Contents

This is Report 6 of the 31 July 2009 meeting of the Equality and Diversity Sub-committee, with details of the development of an equality performance framework.

The Equality Standard for the Police Service

Warning: This is archived material and may be out of date. The Metropolitan Police Authority has been replaced by the Mayor's Office for Policing and Crime (MOPC).

See the MOPC website for further information.

The Equality Standard for the Police Service

Report: 5
Date: 31 July 2009
By: T/ Assistant Commissioner Territorial Policing on behalf of the Commissioner

Summary

The report provides an overview on work undertaken by the MPS to develop an equality performance framework, showing its transition from adoption of the Equality Standard for local government (ESlg) and genesis through to the MPS’s involvement in the development and trail of the Equality Standard for the Police Service (ESPS).

A. Recommendation

That Members are asked to note work in progress and give support to MPS plans for implementation of the Equality Standard for the Police Service (ESPS).

B. Supporting information

Introduction

1. Over the past 15 years the police service has undergone extensive scrutiny on equality & diversity in response to a number of high profile reviews and investigations including the Lawrence Inquiry, the CRE Formal Investigation, and the Morris Inquiry. This has required forces to respond to a series of recommendations for change but with no effective means of integrating those changes into performance in the wider policing context.

2. The concept of a ‘standard’ in the field of equality activity has become the good practice approach and has seen forces adopting such mechanisms as the ‘Stonewall Workplace Equality Index’, the ‘Employers’ Forum for Disability Framework’ the ‘Equality Standard for local government’ (ESlg) as a means of improvement against single or multiple strands of activity. In different ways, each of these standards has helped forces improve their performance in specific areas but none was designed with the Police Service in mind.

3. The MPS has responded positively to each requirement to review its performance, creating action plans with supporting governance to ensure that the recommended changes were implemented. However, despite some visible successes, there has been a problem with this approach over time, with the evidential trail becoming harder to trace after 12 - 18 months.

4. Nationally, public concern continues to focus upon the recruitment, retention and progression of Black and Minority Ethnic officers and, the continued over-representation of Black groups in the annual figures on stop and search procedures. The perception remains that despite a good record on delivering positive outcomes in some areas of service delivery, that the Police Service still has work to do in changing its underlying culture.

5. Diversity and equality is still widely perceived as an adjunct to the mainstream performance framework. This has contributed to our difficulties in sustaining improvements from equality activity. We now need a means of looking forward and driving continuous improvement.

6. In supporting the “Equalities for All” Best Value Review -conducted in 2001/02 by the Greater London Authority (GLA) - the MPS recognised the validity of applying this principle to equality and diversity and committed its resources within the Diversity & Citizen Focus Directorate (DCFD) to work towards level 5 of the ESlg.

7. More recently, the Commissioner restated his support for this approach in publishing the MPA and MPS Policing London Business Plan for 2009 -2012, in which he and the Mayor outlined their commitment to the adoption of an equalities performance management framework, which sets the standard for the mainstreaming of equality and diversity activity across the organisation

Initial MPS activity to adopt an equalities management framework

8. The purpose of the ESlg was to fully integrate equality at the heart of an organisation’s policy-making, service delivery, employment and community engagement using a framework of continuous performance management, cycle of review, assessment & consultation, action and monitoring, within which are five levels of achievement [Level 1: Commitment to comprehensive equality policy, Level 2: Assessment and consultation, Level 3: Setting equality objectives and targets, Level 4: Information systems and monitoring against targets and Level 5: Achieving and reviewing outcomes].

9. On the 7th of February the MPS provided the Police Authority with an update on work undertaken to implement the ESlg. (Equal Opportunities and Diversity Board (EODB 7.2.2008 item 14) The MPS had been assessed by an accredited auditor from the Improvement and Development Agency (IDeA) and found to be at level 3. (With isolated, examples of MPS business groups having engaged in activity associated with Level 5.)

10. In reaching this level of achievement, the MPS had also come to the realisation, that successful implementation of the ESlg was going to prove extremely difficult. The standard was not designed for Police use and was in fact widely criticised by users across the public sector, as being overly bureaucratic, too process driven, resource intensive and did not produce tangible outcomes.

11. Having considered these factors collectively and after consultation with key stakeholders in the MPA and GLA, it was the stated view of the MPS, that with in excess of 132 discrete business areas, the likelihood of success with the ESlg to Level 5 was highly unlikely. The report recognised the benefits that a standard might have in actively promoting Equality and Diversity and concluded by signposting the MPS’s intention to develop its own equality framework, based on the key principles of the ESlg but more relevant to the needs of policing the capitol city.

The national approach to an equality framework

12. In the spring of 2008, the MPS Equality Framework (Working Model) came to the attention of the Association of Chief Police Officers (ACPO) Race & Diversity Business Area and after a wide consultation exercise with Equality and Diversity professionals across all 43 English and Welsh police forces, it was recognised that there was wide support for development of an Equality Standard for the Police Service (ESPS).

13. Under the sponsorship of the ACPO Race portfolio, a project to develop a Standard was formally commissioned by the Tripartite (ACPO, Home Office, Association of Police Authorities (APA)) Equality and Diversity Strategy Board (EDSB) and it was agreed that this work would be undertaken on behalf of the police service by the National Police Improvement Agency (NPIA)

The MPS involvement in developing a national standard

14. A project group was established, including MPS staff from the Diversity & Citizen Focus Directorate to lend their expertise and experience in developing the ESPS and also involved lead equality specialists from a number of forces (covering urban and rural, large and small), Her Majesty’s Inspectorate of Constabulary (HMIC), Home Office, APA and the Improvement & Development Agency for local government (IDeA) (Owners of the ESlg), the NPIA and a NPIA Independent Advisory Group (IAG) member.

15. The initial work on the ESPS built on the work completed by the MPS in developing its own Equality Framework, and was designed using the Home Office’s Assessments of Policing and Community Safety (APACS) performance framework as its model. Over time this model was reworked from five sections to three and the criteria for each section drastically reduced in number to 25 overall.

16. In July 2008 the government published a policing green paper - From the Neighbourhood to the National - in which it outlined a range of proposals focused on continuing to deliver improvements to policing. This included a commitment to develop a tripartite Equality, Diversity and Human Rights Strategy.

17. The green paper gave recognition to the work undertaken by the MPS and the NPIA and outlined plans on how the finished product should be used to support the strategy and used by Her Majesty’s Inspectorate of Constabulary (HMIC) to then inspect on the Police Services efforts to improve confidence with its communities.

18. The tripartite strategy is now in the final stages of development and outlines how the Association of Chief Police Officers (ACPO), the Association of Police Authorities (APA), and the Home Office will promote equality at the Strategic levels of policing and how this should be supported by Forces in implementation of the Equality Standard for the Police Service (ESPS).

Put simply, the strategy sets the direction for change, and the standard measures local achievements.

The ESPS and its impact upon the MPS

19. The ESPS uses a 3 stage model requiring the MPS to gather evidence of its performance against criteria at three levels of performance. Starting at Baseline performance moving through to Developing and on to Good Practice.

20. The MPS will initially be required to identify evidence of performance at the Baseline level to ensure that the fundamental processes for the delivery of effective outcomes are in place.

21. The ESPS’s reduction in size has seen a concentration on the areas of equality and diversity of major importance and concern. It is recognised that one of the major challenges to implementation in the MPS, will be the reaction of the work force to a subject that many people struggle to understand. Equality and diversity has a language of its own and like any specialised language can be difficult for staff who feel unskilled in its interpretation. In managing the MPS trial, DCFD recognised that this would be a potential risk to the trial’s success and developed a guidance document in simple English.

22. In essence, the ESPS requires evidence of activities and outcomes that should already be taking place across the MPS and potentially could include such things as local policing plans, impact assessments, evaluations of deployments and investigations, community meetings and partnership work. This is not a requirement for lengthy report writing but a means of proactively noting evidence of auditable good practice.

23. In the absence of existing information collection systems, additional work will be required. What the ESPS is not is a duplication of effort. This has been addressed in its design to ensure that evidence provided in other key areas of activity - for example Citizen Focus Hallmarks - is evidence for the ESPS as well.

24. In London, Operational Command Units (OCU’s) and Business Areas will be asked to collect evidence about their equality activity across the three sections and to undertake a process of self-assessment followed by community assessment to give added rigour and integrity to the process. The subsequent development of action plans need to reflect local needs and priorities and undoubtedly will be different depending on local demography and policing context. This will form a natural link between equality activity and the core business of operational delivery.

25. It is essential that the implementation and management of the ESPS is not seen as a role for equality or diversity specialists but rather as an element of business as usual, to be undertaken by staff already employed within the MPS’s performance infrastructure. DCFD have endeavoured throughout the MPS trial, to ensure that those gathering evidence at local levels have a performance focus and are experienced in gathering data for performance purposes. It has been evident that with the right support from DCFD staff and familiarity of what is required that, confidence in what constitutes evidence will grow.

26. Ultimately the transparent nature of the process will enhance community engagement and will build trust and confidence both internally and externally.

The expected service-wide benefits include:-

Through being very operationally-focused, the Standard will integrate equality into all business delivery and provides support for delivering Public Service Agreements (PSA's (specifically 23, 24, 25 and 26)
It will drill down to analyse local performance and help to deliver the Flanagan recommendation for local accountability
It will reduce bureaucracy as future evidence gathering for compliance reports will be proactive and much less resource-intensive than now
It will build service delivery capability by looking at skills development and how recruitment, retention and progression are managed
It will focus on outcomes and getting best value of resources by evaluating ‘what works’
It will provide HMIC with a means of inspection of equality activity
It will support local target setting with Police Authorities and other aspects of the Authorities’ work.
The standard is in line with the Commission for Equality and Human Right's emerging vision of equality and fairness and with the Association of Chief Police Officer's requirement of a transparent and integrated approach.
It will also increase local accountability as recommended by the Flanagan Review of Policing.
The standard focuses both outwards on work with partners and communities, and inwards on our organisation processes and our people.

Trialling and promoting the ESPS

27. The MPS embarked upon a three-month field testing of the ESPS in April 2009. This trial involves forces of different sizes and differing policing contexts and is intended to get feedback from users on the difficulty or ease of use, as well as any wider feedback on its content or problems likely to be faced in a wider implementation. (The other forces involved are Cleveland, Lancashire, Derbyshire, North Wales, City of London, Devon & Cornwall, Sussex, Kent and the Greater Manchester Police).

28. To support and manage the trial the MPS Diversity & Citizen Focus Directorate (DCFD) formed a working group to co-ordinate the process. The working group identified early on that the single points of contact at the sites identified - Enfield and Richmond BOCU’s, CO19 Firearms Branch, Human Resources Directorate and DCFD - may have some initial issues with the complex wording of the Standard.

29. As mentioned earlier, the efforts to make the Standard manageable have been to some degree at the cost of understanding the criteria. In recognition of this, DCFD provided the trial sites with guidance notes to put in layman's terms the kind of evidence sought. The project team initially had reservations about potentially influencing the trial by providing users with a list that could in effect become a tick box process that gave little room for initiative and wider thinking. However, it was clear that a compromise was necessary here and on balance, DCFD felt that it was better at this testing stage to accept the risk and provide staff with guidance rather than have a problem with them rejecting the ESPS due to confusion over what was required.

30. In addition to the guidance documents, each site has been introduced to the ESPS through a facilitated seminar where staff were guided through the criteria and introduced to some additional tools in the form of learning and risk logs. The completion of which was mandatory and would assist the MPS team to pass on effective feedback to the national project team as well as determining how DCFD could best implement the ESPS to a wider MPS audience.

31. At the same time this work was being progressed, the working group has been closely working with colleagues in the MPS”S Directorate of Public affairs (DPA) to develop a communication strategy. (This strategy is in draft form and included at Appendix 1).

32. The communication strategy recognises that over time the audience will change with an initial focus on the needs of Senior Managers and those tasked with its management. As it becomes part of the performance infrastructure the kind of products envisaged will be more specific and targeted at a wider audience.

Example - Borough Commanders - The MPS already supports the data collection for the composition of Comprehensive Area Assessments and will be better able to support Local Area Agreements (LAA) in meeting social, educational, health and community targets.
Example - Safer Neighbourhood Teams - The policing Pledge, Pledge 9 commits the MPS to regular public meetings to agree local priorities at least once a month. Safer neighbourhood officers would need to be aware of the standard as evidence of their activities to facilitate opportunities such as surgeries, street briefings and mobile police station visits to meet local needs and requirements will be evidence for the ESPS and will provide the information base by which the MPS can tailor key local messages on progress on local crime and policing issues; on how the MPS is making local neighbourhood safer and information on how the MPS is performing. (Appendix 2 - How delivery of the Pledge provides evidence for the ESPS)
Example - All Staff - The range of evidence available for the ESPS will also provide individual staff members the opportunity to evidence activity for their annual professional development review (PDR).

33. As part of the communications strategy, the DPA have developed a document that explains the relationship between the MPS Equality and Diversity strategy, the MPS Equality Scheme and the ESPS. (See Appendix 3)

34. The National Police Improvement agency (NPIA) MPS was provided with a simple IT Evidence Capture System, using the Microsoft Access database. This software proved incompatible with the MPS Aware infrastructure and through necessity and for the purpose of the trial, DCFD designed its own IT support using an Excel spreadsheet. This has not proved to be ideal and DoI are considering options to replace this.

35. In reviewing the trial sites experience, DCFD, has been measuring the time and resources committed to implementation of the evidence gathering process. Once this data has been collected the Directorate will be better placed to quantify the potential cost in time and resources to successful implementation.

36. The main issues raised in relation to the MPS trial included the following:-

The ESPS was recognised as a useful tool that was straightforward to complete once forces had familiarised themselves with the process.
Trial sites stated that the ESPS had provided an evidence capture tool that highlighted diversity and equality performance in day to day operations that they had not previously been aware of.
Sites had identified areas for improvement as a result of completing the evidence for the tool.
Implementation had been much more effective where there had been senior manager buy-in and it had been incorporated into existing performance management structures.
Despite sites volunteering for involvement in the trial, DCFD surprisingly experienced, amongst some middle managers, an attitude that other pressing priorities precluded meeting evidential deadlines. This tends to reinforce the nature of the challenge e faced in any wider implementation.
The language used needs to be simplified, as the current language is too complex, broad and ambiguous. The DCFD guidance in addressing this issue was well received and helpful.
Some clarification was required from the NPIA to avoid a subjective assessment of the evidence gathered. The MPS has been developing a scoring system to assess its own performance and this issue will be the subject of ongoing discussion with the national project team
Links between the ESPS and the ACPO Strategy, Citizen Focus Hallmark and other national or NPIA products needed to be made more explicit.

The way forward

37. The NPIA project team have now considered the feedback received and incorporated much of this into a reworked ESPS. At the time of writing this report, the updated ESPS has not been circulated but will be available for consideration by the date of the sub-committee meeting on the 31st of July 2009.

38. The MPS expects that between July and November, the NPIA will be engaged in a formal endorsement process that will involve taking the final product to the ACPO council, Home Office Equality and Diversity Strategy Board (EDSB), and Association of Police Authorities (APA) and national Policing Board for sign off. It is the intention of the Tripartite (ACPO, APA, Home Office) Equality & Diversity and Human Rights strategy that forces should plan for implementation in December.

39. DCFD is already developing an implementation plan that will reflect the learning of the trial experience and look to integrate this into the existing MPS planning and financial processes. Work in this respect is already underway with agreement for the ESPS to be included into the Deputy Commissioners work on the 5 P’s as a mechanism of continuous improvement under ‘Performance’.

40. Actual Implementation of the ESPS will require a phased approach across the MPS. The size and numbers of OCU’s and Business areas makes this more complicated and complex process than that likely to be experienced elsewhere in UK policing. The workload to deliver this is being assessed as part of the trial and recommendation for service wide implementation will be made on the outcome of the review.

41. This work will be co-ordinated by DCFD teams led by the Diversity Advisors, who will engage with OCU’s and Business groups to identify, explain and implement the ESPS. It is very likely that this will require tailor made solutions to reflect individual needs and practice. In the long term it is anticipated that once the self assessment and community assessment stages are completed that DCFD will provide advice and practical support in the development of local action plans as local priorities are identified.

42. The intention of developing action plans is to identify ‘key’ areas for policing activity. It has never been the intention in implementing the ESPS to overload the system further with extensive requirements but to focus on the critical and important. This approach is consistent with the Government’s Equalities Bill proposals where there is ‘no’ requirement to set objectives for every area of equality. Indeed, the ‘new’ MPS Diversity strategy recognises this issue and sets strategic priorities which the ESPS will support.

43. The Diversity and Citizen Focus directorate will monitor and collate the corporate picture of equality and diversity performance on behalf of the MPS. At a strategic level, progress on the ESPS to date has been and will continue to be the subject of regular update to the MPS Diversity Board. The board is now chaired by the Deputy Commissioner who will brief the Commissioner via Management Board meetings and report and be accountable on matters of equality and diversity to the Metropolitan Police Authority.

44. In addition to regular scrutiny by the MPA, Her Majesty’s Inspectorate of Constabulary (HMIC) will undertake a national workforce inspection into Public confidence in 2010. The Inspection will examine six areas of activity: - customer service; listening to frontline staff; implementation of equality standards; deployment; workforce mix; and supervision. The ESPS is strongly focused on confidence issues and performance and elements of its delivery will be subject of this inspection with HMIC gathering evidence against achievement at the baseline stage.

C. Race and equality impact

On behalf of the Police Service, an Equality Impact Assessment is being completed by the NPIA and has involved a wide range of engagement activities to raise awareness of key stakeholders. (Meetings held with the Association of Police Authorities Equality Network, Police Federation, Police and Police Staff - Staff Associations, Independent Police Complaints Commission, Welsh Equality Human Rights Commission, Citizens Advice Bureau, Improvement and development Agency (IDeA), ACPO Confidence & Equality Practitioners Network, Government Equality Office.

In June two major consultation events were held in London and Huddersfield involving people from the MPS’s and West Yorkshire Police’s independent Advisory group’s (IAG’s) professional equality bodies and key community members.

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

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 equally compatible with the envisaged changes of the new Equalities Bill.

D. Financial implications

The MPS welcomes the opportunity the Standard provides to integrate performance management within existing frameworks. p>

An assessment of the resource needs from the pilot is being considered. It is the intention that any costs would be found from within existing TP resources.

An initial sum of £20,000 will be identified from the DCFD 2009-10 budget to support the initial stage of roll-out.

E. Background papers

None

F. Contact details

Report author(s): Detective Chief Superintendent Glen Allison assisted by colleagues within the Diversity & Citizen Focus Directorate ESPS Working group.

For more information contact:

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

Appendix 1: ESPS MPS Communication Strategy (Draft)

This strategy sets out how effective communications can support the Met’s delivery of the Confidence and Equality Standard for the Police Service (CESPS). [1]

Communication Objectives

The main objective of this strategy is to promote and raise awareness and understanding of the Standard within the target audience.

This is to help explain the objectives of the Standard and the activities set within it. It is also to assure commanders and senior users that the Standard is necessary in the application of equality activities to meet our duties; has real and beneficial outcomes; and is a business improvement tool that will not be overly bureaucratic.

To help achieve these objectives the MPS Directorate of Public Affairs (DPA) will help publicise the Standard internally to our target audience by raising awareness of the existence of the Standard, promoting good practice and positive outcomes from the field trials and help reassure those who may have fears about its introduction in the MPS.

To do this the DPA will help develop and produce communications products and use appropriate channels and tools to deliver the key messages to the intended audiences.

Audiences

The primary target audience for this strategy is diversity and equality leads and champions; and more generally all MPS staff, particularly those involved in equalities work.

No external audiences are identified at this stage. NPIA is leading on external relations, leaving individual forces to promote the Standard internally.

Key Messages

NPIA key messages are:

The Equality Standard was requested in the Policing Green Paper and endorsed by the Home Secretary
It is a framework for continuous improvement
It will allow police forces to be proactive in embedding equality activities after many years of scrutiny
It links in with other strategic policing and Government objectives such as the Policing Pledge, Citizen Focus and Hallmarks
The Standard will assist police forces with HMIC workforce inspections in 2010-11.

MPS key messages are:

It will help ensure we treat people fairly, with dignity and respect, making sure everyone, regardless of their background, has access to our services which are delivered to a high standard.
It will help structure and record good work and make it easier to share best practice; as well as highlighting gaps and identifying areas for improvement.
It will help in capturing and providing evidence for inspections and evaluations.
It will help us know whether we are meeting our moral and legal equality duties.

‘Narrative’ or ‘core script’ for the Standard

The Metropolitan Police Service is the largest single employer in the biggest and most diverse city in Europe. To achieve our vision of making London the safest major city in the world we must understand, embrace and utilise the diversity of London and have the confidence and trust of all its communities as well as our own staff.

To help make sure we treat people fairly, with dignity and respect, making sure everyone, regardless of their background, has access to our services which are delivered to the highest standards, we must be able to measure what we do.

The MPS Equality Standard provides us with a means of measuring and monitoring how effectively we have addressed the objectives and activities set out in our equality and diversity action plan (the Equalities Scheme); and how far we have met or progressed beyond meeting our legal duties.

It will help us recognise and record the positive work we do, allowing good practice to be shared; highlight gaps or inequalities and identify areas for improvement.

The Standard's emphasis is on continual performance improvement and service delivery and it provides a means for us to integrate equality activity across the board. It will also form the basis of future HMIC inspection criteria for assessing performance on equality and will also be used by the Metropolitan Police Authorities to help set and agree targets.

The Standard will benefit the organization by enhancing community engagement and improving the way we design future policies and procedures by ensuring we take into account peoples needs and concerns. By doing this we hope to close any gaps in satisfaction levels.

Communications channels

Already completed

The Job - brief article in March edition
MPS Diversity SPACE - brief mention in Spring edition, followed by larger article in Summer edition
Intranet - News article, published April

Proposed activities

Three-fold leaflet aimed at target audience
Narrative to be published on intranet
Feedback from field trials to be shared
Refreshed FAQs
Fuller article, based on field trials in The Job magazine later in the year
Toolkit to aid local, internal communications

Appendix 2: The Standard & the MPS Policing Pledge

Pledge 1 - We will always treat you fairly, with dignity and respect, ensuring you have fair access to our services at a time that is reasonable and suitable to you.