Prison
Service
Order
Effective Regime
Interventions
ORDER
NUMBER
4350
Date of Issue
/ Amendment
23/12/2002
Amendments can be tracked in the Numerical Index.
PSI Amendments should be read before and in conjunction with PSO
INTRODUCTION FROM THE DIRECTOR OF RESETTLEMENT
1.
This Prison Service Order provides instructions and guidance on the management
of regime interventions intended to change prisoners’ behaviour.
2.
The PSO establishes an internal Prison Service validation system for regime
interventions which are not validated by an appropriate external body. Each such
intervention will require the approval of a Prison Service Area or Operational
Manager.
3.
This PSO applies to regime interventions for prisoners aged 18 and over. Different
arrangements, to meet the requirements of the Youth Justice Board, apply for
prisoners aged under 18.
4.
Regime interventions which are validated by independent external bodies will
continue to be subject only to the requirements of those bodies and it will not be
necessary for them also to comply with the requirements for validation set out in
this PSO1. Priority must continue to be given to delivery of interventions
which are accredited by the Correctional Services Accreditation Panel and
other external bodies.
5.
Regime interventions in scope will be required to meet nine criteria covering
design, participation and management. These criteria are based on What Works
principles, established through research on effectiveness. Completion of a
business case pro-forma is required to show how an intervention will meet each of
the nine criteria and approval is needed from the Area/Operational Manager.
6.
To date, there have been no guidelines for such regime interventions. This PSO
aims to lay the foundations to raise standards in the delivery of these regime
interventions so that they are more likely to be effective in changing prisoners’
behaviour. Compliance with the PSO will not in itself ensure effectiveness. That
will depend on evidence gained from research and evaluation.
7.
It is recognised that there is already much good work and commitment by
establishments in the delivery of regime interventions. This PSO is designed to
build upon that and to set clear guidelines to support and develop the work. It will
also establish a comprehensive database of interventions, which will assist in the
sharing of good practice.
PURPOSE
8.
The outcomes sought are:




To raise the quality of the design and delivery of regime interventions
To apply What Works principles to regime interventions
To validate a range of regime interventions
To facilitate rational allocation of resources on the basis of needs and
effectiveness
PERFORMANCE STANDARDS
9.
This PSO supports the Regimes Standard. The Standard is:
Every establishment provides a constructive regime which addresses offending
behaviour, improves educational and work skills and promotes law abiding
behaviour in custody and after release.
OUTPUT
10.
This PSO will assist establishments to meet targets relating to purposeful activity,
resettlement, decency and good order.
IMPACT AND RESOURCE ASSESSMENT
11.
There will be some additional work to review current regime provision initially to
implement this PSO. This will vary between establishments. There are no new
1
See Annex F
resources specifically for implementation but the timetable can take account of
this. Establishments must not reduce regime provision solely in order to carry out
the required reviews. The review timetable can take this into account. If current
provision is cut because it fails to meet the criteria, then it must be replaced by
more appropriate provision.
12.
Implementation of this PSO may lead to re-allocation of resources to improve
cost-effectiveness. The allocation of additional resources made available for
regimes under Spending Reviews will take account of regime provision made in
accordance with this PSO.
IMPLEMENTATION
13.
This PSO comes into effect on 1 April 2003. The requirements of this PSO must
be applied immediately to all new regime interventions. Implementation will be
staged for existing regime interventions as follows:






Establishments must notify regime interventions requiring review according
to instructions in this PSO by 30 June 2003.
Establishments must draw up a plan and timetable for reviewing regime
interventions by
30 September 2003, which will be approved by the Area/Operational
Manager and copied to What Works in Prison Unit (WWPU). The plan and
timetable must take account of contractual commitments.
Establishments must complete reviewing regime interventions by 30
September 2004 unless a longer timescale has been approved by the
Area/Operational Manager. A longer timescale will be approved where this
is necessary to avoid this PSO having the unintended consequence of
reducing total purposeful activity time.
Any subsequent changes to an establishment’s plan and timetable must be
approved by the Area/Operational Manager and copied to WWPU.
Where the same internal regime interventions operate in a number of
establishments, arrangements may be made for a lead establishment to
take responsibility for the review2
MANDATORY ACTION
14.
Mandatory action is specified in this PSO by the use of italic typeface.
15.
Governors and Directors of contracted-out establishments must ensure that all
staff and partner agencies with responsibilities for regimes and the movement of
prisoners are aware of the contents of this PSO and have access to it. This PSO
must be available to prisoners and members of Boards of Visitors on request. A
copy of this PSO is available on the Prison Service Intranet.
AUDIT AND MONITORING
16.
Establishments and Headquarters must comply with the mandatory instructions in
this PSO.
2
See Section 2 for details.
Self audit will apply. This PSO is concerned with quality assurance. Monitoring is
integral to its provisions.
17.
This PSO will be taken into account in inspections carried out by HM Chief
Inspector of Prisons and may be taken into account by the Adult Learning
Inspectorate or OFSTED, whose inspections are based on the Common
Inspection Framework.
18.
Periodic reports on the workings of this PSO will be made to the What Works in
Prison Strategy Board (WWPSB) and the Prison Service Management Board.
CONTACT
19.
Further advice on the PSO as a whole is available from What Works in Prison Unit
in Sentence Management Group:
Michael Cole
020 7217 5255
Gareth Mercer
020 7217 5935
Elizabeth Barnard
020 7217 5086
20.
Further advice on topics within the PSO and types of regime intervention is
available from:
Martin Lee, Drug Strategy Unit
020 7217 5045
Anthony Harris, Prisoners’ Learning and Skills Unit, DfES020 7925 6162
Susannah Nisbett, Prison Health Policy Unit, DH
020 7972 3932
Georgina Campbell, Custody to Work Unit
020 8760 1706
Mike Gibbs, Safer Custody Group
020 7217 2135
Jo Gordon, National Voluntary Sector Co-ordinator,
Prisoner Administration Group
020 7217 6842
Steve Niven, RDS, Home Office, for monitoring and evaluation020 7217 5240
KEN SUTTON
Director of Resettlement
NOTE FOR ESTABLISHMENT LIAISON OFFICERS
ELOs must record receipt of this PSO – EFFECTIVE REGIME INTERVENTIONS – in
their registers as issue 161 set out below. This PSO must be placed with those sets of
orders mandatorily required under Chapter 4 of PSO 0001.
Issue
No.
Date
Order
No.
Title
Date
entered in
set
ELO signature
161
23/12/02
4350
Effective Regime
Interventions
CONTENTS
1
2
Overview
1.1
Table 1
1.2 - 1.3
1.4
Introduction
Scope
Criteria
Central database of regime interventions
Implementation arrangements
2.1
General
2.2 - 2.6
Full business case
2.7
Shorter business case
2.8 - 2.11
New interventions
2.12 - 2.15
Review of existing interventions
2.16 - 2.18
Managing change control
Annex A
A1
A2 – A3
A4 – A9
A10 – A15
Scope
Age
In scope
Not in scope
Other issues of scope
Annex B
Quality Assurance Criteria
B1 - B3
Introduction
B4 - B7
Criterion 1: Objectives
B8 - B9
Criterion 2: Rationale
B10 - B12
Criterion 3: Structure
B13 - B23
Criterion 4: Selection
B24 - B26
Criterion 5: Achievement
B27 - B30
Criterion 6: Scale and Costs
B31
Criterion 7: Staff Selection, Competence,
Management and Support
B32 - B36 Criterion 8: Records, Monitoring and Audit
Pro-forma
Prisoner record
B37 - B38
Criterion 9: Evaluation
Annex C
Pro-forma for Business Case and Approval
Annex D
Interventions - Flow Chart
Procedures
Annex E
E1 – E4
Pro-forma
Annex F
F1 - F3
for
Approval
of
Regime
Database of Regime Interventions
Regime interventions validated by independent external bodies
General
F4 - F5
F6
Validating bodies
Central database of regime interventions
1.
OVERVIEW
Introduction
1.1
This PSO establishes internal procedures for validation of regime interventions
which aim to change prisoners’ behaviour and attitudes and criteria for assuring
their effectiveness. The term “intervention” is used to include programmes,
courses and other systematic activities.
Scope
TABLE 1: Summary
Principles
Examples
See
following
paras. in
annex A
for details
 Social and life skills courses
 Victim awareness course, eg. Sycamore
Tree
 Parenting skills course
 Courses run by Alcoholics Anonymous or
Narcotics Anonymous
 Courses for prisoners experiencing
difficulties coping with prison life
 Drug importers’ programme
 Drug mentor scheme
 Pre-release/resettlement courses
A2-3
In scope
The primary or major
objective is to change
prisoners’ behaviour
The intervention has not
been approved or rejected
by any independent,
external body
Not in scope3
Any interventions for
prisoners under 18 years
Offending behaviour
programmes accredited by
the Correctional Services
Accreditation Panel4 or in
the Prison Service
development portfolio with a
view to being so accredited
Interventions validated by
appropriate external,
independent bodies
A1
 Accredited programmes
 ETS, R&R
 SOTP
 CALM
 CSCP
 Development portfolio
 Intensive drug treatment programmes
 Short term resettlement programmes
 Education and training courses approved
by the Qualifications and Curriculum
authority (QLA) such as the National Open
3
The criteria for interventions in scope may be applied where this would be useful to benchmark.
4
This includes programmes accredited by its predecessors.
A4-5
A4-5
Interventions provided for
prisoners which are
identical to those provided
in the community and which
are provided or authorised
by statutory bodies and
subject to their
arrangements for quality
assurance
Interventions provided
solely by professionally
qualified staff such as
doctors and psychologists
whose right to practise is
subject to their professional
bodies’ clinical and ethical
standards
One-to-one interventions
Activities whose primary
purpose is to preserve the
rights, decency and dignity
of prisoners
Activities whose primary
purpose is to enable
prisoners to serve their
sentence appropriately
Activities whose primary
purpose is to enable the
establishment to function
Activities which serve the
interests of the
establishment rather than
the prisoner
Leisure activities
5
College Network, ASET, NVQ awarding
bodies and other education awarding
bodies
 The Guidance Council Accreditation Board
 Careers Service
 Job clubs
A6
 Structured one-to-one work by
psychologists
 Detoxification
A8
















Counselling
Personal officer work
Listeners and befriending
Drop-in advice surgeries
Advisory services provided individually5
Health care
Religion
Clothing and laundry
Meals
Canteen
Visits and ‘phone calls
Legal services
Bereavement courses
Diet and nutrition courses
Induction courses
Lifer discussion groups
A8-9




Cleaning
Maintenance
Catering
Commercial workshops
A7




Association
Recreational PE
Model making
TV, film clubs
A2
A7
A9
A7
Guidance on good practice in relation to housing and employment is provided in the Custody to Work Practice
Framework
 Meditation techniques
More detail on scope is in Annex A of this PSO.
Criteria
1.2
The criteria that must be met by regime interventions to obtain approval are:
Design



Objectives, i.e. the purpose(s) the intervention sets out to achieve
Rationale, i.e. why the methods set out can be expected to achieve the
objectives
Structure, i.e. what the intervention will do; how it will do it; and, if
appropriate, its sequence and intensity
Participation

Selection, i.e. the target group of prisoners for whom the intervention is
designed, how they will be assessed and selected

Achievement, i.e. how outcomes for prisoners will be assessed and
recognised, including feedback from prisoners
Management

Scale and costs, i.e. how many places etc. are to be provided and what the
intervention will cost

Staff selection, competence, management and support

Records, monitoring and audit, i.e. what records will be kept, how they will
be used, and what steps will be taken to ensure practice follows what has
been approved

Evaluation, i.e. how the intervention’s overall success at achieving its
objectives will be assessed. This is broader than ‘achievement’, which is
concerned solely with outcomes for participants.
More detail on these criteria is in Annex B.
1.3
A pro-forma for drawing up the business case for approval is at Annex C. It is
available through the Prison Service Intranet. Formatted disks may be supplied to
partner agencies, subject to IT security requirements.
More detail on the approval process is in Section 2.
Central database of regime interventions
1.4
A database must be maintained of all regime interventions which have been
approved or are in development and at which establishments they are run. What
Works in Prison Unit (WWPU) will use this database to provide an information
service to the Prison Service Management Board, Area/Operational Managers
and establishments. It will also assist RDS in the identification of interventions and
sites for evaluation. Details of the contents and operation of the database are at
Annex E. Requirements relating to the database are in Section 2 and Annex F.
2. IMPLEMENTATION ARRANGEMENTS
General
Regime interventions whose primary purpose is to change prisoners’ behaviour
must comply with quality assurance arrangements. Where an appropriate external
body has validated the intervention, no further quality assurance action is
required6. In all other cases within scope7, the approval of an Area/Operational
Manager is required, on the basis of a business case showing how the nine
quality assurance criteria described in Annex B are met. A pro forma for the
business case is at Annex C. The Area/Operational Manager must be satisfied
that all nine criteria are met, but may permit minor variation from the Code of
Practice set out in Annex B.
2.1
Full business case
2.2
A full business case is required where an intervention is seeking approval for the
first time. This may be an intervention which is already operational or a new
proposal.
2.3
A business case may be submitted by an establishment, a consortium of
establishments, a policy unit, a working group of policy and operational staff, or an
outside body.
2.4
An outside body must have an internal sponsor, whether or not Prison Service
resources are involved. The internal sponsor may be an establishment, a
consortium of establishments, a policy unit, or a working group of policy and
operational staff.
2.5
The steps in the process for obtaining approval must be:
1
2
3
2.6
Originator and/or sponsor prepares full business case, completes proforma at Annex C
Business case submitted to Governor/Director of contracted-out
establishment for support
Governor/Director of contracted-out establishment submits business
case to Area/Operational Manager for approval
At any step, the relevant policy unit or area specialist, such as the Area
Psychologist, may be consulted before proceeding to the next step. Their advice
on relevant evaluation evidence will be particularly valuable. The Area/Operational
Manager must ensure that the decision is recorded in the database of regime
interventions.8
Shorter business case
6
See Annex F for details
7
See Table 1 above and Annex A
8
See Annex E for details
2.7
Where an existing or new intervention has already been approved and
consideration is being given to whether it will be delivered at another
establishment, then the same steps set out at para 2.5 are required, but the
business case need only specify how the intended operation differs from the
approval given elsewhere. This is likely to include Criterion 6-Scale and Costs. It
may also include evidence that the target group, to satisfy Criterion 4-Selection, is
likely to be available. The ID of the intervention already approved must be referred
to.
New Interventions
2.8
All new regime interventions developed from the date of implementation of this
PSO must follow the procedures in this PSO.
2.9
Before an originator may proceed to design of a new intervention, they must:



consult the database of regime interventions;
be satisfied that a suitable approved intervention is not already available or in development9;
be authorised - and, if necessary, resourced - by Governor(s)/Director(s) of
a contracted-out establishment (in the case of an establishment or a
consortium of establishments) or by a sponsoring Head of Group (in the
case of a policy unit or a working group of policy and operational staff) to
design a new intervention.
2.10
Where a consortium of establishments, a policy unit or a working group of policy
and operational staff has been involved in developing a new intervention, any
relevant Area/Operational Manager may take the initial decision on approval, but
each establishment intending to adopt the approved regime intervention must
prepare a shorter business case.
2.11
Before agreeing to sponsor or resource design of a new intervention by an outside
body, the prospective internal sponsor must:



consult the database of regime interventions ;
be satisfied that a suitable approved intervention is not already available or in development;
comply with procurement rules.
Sponsorship does not guarantee commitment to delivery, should a new regime
intervention succeed in becoming approved.
Review of existing interventions
2.12
9
All existing interventions within scope must seek approval within 18 months of the
date of implementation of this PSO or later if agreed with the Area/Operational
Information from the database of regime interventions will be brief but will indicate where relevant regime
interventions exist and advise contacts for details. See Annex E for details of what will be recorded in the database.
Manager.10 The same business case (using the pro-forma at Annex C) is required
for this process.
2.13
The first action establishments must take is to identify existing interventions in
scope and prepare a draft plan and timetable for their review and approval.11
Where similar interventions are in operation at more than one establishment,
Area/Operational Managers may designate a lead establishment to take
responsibility for the review and preparation of a full business case.
Area/Operational Managers must approve plans and timetables and inform
WWPU of the existing interventions in scope at their establishments and the
timetables agreed for their review. Details will be entered in the database of
regime interventions and Area/Operational Managers will have full national
information. Where similar interventions are in operation at establishments in
more than one Area/Operational Command, the Area/Operational Managers
concerned may agree on the designation of a lead establishment to take
responsibility for the review and preparation of a full business case.
2.14
Interventions may already have written material demonstrating how some or all of
the criteria are met. In such cases, it will not be necessary to re-write; it will be
sufficient to attach existing material to the pro-forma, but the appropriate sections
of the pro-forma must refer to the precise parts of the attachments which match
the specified criteria.
2.15
Where a lead establishment has prepared a full business case and it has been
approved, then other establishments must prepare a shorter business case for
approval by their Area/Operational Manager, as set out in para. 2.7 above
10
See para. 13 of the Introduction
11
For timetable, see para. 13 of the Introduction
Managing change control
2.16
In accordance with What Works principles, regime interventions must be delivered
as designed. Substantial changes require a fresh business case to be made and
approved. In such cases, the pro-forma need only:



specify the proposed changes;
state ‘no change’ where the means of meeting any criterion are unchanged;
attach existing material relating to any such criterion.
2.17
Only minor in-year changes in design may be made, but they must have been
justified in writing, and the approval of the Governor/Director of contracted-out
establishment must be recorded in writing and notified to the Area/Operational
Manager, who will consider whether the changes are more than minor and hence
whether a fresh business case is required.
2.18
Continuation of delivery of an approved regime intervention and the scale of
delivery approved must be considered on an annual basis by reference to:




the evidence from monitoring, audit and inspection;
any evidence from evaluation of this or another relevant intervention
any changes in the risks and needs profile of the establishment’s
population; and
any changes in the capacity of the establishment to deliver;
and will be included in the establishment’s business plan. Any decisions to cease
delivery or to change the scale of delivery must be recorded on the database of
regime interventions.12
12
See Annex E.
ANNEX A
SCOPE
A1
This PSO applies to regime interventions for prisoners aged 18 and over. Different
arrangements, determined by the Youth Justice Board, apply for young offenders
under 18.
In Scope
A2
Regime interventions in scope are those whose primary or major objective is to
change prisoners’ behaviour, supported by changes in attitudes and development
of skills. Regime interventions which may have such by-products, but whose
primary or major objectives are different, are not within scope. The changes in
behaviour may be:




A3
To reduce the likelihood of re-offending after release
To improve institutional behaviour, e.g. to reduce assaults and bullying
To improve inter-personal behaviour, including respect for diversity
To improve resettlement prospects, e.g. through education and training
Regime interventions which may in themselves be insufficient to achieve change
in prisoners’ behaviour, but are stages towards this, are in scope, e.g.


Awareness raising
Motivation enhancement
Not in Scope
A4
Interventions validated by appropriate external independent bodies, including the
Correctional Services Accreditation Panel (formerly Joint Prison-Probation
Accreditation Panel) and professional bodies such as in medicine and psychology,
are not in scope. The relevant criteria are set by the appropriate body, along with
procedures to maintain standards such as inspection or audit. Use of such
external bodies is preferred, where available.
A5
An intervention which has been rejected by an external body must not be resubmitted for internal validation unless
 it has been revised
and
 feedback from the external body is added to the business case.
A6
Interventions provided for prisoners by statutory bodies (or by authorised bodies
on their behalf) are not in scope if they are identical to those provided in the
community and if they are subject to the arrangements for quality assurance that
apply in the community. The Prison Service’s resettlement strategies seek to
ensure that prisoners are included within the mainstream service responsibilities
of these agencies, to reduce social exclusion.13 Partnerships are being developed,
13
See PSO 2300 Resettlement
nationally and regionally, with the Department for Education and Skills (DfES), the
Department of Work and Pensions (DWP), the Department of Health (DH) and
others.
A7
Regime elements whose primary objectives concern the following are not in
scope:



Preserving the rights, decency and dignity of prisoners
Enabling the establishment to function
Serving the interests of the establishment rather than the prisoner
Such regime activities may have beneficial spin-off effects in prisoners’ behaviour
and attitudes but they are not justified by reference to these potential outcomes.
They are subject to other Prison Service Standards and Orders. Their importance
is not diminished by being outside scope.
A8
Structured stand-alone one-to-one work with prisoners to assist them to
understand their offending, cope with custody and relationships, and prepare for
offending behaviour programmes will not be within scope. The important
contribution made by such interventions is recognised but it would not be
practicable to complete business cases to cover the wide diversity of such work,
which is normally carried out by professionally qualified staff, such as
psychologists, working to professional standards.
A9
Similarly, stand-alone one-to-one work by Chaplaincy or CARATs workers or dropin ‘surgeries’ providing one-to-one advice for housing, employment or money and
debt management will be outside scope. Personal officer work and day-to-day
one-to-one interactions of staff with prisoners, although often intended to change
prisoners’ behaviour and attitudes, is not within the scope of this PSO.
‘Befriending’ work, e.g. by Listeners or Prison Visitors, is outside scope. Training
for Listeners is outside scope as the behaviour change sought is not the trainees’.
However, the criteria for validation set out in Annex B are appropriate as
benchmarks for such provision.
Other issues of scope
A10
14
The distinction of what is and what is not in scope is not always clear-cut
and discretion will need to be exercised, by reference to the principles set
out in Table 114. For example:

The workplace may serve a variety of objectives, including keeping prisoners
occupied and raising funds to offset costs. Where resettlement is a major
purpose and structured training is introduced to assist prisoners’ future
employment prospects, then the activity will come within scope, unless
externally validated.

A weekly act of worship is a routine element of the regime and is not within
scope. Additional religious activities, such as bible study, Alpha courses
In Section 1
and Islamic classes, where the main aim is to provide religious teaching
(although they may also influence prisoners’ attitudes and behaviour) are
not within scope. But a course run by, or under the auspices of, the
Chaplaincy which is designed primarily to change prisoners’ behaviour will
come within scope, e.g. a course on victim awareness intended to affect
understanding of the impact of their offending and attitudes towards victims.

A11
Basic health care, including mental health care, is not within scope. But
additional group interventions, such as promotion of a healthy lifestyle or
treatment of substance abuse, which have primary aims of changing
prisoner behaviour, are within scope, unless externally validated.
The form of the regime intervention may vary. It is likely to involve some learning
and practice of new skills, but may be one or a combination of the following, if
delivered in a group:

A programme, i.e. a systematic and reproducible set of activities, following
a structured manual

A course, i.e. a sequence of learning to reach a
specified standard of attainment

A general service, such as employment, financial
or housing advice.
A12
This PSO applies to all who provide regime interventions which are in scope,
whether paid or unpaid. This includes any of the following:







Prison Service staff
Staff of companies contracted to manage Prison Service establishments
National Probation Service staff seconded to Prison Service establishments
Contractors, e.g. education providers
Statutory agencies, e.g. local education authorities, local authority housing
departments, Job Centre Plus
Voluntary organisations
Individuals
A13
Contracts and Service Delivery Agreements relating to regime interventions must
include the relevant criteria. Where Prison Service funding is provided to develop
regime interventions, copyright must be held by the Home Office.
A14
It will be good practice, in line with the Prison Service strategic framework for
working with the voluntary and community sector15, for establishments to work with
their current and potential partner agencies to ensure that:


15
they understand the requirements of this PSO
they have a reasonable timescale over which to review current provision and
to prepare business cases for continuation of current provision or for new
provision
“Getting it right together”, December 2001

in appropriate cases, where it is apparent from current provision or from an
outline proposal that benefits to prisoners’ behaviour and attitudes are likely
to be achieved and in the light of resources available to the partner agency
concerned, Prison Service staff are able to offer assistance or to work jointly
in the preparation of business cases
Similarly, policy units will brief current and potential national partner agencies.
A15
Particularly careful consideration must be given to whether services provided by
outside organisations are within scope or not, so that they are not required to do
the additional work specified in this PSO unless it is mandatory.
ANNEX B
QUALITY ASSURANCE CRITERIA
Introduction
B1
The nine quality assurance criteria are set out briefly at para. 1.2. All nine criteria
must be covered when completing a business case for approval of an internally
validated regime intervention. The pro-forma for a business case is at Annex C.
The mandatory requirements set out here constitute a Code of Practice.
B2
The nine criteria are based on What Works principles and are drawn from the
evidence of what contributes to the effectiveness of interventions to reduce reoffending. But they are equally applicable to optimising the effectiveness of other
regime interventions that have the objective of changing prisoners’ behaviour.
B3
As evidence from the evaluation of interventions becomes available, these criteria
will be supplemented by guidance and, if appropriate, instructions relating to the
appropriate content of interventions.
Criterion 1: Objectives
B4
All interventions must have written objectives, which must be made available to all
relevant staff and prisoners. There may be a single objective or a number of
objectives. The objective(s) must be SMART (specific, measurable, achievable,
realistic and time-bound).16 The other features of the intervention must be
consistent with and proportionate to the written objectives.
B5
A variety of objectives are appropriate. They must be related to the Prison
Service’s objectives and principles and they must be designed to change
prisoners’ behaviour. A given activity may have a number of objectives.
B6
Examples of types of group work with prisoners where appropriate objectives for
internally validated regime interventions could be set are17:





Raising awareness or improving self-esteem/motivation, in relation to
specific factors related to the prisoner’s history of offending, including
denial, minimisation or justification
Advice, information and assistance, in relation to specific factors related to
the prisoner’s history of offending and intended to promote resettlement
Raising drugs awareness, reducing harm associated with drug use and
reducing drug dependence
Raising awareness in identifying and managing stress
Improving institutional behaviour
16
Exceptionally, the requirement to be time-bound will not be appropriate. See para. B12 for how this must be
handled in the Structure.
17
These examples are not comprehensive and do not indicate that existing activities with objectives relating to
these types would necessarily gain approval, nor that they have demonstrated effectiveness in meeting their objectives.
They will need to go through the approval process set out in this PSO.




B7
Improving family and social relationships
Improving social interaction
Improving physical, emotional and/or mental health, fitness and welfare
Promoting constructive use of leisure
The objectives for the individual partaking in a regime intervention will not
necessarily accord with the objectives for the intervention.
Example:
A drama programme may be arranged with the primary purpose of
providing a setting where prisoners with deficits in basic education who are not
willing to attend traditional classes may develop self-confidence and begin to
improve their communication skills. However, there may not be enough prisoners
who meet these criteria to make the programme viable. If other prisoners are keen
to join and their participation will enhance the learning of the target group; provide
them with relevant skills; not detract from their priority needs; and contribute
towards good order in the establishment; then the shortage of appropriate
prisoners is not an absolute bar to the intervention being approved.
Criterion 2: Rationale
B8
All interventions must have a written rationale, which sets out why the methods
adopted to run the intervention are appropriate to achieving the objectives and to
the target group.
B9
Where available, reference to research findings may be used to support the
rationale criterion. The Area Psychologist may be able to offer advice on meeting
this criterion.
Example:For an empowerment course for prisoners experiencing difficulties in
prison, structured group discussion is a suitable method to achieve the objective
of improving coping abilities because







the presence of other people with similar problems that they wish to
tackle is a powerful motivating factor for individuals;
it offers opportunities for learning from the shared experience of group
members;
it allows a greater awareness of others and their predicaments;
it enables the acquisition of insight through exposure of an individual’s
views and experiences to the scrutiny of others;
it enables an appreciation of self in relation to others;
it provides mutual support;
given the right atmosphere, it can foster a willingness to work and
learn together.
The Rationale could refer to evidence of the benefits of group work from research
literature or textbooks.
Criterion 3: Structure
B10
There must be a brief written structure for the intervention, which must be made
available to all relevant staff and prisoners. It may be appropriate to provide
different versions for prisoners and for staff responsible for delivery, to take
account of different perspectives. The structure must set out:







a clear indication to staff and prisoners of what is entailed;
a clear brief to staff or others who may be responsible for delivery;
the content, method(s), sequence and intensity of the intervention;
in the case of groups, the minimum and maximum number of places
necessary to make them viable and effective;
the number of sessions, which may be in the form of minimum and
maximum, required to meet the objective(s);
the purposes of specific sessions or modules;
the duration and frequency of sessions, which may be in the form of
minimum and maximum.
B11
In the case of substantial interventions, a full manual may be appropriate.
B12
Exceptionally, an intervention may not be time-limited. Where this is the case,



it must be stated in writing in the business case;
a notional maximum amount must be included in the structure; and
provision must be made to review and justify continuing participation by
individual prisoners beyond the notional maximum.
Criterion 4: Selection
B13
A target group of prisoners for whom the intervention is designed must be written
in the business case. All interventions must respond to needs that have been
identified.
B14
A method or methods of assessment, to ascertain whether the prisoner fits into
the target group, must be prescribed. The basis of assessment of the prisoner’s
risks and needs must be appropriate to the objectives of the intervention. Relevant
and available assessment tools must be used. The prisoner’s wishes and any selfassessment must be taken into account. The assessment process must be
proportionate to the scale of the intervention, i.e. a modest intervention does not
need substantial assessment. The Area Psychologist may be able to offer advice
on this criterion.
B15
All prisoners receive basic health assessments, including assessment of risk of
self-harm, and risk assessment on suitability for cell sharing, on reception. For all
prisoners, assessment is part of induction. Specialised assessments currently
available include:




Counselling, Assessment, Referral, Advice and Throughcare services
(CARATs) assess all prisoners who have self-referred or been referred by a
member of staff or an external body for drug-related needs;
Basic skills assessments, to identify deficits in literacy, numeracy and
communications skills18;
Dispersal Induction Assessment, a package of assessments being rolled
out in the high security estate;
Psychometric tests, used in specified circumstances only; they may be
used only by qualified assessors.
B16
Sentence planning is the most readily available and comprehensive assessment
tool for eligible prisoners. It co-ordinates the efforts of different individuals and
agencies involved with the prisoner and provides the framework for assessing the
prisoner, planning his or her sentence, and setting targets and reviewing progress,
based on the risks and needs identified. For young offenders with a month or
more in custody post-sentence and for adults serving a sentence of 12 months or
more with 6 months or more in custody post-sentence, sentence planning is
required. For lifers, a specialised Life Sentence Plan is being rolled out. There is
currently no assessment and sentence planning system for short term prisoners,
with sentences of under 12 months; some establishments are using local
assessment systems.
B17
OASys has been developed as a joint prison-probation offender assessment
system to assess likelihood of re-offending and risk of serious harm to self or
others and to determine appropriate interventions to reduce risk. It will trigger
specialist assessments where required. Existing specialist assessments are being
reviewed and their links with OASys will be specified. An IT-based version is
being developed and OASys will be rolled out to replace current sentence
18
Specialised educational assessments, eg. to screen for dyslexia, may also be available
planning arrangements for prisoners aged 18 and over. Roll-out across the Prison
Service is scheduled to begin in April 2003 and will take 12 to 18 months. 19
B18
New assessments in development include:


B19
Risk assessment is also a core part of other processes, such as:





B20
categorisation, re-categorisation and allocation;
HDC;
ROTL;
parole reviews;
recall and revocation of licences.
Pending availability of OASys, for interventions with relevant objectives, it may be
helpful to note the risk factors which have been identified as related to reoffending for a significant number of people and which may be improved by an
appropriate intervention:










B21
identification of dangerous and severely personality-disordered;
practical checklist of accommodation and employment resettlement needs.
accommodation;
education, training and employability;
finance;
relationships;
lifestyle;
drug misuse;
alcohol misuse;
emotional well-being;
thinking and behaviour;
attitudes.
Where a prisoner is on an open F2052SH, consideration must be given to the
timeliness of a proposed regime intervention. Risks of heightened anxiety in the
prisoner which might increase the risk of self harm must be avoided. Similarly,
increased risk to others must also be avoided. Prisoners who present a significant
risk of serious harm to others must not be permitted to undertake an intervention
which is inappropriate.
Example:
Prisoners who have committed sexual or violent offences against
children must have a specific risk assessment by relevant professionals as part of
the selection process for a course in parenting skills which is approved under the
validation procedures set out in this PSO or externally validated. Such prisoners
will not attend the course in parenting skills unless this specific risk assessment
recommends it.
B22
19
Participation in any intervention must be considered within the context of the
individual’s career as a whole, particularly their period in custody or under
Further information on the roll-out of OASys will be available in due course. The current PSO and Standard on
Sentence Management and Planning will be rewritten.
sentence, including any licence period and post-release supervision. Some
interventions may need to be sequenced with others to enable them to be
effective.
Example:
An intervention may require a minimum level of literacy in its target
selection of offenders. An appropriate basic skills course will then need to be
taken first by prisoners who do not meet that minimum.
B23
There must be no bias in the opportunities and processes for selection within the
specified target group on irrelevant grounds. The means by which prisoners will
be informed about and have opportunities to attend the regime intervention must
be set out.
Criterion 5: Achievement
B24
The method(s) for assessing and recording what prisoners have achieved on
completion of the intervention must be written in the business case 20. This must
include seeking prisoners’ own feedback on what they have learned and what
benefits they will continue to apply in their lives in custody and on release.
B25
Provision may also be made for assessing and recording progress at stages. This
may be valuable for comparing drop-outs and completers and for improving
design and delivery. Reasons for drop-out must be recorded. The business case
must specify what action may be taken to minimise drop-out, including avoidance
of transfer to another establishment.
B26
Where appropriate, tools to assess changes in attitudes may be used. Completion
of such tests before and after the intervention may provide an indicator of what
has been achieved. The selection of such tests must be informed by professional
advice. Some tests may only be used by qualified staff.
Criterion 6: Scale and costs
B27
The business case must specify details of the scale and costs of the intervention:


B28
Where possible and appropriate, additional cost information should be provided:

20
Scale - number of places, starts, and/or completions to be provided over a
given time period, normally the financial year;
Costs - some measure of costs must be provided as a guide to investment
decisions e.g. grade of staff and cost per hour; rate of prisoner pay that
applies.
for new interventions, including interventions new to the establishment but
previously available elsewhere: total start-up costs;
Existing documentation such as the National Record of Achievement (NRA) produced for education and the
F2055c Inmate Record of Training may often be appropriate.


B29
Where an intervention is provided by an external supplier 21, correct procurement
and accounting procedures must be applied. Contracts must specify:





B30
direct costs incurred, both in total and per unit (i.e. place, start, completion),
and what they consist of (e.g. staff, materials, premises etc.);
indirect and estimated costs, both in total and per unit, and what they
consist of (e.g. overheads for management, utilities, depreciation, staff
training, advice and support, administrative support, monitoring and audit
etc.).
duration of contract and provision for re-negotiation;
scale of provision;
total and unit costs and which party is responsible for which costs;
action in the event of non-delivery;
procedures for monitoring delivery and for resolving disputes relating to
responsibility for non-delivery.
Where an intervention is provided by an external supplier at nil cost to the Prison
Service, a Service Level Agreement must specify:


scale of provision;
procedures for monitoring delivery and for resolving disputes relating to
responsibility for non-delivery.
Criterion 7: Staff selection, competence, management and support
B31
The business case must specify staffing requirements necessary to ensure that
the intervention is delivered as designed and is effective in meeting its objectives.
These must include:






staffing levels, related to scale of provision, including whether staff are
dedicated for the regime intervention or drawn from a pool with other
responsibilities22;
job specification(s), including competences and any required qualifications;
how staff will be selected and trained (if necessary), including any voluntary
or mandatory booster training
how staff will be managed and supported, including frequency and level of
supervision and time allowed for preparation, debrief, supervision etc.
how staff providing management and/or support will themselves be
selected, trained (if necessary), managed and supported
in the case of contracted provision, how staff managing the contract will be
selected, trained (if necessary), managed and supported
21
The Prison Service Management Board (PSMB) has decided that public funds must not be used for interventions
that are based in religious beliefs and provided by religious bodies, other than through the chaplaincy.
22
In the interests of quality and to ensure staff training is cost-effective, where a pool of staff is used, the minimum
commitment of each member of staff must be specified and monitored.
Criterion 8: Records, Monitoring and Audit
Records
B32
is:
The minimum prisoner record requirement23, to be specified in the business case,








prisoner number (to enable linkage to other information, pending availability
of fully-electronic system);
has prisoner been assessed?
has prisoner been found to be suitable or not?
has prisoner been selected?
has prisoner started the activity?
complete record of attendance
has prisoner completed the activity?
what has the prisoner gained from participation?
A simple card index system will suffice if no IT-supported system is available. The
following Prisoner Record pro-forma is available on the Prison Service Intranet:
Regime Interventions: Prisoner Record Pro-Forma
Name of intervention
Prisoner name
Prisoner number
Age
Gender
Ethnic Group
Foreign National
Yes
No
Suitability assessed
Yes
No
Found suitable
Yes
No
Date started
23
Sessions attended
Number
Sessions not attended
Number
LIDS provides the means to record and analyse some of these data.
Completion
Yes
No
Achievement
Monitoring
B33
Arrangements to reproduce and collate data from the general prisoner record such as age, gender, ethnic group, offence, sentence - will be necessary to
enable effective monitoring and evaluation to take place.
B34
These records must be collated routinely, to enable monitoring by management of
take-up rates, drop-out rates, completion rates, and records of achievement.
Governors and Directors of contracted-out establishments must monitor to ensure
that there is no unfair or irrelevant discrimination on ethnic or other grounds in
access to every intervention and that delivery is free of unfair or irrelevant
discrimination on ethnic and other grounds, so that all participants are equally able
to benefit. The frequency of review must be specified; it will vary according to the
scale and frequency of the programme, course or other activity, but must be at
least annual. The business case must specify responsibility for review24. Where
findings cause concern, management must prepare and implement an action plan
to deal with the problem(s); options may include ceasing delivery.
B35
Financial records must be kept which, alongside the prisoner records required, will
enable Governors, Directors of contracted-out establishments, Area/Operational
Managers and relevant policy units to determine whether delivery has been costefficient and to compare the efficiency of different interventions. This will be a
consideration in deciding which activities will continue to be funded and which will
cease.
Audit
B36
Self-audit will apply. This PSO supports the Regimes Standard, to which SAU
audit applies. The Regimes Standard will not be revised to incorporate the
requirements of this PSO.
Criterion 9: Evaluation
24
For example, the Resettlement Policy Committee. Where the intervention is delivered by an external provider,
monitoring may be a shared responsibility.
B37
The business case must indicate how the intervention will be reviewed to establish
that it is meeting its aims and objectives and is having a positive impact.
Evaluation is necessary in order to draw conclusions about effectiveness. RDS
advice on evaluation is available. Where possible, appropriate measurable
indicators of impact must be chosen and specified in the business case. For
example, a course on anti-bullying might be reviewed annually by reference to
records on bullying or assaults on prisoners.
B38
Conclusive evaluation of effectiveness depends on adequate numbers of cases
and suitable comparators. This will be outside the normal capacity of
establishments to provide, but such studies may be conducted periodically on a
national basis.
ANNEX C
PRO-FORMA FOR BUSINESS CASE AND APPROVAL OF REGIME INTERVENTIONS
This pro-forma is available through the Prison Service Intranet. Pro-formas of all
applications for approval must be retained by Area/Operational Managers and
made available when required for purposes related to audit, evaluation or reports
to or on behalf of the What Works in Prison Strategy Board and PSMB.
1a.
or
1b.
Establishment or lead
establishment or sponsoring
establishment
Policy unit or working group
or sponsoring policy unit or
working group
1c.
Outside body or bodies
if applicable
2.
Title of intervention
3.
Intervention Manager
Name
Position
Tel.
FAX
E-mail ID
4.
Name(s) of provider(s)
if not delivered by staff of the establishment
5.
Nature of intervention
Please tick all that apply
GENERAL PURPOSE(S)
Information giving
Raising awareness
Developing skills
Increasing motivation
Other(s) – please specify:
OFFENDING-RELATED FACTOR(S) ADDRESSED
tick all that apply
Accommodation
Education, training, employability
Finance
Relationships
Lifestyle
Drug misuse
Alcohol misuse
Emotional well-being
Thinking and behaviour
Attitudes
OTHER FACTOR(S) ADDRESSED
Please specify:
Please
Intervention history
6.
Date the intervention was introduced at this establishment
if applicable
7.
Date of any previous review at this establishment
if applicable
8.
Has the intervention been approved for delivery at another Yes
establishment?
Please tick appropriate
box
No
9.
If yes, name of establishment
If known, date and/or ID of approval
Date
ID
10.
Date submitted to Governor/Director of contracted-out
establishment for support
11.
Date submitted to Area/Operational Manager for approval
12.
Decision by Area/Operational Manager
Please tick appropriate box
Signature
…………………………………….
Yes
No
Changes required
Date
Name (printed) …………………………………….
Area/estate
…………………………………….
13.
If yes, any variation in scale and costs approved, whichApproved scale
(Number p.a.)
differs from business case
Please leave blank if no variation from business case Approved costs
(£)
FOR WWPU USE ONLY:
ID allocated
Date entered
How quality assurance criteria are met
Note: If a criterion is fully met by the business case prepared by another establishment
and approved by an Area/Operational Manager, please:
 tick the box in the left-hand column
 provide the name of the establishment and/or the ID of the approval in the right-hand
column
Annex B of this PSO sets out the quality assurance criteria in detail and must be
read before completion of this part of the pro-forma
Criterion 1: Objectives
Clear objectives for the intervention must be specified. They should be
SMART and related to Prison Service objectives and principles.
Tick box Give details below of the objectives (or attach
If met
documentation if prepared previously and note below
before
references therein to the objectives).
Criterion 2: Rationale
The rationale must set out why the methods for delivering the
intervention are appropriate to the objectives and to the target group.
Tick box Give details below of the rationale (or attach
If met
documentation if prepared previously and note references
before
therein to the rationale).
Criterion 3: Structure
The structure should be brief and set out what is entailed, the content,
methods, and sequence of the intervention and, for groups, the viable
minimum and maximum number of places, number of sessions,
purposes of specific sessions, duration and frequency of sessions.
Tick box Attach or give details below of the structure (or attach
if met
documentation if prepared previously and note references
before
therein to the structure).
Criterion 4: Selection
A target group of prisoners for whom the intervention is designed and the method
of assessment to fit the target group must be specified, including any assessment
tools used.
Tick box Give details below of prisoner selection (or attach documentation if
if met
prepared previously and note references therein to selection).
before
Criterion 5: Achievement
The method(s) for assessing and recording achievement on completion of the
intervention must be specified including how prisoners’ feedback is to be obtained
and recorded
Tick box Give details below of assessing/recording achievement (or attach
if met
documentation if prepared previously and note references therein to
before
achievement).
Criterion 6: Scale and Costs
The number of places, starts, and/or completions in the financial year (or other
specified period) must be specified together with costs.
Tick box Give details below of scale and costs (or attach documentation if
if met
prepared previously and note references therein to scale and costs).
before
Criterion 7: Staff Selection, Competence, Management and Support
Details must be specified of staffing levels, job specifications, competencies and
qualifications required, staff selection and training process, support and
supervision.
Tick box Give details below of staff selection etc (or attach documentation if
if met
prepared previously and note references therein to staff selection).
before
Criterion 8: Records, Monitoring and Audit
Records – specify details of prisoner records kept. This should include prisoner
number, informed or requested, assessed, selected, suitability, started,
attendance, completion and gains. Also financial records (to determine cost
effectiveness).
Monitoring - specify methods and frequency of checks for unfair or irrelevant
discrimination, access and delivery. Also collation and analysis of records on takeup, drop out, completion and achievement.
Audit – self audit arrangements to be specified.
Tick box Give details below of records, monitoring and audit (or attach
if met
documentation if prepared previously and note references therein to
before
records etc).
Criterion 9: Evaluation
It must be specified how achievements against objectives will be assessed in order
to draw conclusions about the effectiveness of the intervention.
Tick box Give details below of evaluation (or attach documentation if prepared
if met
previously and note references therein to evaluation).
before
ANNEX D
PROCEDURES FOR APPROVAL OF REGIME INTERVENTIONS: FLOW CHART
Is the intervention an accredited offending
behaviour programme?
BEHAVIOUR PROGRAMME?
YES
NO
Is the intervention validated by an
independent external body?
NO
YES
The intervention must have
been validated by a recognised
independent external body
which includes site inspection
or audit OR standards of
professional body.
Is it an intervention
designed to change
prisoner behaviour?
NO
No
Action
YES
Decide if it is within the scope
of PSO 4350 - refer to table 1
and annex A for details.
NO
The programme must have been accredited
by the CSAP or its predecessors; or has been included
in the Prison Service’s programme development
portfolio
If above applies, the only action required
under PSO 4350 is to record details of the
intervention in the database of regime
interventions – see Annex E .
If above applies, the only action
required under PSO 4350 is to record
details of the intervention in the
database of regime interventions – See
Annex E.
YES
No action
A business case pro-forma must be
completed as at annex C, to
demonstrate how the intervention meets
the nine quality assurance criteria in
annex B
ANNEX E
DATABASE OF REGIME INTERVENTIONS
E1
The database set out below is being established to ensure a central record of
regime interventions that:
i.
ii.
iii.
iv.
v.
vi.
E2
WWPU is seeking IT-assisted business change to support efficient operation of
this PSO. If agreed, his will provide:


E3
direct read-only access to the database for establishments; and
direct write-in access to Area/Operational Managers and their teams, and
appropriate Headquarters policy units.
Until this is available, returns will be sent to WWPU via e-mail26, or by FAX to 020
7217 5750 or by mail to room 129, Abell House. The database form is on the
Prison Service Intranet. The responsibility for returns is as follows:




E4
have been validated under the procedures set out in this PSO; or
are in development or under review, with the intention of seeking approval
under the procedures set out in this PSO; or
have been accredited by the Correctional Services Accreditation Panel
(CSAP) or its predecessors; or
have been accepted as part of the development portfolio for future
accreditation by the CSAP25; or
have been accredited by other independent external bodies; or
(optionally) are in development or under review, with the intention of
seeking approval by other independent external bodies.
Area/Operational Managers are responsible for i. and ii.
The relevant HQ policy unit is responsible for iii.
WWPU is responsible for iv.
Area/Operational Managers are responsible for v. and may also use the
database for vi.
Information must be recorded on the database quickly and no later than 4 weeks
after the relevant decision has been made.
25
The development portfolio is approved by the Prison Service Management Board (PSMB) on the
recommendation of the What Works in Prison Strategy Board (WWPSB). See PSO 4360 (forthcoming) for details.
26
A dedicated WWPU e-mail address is being arranged. Until this is notified, any WWPU contact may be used.
See para. 19 of the Introduction to this PSO.
DATABASE OF REGIME INTERVENTIONS: PRO-FORMA
Please tick boxes that apply
1.
ID
(WWPU to allocate)
2.
Title of intervention……………………………………………………………..
3.
Validating body
Internal
CSAP
Other independent external: specify
………………………………………………………
4.
Status
In development
Under review
Approved
Modified
5.
(Lead) establishment………………………………………………………………
(Lead) area/estate………………………………………………………………
OR
(Lead) policy unit……………………………………………………………….
6.
Intervention manager contact details
Name
…………………………
Position
…………………………
Tel.
………………………… Fax …………………………
E-mail ID …………………………
7.
Name of provider(s)
Internal
External: specify ……………………………….
8.
Nature of intervention
General purposes:
Information giving
Raising awareness
Developing skills
Increasing motivation
Offending related factors addressed:
accommodation
education, training and employability
finance
relationships
lifestyle
drug misuse
alcohol misuse
emotional well-being
thinking and behaviour
attitudes
9.
Approved by
name
………………………………..
position
………………………………..
10.
Date approved………………………………………………………….
11.
Scale per annum approved:
12.
Costs per annum approved
places
……………………
starts
……………………
completions
……………………
£ …………………………………….
ANNEX F
REGIME INTERVENTIONS VALIDATED BY INDEPENDENT EXTERNAL BODIES
General
F1
Where there is an appropriate external validating body for the type of regime
intervention, then the requirements it sets will be sufficient as evidence of quality.
It is desirable that the requirements of appropriate external validating bodies are
used where they are available, because:


this demonstrates to the public that the quality of Prison Service
interventions is high
this contributes to reducing social exclusion by providing prisoners with a
standard of provision which is available in the community and by enabling
released prisoners to demonstrate that their knowledge and skills are
comparable to those of others
F2
Many regime interventions, particularly those offered by education contractors, are
already externally verified. Examples of such regime interventions are:

pre-release courses or programmes

courses designed to raise awareness of drugs, victims, bullying, etc.

short treatment programmes that would not be appropriate for Correctional
Services Accreditation Panel (CSAP) accreditation.
F3
It is not necessary for externally validated regime interventions to meet the criteria
set out in this PSO. Nor is it necessary for the business case pro forma at Annex
A to be completed. Quality assurance is provided through meeting the
requirements of the independent external body.
Validating bodies
F4
Prisoners’ Learning and Skills Unit can advise on the processes involved in
accreditation through an Awarding Body. Advice on educational bodies and their
requirements is available from the education contractor to the establishment, from
the Learning and Skills Adviser for the area or function, and from Prisoners’
Learning and Skills Unit. Advice on other bodies is available from the relevant
policy unit or area specialist.
F5
It is important that any independent outside body used to validate a regime
intervention provides, authorises or contributes to site inspection or audit. The
following recognised validating bodies all incorporate this:
CSAP
National Open College Network
ASET
NVQ awarding bodies such as City and Guilds
Guidance Council Accreditation Board
Central database of regime interventions
F6
The only mandatory requirement for externally validated regime interventions
under this PSO is that they must be recorded on the database of regime
interventions, as set out at Annex E.