Governance of the Diversity and Equality Strategy

Report: 5
Date: 3 November 2011
By: Director, Diversity and Citizen Focus on behalf of the Commissioner

Summary

This report provides an update on the progress against the key actions identified within the Governance theme of the MPS Diversity and Equality Strategy and follows on from the report presented to CEP in January 2011. It describes the work carried out by the Directorate to fulfil its responsibilities, ensure there is effective governance of diversity and equality issues across the MPS and that agreed improvements are achieved.

A. Recommendation

That member note the report

B. Supporting information

Introduction

1. The MPS Diversity and Equality Strategy 2009-2013 was launched on 1 December 2009 and provides a clear articulation of what the MPS aims to achieve over the coming years to deliver services that are responsive to the needs of Londoners and its own staff. It provides the organisation with a clear focus on four strategic themes:

• Fair and Responsive Services
• Enhancing Community Engagement
• Workforce and Working Culture
• Governance and Performance.

2. Under the stewardship of the Deputy Commissioner, each theme is being led by a senior police officer or member of police staff who has responsibility for driving change within the organisation whilst ensuring that the principles underpinning each theme are embedded into the organisation’s way of delivering its business.

3. In early 2010 Management Board and the MPA agreed that the role of DCFD be refocused to provide the strategic lead in supporting the delivery of the new strategy, taking specific responsibility for the Governance and Performance Theme and ensuring the MPS fulfils its legislative requirements. Since the previous report to CEP in January 2011, considerable work has been undertaken to consolidate the organisational changes and ensure DCFD is fulfilling its responsibilities as agreed by Management Board, namely:

• Organisational conscience: To act as the conscience of the organisation on diversity and equality issues, providing challenge and ensuring compliance with legislative requirements.
• Professional advice: To provide professional advice and guidance through a team of diversity and equality professionals, identifying and promulgating good practice.
• Performance management: Ensuring the MPS has a rigorous performance management approach on diversity and equality issues, monitoring the outcomes outlined in the diversity and equality strategy, and reporting on issues.
• Delivery of specific work programme: To undertake specific programmes of work on behalf of the MPS as part of the delivery of the MPS Diversity and Equality Strategy.

Achievements

4. The MPS Diversity and Equality Strategy outlined a number of key actions for delivery within the Governance and Performance Theme. Progress within each of these and how DCFD has fulfilled its responsibilities during 2011 are described below.

Review and strengthen organisational governance of diversity and equality issues to deliver strategy

5. The revised governance and accountability arrangements to support the delivery of the MPS Diversity and Equality Strategy outlined in the earlier paper in January 2011 have now been fully implemented.

6. The Diversity Executive Board has met five times during 2010 and a further five times during 2011, at alternate meetings representatives from Staff Associations, Staff Support Associations and Corporate Independent Advisory Groups form part of the Board. The Board has overseen the presentation of plans for the themes of the strategy and has received regular updates.

7. Additionally the role of DCFD in reviewing the equality implication statements in reports submitted to MPS and MPA Boards has been formalised, this provides DCFD with another opportunity to oversee that equality issues are being considered and where appropriate monitored. In all cases authors receive general feedback. Since January 2011 a total of 159 reports have been tracked through this process. More significant, revisions have been proposed by DCFD on one third of all reports.

Ensuring diversity and Equality issues are included within the MPS performance management processes. Robust processes to deliver improvements in our performance in managing diversity and equality issues MPS wide.

8. Diversity and equality issues are embedded in MPS performance management processes in a number of ways.

• At corporate level, the MPS Diversity Executive Board receives a performance report prepared by DCFD. This provides an update on performance against the indicators contained within the MPS Diversity and Equality Strategy, highlighting exceptions and risks and initiating interventions and activities as required. The Board is able to escalate issues to the MPS Management Board, refer to the Performance Board or advise the relevant BOCU of its views as necessary. Equality and diversity issues are considered through the corporate health indicator process and diversity and equality performance is also reported publicly through the MPS Corporate Social Responsibility framework.
• At Business Group level, Diversity Forums are in place to monitor local level diversity and equality activities. Business Groups have in place actions plans, reflecting actions identified through the Equality Standard for the Police Service (ESPS), performance results and issues identified locally.
• All forums are supported by one of the eight Diversity Advisors whose role is to support the delivery of activities identified though the ESPS and local action plans.

9. These arrangements are all supplemented by the Director DCFD who undertakes a series of performance visits to a range of OCUs and Business Groups. Six performance visits have been undertaken since April 2011 (Tower Hamlets, Enfield, Haringey, CCC, DoR, and Westminster). Proposed visits to Lewisham and Croydon were postponed.

Implementation of the Equality Standard for the Police Service

10. In line with the direction from ACPO, the MPS has adopted the Equality Standard for the Police Service, which was designed to provide a consistent framework for assessing and improving diversity and equality performance across all UK police forces. Implementing the ESPS has provided the MPS with a mechanism to assess and feedback on diversity and equality performance and allows units to identify where they can improve operational delivery.

11. The ESPS consists of three phases:

Baseline: Assessing an activity that must be in place. This is looking at the processes and procedures that exist to help consider diversity and equality issues.

Integrating: Assessing an area that is integrated into wider activities. This is identifying how those processes and procedures are used within core business and beyond.

Excelling: Assessing an outcome that contributes to improved community confidence. This is looking at improving service delivery.

Specific indicators exist for each phase and are broken down under the headings of ‘Operational Delivery’, ‘People and Culture’ and ‘Organisational Processes’. DCFD successfully oversaw the implementation of the baseline phase (22 indicators) across the MPS during 2010/11. Where initial results highlighted that a unit may not be reaching the required standards interventions and actions were initiated to address the gaps identified. By the end of 2010/11 the MPS achieved a noteworthy level of performance with 97% of units being assessed as reaching the baseline standard (exceeding the target of 80% of units achieving compliance).

12. Based on the learning from the baseline phase, a number of changes have been made to simplify and streamline the integrating phase these include:

• reducing the indicator set,
• simplifying the wording of indicators to increase operational relevance,
• ensuring (B)OCUs focus on the indicators most relevant to their work (rather than evidencing all indicators),
• aligning evidence presented at baseline to the new indicator set so that information already provided that meets integrating standard does not need to be re-presented,
• linking the assessment process more directly to action plans and providing templates to support this.

13. The integrating phase of the ESPS was launched within the MPS in June and included a letter from the Deputy Commissioner to heads of Business Group and (B)OCU Commanders outlining the process, MPS requirements and the support available. This phase has a clear focus on identifying where gaps and improvements are required to improve operational performance (rather than providing detailed evidence of what is already in place) and ensuring that learning and good practice is shared throughout the MPS.

14. DCFD Advisors and Delivery Teams are supporting Business Groups and (B)OCUs through briefings, meetings and user groups. Support and guidance will be available to assist units in assessing where areas for improvement are required and options for how these can be achieved. Completed assessments will be submitted by (B)OCUs and Business Groups and interim results will be available from December 2011.

15. (B)OCUs and Business Groups will amend their Diversity Action plans and Business plans to mitigate any gaps identified by the assessment process. The intention is to identify ‘key’ areas for policing activity. This approach is consistent with the Government’s Equalities Bill proposals where there is no requirement to set objectives for every area of equality.

16. The proposed targets for April 2012 are:

‘All B/OCUs must have completed the baseline phase and have in place action plans to measure improvement, and demonstrate activity to allow them to achieve integrating.’

‘All B/OCUs are able to demonstrate satisfactory evidence at Integration level.’

Review and improve our approach to conducting equality impact assessments, not only to fulfil our legislative requirements but also to drive change and improvement.

17. The DCFD Equality Impact Assessment (EIA) quality assurance team approves the equality impact carried out on all MPS policies and Standard Operating Procedures.

18. Since January 2011 a total of 23 policies have been approved, a further 19 have been reviewed; authors have been given feedback and are required to make amendments. The main feedback points to authors are:

• The requirement to evidence the outcomes of their policy and ensure effective monitoring arrangements are in place.
• To evidence that the principles will not impact disproportionately on any of the protected characteristics under the Equality Act 2010.
• The requirement to evidence that, in developing the policy consultation has been held with external stakeholders.

19. DCFD is taking forward a number of activities to improve the organisational approach to undertaking equality impact assessments. Informed by consultation with practitioners and DCFD’s monitoring of EIAs, the following key issues have been identified:

• An inconsistent approach to how EIAs are undertaken across the MPS.
• A lack of understanding about the process and when an EIA is (and is not) required.
• The need for a more user friendly process, supported by IT guidance and training as appropriate.
• Need clearer messages on what practitioners should focus on and what are the benefits of carrying out an EIA.
• The need for EIAs to lead to tangible improvement activity and to inform organizational learning.

20. DCFD has responded to the issues identified by:

• Piloting and introducing a simplified EIA form from April 2011.
• Updating the form to reflect the protected characteristics identified in the Equality Act.
• Revising the standard operating procedure for EIAs.
• Working with DPA to develop a campaign to raise awareness amongst MPS staff of the purpose of EIAs and their importance to providing effective policing services .

21. Proposals to progress this work further were presented to the Diversity Executive Board in September 2011. The Board endorsed the next steps that include:

• Rolling out the presentation materials and ‘EIA campaign’ from autumn 2011 with the support of the DPA.
• Developing a technical solution to assist staff in completing an EIA ‘form’. This will provide an interactive facility that provides prompt questions and advice to guide staff in completing the form.
• Further developing good practice in terms of mitigating actions.

22. As reported in January 2011, DCFD is providing enhanced EIA support to a number of critical MPS change programmes where the scale and the impact of the change has a significant impact on London's diverse communities or its own staff.

Other work undertaken by DCFD during 2011 to improve diversity and equality performance

23. DCFD will be hosting its second MPS Diversity Excellence Awards. As in previous years, applications have been invited in five categories:

• Leadership
• Fair and Responsive Services
• Workforce and Culture
• Community Engagement
• Performance.

24. A ceremony is due to be held on 31 October 2011 which will involve the Deputy Commissioner presenting winning and highly commended awards in all categories.

25. In response of the pressures on resources and to enable (B)OCUs to deliver creatively in support of the Diversity and Equality Strategy in 2010, DCFD initiated a Resource Allocation Process. (B)OCUs and Business groups were invited to identify diversity and equality improvement activities requiring financial or other assistance and to apply to DCFD for that assistance. The process required an explanation as to why the proposal was unlikely to be progressed, evidence on how the nominated activities would impact on improving diversity and equality and required successful applicants to engage with DCFD and provide evaluation of the activity once completed. Applications received were selected by an initial panel including senior managers from DCFD and TPHQ. A further panel including MPA representation reviewed bids that required further consideration.

26. Thirty eight applications were received of which seven resulted in assistance in the form of staff knowledge, skills and time being offered. A further sixteen applications received financial assistance from the DCFD budget.

27. This process was very successful and provided funding and support for a number of projects that contribute to realising the aims of the Diversity and Equality Strategy but would not otherwise have been progressed. Examples of the projects funded:

• A HYDRA training package on Disability issues (noted as good practice in the recently published EHRC Disability Harassment Inquiry report).
• A training resource on Homophobic bullying developed with partners in Wandsworth for use in secondary schools and subsequently made available to all boroughs.
• A training resource on Female Genital Mutilation developed with partners including the Foreign and Commonwealth Office.

28. Following endorsement by the Diversity Executive Board, DCFD recently launched its Resource Allocation Process for 2011/12.

Staff Support Associations

29. From April 2011, DCFD assumed responsibility for the MPS Staff Support Associations. A number of changes have been introduced to enhance the governance arrangements and support the SSAs in their work. SSAs are expected to submit a business plan for their activities during 2011/12. In support of these a performance framework is being introduced to monitor and report on the work of the SSAs with progress or otherwise included in the quarterly performance report provided to the DEB. The Chair of the SSAs attends Board meetings. Work will continue to develop the profile and responsibilities of the SSAs

Good practice

30. Throughout 2011 DCFD has proactively identified and captured a number of good practice examples relating to a range of operational service delivery, community engagement and cultural change issues. Examples have been verified and made available via the MPS intranet. DCFD is keen to continue to develop this database as a resource for practitioners across the organisation. It plans to formally launch the database in November 2011 advertising the product across the MPS by which time it is anticipated that it will include forty good practice verified examples.

Update on Operation Kirkin

31. From the onset of the disorder Staff Support Associations and DCFD participated in the community gold group meetings. At these meetings staff provided advice, made recommendations and brought community intelligence to the fore.

32. Community messages were sent out both by SSAs using their own networks and corporately by DCFD working in partnership with MPS stakeholders. Community groups and GLA representatives were visited by SSAs and DCFD sent out messages internally offering advice and guidance to (B)OCUs around Diversity and Equality issues. SSAs responded to media enquiries and gave a number of interviews both on radio and television and were able to offer community reassurance messages. DCFD continues to support the strategic review currently being undertaken, with a particular focus on community engagement.

Looking Forward

33. Considerable work has been undertaken to establish structures, systems and processes to enable DCFD to deliver its responsibilities in supporting the MPS achieve its diversity and equality ambitions. During 2010/11 the MPS exceeded the target it set of 80% of business units meeting the baseline standard of the ESPS, a key outcome for this theme of the strategy.

34. A critical success measure for DCFD for 2011/12 will again be organisational achievement against the two agreed ESPS indicators, namely:

• All B/OCUs must have completed the baseline phase and have in place action plans to measure improvement, and demonstrate activity to allow them to achieve integrating.’
• All B/OCUs are able to demonstrate satisfactory evidence at Integration level.’

35. These will be supplemented by monitoring of and a focus on:

• Satisfaction levels of customers with work done / advice provided by DCFD.
• The delivery of a series of key products for the organisation during 2011/12 – this includes support material, briefings and workshops on the implications of the Equality Act; products to support practitioners in undertaking effective EIAs, products to address organisational gaps identified by the ESPS.
• Compliance with the EIA process, including the tracking of advice provided and organisational learning arising from EIAs, especially in relation to change programmes.
• High level input, guidance and support to critical operational and community policing needs.
• Ensuring the corporate implications and requirements of findings relating to key equality issues are acknowledged and addressed.

C. Other organisational and community implications

Equality and Diversity Impact

1. The aim of the Diversity and Equality Strategy is to create positive outcomes for all communities the MPS serves. A focus on the role and rigour of equality performance and governance ensures that the MPS is better able to identify, analyse and understand issues and then to efficiently target interventions.

2. The Equality Standard has been designed specifically; as a means of promoting positive outcomes for communities; to improve policing performance; address issues of disproportionality and focus local activity on locally identified priorities.

3. Through a transparent process of self assessment and community engagement the Equality Standard will provide evidence that demonstrates how the MPS is meeting the existing Equality General Duties - as enshrined in existing Race, Gender and Disability legislation - and is designed to be compatible with the Equality Act.

4. The ESPS provides a vehicle to consider the nine protected characteristics of the Equality Act 2010. By gathering and recording evidence it will help identify what our service provision is and provide a forum to document compliance.

Consideration of MET Forward

5. The changes to DCFD are designed to support the MPS in achieving the aims set out in its Diversity and Equality Strategy and Met Forward in particular the priority strands of Met Connect, Met Specialist and Met People.

Financial Implications

6. The costs associated with the new structure and impacts on individual Business Group budgets were described fully in the paper presented to CEP in May 2010. £412,000 of savings are being released in 2011/12 as per the approved medium term finance plan (MTFP). These savings are currently shown on the MTFP against the TP Business Group. All other costs associated with the activities described in this paper are covered by existing MPS budgets.

Legal Implications

7. The Equality Act 2010 (“the Act”) now provides for a single equalities duty that brings together the existing race, disability and gender duties, and now extends to areas such as sexual orientation, age, religion and beliefs, pregnancy and maternity and gender reassignment. The general equality duty under Part 11 of the Act requires all public bodies carrying out public functions to eliminate discrimination across all of the protected characteristics, advance equality of opportunity and foster good relations between persons who share relevant protected characteristics.

8. The Equality Standard for Police Services (“the Standard”) aims to ensure all strands of the equality legislation is fully integrated into day to day policing activities so that they contribute to overall improvements and build confidence in the police force.

9. The Standard will assist the MPS to assess how far it has developed beyond the basic compliance with equality law, and ensure there is a drive towards continuous improvement. The MPS will be able to benchmark and learn from other police services by using a single framework.

10. Whilst the Standard has been developed for, and is aimed at, Police forces, the MPA have a duty to secure an efficient and effective police service and therefore will have a significant oversight role.

11. The Equalities and Diversity Sub-Committee may receive and consider the proposals contained in this report, as it is the lead on the integration of equality and diversity work within the MPS, under its terms of reference.

Environmental Implications

11. There are no environmental implications associated with this report.

Risk Implications

12. The MPS continue to monitor risk over time to oversee delivery of the Diversity and Equality strategy through quarterly reporting to Diversity Executive Board where the board is able to take appropriate corrective action.

D. Background papers

None

E. Contact details

Report authors: Diversity and Citizen Focus Directorate, MPS

For information contact:

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

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