MPS Independent Advisory Groups (IAGs) – implementation of the IAG review and their governance, structure, membership and work; at all levels of the MPS

Report: 10
Date: 10 September 2009
By: Assistant Commissioner Territorial Policing on behalf of the Commissioner

Summary

This report provides an update on the history of the MPS Independent Advisory Group Review 2007 and progress on implementation of the recommendations.

A. Recommendation

That The Communities Equalities and People Committee note the contents of this report.

B. Supporting information

1. The MPS IAG Review 2007
The MPS IAG Review 2007 was commissioned in 2006 by T/Assistant Commissioner Rose Fitzpatrick (then DAC and Director of the Diversity and Citizen Focus Directorate (DCFD)) following concern regarding the role, consistency and governance of the IAG process across the organisation, and the degree to which value for money was being achieved. The review also addressed outstanding Recommendations 14, 15 and 16 from the Morris Inquiry (2004). The brief for the review is shown in Appendix 1.

2. Three key stakeholder groups were identified in relation to the Review: MPA members, senior police personnel across the MPS, and independent advisors at corporate, specialist, and borough levels. Documentary research helped to provide the context within which the review would be conducted. Recommendations were then developed through extensive consultation with stakeholder individuals and groups.

3. Emerging recommendations were presented to the MPA Equal Opportunities and Diversity Board (Item 11; 18.01.2007) and Full Authority (Item 12; 29.03.2007). The recommendations were further developed in close consultation with all stakeholder groups through one-to-one, group, and facilitated meetings.

4. The Review generated significant interest. There was consistent agreement about the issues that needed to be addressed, such as tenure, recruitment, and vetting, but often conflicting views between and within stakeholder groups on solutions to create a more effective approach. Recommendations were carefully worded in order to attract broad support; however it was recognised that they would not please everyone.

5. The Review concluded that there was inconsistency and confusion across the independent advisory process in terms of purpose, governance, membership status (both regarding ‘independence’ and an advisor’s potential as an ‘MPS employee’), recruitment, remuneration, communication, monitoring and evaluation, and support.

6 The issue of IAG ‘independence’ was a particular cause of confusion. Some independent advisors considered that an IAG was completely ‘independent’ of the MPS in the way that it organised itself and undertook its remit. The Review concluded that the term ‘independent’ only related to the status of individuals within a group and the nature of their advice. IAGs were not there to scrutinise the MPS, which was the role of the MPA, they existed as part of the wider community engagement framework.

7. The review report was completed in autumn 2007 with 37 recommendations. A concise version of the report was also made available. The Full Report (108 pages), and Concise Version (36 pages) are available from the MPS ‘IAG’ Coordinator, Sarah Gausden who will provide a copy of either report. There is also an ‘Easy Read’ version available.

8. Two additional recommendations, 38 and 39, were added to the Concise Version of the report at the request of the MPA. Recommendation 39 was introduced to enable fulfilment of Recommendation 38, which aimed to replace the existing five corporate IAGs with a corporate pan-community IAG by July 2009. This deadline was subsequently brought forward to May 2008.

9. Continued development of the recommendations
Consultation on shaping the recommendations continued after the completion of the Review report as part of the Equality Impact Assessment (EIA) until 12 August 2008, the date when it was agreed with the corporate IAGs that the majority of them should be implemented.

10. The MPS ‘IAG’ Recommendations Implementation Oversight Group was convened to help manage the development and implementation of the recommendations across the Service. Membership comprised of police personnel advisory group representatives from corporate, specialist and borough groups, and the MPA. An IAG Review Supplementary Report was produced to reflect the changes to the recommendations and an on-going assessment was conducted to manage risk. The final version of the recommendations at Appendix 2 compliments the ACPO ‘Guidance on Independent Advisory Groups’.

11. Number of IAGs and budget considerations
The MPS has 10 formal advisory groups that are specialist and corporate and 35 community advisory groups across its Boroughs. The five corporate IAGs are based around a diversity focus: Gypsy and Traveller, Youth, Disability, Race and LGBT. The most recent advisory group was convened by the HR Directorate in 2008 to enable scrutiny into the current models of promotion processes. The MPS does not set up new advisory groups without careful consideration and consultation with DCFD.

12. Monitoring of expenditure for the independent advice process was identified in the review as an area for improvement. For example, there has been no corporate mechanism in place to monitor the expenditure of local borough Community Advisory Groups. This matter is being addressed through the introduction of internal order numbers for each of the corporate, specialist and community advisory groups and will be in place upon publication of the Standard Operating Procedures (SOPs).

13. There is a budget for the Corporate IAGs, but not for other groups. In 2007/08 and 2008/09 this was £120,000. The approximate cost of independent advice to the MPS using the existing budget monitoring process is shown in Table 1.

Table 1: IAG expenditure

Advisory group	2007/08 (£)	2008/09 (£)
Corporate Groups	112262	57469
Sapphire	301	0
Trident	10825	8076
Safeguarding Children	4242	81
HR Promotion	0	0
HR Training	200	200
Total	127830	65826

Table 2 indicates the approximate maximum amounts claimed by individual independent advisors. This will include remuneration and out of pocket expenses.

Table 2: 'Earnings' /expenses paid to the top 10 advisors

Highest Expenditure [1]	2007/08 (£)	2008/09 (£)
1	4931	4857
2	4422	3478
3	3825	3441
4	2950	3003
5	2135	2495
6	2025	2325
7	2005	2171
8	1729	1601
9	1439	1500
10	1425	1425

Equality impact assessment (EIA)

14. An Equality Impact Assessment (EIA) has been conducted throughout the development of the IAG Review and will be published at the same time as the IAG Policy and SOPs. The EIA summarises the objectives and benefits of the review; the broad range of internal and external stakeholders who have been involved; a screening process and then full assessment of the diversity and equalities issues that have arisen or may arise; a list of amendments which have resulted; and the future monitoring arrangements.

15. The EIA and review have revealed a considerable difference in opinion in some areas between and within stakeholder groups and therefore not all of the sometimes contradictory views have been incorporated. It is accepted that ongoing engagement is necessary and as a result the SOPs and EIA may undergo further refinement during the remainder of 2009. The EIA is shown in Appendix 3.

Barriers to implementation of the recommendations

16. The Review was welcomed by all stakeholder groups who contributed enthusiastically to the process. However, there have been some key barriers to implementing the recommendations. These may be summarised as follows:

• The introduction of Recommendation 38 and 39, that related to the introduction of a single corporate IAG rather than five separate groups, without any prior consultation caused significant resentment by corporate independent advisors. Intense negotiations were necessary over several months between all three key stakeholder groups to restore some normality before effective engagement could continue.
• Despite the resentment much work was done with the MPA, police personnel and independent advisors to explore the feasibility of a single group. Whilst the MPS has not decided to move away form this recommendation it is our view that until the outcome of the Race and Faith Inquiry is made known a major reorganisation of this nature will be a distraction. The MPS has therefore deferred current activity on this recommendation with the intention of a full review of our approach in light of the findings of the MPA inquiry.
• The loss of ‘independence’ that some advisors erroneously perceived that they had from the MPS met with partial resistance, particularly from some specialist groups.
• The loss of remuneration has caused disquiet among some independent advisors who believe that they should be paid to compensate them for the time that they contribute to the advisory process, as is done for consultants when the MPS requires ‘specialist advice’.
• The present audit by Her Majesty’s Revenue and Customs of the MPS includes consideration of remuneration to independent advisors. Its current view, which is shared by the MPS Directorate of Legal Services, is that an independent advisor who receives remuneration is not a ‘volunteer’. ACPO guidance indicates that an independent advisor should be a volunteer, and this is the historical approach taken by the MPS. A further complication here is the issue of procurement. MPS Procurement Services has indicated that if a person is self-employed then there should be a tendering process to ensure equality. Such an approach in relation to independent advisors could conflict with the whole concept of the advisory group process. The MPS is keen to work with the IAG and MPA on how these issues may be resolved appropriately.
• The introduction of tenure is seen by some police personnel as depriving them of key community representatives and by others as an opportunity to involve a wider section of the community. Some independent advisors do not want to lose their status and are resisting tenure. Again at this stage the historical perspective and understanding that some long standing IAG members bring may be of particular relevance in working with the MPA on the outcome of its inquiry and whilst we are committed to the ethos of new advisors and change, the MPS believes that this recommendation should be subject to further review.
• Vetting has been opposed by some independent advisors who consider it intrusive, whilst others have welcomed it as an opportunity to become more involved in the MPS. The MPS Identity Management Project is further exploring the issue of vetting for independent advisors.

Implementation of recommendations

17. Morris Inquiry (2004) Recommendations 14, 15 and 16 have been implemented through the Review recommendations within the SOPs.

18. Overall the Review recommendations are being positively received. They have been implemented across most of the 35 borough Community Advisory Groups, and are gradually being implemented by corporate groups. The Review was formally concluded in January 2009, but the MPS continues to work closely with stakeholders in order to implement the recommendations where difficulties continue to be experienced. In light of this there are no formal milestones set for conclusion of these discussions.

19. The following progress may be reported:

• The Director of the Diversity and Citizen Focus Directorate (DCFD) is now the identified corporate lead for all MPS IAGs. The Director is supported by the MPS IAG Coordinator in undertaking her responsibilities. A flowchart identifying how IAGs are structured within the MPS is at Appendix 4.
• Amendments to the SOPs have been completed following consultation with stakeholders in the spring. The SOPs have been submitted for final sign-off and publication and will be reviewed and updated as necessary in 2010.
• The SOPs detail the relationship that exists between the MPS and independent advisors. Upon their publication senior police personnel and each MPS independent advisor will be invited to sign a Memorandum of Understanding. This will provide a non-legally binding acceptance of the relationship between the MPS and independent advisors.
• A new system of internal order numbers is being implemented across the MPS to help monitor financial expenditure on the independent advice process. Full expenditure data will be available next year.
• Masterclasses have been introduced for all MPS IAGs to support their learning and networking. The first took place in May and explored ‘Deaths in Police Custody’. They will occur three times a year.
• Annual reports are being completed for the first time by police users of every MPS advisory group. These are being collated by DCFD to establish IAG activity, value for money, and to promote good practice. Details will be published in the autumn.
• The development of a familiarisation handbook is well advanced. It will be circulated to all independent advisors to promote their understanding of the MPA and MPS.
• Further consultation is underway with corporate IAGs to consider recruitment options and to optimise opportunities to provide independent advice.
• Details of membership for each IAG across the Service are retained by individual OCU Leads, and the DCFD for corporate groups. Further research is to be undertaken to establish the diversity make-up of each IAG.

Future considerations

20. The MPS strategic approach towards community engagement is constantly evolving in light of the ever changing demographics within London and the associated needs to identify effectiveness and efficiency. Issues such as the MPA Race and Faith Inquiry, the emerging distinctions between what constitutes independent advice, specialist advice, and community feedback, and how best to secure them, will all help to shape future IAG arrangements. A new joint MPA/MPS engagement strategy is now being developed with the MPS formerly creating a new strategic engagement committee to oversee and shape how all of its engagement processes work. This together with the outcome from the Inquiry will provide an opportunity to refocus the implementation of the remaining 2 recommendations.

C. Race and equality impact

A full EIA has been undertaken, as discussed in Paragraph 10.

D. Financial implications

The budget and expenditure for IAGs (excluding Borough expenditure met from within local budgets) is identified in paragraph 11. It is anticipated that likely changes to the remuneration arrangements with independent advisors brought about by the HMRC ruling, compliance with ACPO ‘Guidance for Independent Advisory Groups’ in relation to ‘volunteer’ status, and new meeting arrangements for IAGs, could reduce MPS IAG expenditure. Any other changes required will be managed within existing budget provision within the Territorial Policing budget.

E. Legal Implications

1. Section 96 of the Police Act 1996, and Section 30 of Schedule 2 of the Police and Justice Act 2006, sets out the MPA’s duties of community engagement.

2. The Independent Advisory Group (IAG), though not a statutory requirement, is considered to be an appropriate mechanism for helping to achieve community involvement in MPS business. The MPS established the IAG following the Stephen Lawrence Inquiry Report in 1999, and since then other police forces have adopted the same approach, which is now recognised as good practice by the HMIC.

3. The proposed recommendations for the structure, membership, governance and work of IAGs aim to improve efficiency and effectiveness of the independent advice process, produce greater transparency, build public confidence and secure continuous improvement in the way the Police Force exercises its functions.

F. Background papers

• MPS Independent Advisory Group Review 2007

G. Contact details

Report author(s): Tom Morrell. Internal contact 782722

For information contact:

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

Abbreviations

ACPO

Association of Chief Police Officers

DAC

Deputy Assistant Commissioner

DCFD

Diversity & Citizen Focus Directorate

EIA

Equalities Impact Assessment

LGBT

Lesbian, Gay, Bisexual & transgender

SOPs

Standard Operating Procedures

IAG

Independent Advisory Group

OCU

Operational Command Unit

HMIC

Her Majesty’s Inspectorate of Constabulary

Appendix 1: Aim and objectives of the MPS ‘IAG’ Review 2007

Aim

In partnership, to review the concept of Independent Advisory Groups, related procedures and existing protocols with a view to updating MPS guidance

Objectives

1. To ensure consistency across the MPS Corporate IAGs in tasking and deployments
2. Review efficient working practices between Corporate IAGs that avoid the ‘silo’ effect
3. To develop standard operating procedures for Corporate IAGs
4. To develop efficient monitoring, feedback and financial systems
5. To update existing MPS guidance for Independent advisors that promotes effective working practices and sets minimum standards for dissemination across the organisation.

Appendix 2: Final version of IAG review recommendations as at 11 August 2008 [2]

Role, governance and definitions

Recommendation 1

That the recommendations contained in this report apply equally to all MPS advisory groups: Independent Advisory Groups (IAGs), Specialist Advisory Groups (SAGs) and Community Advisory Groups (CAGs) except where explicitly stated.

Recommendation 2

The following definitions will apply:

• Independent Advisor
  An ‘Independent Advisor’ is independent of the police service, of other independent advisors, and independent of any local or national government body or linked organisation that has a formal monitoring or scrutinising responsibility for police performance or activity. An independent advisor may be representative of a community but does not represent a community. An independent advisor would not be regarded as independent if they had immediate family members employed by the police service e.g. a sibling, parent, spouse or partner.
• Advisory Group
  ‘‘An Advisory Group is one that is constituted to help develop a genuine partnership between the Metropolitan Police Service and London communities. It consists of people who are brought together to provide advice to the police for the benefit of improving the quality of policing services to London.'
• Types of Advisory Group
  There are three types of advisory group:
  • Independent Advisory Group (IAG)
    An IAG consists of volunteers who are known as Independent Advisors and provide independent advice to the MPS.
  • Specialist Advisory Group (SAG)
    ‘A Specialist Advisory Group consists predominantly of independent specialists or experts within a particular discipline or with unique relevant experience. The group provides advice to the MPS relating to a specialist area of work. Specialist Advisory Groups include the Trident, Safeguarding Children and Sapphire Advisory Groups.’
  • Community Advisory Groups
    A Community Advisory Group consists of people who provide advice to Borough Commanders. Whilst the group will include ‘independent advisors’ it may also include central or local politicians, business people, statutory partners or other community representatives.
• Independent Advice
  ‘Independent Advice’ comprises of advice, guidance or constructive critical appraisal that is provided to the police by an independent advisor to challenge or inform current police decision-making, policy or practice. The advice or observation may or may not be applied and it carries no liability to the person delivering it.
• Non-Independent Advice
  ‘Non-Independent Advice’ comprises of advice, guidance or constructive critical appraisal that is provided to the police by any person who is not an independent advisor or police employee. The advice or observation may or may not be applied and it carries no liability to the person delivering it.

Recommendation 3

Recommendation 3 was deleted.

That where an advisor currently serving as an Independent Advisor would not qualify as such following the introduction of Recommendation 2 (immediate family employed by the police service), they shall be allowed to remain as advisors for the full period of their current tenure.

Recommendation 4

That, subject to the MPA making the decision to take over the governance of IAGs responding to Recommendation 14 of Morris, that the Director of the MPS Diversity and Citizen Focus Directorate retains the MPS strategic lead for independent advice.

Recommendation 5

That the Director of the MPS Diversity and Citizen Focus Directorate will meet at least three times a year with Corporate Independent Advisory Group chairs.

Recommendation 6

That the MPS will organise an annual conference for representatives of all MPS advisory groups aimed at recognising excellent work, learning, and sharing good practice.

Recommendation 7

That there will be no hierarchy between the pan-London Corporate IAGs for Disability, LGBT, Race, Gypsy and Travellers, and Youth who will together be known as Corporate Independent Advisory Groups.

Deployment and training

Recommendation 8

That a Memorandum of Understanding (MoU) is developed with the support of MPS DLS in consultation with advisors clarifying the relationship and expectation between the MPS and an MPS advisor. Every MPS advisor will sign a MoU that will also be countersigned by the appropriate senior police representative.

Recommendation 9

That each advisory group identifies at least one member who will be responsible for identifying an appropriately skilled and experienced advisor to deal with a request received from the MPS for advice. The member(s) will provide a single point of contact for the deployment of an advisor from their group. If a group has particular difficulty in contacting a member in response to a request then the MPS should be contacted to provide support.

Recommendation 10

That all requests to deploy an independent advisor from a Corporate IAG be made through the MPS Communities Together Strategic Engagement Team (CTSET). CTSET will identify the Corporate IAG that can best support the request. CT SET will pass the request on to the group to nominate the most suitable independent advisor volunteer to deal with the task. Once an independent advisor has been identified, the task of contacting the advisor and for ensuring that appropriate access issues are met will fall to CTSET in fast-time cases.

Recommendation 11

That MPS staff engaged in supporting and co-ordinating the work of advisory groups should receive appropriate learning in knowledge and skills to support their role.

Recommendation 12

That the Diversity and Citizen Focus Directorate develop a corporate familiarisation product to support new advisors understand the structure and responsibilities of the MPS and the role of the independent or community advisor.

MPS/Advisor relationships and finance

Recommendation 13

This recommendation was not agreed and will be reviewed following completion of Her Majesty’s Revenue and Customs audit of the MPS, which includes consideration of independent advisor remuneration.

That the current remuneration arrangements for Corporate IAGs and SAGs (where remuneration is provided) be replaced with a ‘Payment for Inconvenience’. A ‘Payment for Inconvenience’ will be paid at an hourly rate to be determined and reviewed annually by the Director of the MPS Diversity and Citizen Focus Directorate

Recommendation 14

That independent advisors shall continue to be financially compensated for money paid out in consequence of their involvement in the advisory group process. This will include expenses such as travelling (public transport only), mileage, phone calls, childcare arrangements, access needs and any other agreed necessary expense.

Recommendation 15

That an advisory group member wishing to claim expenses (or in the case of a Corporate IAG or SAG ‘Payments for Inconvenience’) shall forward their claim form within three months to their respective MPS representative. Claim forms will be redesigned to provide consistency and compatibility with MPS financial management systems.

Recommendation 16

That Corporate IAGs and SAGs (in the absence of exceptional circumstances) will ordinarily meet no more than once every two months. There will be some flexibility to meet between 6 weeks and 2 months if the agenda is particularly heavy.

Recommendation 17

Membership size of any advisory group should be based upon the demands made of that group by the MPS. The size should be determined by the senior MPS police user of respective groups in consultation with the group.

Recognition of advisors

Recommendation 18

That an advisor’s exceptional commitment to the MPS Advisory Group process is appropriately acknowledged through the organisation’s existing commendation or other recognised reward system.

Recruitment, tenure, membership and meetings

Recommendation 19

That an independent advisor, or an advisor to a SAG, shall be appointed for four years. An advisor may apply for reappointment at the end of that period but cannot serve for more than two terms in the role (maximum 8 years). They may only serve a second term with the support of the respective advisory group chairperson and agreement of the Director DCFD or respective advisory group senior police lead. This recommendation applies retrospectively.

Recommendation 20

That where the implementation of the new recommendation concerning tenure (Recommendation 19) would result in the immediate exit of an advisor, that person shall be permitted to remain for a further 24 months from the date that the recommendations have been ratified by the MPS Diversity Board.

Recommendation 21

That an independent advisor shall only belong to one Corporate IAG or a Specialist Advisory Group but not both. This does not preclude advisors attending local community advisory groups. Whilst this recommendation will not be retrospective (e.g. advisors who are already members of two groups will be allowed to continue), advisors shall only be permitted to remain as a member of two groups for 12 months from the date that the recommendations are ratified by the MPS Diversity Board.

Recommendation 22

That a single Corporate IAG recruitment process be held each year unless considered unnecessary by the Director of the MPS Diversity and Citizen Focus Directorate in consultation with IAG chairs. Whilst there will be a single campaign, DCFD staff and IAG chairs will work with the MPS Directorate of Public Affairs (DPA) to successfully focus advertising toward their specific communities.

Recommendation 23

That whilst the recruitment process for Corporate IAGs shall focus on target audiences from relevant ‘grass root’ communities, membership of advisory groups must also aim to reflect the wider diversity of London.

Recommendation 24

That BOCU Commanders are notified when a Corporate IAG recruitment process is proposed so that they can bring it to the notice of local advisors and communities.

Recommendation 25

That the process to recruit new independent advisors is coordinated by the MPS in the strict spirit of ‘The Commissioner for Public Appointments Code of Practice For Ministerial Appointments to Public Bodies’ in respect of Lower Tier Bodies.

Recommendation 26

That the Director of the MPS Diversity and Citizen Focus Directorate shall be responsible for accepting the appointment of an independent advisor to a Corporate IAG; the respective senior police lead to a Specialist Advisory Group (SAG) will accept the appointment of an advisor to a SAG and a Borough Commander will accept the appointment of an advisor to a Community Advisory Group

Recommendation 27

That a member of the MPS Diversity and Citizen Focus Directorate senior management team and a representative from the respective MPS Diversity Strand Team should attend the ‘Full’ meetings of each Corporate Independent Advisory Group.

Recommendation 28

That IAG, SAG or CAG chairs or co-chairs (maximum of two) and vice-chairs will be elected or re-elected every two years.

Recommendation 29

That IAG, SAG or CAG chairs or co-chairs and vice chairs shall have a maximum of two consecutive terms of office.

Recommendation 30

That Corporate IAG or SAG sub groups will only be formed with the agreement of the Director of Diversity and Citizen Focus or respective senior police user. A Corporate IAG sub group (e.g. hate crime) would normally include a representative from each Corporate IAG.

Monitoring and evaluation

Recommendation 31

That the MPS, develops an evaluation framework to monitor the benefit of advisory groups based upon information such as the nature and volume of the issues they are asked (or ask) to advise upon, number of call-outs, feedback from MPS users or feedback from IAG members concerning MPS support.

Recommendation 32

That each advisory group complete a brief, structured annual report for the attention of their respective MPS liaison lead i.e. Director of DCFD, senior lead officer for each SAG or Borough Commander for CAGs by 31st May each year. The guidance and framework for this report will be developed by DCFD in consultation with advisory group chairpersons and MPS senior contact officers.

Recommendation 33

That where advisory group members at a meeting provide specific advice to the MPS it be fully recorded in the minutes in a manner that is retrievable at a later date. Wherever possible, the action taken as a result of the advice should also be recorded and cross-referenced to the original record of the meeting. The police user should ensure that, wherever possible, any advice received outside of a meeting is subsequently brought to the notice of members and recorded in the minutes.

Vetting

Recommendation 34

That all new Corporate IAG members shall be vetted to ‘Initial Vetting Clearance’ (IVC) level. Existing Corporate IAG members will continue not to be vetted but will be provided with the opportunity to volunteer for IVC or CTC vetting should they wish to do so. Personal assistants will be required to be vetted to IVC level and escorted by their respective IAG member. If not vetted they will be treated as visitors and escorted by an MPS staff member.

Recommendation 35

That information relating to the terms of appointment, remuneration and tenure of MPS IAG members (proposed and agreed by this Review) shall be placed upon the MPS website

Recommendation 36

That a protocol concerning the disclosure of documents to MPS advisers shall be developed in consultation with advisors and other stakeholders and appended to the new ‘MPS Standard Operating Procedures (SOPS) for Independent Advisors’

Standard Operating Procedures (SOPS)

Recommendation 37

That following ratification of the Review's recommendations, they shall be enshrined within a new ‘MPS Standard Operating Procedures (SOPS) for Advisory Groups’ that will thereafter govern and inform the MPS approach and relationship with independent advice.

The future structure of MPS Corporate IAGs

Recommendations 38 and 39 have been indefinitely postponed.

Recommendation 38

That the Director DCFD, in consultation with existing advisory group members, shall introduce a new corporate pan community IAG to the MPS by July 2009.

Recommendation 39

That during the transitional stage of introducing the new pan community IAG, Recommendation 21 (advisors cannot be members of more than one Corporate IAG or SAG) shall not apply in the case of a Corporate IAG or SAG member also sitting as a member of the new IAG.

Appendix 3: Equality Impact Assessment

The Equality Impact Assessment Guidance must be used when completing this form:

http://intranet.aware.mps/Corporate/Policy/Operational_Services/SOP/Equality_Impact_Assessment_SOPs.htm

Freedom of Information Act Document

Protective Marking: Not Protectively Marked Publication (Y/N): Y

Title: Metropolitan Police Service (MPS) Independent Advisory Group (IAG) Review

Summary: The purpose of this equality impact assessment is to ensure that the final recommendations made within the IAG Review comply with the MPS equalities agenda.

Branch / OCU: Diversity and Citizen Focus Directorate, IAG Review Team

Date created: August 2009 Review date: August 2012

Version:0.4

Author: Tom Morrell P170124 and Sarah Gausden P196330

Directorate / Department / Borough / OCU: Central team, Diversity and Citizen Focus Directorate

Name, type or title of proposal: Metropolitan Police Independent Advisory Group Review

1. Aims and Purpose of Proposal - see Step 1 of the Guidance

The aim of the IAG Review is to revisit the concept of all Independent Advisory Groups and their related procedures and existing protocols. This is being done in partnership with police users and advisors from existing Independent Advisory Groups (IAGs) within the Metropolitan Police Service (MPS), the Metropolitan Police Authority (MPA), The Greater London Authority (GLA), and the Government Office for London (GOL).

The objectives of the review are:

• To ensure consistency across the MPS Advisory Groups in tasking and deployments
• Review efficient working practices between MPS Advisory Groups that avoid the ‘silo’ effect
• To develop Standard Operating Procedures for MPS Advisory Groups
• To develop efficient monitoring, feedback and financial systems
• To update existing MPS guidance for independent advisors that promotes effective working practices and sets minimum standards for dissemination across the organisation.

The intended benefits emanating from the IAG review are:

• Improved working practices of the existing Advisory Groups
• More effective and efficient use of resources
• More effective processes
• A cohesive strategic vision
• Greater community focus and increased community participation
• An opportunity for greater involvement and representation from across London’s communities to promote increased trust and confidence in the MPS

2. Examination of Available Information – see Step 2 of the Guidance.

Full details of the review report provide background information that underpins this EIA (see Independent Advisory Group Review 2007 Full Report sections 6 –8).

(short history) Review of IAG processes took place, resulting in the incremental development of recommendations which were amended in response to feedback, and this EIA ran alongside this process.

3. Consultation/Involvement - see Step 3 of the Guidance

a. Who is responsible for managing this consultation/involvement?

The Head of the IAG Review Team MPS’ Diversity and Citizen Focus Directorate

b. Why is this consultation/involvement taking place?

• To meet the potential benefits as outlined in section 1
• To obtain the views of stakeholders on the concept of the new Pan London IAG, and identify any emerging concerns in relation to the original 37 recommendations prior to their implementation
• To identify areas of potential risk and possible impact on related policies, practices and procedures
• To help to prioritise actions resulting from the EIA and risk assessment process
• To ensure that diversity issues are considered across all diversity strands.

c. Who is included within the consultation/involvement, including which group(s)? Consider beneficiaries, stakeholders, service users or providers and those who may be affected.

Police users who are involved in the management of the range of advisors in the MPS. These individuals include representatives from MPS directorates and BOCUs.

Advisors from existing corporate independent advisory groups (IAGs) within the MPS, namely:

• Lesbian, Gay Bisexual and Transgender Advisory Group
• Disability IAG
• Race IAG
• Gypsy and Traveller IAG
• Met Youth Advisory Group

Advisors from specialist advisory groups (SAGs) within the MPS, namely:

• Sapphire
• Trident
• Safeguarding Children
• Training
• Blunt

Advisors from local Borough community advisory groups (CAGs) within the MPS

The Metropolitan Police Authority (MPA)

The Greater London Authority (GLA)

Government Office for London (GOL).

Full details of the review report provide background information that underpins this EIA (see Independent Advisory Group Review 2007 Full Report sections 6 –8). Further details of the consultation process for the review may be found in the timeline of events below (this list is not exhaustive):

Timeline of events relating to IAG engagement and consultation regarding the IAG Review

Consultation: Discussion Point: Date:

1st IAG Review Steering Group (IAG reps and MPS users)

Structure and role of IAGs

14th August 2006

2nd IAG Review Steering Group (IAG reps and MPS users)

Feedback and monitoring, conflicts of interest and independence, length of membership/tenure, duplication, security and CRB vetting, induction and awareness support, 14th September 2006

Questionnaires

Circulated to Users and IAG members across the MPS October 2006

RACE IAG Attended to seek views 2nd October 2006

LGBT AG Attended to seek views 18th October 2006

Ibrahim Elnour – (DM IAG) Interview 24th October 2006

3rd IAG Review Steering Group (IAG reps and MPS users) Strengths, areas of improvement and general discussion: 31st October 2006

Bob Hodgson Interview: 27th November 2006

Ruth and Anne (DIAG) Interview 30th November 2006

Race IAG Ben Owusu Interview 4th December 2006

RACE IAG Attended to seek views 4th December 2006

Steering Group update meeting First presentation of draft recommendations, with Rose and Ed. 15th December 2006

Cliff Codona (T & G IAG) Interview after meeting 15th December 2006

Email to IAG users and Independent Advisors 15th December

Draft recommendations circulated. 2006

Report from Questionnaires – Police Boroughs 1st December 2006

Report from Questionnaires – Independent Advisors 4th December 2006

EODB Chair’s briefing 5th January 2007

EODB meeting

Presented Draft Recommendations 18th January 2007

Southwark Critical Incident and Risk Advisory Group Development Day

Presented Draft recommendations 25th January 2007

Ibrahim Elnour– (DM IAG) 2nd Interview 5th February 2007

DIAG Attended to seek views 15th February 2007

DAC Hitchcock Briefing re IAG Review 22nd March 2007

LGBT AG Attended with Alf to seek views 22nd March 2007

MPA Full Authority Attended with Rose and Alf 29th March 2007

Concise version Circulated April 2007

Corporate IAG Chairs meeting Sought views 26th April 2007

DAC Hitchcock Briefing re IAG Review 3rd May 2007

MPA Roundtable meeting Discussion with Members 4th May 2007

Helen Ball and Alistair Jefferies Consultation re Trident, Sapphire and Safer Children IAGs 14th June 2007

MYAG meeting Attended 14th June 2007

Email for BOCU commanders with collation date as shown. Should local community advisory groups embrace the spirit of the review recommendations? 22nd June 2007

Op Blunt meeting Presented Draft recommendations 26th June 2007

National IAG Working Party. Attended and provided MPS perspective 2nd July 2007

MPA Roundtable meeting: Discussion with Chair and members: 9th October 2007

Email to IAG users and Independent Advisors Latest version of the MPS IAG Review (concise version) : 12th October 2007

IAG Chairs meeting Discussion of changes to the IAG recommendations 19th October 2007

IAG, CAG and police user meeting. Discussion of changes to the IAG recommendations 2nd November 2007

DIAG meeting

Discussion of changes to the IAG recommendations

MPA Discussion of changes to the IAG recommendations 17th January 2008

DIAG meeting and BOCU event

Discussion of changes to the IAG recommendations 21st January 2008

Meeting with Lee Jasper: 25th January 2008

IAG event Discussion of IAG recommendations: 31st January 2008

Race IAG meeting: 4th February 2008

John Azah will prepare a report containing concerns about the review

Trident meeting

Discussion of changes to the IAG recommendations: 6th February 2008

DIAG report to the Equalities and Human Rights Commission

LGBT meeting Discussion of changes to the IAG recommendations

7th February 2008

Corporate IAG Chair meeting with Deputy Assistant Commissioner Discussion of changes to the IAG recommendations 10th July 2008

All events supplemented by e-mails and phone-call discussions.

d. What methods of consultation/involvement are employed to ensure full information sharing and participation, e.g. surveys, interviews, community meetings?

See the timeline in section 3C and the methodology under section 5 of the Full Report.

All comments supplied during the consultation period have been retained on record within General Registry file OG11/06/55.

e. What are the results of the consultation/involvement? How are these fed back into the process?

See Full Report “Findings from consultation” – Section 9. The results of the consultation helped to shape the first 37 recommendations. The criteria applied regarding the acceptance of feedback was how pragmatically ideas and views could be implemented into a final framework which was likely to be acceptable to the majority of stakeholders. Where conflicting views were provided, the review team took counsel from the Director of the DCFD in relation to the final wording of respective recommendations.

Two new recommendations; 38 and 39 were added after the initial consultation. Recommendation 38 relates to the formation of the new single corporate group of independent advisors for London, recommendation 39 is an enabler for this new group. However following consultation these recommendations have not been implemented.

The initial 37 recommendations were implemented over the course of 2008 to 2009 at local Borough level in consultation with Link Commanders, Borough Commanders and their local advisory group support teams. This was with the help of supplementary documents which were updated according to the results of continuous consultation with an internal stakeholder implementation group and our corporate IAG chairs.

4. Screening Process for relevance to Diversity or Equality issues - see Step 4 of the Guidance

(i) Will the proposal have significantly higher impact on a particular group, community or person the MPS serves or employs?

Possibly, for example the Race IAG, has traditionally operated with more autonomy that the other groups and as such the review and new processes implemented as a result may have a greater impact on this group. It is not believed that the changes proposed in the review recommendations will significantly impact on employees of the MPS other than in relation to potential benefits as outlined in Section 1.

(ii) Will any part of the proposal be directly or indirectly discriminatory?

It is not anticipated that this proposal will be either directly or indirectly discriminatory. To reinforce this position, the MPS will continue to consult with independent advisors and extend the consultation process to other community members to ensure that the final recommendations have been properly informed. All advisory groups seek to have a broad representation of people and therefore this review aims to tackle any discrimination.

(iii) Is the proposal likely to negatively affect equality of opportunity?

No, the review intends to improve the equality of opportunity for community participation. Current IAG membership does not reflect the involvement of all diverse areas covered by legislation. The new proposals are likely to have a positive effect on the equality of opportunity because the new arrangements will seek to encourage the involvement of wider sections of the community in police business, than is currently the case.

(iv) Is the proposal likely to adversely affect relations between any particular groups or between the MPS and those groups?

Possibly, because of the perceived hierarchy of importance and access to the MPS from some of our corporate advisory groups. The debate that has shaped the recommendations of the review has been at times lively and emotive. This reflects the passion that the stakeholders have brought to the process in seeking to create a police service for London that is fair and truly reflective of and responsive to the communities that it serves. The extent of consultation should mitigate any adverse affect on relations between particular groups or between the MPS and those groups.

(v) Are there any other community concerns, opportunities or risks to communities arising from the proposal?

Yes, the review raised various concerns which have been addressed within this document. The IAG process is a small but intimate and important part of the MPS community engagement strategy with Londoners. The significance of the advisory group process is that it can provide ‘visible’ engagement between the police and vulnerable communities, such as the involvement of an advisor when the police are dealing with a critical incident.

The importance of getting this process right cannot be understated because it can both provide opportunities and risks to the trust and confidence that exists between the police and communities and between community groups.

(vi) Is the proposal likely to harm positive attitudes towards others and discourage their participation in public life?

Possibly, especially if groups are not involved in shaping the review and if the process is not transparent.

(vii) Is the proposal a major one in terms of scale or significance?

Yes, the proposal is a major one in its scale and significance. It will affect the function and arrangements relating to the advisory group process across London, as such it could impact on the relationships and credibility that the MPS has with London’s communities.

From the answers supplied, you must decide if the proposal impacts upon diversity or equality issues. If yes, a full impact assessment is required. If no, complete the following box and enter a review date at the end of the form.

Full Impact Assessment Required Yes (delete as applicable)

Signed: Date: March 2008

Supervised: Ch. Insp. Tom Morrell Date: March 2008

5. Full Impact Assessment – see Step 5 of the Guidance

a) Explain the likely differential impact (whether intended or unintended, positive or negative) of the proposal on individual service users or citizens on account of:

Age: older people, children and young people.

Details: Positive because the review encourages new membership of advisors from a cross-representation of London’s communities and those that are appropriate to the borough, business group or corporate position. This is unless the very nature of the group determines its unique membership. Equality and diversity must be uppermost in the minds of those recruiting members to a group. Young people particularly are beginning to be engaged with more pro-actively and many boroughs are choosing to link into existing youth groups from the third sector or run by the council or are forming their own bespoke young people groups. These are not always advisory groups as it is recognised that younger people may contribute more effectively out of structured meetings within adult groups. The youth strategy is currently reviewing a Key Individual Network approach to obtaining advice for the MPS which may be more effective than an advisory group process.

Disability in line with the Social Model.

Details: Positive because the review encourages new membership of advisors from a cross-representation of London’s communities and those that are appropriate to the borough, business group or corporate position. This is unless the very nature of the group determines its unique membership. Equality and diversity must be uppermost in the minds of those recruiting members to a group. This group are particularly believed to be under-represented at local Borough levels and the one to one implementation approach with each BOCU Commander allows discussions to encourage representation in advisors from previously marginalised communities.

To ensure that disability issues continue to be considered within the provision of MPS policing services, the review retains a specific Independent Advisory Group of disabled people and the MPS continues to develop this process of engagement, for example through the development of a Deaf ‘British Sign Language’ User Group.

Faith, religion or belief: those with a recognised belief system or no belief.

Details: Positive because the review encourages new membership of advisors from a cross-representation of London’s communities and those that are appropriate to the borough, business group or corporate position. This is unless the very nature of the group determines its unique membership. Equality and diversity must be uppermost in the minds of those recruiting members to a group. There is no specific Faith, religion or belief advisory group in the MPS.

Gender or marital status: women and men.

Details: Positive because the review encourages new membership of advisors from a cross-representation of London’s communities and those that are appropriate to the borough, business group or corporate position. This is unless the very nature of the group determines its unique membership. Equality and diversity must be uppermost in the minds of those recruiting members to a group. There is no specific gender advisory group in the MPS.

Race, ethnicity, colour, nationality or national origins.

Details: Positive because the review encourages new membership of advisors from a cross-representation of London’s communities and those that are appropriate to the borough, business group or corporate position. This is unless the very nature of the group determines its unique membership. Equality and diversity must be uppermost in the minds of those recruiting members to a group.

Sexual orientation, transgender or transsexual issues.

Details: Positive because the review encourages new membership of advisors from a cross-representation of London’s communities and those that are appropriate to the borough, business group or corporate position. This is unless the very nature of the group determines its unique membership. Equality and diversity must be uppermost in the minds of those recruiting members to a group. The corporate LGBT advisory group includes people from the groups outlined above, but there is no separate group for Transgender, who may prefer to identify under “Gender”.

Other issues, e.g. public transportation users, homeless people, asylum seekers, the economically disadvantaged, or other community groups not covered above.

Details: Positive because the review encourages new membership of advisors from a cross-representation of London’s communities and those that are appropriate to the borough, business group or corporate position. This is unless the very nature of the group determines its unique membership. Equality and diversity must be uppermost in the minds of those recruiting members to a group. Membership to an advisory group of individuals from this community would be relative to their presence as substantial enough demographic group for the OCU in question and need to be realistic enough in regard to accessing communication systems (telephones for example) which allows an advisor to respond and perform their advisory role.

b) Is the proposal directly or indirectly discriminatory? Is there a genuine occupational requirement?

Details: There is a need for a certain type of skill level to function to a standard that benefits the MPS. The SOPs will hold the following suggestion:

The type of person that could undertake the above role might be someone who is able to:

• critically appraise police policies and practices,
• make dispassionate, measured considered and ethical assessment of what they experience,
• bring relevant expertise, experience and integrity,
• reason and willing to articulate their views,
• be committed to the improvement of community/police relations,
• exercise judgment and discretion re conflict of interest.

The review of Advisory Group practice will enable new people to have access to an advisory role to the MPS. This is critical for our continued evolution; to invite new perspectives into our business and continue to allow insight to form our thinking which can become institutionalised and too focused because of the detail of our specialist skills.

c) Explain how the proposal is intended to increase equality of opportunity by permitting positive action.

Details: This will be achieved through selection and recruitment processes, tenure and training. Training develops individuals within the groups to function at an equal level in their role of advisor. Tenure and recruitment allows freshness within groups and promotes ongoing community access to the group.

d) Explain how the proposal is likely to promote good relations between different groups.

Details: A central corporate IAG was considered with the aim of bringing together different equalities groups, however this was rejected due to the perceived fear that certain groups would feel marginalised. CAGs however will be reflective of the local demographics and as such will engender a communities together approach. This has brought together individuals and groups who may otherwise regard themselves in conflict.

e) Explain how the proposal is likely to promote positive attitudes towards others and encourage their participation in public life.

Details: Drawing upon section ‘d’, a centrally produced Advisor Handbook will be available for advisors and this helps them to understand how the MPS functions.

f) Explain how the proposal enables decisions and practices to adequately reflect the service users perspective.

Details: This proposal is intended to improve the IAG process across the organisation and in so doing should help to promote trust and confidence between communities and the police. Advisors as service users have a significant role to play in advising the MPS on how to police London, taking into account different perspectives.

6. Modifications – see Step 6 of the Guidance

Could the proposal be modified to reduce or eliminate any identified negative impacts, or create or increase positive impacts? What improvements have been made?

Yes, a key meeting was held on 10th July 2008 which sought agreement on the IAG review recommendations from our corporate IAG chairs. The following areas were amended as a result of the discussion:

Recommendations 1, 4, 5, 6, 7, 8, 10, 11, 12, 15, 18, 19, 22, 23, 24, 26,27, 30, 31, 32, 33, 35, 36, and 37 - Agreed - no amendment necessary

2. Definitions: The word 'independent' was inserted in the definition of a SAG. The last line of the definition for an ‘Independent advisor’ was deleted.

3. Relatives: Recommendation 3 was deleted and an advisor may have relatives in the MPS and still be able to provide advice.

8. MOU: The MoU is to be created in audio format.

9. Responsible member: The member(s) will provide a single point of contact for the deployment of an advisor from their group, although if a group has particular difficulty in contacting a member in response to a request then the MPS should be contacted to provide support.

11. MPS (IAG) Personnel : Not amended, but we agreed to provide specific

support over and above the performance development report process.

14. (Expenses): Expenses to include the word ‘mileage’:

16. Meetings: Amended to reflect the workloads of meetings

To ensure consistency, regular meetings are to be held every 2 months with flexibility to go to six weeks if there is a heavy agenda.

17. Size of Group Amended to reflect previous discussions:

Membership size of any advisory group should be based upon the demands made of that group by the MPS and determined by the senior MPS police user of respective groups in consultation with the group.

20. Tenure to remain: The period has been amended from 18 to 24 months to allow experienced advisors to remain whilst new members are recruited.

25. OCPA No amendment, but we agreed that a member of

OCPA would not be involved in the recruitment process, other than as an observer.

28/29. Chairs’ election : To include vice-chairs in the election period and criteria as main chairs.

Further to this, the following areas have been resolved as follows:

• Recommendation 13 (remuneration) - the MPS is still awaiting outcome of external tax audit although the MPS seeks to apply ACPO’s IAG guidance which would allow advisors to claim expenses but no remuneration. Currently existing corporate IAGs who claim remuneration are continuing to do so. This does not affect Borough advisory groups.
• Recommendation 21 (An advisor sitting only on one group) - this is embedded in the MPS Advisory Group SOPs and is currently being managed within the MPS
• Recommendation 34 (The need to vet personal assistants) - due to MPS security directives, personal assistants will be escorted if they are not vetted. This may be achieved by the advisor being vetted who has a personal assistant and is able to provide this escort.

7. Further Research - see Step 7 of the Guidance

Given the analysis so far, what additional research or consultation is required to investigate the impacts of the proposal on the diversity strands?

Further research is to be undertaken in order to monitor the diverse memberships of MPS IAGs.

8. Decision-making - see Step 8 of the Guidance

a. Name, rank or grade of decision maker

Chief Inspector Tom Morrell

b. What is the Decision?

Reject the proposal No (delete as applicable)

Introduce the proposal Yes (delete as applicable)

Amend the proposal (an impact assessment should be made of any amendments) No (delete as applicable)

c. Name, rank or grade of SMT/(B)OCU/Management Board endorsing decision:

Detective Chief Superintendent Glen Allison

9. Monitoring - see Step 9 of the Guidance

a. How will the implementation of the proposal be monitored and by whom?

MPS Advisory Group Co-ordinator will provide ongoing support to the implementation through strategic support from Director DCFD, Link Commanders and other OCU Commanders.

The central co-ordinator will liaise with local advisory group co-ordinators to ensure that the corporate SOPs are adhered to and local Equality Impact Assessments are completed to contain local implementation details.

DCFD Diversity Advisors have been involved in supporting BOCUs in the completion of the EIA. An annual report will be required from each OCU that holds an advisory group.

b. How will the results of monitoring be used to develop this proposal and its practices?

Individual OCU meetings will be held to develop effective practice and engagement with locally held advisory groups, including the retention and recording of advice for an annual report.

c. What is the timetable for monitoring, with dates?

Annual report to be completed by OCU senior leads in collaboration with their advisory group chair or other nominee for submission to the MPS Advisory Group Co-ordinator by the end of May each year, who will receive them, analyse them and check OCU compliance with the SOP.

Masterclasses will be run for MPS advisors which include feedback from MPS advisors three times a year: January, May and September. These will be analysed and any points relating to organisational continuous improvement will be assessed and considered for implementation.

10. Public Availability of Report/Results - see Step 10 of the Guidance

What are the arrangements for publishing, where and by whom?

This will be published under the MPS Publication Scheme.

Person completing EIA:

Signed: PC Sarah Gausden DCFD Date: 16/6/09

Person supervising EIA:

Signed: Chief Inspector Tom Morrell DCFD Date: 16/6/09

Quality Assurance Approval:

Name and Unit: Inspector Colin White DCFD Date: 16/6/09

Date Review Due:

Retention period: 7 years

MP 746/07

Appendix 4: Flowchart identifying how IAGs are structured within the MPS

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