1. Introduction

The Prisons and Probation Ombudsman (PPO) carries out independent investigations into complaints and deaths in custody. The PPO’s role and responsibilities are set out in detail in the office’s Terms of Reference.

The PPO has three main duties:

  • to investigate complaints made by prisoners, young people in detention (prisons and secure training centres), offenders under probation supervision and individuals detained under immigration powers (detained individuals)
  • to investigate deaths of prisoners, young people in detention, approved premises’ residents and detained individuals due to any cause
  • to investigate deaths of recently released prisoners that occur within 14 days of release from prison (except homicide)

The purpose of these investigations is to understand what happened, to correct injustices and to identify learning for the organisations whose actions we oversee so that we can make a significant contribution to safer, fairer custody and offender supervision.

In November 2023, Independent Prisoner Complaint Investigations (IPCI) was launched as the new name for the PPO’s complaint investigations function in prisons and youth custody.

During the course of their work, our staff will meet with, contact and speak to a variety of different people. These include:

  • complainants (for example, people in prison)
  • bereaved family members
  • employees of the services we investigate
  • employees of other investigatory bodies, such as the police, Coroners, clinical
  • reviewers, Independent Office for Police Conduct (IOPC) etc.
  • civil servants
  • employees and volunteers at campaigning groups or charities
  • journalists or researchers
  • members of the public with an interest in our work, including those who submit
  • Freedom of Information requests

The PPO and IPCI communicate via letter, email and telephone. Video-conference and face-to-face meetings are held when necessary.

The PPO is committed to ensuring all communications are positive, fair, polite and helpful. Everyone who contacts the PPO or IPCI will:

  • be treated with respect and dignity
  • be treated fairly with regard to all procedures, policies and assessments

No individual will be unjustly discriminated against. This includes, but is not limited to, discrimination because of gender, age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion and belief, and sexual orientation (including perceived sexual orientation).

  1. Unreasonable behaviour

Very occasionally, people will contact the PPO or IPCI and exhibit behaviour or actions that make it very difficult for us to assist with their enquiry. This unreasonable behaviour might take many forms but could include abusive language and/or unreasonable demands made of our staff or sending us offensive/explicit material.

We take responsibility to our staff extremely seriously. It is unacceptable for our staff to experience the following:

  • aggressive or abusive behaviour (including making threats, physical violence, personal verbal abuse, derogatory remarks and rudeness, inflammatory statements and unsubstantiated allegations)
  • offensive or explicit language or content
  • people persistently making the same complaint or request, or who by the frequency or nature of their contacts, hinder the PPO’s work.

In line with paragraph 21 of our Terms of Reference, in such cases we have a responsibility to take action to protect staff.

This policy explains how we identify unreasonable behaviour and manage these interactions with the PPO or IPCI, and how we protect the rights of individuals throughout the process.

Examples of behaviour that the PPO finds unacceptable:

These are some of the types of behaviour that the PPO finds unacceptable and may take action against under this policy. The list is not exhaustive.

a. Excessive unhelpful communication during an investigation

The PPO and IPCI are pro-active in seeking out the information required to investigate a case thoroughly and objectively. We will endeavour to keep individuals up to date with progress when the case is complex and the timescale lengthy. Generally, we do not require additional information to be sent in during our investigation unless it is new and relevant to the case.

Sometimes the length/volume and/or unfocused nature of letters sent to the PPO or IPCI by individuals can delay resolution of a case. For example, a prisoner submitting a complaint might send many copies of information that has already been submitted or that is not relevant to the complaint.

b. Unreasonable demands

The PPO, including IPCI, exists to provide a service to all individuals and aims to respond positively to requests when reasonable. A demand though is unacceptable if complying with it would substantially impact on the work of the office, not be a good use of staff time, and/or the cost of responding would exceed appropriate limits.

Such demands include repeatedly demanding a response within an unreasonable timescale, insisting on speaking to a particular member of staff when that is not possible and insisting that particular staff members do or do not deal with a complaint or request. Such behaviour may also include repeatedly changing the substance of a complaint or request or raising unrelated issues.

c. Abusive or offensive behaviour

We understand that individuals that contact us might be in difficult or upsetting circumstances themselves, and that they may be frustrated and angry because of the way they feel they have been treated. However, we have a duty to protect staff. We will not accept any abusive behaviour directed towards staff, whether this is in written, phone or face-to-face communication and/or over social media.

Such behaviour would include:

  • aggressive swearing
  • repeatedly directing swear words at PPO/IPCI staff and ignoring requests to stop doing so
  • discriminatory language, such as racist or sexist language (see our ‘Zero tolerance policy’ below)
  • making unfounded accusations about staff motives or behaviour
  • shouting
  • repeatedly interrupting
  • making threats
  • making lewd or obscene comments
  • using social media to gain personal information about staff to embarrass or harass staff

Zero tolerance policy

The PPO will not tolerate or engage with abuse, harassment, or discrimination in any form, particularly with direct, or indirect reference to race, age, disability, religion or belief, sex, gender or gender reassignment. We may report any such abuse to relevant bodies, such as HMPPS and/or the Police if necessary.

d. Unreasonable use of the complaints process

It is important for individuals to be able to ask for an objective investigation into a situation where they believe they are not being treated fairly or according to policy. A complainant has the right to complain to us about an individual establishment as many times as they need.

There may be times though when we consider that an individual is making continued vexatious complaints. Such use of the complaints system would risk taking up PPO (including IPCI) staff time and delaying the progression of genuine complaints.

Access to the PPO and IPCI is a right for individuals but if such circumstances do arise, we reserve the right to take action to ensure the use of the complaints process is legitimate.

e. Other unreasonable behaviour

The categories and examples listed in this policy provide the basis for the PPO to determine whether any action is required against individuals but are not exhaustive. We reserve the right to determine that other repeated behaviour that stops it performing efficiently and effectively or ensuring its staff can work without abuse or harassment, is classed as unreasonable.

This includes enclosures within communication as defined by the inappropriate enclosures policy.

We consider sending letters or other material smeared with blood or other bodily fluids, excrement or other undesirable substances, or containing obscene material as unreasonable.

  1. Process for managing unreasonable behaviour

Stage 1 – Initial concerns raised
Anyone at the PPO/IPCI may decide that the behaviour of an individual complainant needs to be considered to identify whether it is unreasonable, under the guidelines given in section 2 of this policy. At this stage the member of staff will gather the evidence and raise the matter with a manager.

Stage 2 – Confirmation of unreasonable behaviour
A manager will consider the evidence presented. The manager will also consider the individual’s circumstances and any mitigating factors. The manager may also consult others in the PPO/IPCI. The manager will then take the decision whether the individual’s behaviour is considered to be unreasonable by the PPO/IPCI.

Stage 3 – Notification of unacceptable behaviour
If unreasonable behaviour is confirmed, a manager may write to the individual to notify them that their behaviour has been deemed unreasonable and what action the individual is expected to take to cease the unreasonable behaviour. The letter will detail what behaviour specifically is unacceptable and when in the past this behaviour has been shown. We will explain that their behaviour is impacting negatively on our consideration of their, or other people’s, complaints or requests for information and that if it continues, we reserve the right to take action. This stage will be omitted if the abuse is through the form of social media.

Stage 4 – Implementation of action
If the unreasonable behaviour persists, we will take appropriate action, as outlined in paragraph 4.

Stage 5 – Review
All cases where an individual has had their behaviour classed as unreasonable will have that classification reviewed on at least a monthly basis. There is a presumption to relax or remove actions where this is possible, and if a change in behaviour warrants it. A manager will conduct the review.

Not all individuals will be managed through all of these steps. We reserve the right, in the most exceptional of circumstances to take immediate action against the most abusive individuals, including (where appropriate) discontinuing any complaints investigations.

  1. Examples of what action might be taken

Actions that we may take in response to unreasonable behaviour include:

  • reporting the behaviour to the service in remit (e.g., prison governor) or the police
  • limiting or withdrawing the service
  • where the individual is a complainant, requiring the complainant to refer to no more than one complaint in each correspondence
  • where the individual is submitting information requests, requiring the complainant to refer to no more than one request in each correspondence
  • requiring correspondence to be submitted on a PPO or IPCI pro-forma
  • temporary or permanent blocked access to our voicemail service
  • on social media, accounts may be blocked, and threats may be reported to the social media platform and/ or the police
  1. Dealing with abusive voicemails

The details of abusive voicemails will be logged and reported to the prison. We may request that the PPO and IPCI number is blocked for repeated and extreme abusive callers.

  1. Dealing with threats to staff

Threats made against our staff will always be taken with the utmost seriousness whether made in writing, by phone, during a personal interview, or over social media. Incidents may be reported to the police or, where appropriate to the services in remit to consider further action.


Please note, if you want to make a complaint about the conduct of Prisons and Probation Ombudsman staff, including IPCI staff, please contact: officialcomplaints@ppo.gov.uk.  Further details can be found on the PPO’s website at https://ppo.gov.uk/about/senior-management/complaints-about-professional-conduct-of-ppo-staff/.