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Guidance

Checklist: When to issue following new health-related information (accessible)

Updated 3 July 2026

Application

1.1. The following guidance applies to healthcare staff, contracted service providers (CSP), and Home Office staff in immigration removal centres (IRCs) and residential short-term holding facilities (RSTHFs).

1.2. This checklist applies specifically to health-related risks. All existing guidance relating to non-health factors considered within an IS91RA Part C submission (including security, behavioural and operational risks) remains unchanged and continues to apply.

Purpose

2.1. This guide assists both medical and non-medical staff in IRCs and RSTHFs in deciding when to issue an IS91RA Part C following new health-related information about a detained individual. It is not intended for non-health-related risks.   

2.2. As the IS91RA Part C contains special‑category health information, all sharing must comply with:

  • the Common Law Duty of Confidentiality (CDLC);
  • the UK GDPR, and
  • the Data Protection Act 2018

2.3. The lawful basis for processing and sharing this information is set out in relevant Home Office and NHS England information‑governance guidance, including the Home Office Borders, Immigration and Citizenship Privacy Information Notice and the . Sharing an IS91RA Part C does not rely on the detained individual’s consent.

2.4. Staff must ensure that only the minimum necessary information is included in the IS91A Part C to describe the nature of the risk or change in vulnerability. Diagnostic details, clinical history or symptoms must not be included unless essential to explain the specific risk for safeguarding or detention‑suitability purposes. The completed form must only be shared with those who have a legitimate need to receive it, using an approved secure route such as secure email or another locally approved secure system.

2.5. The IS91RA Part C enables the relevant casework team to review the individual’s Adults at Risk considerations and suitability for continued detention. It also ensures that relevant health-related risk information is communicated promptly to support safe management in detention, while maintaining robust confidentiality and proportionality standards.

2.6. Where health concerns appear to meet the threshold for:

  • Rule 35(1), 35(2) or 35(3) (IRCs) or Rule 32(1), 32(2) or
  • Rule 32(3) (RSTHFs), staff should recognise that a full Rule 35 (IRCs) or Rule 32 (RSTHFs) report may ultimately be required. See DSO 09/2016 Detention Centre Rule 35 and Short-Term Holding Facility Rule 32 for further information. Where such a report is not required, an IS91RA Part C notification enables the responsible casework team to review suitability for detention and, where appropriate, the Adults at Risk level.

3.1 Healthcare-led notifications

Healthcare staff must issue an IS91RA Part C as quickly as possible where:

  • a new diagnosis of a medical condition such as (but not limited to) epilepsy, diabetes, heart disease, severe mental illness which may present urgent risk, significant incapacity or have a long-term impact on health. Information shared must focus on the specific risk arising from the condition (e.g., “increased risk of seizureâ€) rather than full diagnostic detail, symptoms or clinical history, unless those details are essential

  • there is a change in an existing medical condition which, in clinical judgement, affects the person’s risk level or their ability to be managed safely in detention (e.g. worsening symptoms, new complications, or the need for specialist assessment or treatment).  Only the minimum necessary information should be shared to describe the nature of the risk (e.g. “increased risk of seizureâ€), rather than full diagnostic or clinical history, unless specific details are essential to understanding the risk

  • there is a change in medication or treatment which, in clinical judgement, does, or may affect the person’s risk level or their ability to be managed safely in detention.  Only the minimum health information necessary to explain the nature of the risk should be shared. Detailed clinical history or diagnosis should not be included unless essential to understanding the risk

  • a confirmed or suspected communicable disease that may pose a risk to others such as (but not limited to) tuberculosis, measles, COVID-19, including where:

    • the individual is symptomatic and requires isolation; or
    • there has been identified exposure to a confirmed case

This ensures healthcare providers and CSP can assess potential exposure and take appropriate safeguarding measures. A full list of communicable diseases is available at: www.gov.uk/guidance/notifiable-diseases-and-how-to-report-them

  • a referral is made by healthcare staff for a detained individual to receive mental health support or specialist intervention where the referral indicates a change in risk or care needs. Only the minimum necessary information should be shared to explain the nature of the risk (e.g., “referral made due to increased risk of self‑neglectâ€).  Detailed clinical history or diagnosis should not be included unless essential for understanding the risk

3.2 Multi-agency notifications

It is necessary for whichever team was first made aware of the risk (be it the CSP, compliance team, detention engagement team or healthcare team) to issue an IS91RA Part C as quickly as possible in the following situations:

  • signs of new or worsening mental health issues (e.g. severe depression, psychosis, acute anxiety, or PTSD symptoms) that do not currently meet the threshold for a Rule 35(1) or Rule 32(1) report. This does not prevent such report being raised at a later stage

  • referrals to Healthcare to request mental health support or specialist intervention for a detained individual

  • new concerns regarding self-harm or suicide risk that do not currently meet the threshold for a Rule 35(2) or Rule 32(2) report. This does not prevent such report being raised at a later stage. See for more information

  • expressions of concern or confusion by a detained individual regarding changes to prescribed medication, where this is associated with distress or indicating a potential increase in risk of self-harm or deterioration in mental health

  • a previously undisclosed health concern coming to light, including where it is no longer current (e.g., past self-harm risk, previous suicidal ideations, or an infectious condition that required isolation)

  • the detained individual has experienced a medical emergency or has been hospitalised, and, in clinical or professional judgement, this may indicate a change in risk, vulnerability, or suitability for detention

This is not intended to apply to all hospital attendances, but where the event may impact detention suitability.

An IS91RA Part C is not required where:

  • a condition is clinically low-risk and self-limiting, can be managed within standard primary care pathways, and does not affect the detained individual’s risk profile or care needs. Examples include (but are not limited to) uncomplicated STIs, common viral respiratory infections, and mild skin conditions, unless, in clinical judgement, these indicate a change in risk or care needs

  • a medication change does not affect the individual’s risk level or their safe management in detention and only represents a routine clinical adjustment. The healthcare team will only raise an IS91RA Part C form where, in their clinical judgement, the change impacts the person’s risk or their ability to be managed safely in detention

  • the issue relates solely to administrative or clerical matters concerning medical records that do not affect the individual’s risk level