Inside the Suicide-Watch Procedure for Immigration Detention, a 72-Hour Commercial Boundary

Someone asked the Department of Home Affairs for its mental health policies, crisis management arrangements, risk assessment and incident reporting, and legal and compliance framework for people held in immigration detention. On 24 June 2025 the department published 228 pages in response.

The documents are not, for the most part, departmental policy. They are the operating manuals of the company that runs the detention centres, released by the government as its answer to a question about how detainees are cared for. Read that way, they are a document about how a duty of care is written down when the duty is contracted out.

This article is about the architecture only. The release concerns people in detention, and nothing here describes any individual, any incident, or any circumstance from which a person could be identified.

What was released#

Two PDFs, 114 pages each. The department numbered the release continuously — pages 001 to 114 in part one, 115 to 228 in part two — and the page references below use that numbering. Roughly ninety pages are rasterised images with no text layer, so quotations from those pages were read from rendered images.

The material includes Serco policy and procedure manuals (“Policy & Procedure Manual — Detainee Management & Welfare Support”, SIS-OPS-PPM-0067, version 3.0, dated 11/2023; and a suicide and self-harm prevention procedure, SIS-OPS-PPM-0001, version 3.2, dated 30/04/2020), correspondence between the Australian Border Force and the contractor, and a review of staff safety. Most pages carry “Serco Business” at the top and ”© Serco” at the foot.

Redactions are claimed under s 22(1)(a)(ii) for irrelevant material such as internal contact details, and s 47 — trade secrets and commercially valuable information — over parts of the contractor’s reasoning.

The 72-hour clock#

Supportive monitoring and engagement is what happens when a person in detention is judged to be at risk of self-harm: a staff member stays with them, watches, records, and engages. The procedure sets three levels of risk — Ongoing, Moderate, and High Imminent.

It also sets a commercial boundary, in the same section, in the same voice:

Where are a detainee is placed on PSP/SM&E resulting from the PSP (or Serco’s Keep SAFE policy if the DHSP is offsite or unavailable) and the Detainee remains on SM&E for a consecutive period in excess of 72 hours then any costs incurred by SIS for the period in excess of the initial 72 hours will be payable at the PSP high imminent or PSP moderate variable rates. For clarity, the calculation of the 72 hour period commences at the time the Detainee is placed on a SM&E plan (i.e. the classification of a detainee as High imminent, Moderate or Ongoing is a single event triggering commencement of the 72 hour period).

The first three days of watching someone at risk of suicide are at the contractor’s expense. After that the meter starts, at rates set by the risk level. The paragraph is precise about when the clock begins — the moment of classification — and the phrase “For clarity” signals that this had been argued about.

We make no claim that this changes clinical decisions, and the documents do not say that it does. What they show is that the boundary exists, that it is set at 72 hours, and that it sits inside the operating procedure a frontline officer reads rather than in a separate commercial schedule.

Who decides that someone has high needs#

The second manual sets up a national forum, the Complex Case Review, for “vulnerable and at-risk people in detention who may require additional support to manage behaviours of concern or vulnerabilities”. Where a case is more complex than a local meeting can handle, it goes there.

Out of the Complex Case Review comes a classification, and the classification is what releases resources:

Some detainees who are discussed at CCR may be approved as a High Needs detainee. A detainee can only be classified as a High Needs detainee following formal application to, and approval by, the Contract Administrator. Additional costs will be charged at the additional monitoring variable rate or such other applicable pricing mechanisms in the Contract.

The Contract Administrator is a contract-management role, not a clinical one. The manual’s own flow chart shows the two outcomes: approved as a High Needs Detainee with “Ongoing support via CCR”, or “Not approved by Contract Administrator” and supported as a Complex Case or referred back to the lower-level committee.

The manual is explicit that this is where the decisions get made:

the CCR process is the key decision-making forum for the approval of additional services and or resources to support detainees who are requested to be identified as ‘High Needs’ detainees.

Media notoriety as an eligibility criterion#

The eligibility list for the Complex Case Review runs to seven bullet points. Most are what you would expect: enhanced security monitoring needs, threats to the safety of persons in the facility, conditions or vulnerabilities including “neuro development disorders, congenital or behavioural conditions, physical, cognitive, mental, sensory, emotional or development disabilities”.

One is not:

Is of significant stakeholder interest or has specific media notoriety.

It appears in the same list, at the same level, as clinical vulnerability. A person can reach the national forum that decides additional welfare resourcing because of who is watching their case.

The membership table makes the same point from the other direction. National membership includes the contractor’s National Welfare & Engagement team as chair, its Commercial Lead, its National Intelligence Manager — and its Legal Counsel. The roles and responsibilities table gives Legal Counsel a single listed function:

Assessment of legal / media issues and / or risks.

Alongside it, the Commercial Lead’s listed responsibility is “Preparation in collaboration with facility of financial documentation”. The standard agenda’s item six is “Terms of High Needs resource”.

A meeting convened to decide what support a vulnerable person receives has, built into its standing membership, a lawyer briefed on media risk and a commercial officer preparing the financial paperwork.

Current policy, dated 2020#

The request was for current mental health policies. The suicide and self-harm prevention procedure released in answer is version 3.2, and the footer of every page carries its date: 30/04/2020.

Five years separate the document from the release. That is not by itself a criticism — a procedure can be sound and stable — but it is the document the department produced when asked what applies now.

The manual’s own examples have aged with it. Its illustration of a poor observation note reads: “Checked on Mr. Smith. He seems fine.” The name is a placeholder in the manual, not a person.

What the documents do not say#

What the rates are. The 72-hour provision refers to “PSP high imminent or PSP moderate variable rates” and to an “additional monitoring variable rate”. The rates themselves are not in the release, and passages of the contractor’s material are withheld under s 47 as commercially sensitive.

How often High Needs status is refused. The manual describes a decision point and its two outcomes. No numbers accompany it.

Whether the commercial boundary affects care. The documents establish that a cost boundary exists at 72 hours. They contain nothing about its effect, and we have not inferred one.

What the withheld reasoning says. In the staff safety review, the contractor’s conclusion on staffing is followed by material withheld under s 47. We do not know what it argues.

Anything about individuals. By design. The release concerns a population held by the state; this article reports the rules, not the people.

The 138 pages we did not quote. We read the welfare and suicide-prevention manuals and the staff safety correspondence closely, and skimmed the rest. A reader with a specific interest should go to the PDFs.

How to check this#

Both PDFs are linked at the top of this page. The department’s page numbers run 001–114 and 115–228 and are stamped on each page; the references above use them. The Serco manuals also carry their own internal pagination (“Page 21 of 29”), which is why a quotation cited here at page 205 sits on a page the manual itself calls 21.

About ninety pages have no text layer. Quotations from those pages were read from images rendered at 150 dpi, not from an extraction, and the contractor’s own spelling and grammar have been left as they appear — including “Where are a detainee is placed”, which is how the procedure reads.