Complaints management information

Report: 5
Date: 19 July 2007
By: Assistant Commissioner, Operational Services on behalf of the Commissioner

Summary

This report includes data for the 12 months to April 2007. It focuses on the key changes or exceptions within the data, as trends are slow to change. The majority of figures used are based on 12-month rolling averages, which ensure that the trends are less affected by natural variation.

Workload

There has been an increase of 13% in the number of public complaint allegations being recorded over the past 12 months from a monthly rolling average of 597 to 684. [NB. These rolling averages illustrate longer-term trends and contain data for 24 months, which include 994 residual allegations arising from extraordinary events such as the Pro-Hunt demonstration, and more recently, the Danish Cartoon protest and Parliament Square protest].

The number of conduct matter allegations recorded over the same period shows only minor variation and the monthly average is now 95 per month.

Timeliness

The average number of days to complete a public complaint investigation remains below the threshold of 90-days. It has remained at a similar level since December 2005 and was at 79 days in April 2007.

The average number of days to complete an investigation into a conduct matter continues to improve and it also remains below the threshold of 90-days. It reduced by 10%, from a peak of 82 days in May 2006 to 74 days in April 2007.

The average number of days between the decision and the holding of a misconduct hearing or final disposal is additionally below the threshold of 100-days and, at 77 days in April 2007.

It is recognised that the targets set continue to be challenging and in the categories where targets have not been achieved MPS attention is focused to meet each target in the shortest period possible.

A. Recommendations

That members note the report and the illustration of trends in the report and the Borough performance information contained in Appendices 1 and 2.

B. Supporting information

1. Appendix 1 contains data relating to Borough or Operational Command Unit performance.

2. Appendix 2 contains diversity information in respect of the Borough or Operational Command Units.

MPS/DPS performance

Table 1 - Allegations recorded (see supporting material)

3. In addition to the 12-month rolling average, this chart now incorporates the ‘actual’ number of allegations recorded each month. The rolling average smoothes out natural variation and is more indicative of the trends involved. Due to the process of recording allegations it is possible that the latest ‘actual’ monthly figure may be between 10% and 15% too low.

4. There has been an increase of 13% in the number of public complaint allegations being recorded over the past 12 months from a monthly average of 597 to 684.

5. These rolling averages contain data for 24 months in total and cover the two periods May 2005 to April 2006 and May 2006 to April 2007. The following table illustrates the effect that the 994 residual allegations, arising from extraordinary events, have on the long-term trends such as the Pro-Hunt march, the Danish Cartoon protest and Parliament Square demonstration.

6. It should be noted that, although these allegations appear in the averages for the period up to the end of April 2007 they are not included in the ‘actual’ data after November 2006.

7. Over the 12 months to April 2007, the average number of conduct matter allegations recorded each month has stabilised at 95.

8. The overall average increase in public complaints in the 12-months to April 2007 is not proportionate across all allegation categories. Using the actual 12-month rolling average figures, over an extended period, it was possible to see that there was a distinct upward trend for certain types. The most significant trend appears with rises in Failures in Duty, Malpractice, Discriminatory Behaviour and Incivility.

9. This rise in Discriminatory Behaviour can be traced back to the introduction of the IPCC when there was a widening of the definition of such allegations to include Religion, Gender and Sexuality etc. This category also incorporates the new type of allegations made about ‘Fairness and Impartiality’ brought in by the Commission in April 2004. Although there has been a numerical rise in these types of allegations, as a proportion, they have reduced from 7% of the total in 2004/05 to 6% at the end of 2005/06 and 2006/07 respectively.

10. Failure in Duty allegations have risen steadily. At the end of 2005/06 such allegations had risen by over 1000 and represented 38% of all allegations recorded against 27% in both 2003/04 and 2004/05. At the end of 2006/07 such allegations represented 37% of the total. Since the inception of the IPCC, DPS are investigating a higher proportion of failure in duty allegations that have come via the Commission, including those of failure to record or investigate a particular allegation. It is possible that, before the IPCC, some of these issues may not have been brought to the attention of DPS. Some more analysis into Failures in Duty allegations has been programmed into future work.

11. Incivility allegations have also risen in numerical terms since the inception of the IPCC in April 2004 but reduced as a proportion of all allegations from 22% of the total in 2003/04 to 18% of all allegations at the end of 2006/07.

12. Oppressive Behaviour allegations that had previously risen significantly due to the ‘Pro-Hunt’ demonstrations now appear to be on the decline as a proportion of the overall total. In 2004/05 they represented 38%, which reduced to 30% in 2005/06. This has carried through to the end of 2006/07 when they were 29% of the total.

13. Table 2 illustrates the ‘actual’ number of public complaints recorded over the period May 2006 to April 2007 converted to a per 100 officers figure. It is also broken down by allegation sub-type, and split into quarterly periods.

14. You will note that there is a visible reduction in period 4. As previously mentioned in paragraph 5, the high level of allegations recorded over preceding periods, due to extraordinary events such as the ‘Danish Cartoon’ protest, no longer appear in the ‘actual’ data after November 2006.

15. This has artificially given the impression that period 4 has reduced significantly whereas complaints have now in fact returned to a level apparent prior to these incidents.

Table 2 – Allegations per 100 Officers (see supporting material)

16. The table below illustrates the numbers of allegations by type and whether a period is above the MPS period average in which case the figures will be in both blue and bold text. The MPS total number of allegations, per 100 officers, over the 12-month period is also shown for comparison.

Table 3 – the numbers allegations by type (see supporting material)

17. Period 1 (May 2006 to July 2006) and to a lesser extent period 2 (August 2006 to October 2006), shows the rise in Failure in Duty allegations resulting from the Danish Newspaper Cartoon protests recorded during this period.

18. Other allegations types appearing above the period averages are small enough as to not be significant.

Timeliness - public complaints

Table 4 - Average days taken to complete full investigation & all other results (see supporting material)

Meeting target - Investigating complaints within the 90-day threshold (79 days)

19. The average number of days to complete a public complaint was 79 days in April 2007. Overall, the number of days has remained at a similar level since December 2005 and below the threshold of 90 days.

Missing target - A month on month reduction in the average number of days to complete an investigation (0% decrease on the previous month)

20. There was a reduction of 1% in the average number of days taken to complete an investigation from February 2006 to March 2007 but this was not sustained in April where no reduction occurred.

21. This target is an aspiration but it must be balanced in that excessive speed will reduce quality and thus frustrate any gain by encouraging dissatisfaction of the complainant and subsequent appeal to the IPCC.

22. Presently, the potential to improve significantly further in this area is unlikely, as the current level has been achieved through changes to business processes and practices. However, the work being undertaken by DPS in respect of the changes to legislation brought about by the Taylor Review will afford another opportunity to review these practices. Current information suggests that the legislation will not now receive Royal Assent until Spring 2008.

Table 5 - Average Days Taken to Submit Dispensation/Discontinuance Requests to the IPCC (see supporting material)

Missing target - Submitting requests for Dispensations/Discontinuances to the IPCC within a 60 day target (72 days)

23. Since May 2006, the average number of days taken to submit a dispensation or discontinuance request to the IPCC has reduced by 3% from 74 days to 72 days. However, although this is positive, it still remains above the 60-day target and higher than the 69 days achieved in January 2007.

Table 6 - Average Days Taken to achieve a Local Resolution (see supporting material)

Meeting target - Average days taken to achieve a Local Resolution within a 60 day Target (49 days)

24. Since May 2006, the average number of days taken to achieve a local resolution remains fairly static varying between a maximum of 51 days and a minimum of 49 days. This is currently within the 60-day target.

25. Analysis of local resolutions reveals that, in the 12-months to April 2007, 54% have been achieved by DPS staff and the remaining 46% by Boroughs themselves. The proportion of local resolutions undertaken by DPS has increased, when compared to the previous 12 months, where it was previously 50%.

Table 7 - Percentage of cases over 120-days [2] old – Public Complaints / Conduct Matters  (see supporting material)

Missing expectation - A reduction in the percentage of public complaint cases over 120-days [2] old

26. DPS has made efforts to reduce in the percentage of public complaint cases over 120-days [2] old, but it has remained fairly static over the last 12 months varying between a sustained low of 21% between October 2006 and January 2007 to a current high of 27% in April 2007 (224 of 837 cases).

27. By drilling down into the figures it is apparent that the majority of the cases that now are over 120-days old are those that are the responsibility of either the Human Resources i.e. Police Staff investigations (79% or 182 cases), External/Outside force investigations (100% or 2 cases) or IPCC investigations (100% or 4 cases).

28. To illustrate the impact such cases have on this target, the performance of DPS Investigations Command has been illustrated separately on the chart. This shows that 13% of the cases (52 cases) within their responsibility are over 120-days old.

Conduct matters

Table 8 - Average days taken to complete an investigation (see supporting material)

Meeting target- The average number of days to complete an investigation (74 against a 90 threshold)

29. The average number of days to complete a conduct matter investigation, illustrated above, remains below the threshold of 90-days. It reduced by 13%, from a peak of 85 days in September 2006 to 74 in April 2006.

Missing expectation - A reduction in the percentage of conduct matter cases over 120-days [2] old

30. Conduct Matters over 120-days [2] old rose from 36% (48 of 133 cases) in June 2005 to a peak of 60% (64 of 107 cases) in November 2005. However, despite an earlier downward trend where it reached 29% (39 of 134 cases) in January 2007 it has risen in April 2007 to 43% (60 of 140 cases).

31. Research has revealed that the increase in February 2007 is due to a number of Police Staff investigations (suspensions) being recorded on the complaints system, the majority of which are over 120-days old. Such investigations should be recorded on the complaints system but this had not previously been actioned. It would appear that these cases have remained on the system since and have contributed to the continuing rise of this indicator.

32. Cases that are the responsibility of DPS Investigations Command have been illustrated on the chart, which shows that 26% of cases (22 cases) that they are responsible are over 120-days old.

Misconduct

Table 9 - Misconduct – Average number of days from decision to hearing or final disposal (12 Month Rolling Average)

Meeting target - Average days to reach Misconduct decisions (77 against 100 threshold)

33. The average number of days between the decision to hold a misconduct hearing or reach a final disposal remains below the revised threshold of 100-days.

External Partners – CPS Decision making

Table 10 - Average number of days from report to receipt of decision from CPS (12 Month Rolling Average)

34. Table 11, illustrates the timeliness of the CPS decision-making in respect of the Specialist Investigation work, such as Deaths Following Police Contact and Discharge of Police Firearms and the more routine complaint and conduct investigations of the Borough Support Units.

External Partners – IPCC Decision making

Table 11 - Average number of days from report submission to receipt of decision from IPCC (12 Month Rolling Average)

35. Table 11 above reveals the average time taken for the IPCC to reach decisions in dispensation and discontinuance cases.

Table 12 - Number of appeals made to the IPCC by type and outcome(12 Month Rolling Average)

36. The chart above shows the number of appeals made to the IPCC where a decision has been received from the Commission within the last 12 months. It illustrates the type of appeal being made and the validity of that appeal as determined by the IPCC.

37. In future reports we intend to supply data for the current 12 months compared with the previous 12 months. To achieve this we need to ‘back record convert’ the data we hold manually to the new TRIBUNE fields. It is planned to conduct a further reconciliation exercise with the IPCC following the upgrade of TRIBUNE scheduled for summer 2007.

Outcome Trends

Table 13 - Public Complaints Finalised allegation by result (12 Month Rolling Average)

38. The average percentage of local resolutions has increased in the 12-month period from 31% in April 2006 to 34% in April 2007 but it remains considerably below the target of 50%. Whilst the proportions of the other outcomes affect this figure, it is likely to remain low until BOCUs are able to take on more responsibility for the resolution of their own complaints and undertake lower level investigations.

39. There are however tensions between the desire to see more issues being dealt with locally e.g. Local Resolutions and the scrutiny DPS is under to improve timeliness. DPS investigators losing close control over a complaint being investigated/resolved on borough can adversely impact on their timeliness and the inclination is for them to recall the file and deal with it themselves.

Borough (BOCU) / Operational Command Unit (OCU) Performance – Public Complaints: Allegations and People.

40. At each Professional Standards and Complaints Committee, members will be presented with a comparative analysis of public complaint data relating to groups of BOCUs in relation to MPS professional standards matters.

41. The BOCU groupings are made using the Territorial Policing Performance Focus Meeting (TP PFM) cluster.

42. The exception to this is what DPS have called Group 6, which consists of TP non-Borough based units and non-TP Operational Command Units.

43. The TP families have been grouped together based on demographics and volume crime within the boroughs in question. Both of these factors are likely to affect complaints. By using these family groups and converting ‘actual’ numbers of complaints recorded into a ‘per 100 officers’ figure enables more accurate comparisons to be made.

44. The ‘actual’ figures appear in the Borough Support Management Information (BSMI) report, which is made available to the MPA as a separate document and which could be circulated to members if required by MPA officers.

45. To publish the actual figures in this document would make the report unwieldy due to the amount of additional pages necessary to incorporate the expanded information. Furthermore, it would divert from the purpose for which both of these documents were designed i.e. the strategic overview of this report and the detail of BSMI.

46. This information provides a benchmark against which the Authority will be able to judge DPS’s Professional Standards Support Programme (PSSP) in the future by looking for variations in performance from this report to the next occasion the same family group appears.

47. Variations in performance of each of the boroughs when compared to their peers are highlighted in both blue and bold text. Variations could be for any number of reasons such as a particular operation/initiative being run on the borough or environmental factors such as the number of licensed premises, entertainment venues or shopping centres. The demographics in relation to both the resident and transient population and the length of service and experience of the officers concerned will also be relevant factors.

48. It should be noted that, once the ‘per 100 officers’ element is introduced to the data, some of the numbers are small which makes it difficult to draw any significant conclusions from them.

49. Because a Borough or Command Unit is different from their peers does not automatically mean that they are worse.

50. The Professional Standards Support Program (PSSP) incorporates a ‘tasking’ process whereby information in relation to public complaints, conduct matters, civil actions, accident claims and intelligence are assessed in order to ascertain what intervention activities are most appropriate to assist the boroughs with. The borough requiring the most assistance will have a ‘profile’ compiled on it based on all the information previously mentioned but in greater detail by drilling down into the data to establish the exact nature and likely cause of the variation.

51. The Prevention & Organisational Learning Command (POL) will then work with the borough in question, through the PSSP process, to define an action plan that will bring the BOCU closer to the average of similar boroughs in their group.

52. The group of boroughs under focus for this period are from Group 4. The data and associated analysis is presented in Appendix 1.

Thematic Analysis

53. In support of the PSSP, it is planned to conduct ‘thematic’ analysis of public complaint data so that, either by using family group or the MPS as a whole, a greater proportion of the information contained on TRIBUNE will be used to extract learning, which can be promulgated as part of the support program.

54. The thematic analysis will be linked into the DPS Control Strategy Priorities and/or the ‘core’ or ‘core-plus’ deliverables of the PSSP. Examples of the ‘thematic’ analysis that are currently being considered are as follows:

• Failures in Duty
• Custody
• Off-duty behaviour
• Information Leakage and Computer Misuse
• Officer Safety Equipment
• Stop & Search
• Officers subject to the ‘Complaints Intervention Scheme’
• Repeat Complainants
• Alcohol/Drug related allegations
• Misuse of Property related allegations

TRIBUNE

55. DPS are currently running a pilot in the NW Borough Support Unit to enhance the value of TRIBUNE, the complaints & discipline system, by using it to record electronically elements of the investigation that would otherwise be logged on paper.

56. By using it in this way, TRIBUNE provides an entirely efficient way of recording the investigative process but does not go so far as to make it an ‘investigative’ tool or ‘intelligence’ system.

57. It is estimated that TRIBUNE will do 80% of what DPS would like it to do in this regard and it allows closer supervision of investigations and easier oversight by the MPA. In this respect, it is entirely fit for purpose.

58. To achieve the functionality of, for example, the Crime Reporting Information System (CRIS) would involve considerable additional expenditure and may not represent good value for money.

59. Presently, one of the NW investigating officers (IO) and his team have access to the system and are currently recording the following types of information:

• Investigative Strategy (Initial Overview) – as defined by the IO
• Decisions
• Risk Assessments
• Actions to be completed and those that have been completed
• All progress updates to the complainants/witnesses/interested parties
• All progress updates to the officers/staff involved
• Briefings undertaken
• Recording that intelligence reports have been submitted

60. The benefits are expected to be:

• The MPA professional standards officer now has online access to a ‘current’ and detailed stage at which the investigation is.
• DPS supervising officers will have ready access to the progress of an investigation
• With such ‘external’ scrutiny it is hoped that the timeliness and accuracy of data input to the system will improve especially when coupled with the enhancements planned with the introduction of TRIBUNE phase 3 such as, increased mandatory fields, improved finalisation checks and a ‘traffic light’ warning system of overdue actions on the progress log.
• The system has increased ‘integrity’ over a paper-based system as it provides an audit trail requiring users to justify their actions if required.
• When all units are using TRIBUNE in this way the service provided by the DPS Reception Desk will be enhanced, as they will be able to use the information contained to inform complainants and officers/staff of the progress of the investigation.

61. The pilot is being extended to other IOs in NW and will, if successful; then expand to the NE teams and then throughout the remainder of DPS Borough Support.

62. The rollout is being handled incrementally as we are currently unsure of the impact that the additional user base will have on the system performance. TRIBUNE was only anticipated to have a maximum of 60 ‘concurrent’ users on the system at any one time and the number of licences bought and the hardware ‘spec’ matches this stipulation.

63. If the number of concurrent users exceeds 60, or if the system performance degrades significantly, it will be necessary to increase the number of licences and/or the hardware. There will obviously be a cost implication should these measures become necessary.

C. Race and equality impact

Appendix 2 includes MPS data in respect of diversity relating to both complainants and officers that is compared against the family of Boroughs or Operational Command Units in focus.

D. Financial implications

None.

E. Background papers

None.

F. Contact details

Report author(s): Michael Clark, Higher Performance Analyst and Hamish Campbell, Detective Chief Superintendent, MPS

For more information contact:

MPA general: 020 7202 0202
Media enquiries: 020 7202 0217/18

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