFF 1, 15, 18; DEDRB 2; DRM 4; DHRIN 5. In relation to children specifically see CRC 3, 19, 24, 33–37, 40; HR 17.