MPS Service Delivery to Deaf and Disabled People

Report: 5
Date: 21 October 2010
By: Director of Diversity and Citizen Focus on behalf of the Commissioner

Summary

This report provides a strategic overview of the work being undertaken by the Metropolitan Police Service to provide a good accessible service to Deaf and disabled people living and working in, visiting and travelling through London. The report will provide information on practices within service delivery ranging from community engagement and partnership work to the handling, reporting and investigating of crimes and identify the challenges that the MPS face. The report will also provide an update in relation to work achieved against the disability objectives contained within the MPS Equalities Scheme 2006-2010.

A. Recommendation

That Members

1. note the contents of this report
2. Note the progress made by the MPS against the service delivery objectives within The Disability section of the MPS Equalities Scheme 2006-2010.

B. Supporting information

Introduction

1. The Metropolitan Police Service aims to provide a good, accessible service to all people living in, working in, visiting and travelling through London. In accordance with the Disability Discrimination Act 2005 we aim to tailor our services to meet the differing requirements of Deaf and disabled people. The following section of the report provides a strategic overview of the service provided to Deaf and disabled people across London, including identifying examples of good practice and how these practices are shared, areas of success and those requiring improvement, and identifying the challenges faced by the MPS. Information in this report is grouped under a number of themes and provides example of good practice that is taking place at both corporate and local levels. The key themes are: 1. Community Engagement; 2. Contacting the Police: Call Handling and Front Counters; 3. Crime Reporting, Recording and Investigation; 4. Protection of Vulnerable Individuals and Groups; 5. Community Reassurance; 6. Partnership Working; 7. Custody; 8. Witness Care; 9. Event and Contingency Planning; 10. Complaints Handling; 11. Training; 12. Languages Programme and Communication; 13. Evaluation and Improvement. Appendix 1 provides an update on the service delivery objectives within the Disability section of the MPS Equalities Scheme.

Theme 1: community engagement

Corporate approach to community engagement

2. In July 2010 the Metropolitan Police Authority and the Metropolitan Police Service agreed a joint Community Engagement Commitment 2010-2013. The aim of the ‘Commitment’ is ‘to provide accessible, multiple opportunities for communities to engage with the MPA and MPS in shaping policing, policy, practice and priorities.’ The MPA and MPS have recognised through the Commitment that traditional methods of involvement and engagement e.g. public meetings do not always attract the attendance of Deaf and Disabled people. The Commitment outlines how the MPS will ensure that engagement activities are built on a detailed understanding of communities and ensure that community profiles are regularly updated and any gaps in representation of Deaf and Disabled people are identified and addressed. An action plan to deliver the Commitment is being developed and will be monitored by the MPS Confidence and Satisfaction Board. All OCUs and BOCUs across the MPS will aim to meet the needs of the communities identified through community profiling activities by using appropriate engagement plans and approaches.

Local community engagement activity - Safer Neighbourhoods

3. Safer Neighbourhoods Teams are in place on all 624 wards across the MPS. Officers and staff working on Safer Neighbourhoods Teams (SNTs) are trained to deliver a very specific Safer Neighbourhoods policing engagement model. This model involves seven stages which collectively identify the priorities of local people within any given neighbourhood and then ensures that these priorities are tackled effectively. Each of the seven stages is an important step in delivering a service that meets the needs of all communities. This model allows the MPS to concentrate on the priorities that reflect what communities want.

1. Research. Undertaken to understand their communities. Each team is required to complete a ward profile that clearly identifies the demographic make up of the ward. This ward profile then provides a baseline to assist in the development of a relevant and clear engagement strategy and is updated every six months. This should capture information relating to disabled groups within the area.
2. Engage. We use the mnemonic GARRDS, Gender/Age/Race/Religion/Disability/Sexual Orientation. We introduce ground rules to control meetings that include diversity. We refer to the diversity windmill to ensure all communities are engaged. Key Individual Networks (KINs) and representation across the community is also discussed.
3. Public Issues. Continuous referral is made to ensure all communities are consulted and engaged.
4. Investigate and Analysis. Ensure that all areas are looked at and all questions around equality and diversity are considered.
5. Public Choices. Ensure that the neighbourhood panels are reflective and representative of the community. Diversity matrix used to show how to measure and ensure that this is being monitored. Officers are reminded of the need to record their effort to get communities to engage and participate. Emphasis is made as to why negative responses are also important facts to record.
6. Plan and action. Ensure any action taken is compliant with Data Protection Act and Human rights Act. I.e. Proportionate, Legal, Accountable and Necessary. All actions recorded including who consulted and what difficulties / barriers encountered in getting the diverse communities within the ward to engage.
7. Review. What we did well/not so well and how can we do better/be more inclusive?

4. Teams use a variety of engagement methods to ensure that new people are identified and their concerns captured, these include: Safer Neighbourhood Panels, Surgeries, and/or 'Street Briefings' where teams meet residents and businesses on street corners to identify local concerns at pre-arranged times and places.

5. Safer Neighbourhood Teams utilise ‘A Guide to Accessible Meetings’ to ensure that their meetings/forums and other related engagement activities are accessible to Deaf and Disabled people.

6. The Central Safer Neighbourhoods Unit has pro-actively encouraged representation of disability groups within ward panels. When surveyed in 2007 219 ward panel members personally stated they were disabled. When resurveyed in 2009, 269 ward panel members identified that they had a disability.

7. Examples of identified good practice include:

• Hounslow BOCU where the SN inspector was an active member within the "Local Disability Network" again allowing an understanding of local community needs but also creating ties within the community to encourage reporting of issues. There have been a number of reports of SN team members attending signing course to assist them engage with the Deaf community, for example, again at Hounslow a Police Community Support Officer took a “signing” course and subsequently produced a set of “sign cards” to assist station officers when dealing with those with hearing issues and thereby improve capture of information and support of victims.
• The work of Bromley's Darwin Safer Neighbourhood Team is featured on a brand new government website site, which has launched to help children aged 11 – 14 engage with citizenship in a fun and unique way. “Directgovkids Papertown” is aimed at children in Key Stage 3 and contains a range of resources including videos, online interviews, interactive comics, games and fact files. All resources are designed to be included within a teacher's Personal, Social and Health Education (PSHE) and Citizenship lessons, and will encourage real engagement with the subject. The site contains four missions: bullying; democracy; disability awareness; and safer streets.
• As a part of an ongoing partnership strategy, Bromley Borough police have teamed up with Mencap, the Learning Disability Partnership Board, Bromley Sparks Advocacy Service and the MPS's Violent Crime Directorate to provide awareness training around the everyday issues that people with learning difficulties face when attempting to report a crime or when they are a victim of crime. The training seminar - attended by officers from Bromley's Safer Neighbourhood Teams, Safer Transport Teams and local residents who are members of the local Safer Neighbourhood Team Ward Panels was designed to ensure that the police provide the best possible service to people with learning difficulties, thus increasing trust in the Service. The seminar also heard from parents of children with learning difficulties.

Corporate Community Engagement - Violent Crime Directorate (VCD) Safely Together project

8. ‘Safely Together’ is a concept by the VCD, whereby disabled people can attend an 'informal' location over one or two days, at a specified location (i.e. a Café or supermarket), and speak to police officers and representatives from local disabled peoples’ organisations. This will also be an opportunity to report hate crime and the trial commences in September 2010. Incorporated within this event will be the launch of ‘Keep Safe’, a national scheme which identifies places of safety for disabled people. The ‘True Vision’ disability hate crime packs will also be available and widely advertised as part of this project.
Officers from the VCD attended the Newham local authority ‘Feeling Safe’ Task Group which is made up of representatives from Newham People First; Powerhouse (an advocacy group for women with learning disabilities); Newham Advocacy Project and the London borough of Newham Safeguarding Team. The role of the task group is to look at what can be done to ensure adults with learning disabilities stay safe in the community.

SCD2 Sapphire community engagement strategy

9. Actions taken as a result of the creation of SCD2’s Community Engagement Strategy has led to the creation of a reference group of individuals including experts in mental health and disabilities. The group has provided SCD2 with feedback and suggestions on improving victim care and enhancing wider trust and confidence in the recording and investigation of sexual crimes.

Pan-London Community Engagement

10. The DCFD has organised MPS attendance at a number of Disability events, including the Independent Living Event at Alexandra Palace in 2006, the No Limits event in 2008 and Capital Age in 2007 and 2008. Local Safer Neighbourhood Officers attended these events with DCFD staff. The MPS theme was Stay Safe and how to report crime. DCFD has also arranged MPS participation at the City Lit Deaf Day for the last 7 years, City Lit Deaf Day is the largest Deaf Community event in the UK, attended each year by many thousands of Deaf people their friends and families. Although the main theme each year has varied, advice on hate crime has always been made available.

Theme 2: Contacting the Police: Call Handling and Front Counters

Call handling

11. All calls to the MPS are received by the Central Communications Command (CCC). To ensure that vulnerable victims and witnesses are identified at the earliest possible stage CCC have initiated a programme of work to raise awareness of caller vulnerability amongst all of its call takers. All call takers have been briefed on how to identify caller vulnerability, and there is now a new National Incident Category List (NICL) code within the call handling system and Computer-Aided Despatch (CAD) for agents to be able to 'flag' vulnerable callers throughout the process of dealing with and responding to their call. In addition a 'Hydra' style programme has been developed in relation to identifying and dealing with 'vulnerability' effectively, and subject to restraints in relation to shift patterns it is expected to be rolled out from mid October. It is anticipated that all operational staff will take part in this training over the coming months. Hydra is a training simulator designed to provide learning scenarios that are as close to the real thing as possible. Realism within a training setting ensures that experiences gained within the learning environment can be readily and easily transferred to the real world.

12. In addition a new set of identification codes relating to caller vulnerability will be introduced alongside the roll-out of the National Standard for Incident Recording (NSIR) later this year. This change will mean that cases involving vulnerable victims can be tracked throughout the various stages of the police response, and any shortcomings or disproportionality can be readily identified and addressed.

13. In terms of accessibility the MPS advertises a text relay number on the MPS web site for deaf and hard of hearing people. This number provides a route in to the MPS via a text relay operator so that any one of our first contact operators can take the call and speak to the caller. Phone calls can also be made to deaf callers using the same method. The caller must use a text phone to make the call.

14. Deaf people can also use text phone to call emergency services in the case of an emergency. This connects to 999 and then onto the MPS. As above the call will go through to a first contact operator who will then deal with the call.

15. Emergency SMS is a national facility that is still in a trial phase. It is due to be rolled out from January 2011. This allows Deaf people who have registered with the system to send SMS messages to 999 on any registered mobile phone. The calls are again routed through text relay then on to the emergency service required. CCC has received some of these calls and feedback has been sent to the RNID. Emergency SMS calls do tend to be long and lack resilience because they rely on SMS technology and sometimes texts take a long time to come through. Deaf people are advised to contact the MPS via a text phone if they can in preference to ESMS.

16. The Deaf and hard of hearing communities have been prioritised within the Equality and Diversity Strategy of the Central Communications Command (CCC). The CCC 'Service Improvement Panel' has been given responsibility for reviewing the accessibility and quality of services provided to this/these communities, as well as subsequently making recommendations to the Equalities Panel. The role of the Service Improvement Panel also includes working with partners to understand the requirements of the Deaf community. In addition CCC engages with the MPS Deaf Group to gain an understanding of issues relating to call handling and the Deaf community and to guide service delivery.

17. The CCC’s Equality and Diversity Board is reviewing the service delivered to callers with mental health difficulties. The project has three strands: - culture, engagement and performance and aims to identify areas where the service could be improved.

1. Within the culture strand of the project CCC is examining the working environment and attitudes towards callers with mental health difficulties. The intention is to develop learning and development materials to assist call handlers and despatchers so that they have a better understanding of the difficulties faced by people with mental health difficulties.
2. The engagement strand involves working with internal and external partners to identify best practice, develop strategic relationships and develop a corporate approach to responding to callers with mental health difficulties across the MPS.
3. The performance strand is looking at data in relation to the volume and type of calls received, reviewing the data to ensure that callers were dealt with appropriately and undertaking customer recovery where it appears that the service delivered could have been better.

Front counters

18. There are currently 138 front counters in the MPS. Property Services Directorate (PSD) carried out a full access audit to all sites with front offices in 2004 in preparation for the commencement of the DDA part 3 legislation. This was done in conjunction with the Accessibility Strategy, a planned front office refurbishment project and the setting up of information under direct enquiries.

19. The following work was completed:

1. A front office programme was engaged upon and 54 front offices were fully refurbished.
2. Small works were completed at other sites such as automatic door facilities and hearing induction loops.
3. A full direct enquires contract was established and all the access data was published including links to and from the MPS’ external website.
4. Each BOCU was charged with keeping this database up to date and given administrator rights to the web site so alterations could be carried out and the detail could be kept up to date.
5. Hearing induction loops were installed at the majority of front counters and are maintained annually by contractors.
6. All new builds are fully DDA compliant e.g. those front counters in Safer Neighbourhood Bases such as the newly opened Kirkland House in Harrow.
7. Direct Enquires is accessible via the intranet www.met.police.uk. Each front counter is listed under each BOCU and has details of 'Disabled access and facilities’. This goes to Direct Enquiries which specifies what facilities are available.

20. This work will be further progressed as part of the TP Development Programme which is examining footfall across the MPS for each TP front counter.

Theme 3: Crime Reporting, Recording and Investigation

Crime reporting policy

21. A corporate approach to crime reporting is documented within the MPS’ Policy and Standard Operating Procedures (SOP) entitled ‘Reporting Crime in the MPS’. These documents detail the various ways in which an initial report of crime can be made and provides examples of special arrangements for particular vulnerable groups including people with physical disabilities. The policy aims to ensure:

1. That the MPS provides a service that will enable members of the public to report crime in confidence
2. That MPS personnel are given a framework for the various ways in which crime can be reported
3. A corporate approach to crime reporting
4. Different ways for reporting crime to be fully utilised by having a single reference document.
5. That response to disability issues will be enhanced by adhering to minimum standards of access and equipment

22. The different methods identified for contacting the police and reporting crime and how these have been developed to meet the needs of Deaf and disabled people are detailed below:

23. Emergency and non-emergency calls: Calls are graded by Central Communications Command (CCC) staff who will decide if it is necessary to deploy a resource immediately or pass the incident to the local Telephone Investigation Bureau (TIB) who will conduct an initial investigation. To ensure that vulnerable victims and witnesses are identified at the earliest possible stage CCC have initiated a program of work to raise awareness of caller vulnerability amongst all of its call takers described at paragraph 17.

24. Reporting Crime at a police station: Staff employed on the front counters of police stations will conduct an initial investigation of crime whenever an allegation is made to them. Crime or incidents reported at a police station must be recorded in accordance with National Crime Recording Standards (NCRS) or National Standard for Incident Recording (NSIR). In addition, the new set of identification codes relating to caller vulnerability which is being introduced alongside the roll-out of the NSIR will mean that cases involving vulnerable victims can be tracked throughout the various stages of the police response, and any shortcomings or disproportionality can be readily identified and addressed.

25. Telephone Investigation Bureaux: Non-urgent reports of crime will be passed from CCC to the local TIB for initial investigation. Members of the public are not able to contact TIB direct. When responding to non-emergency cases involving vulnerable victims and witnesses, which includes disabled people, a police officer aims to be in attendance within 60 minutes.

26. Online Reporting of Crime: Online reporting is available through the MPS website www.met.police.uk. Once the reported crime has been submitted it is transferred to the CCC Contact office and forwarded to the MPS borough covering the location of the crime where the TIB will handle the report. The current Internet site has been designed to provide the optimum colour background and adjustable font to assist with completion by persons who are visually impaired. The form allows victims who are unable to either phone CCC First Contact or to attend a Police station to report a crime to do so remotely via a computer. The Internet form has specific fields relating to the person’s disability that will highlight any specific issues that would need to be considered by the investigator prior to re-contacting the victim.

27. Third Party Reporting: The MPS encourages victims to report every crime. It acknowledges that not everyone is comfortable reporting crime directly to police and therefore boroughs are responsible for making arrangements for third party reporting. Organisations that will pass reports to police can be found by searching on 'third party reporting' on the MPS internet site or by contacting local police. Reports received from these agencies will be treated in the same way as reports received direct from the victim. For example Havens Communications Group which is a media campaign to raise awareness of reporting issues anonymously through the Havens. In addition Haven staff travel off site to conduct forensic examinations for those people with disabilities. There is awareness in the MPS and the Havens that the forensic window can be extended where victims have had their movements restricted due to mobility impairments.

28. Two third party reporting systems used by the MPS are as detailed below:

1. True Vision is a national third party reporting system for hate crime. It has been designed to be accessible to all. It utilises the MPS’ secure gateway to provide this ‘virtual’ system to the UK’s police services. When a report has been submitted it will be automatically submitted to the respective constabulary/borough.
2. The VCD is considering the third party reporting organisation ‘Stop Hate UK’ with a view to employing them to take over the management of Third Party Reporting within the MPS. The boroughs who have already signed up to Stop Hate UK are the London Boroughs of Barking and Dagenham, Croydon, Havering, Wandsworth, Merton, Richmond, and Sutton. The service provided is a 24 hour independent reporting and support helpline covering all strands of Hate Crime: Race, Religion or Belief, Disability, Sexual Orientation and Gender Identity. The Stop Hate Line provides immediate support and information for victims and Third Party callers. The service is based on the needs of the caller, and those needs are established through the conversation between the caller and the trained helpline operator. This enables details for the report to be obtained, and also provides reassurance and information to the victim. The recorded details are then passed to agencies in the commissioning area, depending on the permissions obtained from the victim. Methods of reporting crime include by telephone, with text relay (for people who are Deaf, or have speech or hearing impairments, in an email, chat on the web (chat live to an operator), by post, with an online form.

BOCU example

29. Wandsworth BOCU ran a Hate Crime Awareness week between 12-18.6.2010, together with local MPS and major partners. The purpose of the activity was to promote the reporting of Hate crime, including disability hate crime, and raise trust and confidence in the police to encourage reporting. Over 20 further additional events were held across the borough by SNTs with the same purpose. The Borough has also commissioned the services of Stop Hate UK and this 3rd party reporting service was promoted during the week.

Crime recording system

30. On 5 December 2008 the Crime Reporting Information System (CRIS) was updated to more accurately identify and flag hate incidents/offences. This has led to an improved identification of all categories of hate crime including; race hate, faith hate, Islamaphobic, Anti-Semitic, homophobic, transphobic and disability targeted hate crime. These changes have enabled the MPS to improve the way it identifies communities and people targeted by hate crime suspects and identify victim’s needs. It also enables the MPS to deploy its resources and that of its partners in a more cost effective way.

31. External stakeholders were consulted to ensure the changes were relevant and effective i.e. the MPA, MPS Disability Independent Advisory Group, Community Security Trust, Muslim Safety Forum, LGBT Advisory Group, and the CPS.

32. The changes have enabled the following information to be recorded in relation to disabled victims, informants and witnesses:

1. Person who identifies disability (i.e. victim or other person)
2. Disability description
3. Physical access needs
4. Communication needs
5. Personal care needs
6. Medical needs
7. Preferred methods of communication (e.g. letter, phone, email, visit).

Crime Recording and Investigation Bureau (CRIB)

33. As part of the TP Development programme the MPS is looking to take all the current Telephone Investigation functions currently undertaken at 32 borough sites and centralise them.

34. Centralising the process will improve the level of service to all victims of crime. Customer focus will form a central part of training for members of staff who join the new unit including Deaf and disability awareness training. It will move away from locally driven processes of how and when victims are contacted by their local Telephone Investigation Unit and the subsequent service they are given, so that everyone coming into contact with the CRIB will be dealt with in a way that meets their requirements and expectations.

35. An EIA is being undertaken to ensure the specific requirements of Deaf and disabled victims are captured in the new model. Work is planned with organisations of Deaf and Disabled people to discuss the proposals and how we can improve our service.

Investigating crime

36. A corporate approach to investigating crime is documented within the MPS’ Policy entitled ‘Investigation of Crime’ and Standard Operating Procedures (SOP) entitled ‘Investigation of Crime (Primary) SOP’ and ‘Investigation of Crime (Secondary) SOP’. These documents ensure that minimum standards are applied throughout the investigative process from when an initial allegation is made through to the conclusion of the enquiry. The minimum standards of investigation into all offences have been broken down into the following six key areas: 1. Immediate Action, 2. Scene, 3. Forensics, 4. Victims/Witnesses, 5. Suspects and 6. Other Evidence.

37. Specific reference is made to disabled people within 2 areas of the Primary SOP: Firstly in the investigation of auto crime offences where consideration must be given to the human rights implications of seizing a vehicle and the duty of care that may arise to persons left without alternative transport facilities in particular people who are vulnerable or disabled. The SOP states that application of the powers must be measured and proportionate. Secondly in the investigation of Hate Crime where all such allegations will be investigated in accordance with the MPS Hate Crime Policy which defines Hate Crime as 'Any incident that is perceived by the victim, or any other person, to be racist, homophobic, transphobic or due to a person's religion, belief, gender identity or disability'. This is also made reference to within the Secondary SOP.

38. Specific reference is made to vulnerable people within the Secondary SOP under the minimum standards section of victims/witnesses. All relevant MPS personnel must ensure that the Victims Code of Practice is fully complied with treating vulnerable people with particular consideration at all times.

39. Within the minimum standards of investigation in both SOPs, specific reference is made to the communication needs of Deaf, Deafened, Hard of Hearing or Deafblind people referring all personnel to a guidance document regarding communicating with persons who are deaf, deafened, hard of hearing or deafblind which can be found in Police Notice 16/2007.

40. Portable Interviewing Equipment is available on every cluster in order that victims with disabilities unable to travel to ABE suites can be interviewed at home/in care homes/in hospitals.

Theme 4: Protection of Vulnerable Individuals and Groups

Corporate policy

41. A corporate approach to protecting vulnerable individuals and groups has been developed by the TP Violent Crime Directorate and is documented within the new MPS Policy and Standard Operating Procedures entitled ‘Safeguarding Adults at Risk’, which is due to be launched in autumn 2010. These documents establish clear guidelines and accountability for the investigation of Safeguarding Adults at Risk cases to create a framework for all staff to provide an effective, professional and corporate level of service.

42. The policy seeks to professionalise and improve the quality of service delivery to adults at risk who are or suspected of being the victims of abuse/crime. It will provide a standardised approach across the MPS to the identification and management of Safeguarding Adults at Risk incidents, by issuing clear instructions to staff ensuring that everyone understands their roles and responsibilities.

43. In addition, every borough within the Metropolitan Police Area must have a policy/protocol in place involving local partner agencies, detailing local procedures for progressing allegations of abuse and crimes committed against adults at risk. Those policies/protocols must reflect and be in accordance with, the government publication 'No Secrets' (Department of Health – March 2000). The borough Crime Manager has the responsibility for ensuring that an inter agency working policy is in place and that it is adhered to. These borough-working policies will also be reflective of bespoke borough procedures. This may be subject to change upon completion of Pan London Local authority procedures. The safety and welfare of the vulnerable person is of paramount importance. The purpose of local policy is to create an information sharing and decision making process with statutory partners that are bespoke, effective and efficient in protecting vulnerable adults from abuse.

44. A 'vulnerable adult' is defined, by the Department of Health, as: "A person aged 18 years or over who is or may be at risk of abuse by reason of mental or other disability, age or illness and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation."

45. The multi agency Safeguarding Adults Group was established as a working group to inform and advise the completion of the MPS Safeguarding Adults at Risk Policy and Procedures. It is made up of relevant internal police units that can have a direct impact on improving provision for all those who may face additional challenges when entering the criminal justice system. Partner agencies include the Crown Prosecution Service, Action on Elder Abuse, VOICE UK, Mind and Leonard Cheshire. The group continues to assist the MPS in a number of development projects for disabled people.

46. In addition the following organisations were part of the ‘safeguarding adults at risk’ steering group: MPS Disability Independent Advisory Group (DIAG), Commission for Social Care Inspection (CSCI), Action on Elder Abuse, National Forum for people with Learning Disabilities, Respond, Health Care Commission, Voice UK, Ann Craft Trust, Guy’s and St Thomas NHS Hospital Acute Trust, Age Concern England, Albert Kennedy Trust, Black Gay Men’s Advisory Group, Broken Rainbow, Family & Friends of Lesbians and Gays, Gay Men Fighting Aids, Gender Identity Research and Education Society (GIRES), Gay and Lesbian Association of Doctors and Dentists (GLADD), Jewish Gay and Lesbian Group, London Area Procurement Network (LAPN), Lesbian & Gay Christian Movement, Lesbian & Gay Humanist Association, Local LGBT Forums, London Consortium, London Friend, Metro Centre, NAZ Project, Out on Thursday, Polari, Regard LGB Disabled Group, Schools Out, Stonewall, Terence Higgins Trust and Victim Support.

London Adult Safeguarding Network

47. This is a Pan London group of Local Authority Safeguarding Adult coordinators. They have both an operational and strategic role providing support to investigations for adults where there may be safeguarding concerns. The network is attended by the Violent Crime Directorate and provides a forum to discuss matters for adults with disabilities who are subject to safeguarding investigations. They have received presentations from the MPS VCD on Disability Targeted Hate Crime.

Hate Crime Policy

48. A new Hate Crime policy, awaiting formal publication, has been developed in consultation with the following organisations via the Metropolitan Police Authority (MPA) Hate Crime Forum: London Gypsy and Traveller Unit, UK Disabled Peoples Council, Representative from the MPS Disability Advisory Group, GALOP (London's lesbian, gay, bisexual and transgender community safety charity), The Monitoring Group, London Criminal Justice Board, Community Security Trust, London Councils, Muslim Safety Forum.

49. In addition, a specially convened meeting was held within the MPA with members of the Hate Crime Forum on 20th January 2010, to give feedback on the Standard Operating Procedure (SOP) as part of the consultation process.

The ‘Early Warning System’ (EWS) for disability hate crime

50. The EWS tool has been devised by the MPS VCD in consultation with the Territorial Policing Intelligence Unit (TPIU). It provides an intelligence framework for the identification and management of dangerous offenders; dangerous locations and vulnerable victims (repeat victimisation), in relation to disabled people and disability hate crime. There are 32 London boroughs, each with their own management system and early warning system. These are monitored by both the boroughs and centrally.

51. This system is based on a series of searches that are run by the TPIU on a fortnightly basis. The product produced is raised at the VCD daily management meeting (DMM) and areas of risk elevated to TP SMT for intervention. The borough concerned has the intelligence passed to them for their immediate action and risk management. The borough then reports back to the VCD with details of actions taken to ensure that the disabled victim has been dealt with appropriately.

Theme 5: Community Reassurance

Safer Neighbourhoods

52. Safer Neighbourhood Teams work to a reassurance model of policing in line with the National Reassurance Policing Programme. The implementation of reassurance policing and intelligence gathering through community engagement activities are inextricably linked. Using the seven stage policing engagement model (explained in paragraphs 3-10). SNTs place people at the heart of all policing activity and demonstrate an understanding of the issues that affect them. Through the application of this model SNTs conduct activities to identify local community priorities and gather community intelligence, provide reassurance policing through using the intelligence gathered and identification of priorities to conduct activities to target those areas of concern and thereby achieve the trust and confidence of local communities. Neighbourhood policing activities are summarised by the “We asked, you said, we did” process.

53. Ealing BOCU is currently running a project to increase representation of the disabled community on ward panels. This project involves SNTs actively identifying disabled community groups in their areas and providing “outreach” engagement activities at a local ward level to encourage representation.

54. Bromley BOCU held a community engagement day in May 2010 focusing on service providers and disabled service users. Their objective was to gain the involvement of disabled people in the development of policing activity to tackle hate crime and ASB. Activities to be conducted as a result of intelligence gathered at the event were presented to the BOCU Community Advisory Group in June and an action plan developed.

55. Hillingdon BOCU identified communication as a major issue in police interaction with Autistic people. A “pocket book” sized Makaton communication guide has been produced which covers a few basic signs that are of use in the initial contact situation. The intention is to enable the officer to reassure an autistic person in what can be a very stressful situation. The cards were compiled with a number of local disabled people and those with information and experience of living with autism, including a local school.

Theme 6: Partnership working

56. The MPS is committed both corporately and locally to working in partnership to achieve organisational and local objectives in service delivery. Partnership working is well established across the MPS and in accordance with our statutory obligations OCUs and BOCUs work closely with local authorities, health services, community groups and individuals including diverse individuals and communities through for example Crime and Disorder Reduction Partnerships, Local Strategic Partnerships/Joint Action Groups and Local Criminal Justice Boards, Ward Panels, Community Engagement Groups Independent Advisory Groups and Critical Incident Groups. The MPS recognises that the quality and cost effectiveness of the services that we deliver are improved significantly through working in partnership.

57. OCUs and BOCUs across the MPS work in partnerships with Deaf and disabled individuals and organisations of and for Deaf and disabled people to understand the policing requirements of this diverse group and gain their trust and confidence through meeting those requirements through reassurance policing. The work of the multi agency Safeguarding Adults Group has been described above and illustrates the MPS approach to partnership working at a corporate level.

58. BOCU Example: Wandsworth BOCU set up a Disability Community Safety Steering Group in June 2008 consisting of disabled people, organisations of disabled people, public sector and third sector organisations for example, people with learning difficulties, people with mental health difficulties, young disabled people, Deaf people, members of the MPS Disability IAG, Community Safety, WBC, special needs and children with disability services, WBC, Community Safety Unit, MPS, Leonard Cheshire Disability, Victim Support, Age Concern, Safer Neighbourhoods, MPS.

59. This Group aims to engage with the disabled community in general and especially those who are not fully supported by local organisations (either statutory of voluntary) to:

1. Raise their trust and confidence in the police & partner organisations,
2. Raise awareness of disability hate crime with police, partner organisations and disabled people,
3. Improve access to and encourage/increase reporting of crime, especially disability hate crime,
4. Undertake crime prevention and personal safety activity,
5. Work towards improving the response, and support available through police and partner agencies, and
6. Implement the Social Model of disability

60. In November 2009 Wandsworth BOCU held an Equalities conference to consider how the service to diverse communities may be improved with partners. As a direct result of feedback from diverse communities including Wandsworth’s disabled community the borough ran a Hate Crime awareness week between 12-18 June 2010.

Learning and advice

61. Learning and advice has been gained from Deaf and disabled people at a corporate level until August 2010 through the Disability Independent Advisory Group, a central model of advice provision whose principles went on to be included within Ward Panels, Community Police Engagement Groups, Borough Independent Advisory Groups and Critical Incident Groups. As part of the development of the new MPA/MPS Community Engagement Commitment 2010-2013 the MPS has reviewed a number of its engagement mechanisms. Following consultation with members of the existing group it was agreed that there was a need to revise the role and membership of the current group to allow it to operate at a more strategic level to better meet the current needs of the MPS. Work is currently progressing to recruit members into a new group which should be established during 2010. Through implementation of the MPS Community Engagement Commitment 2010-2013 further engagement activities will take place locally to encourage engagement with Deaf and disabled people.

62. An illustration of how a borough uses learning and advice from Deaf and disabled people comes from Sutton BOCU that works in partnership with local Deaf and disability agencies and forums to identify local crime trends and community needs. The Partnership Chief Inspector represents the borough at the London Borough of Sutton Equalities forum, which includes representatives from groups of Deaf and disabled people. One of the issues raised recently was in relation to bullying on public transport and isolated incidents in Sutton High Street. These matters were taken to the Police fortnightly Problem Solving Meeting where the appropriate agencies including safer transport teams, safer town centre teams, safer neighbourhood teams and adult social services etc developed an action plan of activities to address these issues.

Theme 7: Custody

63. Detailed below are the provisions made for Deaf and disabled people in new custody builds:

1. Hearing aid loops in the charge and receptions areas (the noisy areas of the suite)
2. Liaison with language services to ensure appropriate equipment is in place to assist with remote sign language assistance
3. DDA compliant toilets in front reception and within secure custody environment
4. All cells equipped with cell intercoms for detainee safety
5. DDA compliant cells with lowered sinks and cell intercoms and emergency call points by the bed and toilet. These cells are situated closest to the charge area
6. DDA compliant shower facilities
7. All doorways are wide enough for wheelchairs
8. All processing rooms are large enough for wheelchair manoeuvring
9. All suites are on one level for ease of access.

64. Detailed below are the provisions made for Deaf and disabled people in existing custody suites:

1. It has been recognised that rousing people who are Deaf or hard of hearing can be difficult. As a result additional information has been included on the Custody Directorates DVD to give guidance to officers and staff explaining the process of how to carry out the 4Rs with a person who is Deaf or hard of hearing. This has been done in liaison with the RNID and they have endorsed this training. To further support the session on Deaf detainees, the DVD has been subtitled and signed. This will enable the DVD to be shown to groups within the Deaf community and any MPS staff that may require this additional information.
2. Finding suitable custody suite access for disabled detainees was problematic across the MPS as not all suites cater for this aspect. A list of custody suites with suitable access for disabled prisoners has now been made available.
3.  Work has been undertaken with Property Service to improve compliance with the DDA and certain suites have been upgraded. Custody Managers have been made aware of this aspect by providing them with a list of DDA compliant suites to assist and expedite times for taking detainees to the nearest custody suite able to accommodate the needs of disabled people.

65. Detailed below is the assistance available for Deaf and disabled people in existing custody suites from health care professionals:

1. Custody Nurse Practitioners (CNP) complete a detailed nursing assessment to determine the individual needs of detainees. CNPs liaise with Health Care Professionals within the community, for example GPs, pharmacists, key workers, drug centres, hospitals and the local Mental Health Liaison Team. This enables current and accurate information to be obtained relating to a detainee’s history, their current needs and their latest treatment plans. This detailed information is collated and used when assessing the detainee’s current physical and mental presentation in custody. An appropriate care plan is then devised.
2. For detainees with physical disabilities, CNPs are able to assess the level of disability and the potential effects that being in a cell could have on the detainees. They advise Custody Sergeants on the variety of aids available to assist. This could include physical aids and adaptations to assist with general hygiene and toileting needs.
3. For detainees with acute or chronic mental health conditions, CNPs are able to determine whether they are fit to be detained and interviewed, and to advise the Custody Sergeants whether an appropriate adult is required. Using objective assessment tools CNPs are able to prescribe substitute medication, using Patient Group Directives, for detainees who are substance misusers. This ensures that detainees are safe in custody, and that their physical and mental health needs are addressed.

66. Investigation is covered in the PACE codes of practice with the provision of interpreters for interview. This is normally identified during the booking in of a detainee by the custody officer who will ask them various questions concerning their needs and welfare. Arrangements can then be made for an interpreter or appropriate adult if necessary for their rights and entitlements, interview and charging/case disposal. Where an individual requires an interpreter this is normally mentioned on the case papers so ongoing arrangements can be made at court.

Theme 8: Witness care

67. After the initial investigation and once a suspect has been charged, all cases with victims and witnesses are dealt with the by the local Witness Care Unit (WCU). It is the responsibility of the Witness Care Units to support victims and witnesses through the Criminal Justice process by providing regular and timely updates and ensuring than their individual needs are catered for.

68. All WCUs should establish a preferred means of communication with victims or witnesses and this tends to be by phone or letter. In cases where the victim or witness has a hearing impairment the WCU would undertake efforts to ascertain if the victim/witness has access to a 'talk type' or similar messaging service, alternatively they may look to establish contact with a relative or friend who can assist with communication, email communication is also used.

69. Should a victim or witness be required to attend court, again the WCU will ascertain what communication methods the victim would require at the hearing. The supporting information that explains more about what to expect at court is available as a DVD and does have subtitles as required. Come the day of the court hearing, should the victim or witness know sign language then the WCU would ensure that two registered signers are booked to attend, and that regular breaks are adhered to during the hearing to allow the victim and the signer to take appropriate rests.

70. The WCU approach is very dependent on the individual needs, for those who use hearing devices or lip reading the WCU would be informing the Crown Prosecution Service of this fact to ensure that appropriate steps are taken, for example moving the case to a court that has a hearing loop or making sure that all parties at the hearing face the victim so they are able to interpret their words.

Theme 9: Event and contingency planning

Spontaneous incidents- not site specific

71. By their very nature, spontaneous incidents can strike at any time and in any place and involve casualties with a range of injuries from minor to very serious or fatal. The cross section of public encountered is random. People are disoriented, probably in need of urgent medical treatment, and the responsibility for their rescue and medical treatment falls to the LFB and LAS. Police have a central role in saving life by the co-ordination of the blue light services and the investigation of the incident. The initial police response will also encounter ‘walking wounded’ who will need to be relocated at various rest centres for progressive interview, documentation and care. Local Authority expertise assists at that stage with any necessary humanitarian and psycho-social support.

72. To this end the capabilities of police to communicate will rely on the number and speed of officers on scene, any particular skills they have with communicating with vulnerable people, the number of victims and their medical conditions. The main priority is relocation (evacuation) to a safe area, which although onerous is multifaceted and flexible as to the needs of the individuals concerned (e.g. individual escorting of wounded- disabled survivors as best as possible).

73. CO3 have acknowledged the need to ensure Deaf and disabled people feel able to participate in training when planning large scale live exercises to test the multi agency response. In 2008, police organised a large scale incident at the O2 arena involving the transport of Deaf and disabled volunteers, and in addition on June 29th of this year the MPS was the joint planning authority for Exercise Milo. This was held at the Excel Centre and simulated a large collision between a lorry carrying chemicals and a coach carrying disabled paralympic athletes, played convincingly by volunteers from the ‘Amputees in Action’ agency. They were rescued from the scene by LFB and LAS, and also experienced the decontamination process necessary to treat exposure to hazardous materials. Much practical knowledge was gained in subjecting responders to the needs of these volunteers and incorporated into guidance material.

Spontaneous incidents - site specific

4. Many plans held by Boroughs relate to specific sites, which can benefit from a pre-determined response plan. A good example of this is planning for chemical works etc, where there are legal requirements to warn and inform the local community. Documents are prepared by site operators, and a multi agency safety liaison group uses the data held by Utilities companies (who hold many details of vulnerable people e.g. patients on dialysis etc) and local authorities on the location of vulnerable persons, compliant with data protection legislation. Obviously information at this level changes frequently, and the guidance given by CO3 relates to the need to comply with DDA in order to be aware of the vulnerable community, to anticipate its needs and engage volunteer agencies at a local level in order to reflect regional policy.

Borough based flood plans

75. These plans are now held by local authorities, and also recognise the location and needs of known vulnerable communities. One very useful example of good practice has emerged (and been shared) where local police SNTs have demonstrated that they are aware of individual vulnerable residents that would be in particular need of assistance when an evacuation is contemplated. This capability has been captured and recorded on flood plans so that SNTs, where highlighted, are involved in the warning and informing process.

Theme 10: Complaint handling

76. Detailed below is the work of the Directorate of Professional Standards in the area of disability and demonstrates the measures that have been put in place to ensure that all communities, including Deaf and disabled people are afforded an equitable service.

1. A dedicated Diversity and Equalities coordinator is available to give specific advice and guidance on e.g. assistive technologies
2. Their Equalities Forum monitors performance information supplied from the Performance and Analysis Unit and recommends where necessary, remedial action in areas of diversity.
3. The Customer Service Team (CST) is the first point of contact for complaints coming in via the telephone. They have received training on dealing with callers with mental health difficulties. They will ask callers diversity monitoring questions including whether the caller is disabled and what if any particular requirements a caller might have e.g. requiring written communication in a larger font. They tailor their service to an individual’s needs to ensure a good service is provided to all.
4. Training and familiarisation sessions have taken place which enables the CST to identify and deal with people with mental health difficulties when call handling people with complaints.
5. Deaf and Disability Awareness Training has been provided to all CST and supervisors.
6. The CST have installed assistive technologies e.g. Mini com.
7. First line managers have attended a one day workshop on ‘Dealing with Diversity’ to familiarise themselves with some of the issues that affect diverse individuals.
8. A DCFD Advisor works closely with the DPS and has a direct input into the work of the Equalities Forum.
9. All complaints that come through the system are monitored to ensure a consistent service is being provided.
10. CST Borough support units provide advice and close liaison to ensure consistency across the MPS

Theme 11: Training

Corporate training

77. Detailed below is information on how police officers and police staff are trained and supported to deliver specific services to Deaf and disabled people and explains how a consistent level of service is maintained across London

78. The Police Race and Diversity Learning and Development Programme (PRDLDP) is a major programme aimed at improving police performance in race and diversity (R&D) across the 6 strands, including disability, with an emphasis on making the R&D learning relevant to the role performed, leading to improved performance at an individual, team, force and service-wide level.

79. One of the key aims of the programme is everyone in the police service being assessed as competent against National Occupational Standards (NOS) AA1 “Promote equality and value diversity”, and that standard being maintained thereafter through Personal Development Reviews (PDRs).

80. New entrants to the MPS as police constable recruits or PCSO (and SRO or DDO), MSC, custody nurse practitioners and volunteers receive learning and development input across all six strands, covering the learning outcomes as detailed in the PDF document ‘PRDLDP Learning Descriptors’. The three week SPCSO training course has an element of customer service training which includes responding to the requirements of disabled people.

81. As part of the MPS response to one of the requirements of the national programme (to ensure that all members of the service are assessed as competent against NOS AA1 by the end of PDR year 2010 – 2011) an e-learning package ‘MPS Equality and Diversity’ is available on the NCALT managed learning environment. To date over 52,000 members of the MPS have completed this learning.

82. Personal and organisational responsibilities around the Disability Discrimination Act are also covered in other programmes such as those owned and delivered by the MPS Leadership Academy and NPIA.

83. HR Organisational Development is responsible for embedding appropriate race and diversity learning and development into all new programmes as they are developed.

Training for primary responders

84. The VCD has produced a training package for first responders through to Borough Commanders to highlight disability matters. This was as a direct result of engagement with members of the MPA Hate Crime Forum. In addition VCD has had a significant input in improving disability awareness at all levels of the MPS and are assisting in the future input on various courses, up to and including the new Borough Commanders course.

Training for crime managers and investigators

85. The VCD’s Community Safety Unit Service Delivery Team and the Crown Prosecution Service London recently hosted two events opened by the Director of Public Prosecutions, Kier Starmer. The events were developed and delivered in partnership with Leonard Cheshire Disability, Mind, and Action on Elder Abuse, Guy’s and St Thomas’ Hospital and the Royal Borough of Kensington and Chelsea local authority.

86. The events were for Crime Managers and Detective Inspectors within the MPS Community Safety Units or Criminal Investigation Units, Community Borough Crown Prosecutors and CPS lawyers. The objective of the day was to raise awareness of situational vulnerabilities that impact on victims and witnesses entering the criminal justice system. In addition the events promoted greater understanding between partner agencies regarding maximising evidential opportunities and sharing good practice in safeguarding cases. Representatives from partner agencies and specialised departments attended to provide expert advice and promote challenging debate.

87. The VCD also delivers a number of other seminars, focusing on Enhanced Victim Care for those who may require additional support when entering the criminal justice system. These events are open to MPS staff and partner agencies.

88. VCD is currently organising three training events with specialist interviews from this course to update existing investigators around emerging issues, judicial concerns and best practice in obtaining the best evidence from adults requiring additional support in the criminal justice system. These events are scheduled for October 2010.

89. Arising from the London Adult Safeguarding Network, the MPS has recently completed a two-day joint agency training package, which has been developed and delivered in partnership with local police in Enfield, Health and Adult Social care. It highlights the significant impact that crime may have on disabled people and seeks to increase confidence of disabled people. Development of this training is now in hand to include service user involvement and dissemination of the training across London as a good practice model. The training also aims to learn from recent serious case reviews to identify opportunities for early intervention, effective partnership working and appropriate information sharing.

Values into Action borough hate crime days

90. The VCD arranged for a member of a high profile disabled peoples organisation to visit Havering borough together with disabled service users. For first responders and CSU staff it was a valuable opportunity for them to improve their knowledge and understanding of the issues faced by disabled people when they report crime. Service users were able to gain an understanding of the Police perspective on investigating hate crime. The VCD are currently working on widening this scheme to other boroughs.

Specialist training

91. The MPS runs a two week Specialist Adult Investigators Course. This is a two-week course which provides specialist training to staff on how to obtain the best evidence from adults with a range of disabilities. It includes contributions from a variety of partner agencies including VOICE UK and provides interviewers with an opportunity to spend time and gain interview skills with disabled people who have a range of communication methods.

DCFD

92. The DCFD has run a number of basic sign language courses and deaf awareness courses in partnership with the RNID to greatly increase the number of police officers and staff who understand the Deaf Community.

Specialist Crime Directorate

93. The Sapphire Investigators Training Course includes elements outlining victim vulnerabilities and the affects on attrition. SCD2 have planned a bespoke Investigative Interviewing Seminar which will re-emphasise training on Special Measures for vulnerable and intimidated witnesses. They are also developing a training day to provide a practical introduction to forensic care for nurses. This will include an understanding of the principles of Achieving Best Evidence. SCD2 are also developing a link/referral process with the Independent Sexual Violence Advisor (ISVA) at Respond in order to challenge vulnerability and sexual abuse in the lives of people with learning disabilities.

Deaflink

94. Deaflink is a policing scheme that is designed to offer an accessible non-emergency service to Deaf, deafened, hard of hearing and deafblind people. The scheme is based on the Police Link Officers for Deaf people (PLOD) model of policing developed by Hampshire Constabulary.

95. Deaflink aims to introduce a non-emergency accessible policing service for the Deaf Community and offer support to deafened and hard of hearing Londoners through training officers in basic BSL, communication tactics and deaf awareness. Boroughs with trained officers offer accessible contact facilities e.g. SMS texting, Textphone, email to the Deaf community, providing Deaf people with the ability to contact their local police and the confidence of meeting an officer who understands them. The scheme has been developed in Westminster, Sutton, Lewisham and Barnet with Camden introducing the scheme later in 2010.

BOCU example

96. Lewisham Borough operates a Deaflink scheme and has a dedicated mailbox and mobile phone number for enquiries and requests. They have 8 Officers that are qualified to Level 1 BSL and another 7 who are soon to qualify, with 5 staff studying for level 2 BSL. In addition approximately 70 Officers and Police staff have completed the deaf awareness training.

Theme 12: Languages Programme and Communication Strategy

MPS language programme

97. The Language programme aims to improve access to linguistic support for MPS officers and staff enabling them to improve the quality of service on behalf of the citizens of London. (A paper was presented to the Equality and Diversity Sub-committee in April 2010.) Historically the Deaf and disabled community has been disadvantaged with respect to ease of contact with the MPS. This in turn has led to a piecemeal approach to the provision of BSL and other appropriate language formats e.g. lip speaking, MAKATON across the service. The inception of MPS Language Programme provided the opportunity for a long needed review of BSL service provision. Using a variety of sources to determine the efficiency and efficacy of previous provision and through extensive consultation with both the Deaf community and BSL service providers each element of the language programme has been considered for its impact either positive or negative on the Deaf and disabled community and appropriate action has been taken to look at ways of mitigating these impacts where necessary. The key elements of the programme are outlined in brief below. Currently BSL is within the top four difficult to service languages requested within the MPS. There also appears to be a growing need to provide sign language other than British Sign Language within certain geographical areas which requires careful consideration and action within the key elements of the programme

Interpreters Deployment Team

98. This team provides access to MPS interpreting services, the efficient and effective use of an MPS pool of interpreters and 24/7 language services to other similar Statutory bodies that generally have an investigative function such as the UK immigration Service, Serious Organised Crime Agency (SOCA), The Child Exploitation and Online Protection Centre (CEOP) etc.

99. Within this element it was necessary to determine the extent of current usage of BSL across the MPS and also current BSL interpreter provision. This was to ensure that there was no risk to the MPS of failing to provide a reasonable service to the Deaf and disabled community and to minimise the potential for any claims under the DDA and Human Rights Act.

100. Provision of BSL interpreting services has improved through the use of initial contact software which allows all staff at the Service Centre to match and allocate appropriate resources to demands for linguistic support and also to assess the risks associated with each request for the customer, staff and MPS.

Staff programme

201. This is a project to develop and maintain an own staff database that is wholly representative and reflective of the MPS internal communities and the wider communities of London. The Own staff database does not currently have details of any volunteers from the Deaf Community. There are a number of hearing individuals that have highlighted their knowledge and skills in BSL and Deaf culture. The Deaf Community do not consider that the loss of/or having been born Deaf to be a “Disability”. The Languages Programme has recognised the skills gap that exists and has formed a bespoke BSL users group with Deaf staff members. This group examines all aspects of the LP business to determine the positive and potentially negative ramifications of decision making on their community. Deaf members of staff were fully briefed on the LP, and canvassed through the Deaf Staff Association for interest on becoming own staff volunteers.

102. The Languages Programme presented to the National Safeguarding Deaf Children’s Group in 2010. The presentation included a full briefing on the use of appropriately qualified BSL staff to assist with Deaf issues, and the intention to recruit Deaf staff to the database. An own staff database analysis is being conducted If it is discovered that there are volunteers who are disabled and are being denied the opportunity of utilising their skills, then consideration will be given to allow for any necessary reasonable adjustments with regards to disabilities in line with DDA and MPS policy.

Language training programme

103. Linked to the above and to ensure consistency and efficiency is the roll out of a training programme designed to enhance and develop language skills within the MPS. The courses and tutorials have been created for MPS staff and officers to meet the specific requirements of each MPS OCU and Business Groups' linguistic and cultural profile and is inclusive of BSL.

104. The Language Training Programme will include a new MPS Language Training Framework with 3 levels of training and qualification, in line with national and international language standards.

105. The existing community profiles will be further updated by effective use of information supplied by OCUs as part of their returns for the Equality Standard for the Police Service (ESPS) which will include information on Deaf and disabled communities.

Video conferencing

106. In order to speed up access to linguistic support and reduce costs, a new video conferencing platform will be created. Working in harmony with the Virtual Courts scheme, video equipment will be installed in each custody suite for use with detainees and in selected interview rooms for dealing with witnesses and victims. This network will be supported by the creation of 8 "interpreter hubs" around London, in order to take account of demand and interpreter availability.

107. Currently there are no guidelines that preclude the use of the video conferencing platform to deliver linguistic support to an individual purely due to physical disability. Victims and Witnesses with physical disabilities will be directed to attend one of the MPS sites that comply with DDA regulations in terms of access to services. The Language Programme intends to take a pragmatic approach to ensure that all Victims and Witnesses are afforded equal access to linguistic support. The sites that afford enhanced levels of wheel chair and/or pedestrian access will be clearly publicised to Communities.

108. There are guidelines that will automatically preclude the use of the Video Conferencing Platform to all individuals that self declare, or are deemed to be people with mental ill health. The Language Programme Standard Operating Procedures will allow for the declaration of these risk factors at an early stage in the investigation or detention of an individual(s). This type of declaration or assessment would ordinarily necessitate the use of a face to face interpreting resource The older Deaf Community may have reservations with the use of Video Conferencing in terms of the security of their personal data. Members of the older Deaf community will be consulted and have access to the video conferencing network to dispel and promote its use, particularly amongst their peers who have historically been unable to, or unwilling to access the Criminal Justice System.

109. Those interpreters that declare they have a physical disability will be directed to attend one of the eight separate hub sites that afford greater access to them. This will be reliant on early self declaration from the interpreter(s) involved.

MPS Communication Strategy

110. The DPA as a matter of course instruct all corporately produced publicity material to be compliant with Disability Discrimination Act requirements, ensuring text size and colour combinations are appropriate. Versions in alternative formats are also produced. When the MPS’ first ever youth magazine: The Beat was produced, online and plain text versions were made available. The MPS recently launched youth website: Safe, was tested for compliance and against all web accessibility standards.

111. In all publicity campaigns, the MPS attempts to make the messages as accessible as possible, using all available channels to reach diverse audiences in London, including Deaf and disabled people. In this year's anti-weapons publicity campaign the TV trailer and online film includes a voice over, and is supported by a leaflet on 'joint enterprise' which complies with DDA. Similarly publicity material relating to topics such as violent extremism have been developed to ensure they are jargon-free, clear and engaging.

112. To improve skills and knowledge in communicating with diverse groups, at this year’s annual communications seminar communications officers from across the MPS were presented with advice on making information and messages more accessible by an industry leading expert.

Theme 13: Evaluation and improvement

Evaluation of service provision

113. The MPS evaluates corporate and local service delivery to diverse communities including services to Deaf and disabled people using a variety of methods:

1. Corporately the MPS monitors service delivery, victim satisfaction and public confidence and analyses any difference in results between Deaf and disabled people and others. Results across a range of service delivery issues are presented to the MPS Diversity Executive Board, chaired by the Deputy Commissioner. This allows any disproportionality across any area of our service delivery to be identified and addressed.
2. Locally Boroughs review performance at fortnightly performance meetings. Some Boroughs in addition to performance meetings have confidence and customer service board meetings to review local performance against indicators for confidence and satisfaction, identify research required, tactics to support objectives, review action plans, undertake case reviews and review training needs and communication plans.
3. The Diversity and Citizen Focus Directorate will identify gaps in local service provision through the quality assurance process of local Equality Standard for the Police Service returns. Gaps in service provision to the Deaf and Disabled community will be identified and local action plans will be developed as a result of the quality assurance process.
4. Equality Impact Assessments and Community Impact Assessments will continue to be completed both corporately and locally and used to evaluate service delivery to all diverse individuals and communities including services to Deaf and disabled people.
5. Locally project activities are regularly monitored and evaluated against initial project objectives to ensure the achievement of objectives.
6. Locally individual cases are reviewed to identify failures in services and actions to be taken e.g. boroughs reviewed the Pilkington case and action plans were put in place to prevent similar cases e.g. Review of ASB joint protocols with local authorities.
7. Locally Ward panels evaluate local service through use of the engagement model “we asked, you said, we did process”.
8. The MPS Performance Information Bureau produces monthly data for BOCU SMT and SNT teams in relation to repeat/vulnerable victims of Anti Social Behaviour.

Improvements

114. This report has described some of the ways in which the MPS tailors services to meet the needs of Deaf and disabled people, how these services have developed over the last few years and what further work is planned. The MPS recognises that there is still more to do. Some of the challenges faced by the MPS and how it is working to address these are described below.

1. A key improvement area is the creation of new services and the development and maintenance of existing services to Deaf and disabled people during a time of financial pressure to review service provision across the MPS. Working in partnership to share financial responsibility with statutory, public and voluntary agencies and exploring funding opportunities available from for example charitable Trusts and Foundations, will be a key medium for developing new services and continuing to provide existing services to Deaf and disabled people across the MPS.
2. The sharing of good practice across such a large organisation can sometimes encounter difficulties which are being addressed through the following mechanisms: use of the intranet to share good practice examples from across the MPS, the DCFD’s new Diversity Practitioner’s Network (DPN), which is a networking group for MPS diversity practitioners to come together to learn and share good practice around the four themes of the Diversity and Equality Strategy; the Equality Standard for the Police Service quality assurance process which highlights good practice which is then shared across the MPS through the roles of the Diversity and Citizen Focus Advisors and the DCFD’s Delivery Teams
3. A consistent approach to the delivery of services to Deaf and disabled people is being addressed through the MPA/MPS’ joint Community Engagement Commitment 2010-2013. An appropriate focus on engagement with Deaf and disabled people within community engagement action plans will be monitored through the ESPS process, including representation of Deaf and disabled people on IAGs, CPEGs, Ward Panels and KINs and more actively working with organisations predominantly led by disabled people.
4. The completion of Equality Impact Assessments across the MPS enables the identification of both positive and negative impacts on the provision of services to Deaf and disabled people. Anecdotal evidence suggests that the completion and quality of these assessments has improved significantly due to governance arrangements being put in place for the quality assurance of corporate EIAs and since the introduction of the role of the DCFA. In order to ensure that local EIAs are being completed DCFD is carrying out a scoping project to identify the range and extent of EIAs that are being carried out locally in BOCUs, the reason why they are generated and the impact the EIA is having on service delivery. In addition to this a new EIA form and SOP will be published in October 2010.
5. Co-ordination of services provided to Deaf and disabled people has remained the responsibility of individual Operational Command Units (OCU). The Diversity and Citizen Focus Directorate will now take ownership of the governance of all work relating to services provided to Deaf and disabled people across the MPS and maintain an oversight of this work. A cross-OCU Steering Group is in the process of being formed and will include representation from Territorial Policing’s Safer Neighbourhood Teams and Violent Crime Directorate, Human Resources, Training, Staff Associations, the Directorate of Public Affairs and the Directorate of Professional Standards.

C. Other organisational & community implications

Equality and Diversity Impact

1. This report details both the corporate and local provision of services to Deaf and Disabled people in London by the MPS. The equality and diversity implications of the work are addressed throughout the report.

Consideration of MET Forward

2. This report sets out the ways in which the MPS is improving the services it provides to Deaf and disabled Londoners. Meeting the needs of Deaf and disabled Londoners will contribute to the delivery of Met Forward and its outcomes of increasing confidence in policing, fighting crime and reducing criminality.

Financial Implications

3. The costs associated with the activities set out within this report are all covered by existing budgets.

Legal Implications

4. The current statutory duty is contained in Section 49A of the Disability Discrimination Act 2005 (DDA 2005) which provides that every public authority, when carrying out its functions, shall have due regard to the need to:

1. Eliminate discrimination that is unlawful under the DDA 2005.
2. vii. Eliminate harassment of disabled persons, which is related to their disability.
3. Promote equality of opportunity between disabled and other persons.
4. Take steps to take account of disabled persons' disabilities, even where that involves treating disabled persons more favourably than other persons.
5. Promote positive attitudes towards disabled persons.
6. Encourage participation by disabled persons in public life.

5. On 8 April 2010, the Equality Act 2010 received Royal Assent. The Act sets out a general duty requiring those subject to the duty to have regard to the need to:

1. eliminate unlawful discrimination, harassment and victimisation;
2. advance equality of opportunity between different groups; and
3. foster good relations between different groups.

6. Some provisions of the Equality Act come into force on 1 October 2010 but the government proposes to bring the general and specific equality duties into force through regulations in April 2011. Public bodies will have an extra year after the regulations have come into force before having to publish their equality objectives and whether they are being met.

7. The Equality and Human Rights Commission will produce guidance for public bodies 12 weeks before the regulations bringing the equality duties come into force. The guidance will explain the general and specific duties and what the different types and sizes of public bodies will need to do. The Commission will also be able to use its statutory powers to enforce the general duty.

8. The MPS Equalities Scheme 2006-2010 must be re-assessed in light of these forthcoming changes.

Environmental Implications

9. There are no direct environmental implications.

D. Background papers

None

E. Contact details

Report author(s): Shelley Perera, DCFD, MPS

For information contact:

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

Appendix 1

Progress on MPS Equality Scheme objectives relating to disability

Objective D1 Implement the Social Model of Disability

1. The MPS has adopted and works to the Social Model of Disability to remove the ‘disabling barriers that arise from the attitudinal, economic, and/or environmental factors that prevent disabled people from experiencing equality of opportunity.’ In the MPS Equality Scheme 2006-2010 the MPS agreed to implement the Social Model of Disability and eradicate any barriers that exist in relation to the service that Deaf and disabled people receive or the environment in which they work.

2. Through the completion of EIAs the MPS implements the social model of disability by ensuring that Deaf and disabled people are involved in the development of new policies, strategies, business plans, pre planned operational activities etc and that their requirements are identified and met throughout each stage of development and implementation. EIAs are a method of ensuring that attitudinal, economic and or environmental barriers are removed or reduced in the delivery of services to Deaf and disabled people.

Objective D3 Develop, maintain and co-ordinate effective relationships with HMIC, Home Office, ACPO, GLA and groups representing disabled people, to enable the MPS to be at the forefront in developing creative solutions to disability issues.

Objective D18 Develop, maintain and co-ordinate effective relationships with disabled people in the widest sense, i.e. visible, non-visible, hidden and learning disabilities and organisations to assist the MPS in identifying and addressing disability issues.

3. Activities relating to both objective D3 and D18 are described within the partnership and community engagement and reassurance sections of this report.

Objective D4 Deliver on the recommendations contained in the MPA Report: Disabled People and the Police – a New Relationship.

4. A response to the activities that have taken place to meet this objective can be found in appendix 2.

Objective D5 Take full account of the advice and guidance provided by bodies such as the ACPO Disability and Mental Health Portfolio, MPS Disability Independent Advisory Group (DIAG), MPS Disabled Staff Association (DSA), the National Disabled Police Association (NDPA) and other disabled groups.

5. It is believed that the Home Office has withdrawn funding from the NDPA. The MPS has continued to support its own internal Disability Staff Association (DSA).

6. The MPS Disability Independent Advisory Group (DIAG) was established in 2004. The MPS is currently in the process of recruiting a new strategic group. Similar activities are being progressed to recruit a British Sign Language advisory group. Examples of how the MPS has worked with and taken advice from a range of groups are included throughout the report.

Objective D6 Assistant Commissioner Operational Services assumes the responsibility for taking forward the disability agenda for the MPS.

7. This objective is complete.

Objective D7 Improve information on, and access to, existing and future MPS buildings, for disabled people.

8. Activities relating to this objective are described within the front counter and custody sections of this report.

Objective D8 To ensure any MPS Communication Strategies take account of the needs of disabled people.

9. Activities relating to this objective are described within the MPS language programme and communications sections of the report.

Objective D9 Deliver the policing elements of the Greater London Authority’s Disability Equality Scheme and Action Plan, including our response to Hate Crime.

10. The Greater London Authority (GLA) has published its draft new Disability Equality Scheme, which sets out what the GLA has done, and plans to do, in relation to disability equality. The consultation closes on 15 October 2010. Once the consultation is complete and the scheme is published the MPS will review and update this objective.

Objective D10 To implement an independent ‘Mystery Shopper’ approach to measure the quality of the service provided to disabled people. To provide a source of performance management information on the success of the Equalities Scheme, including the delivery of the Action Plan and evaluation information on the effectiveness of equalities based learning and development.

11. This objective has been withdrawn. Please see the update on the MPS Equalities Scheme presented to the Equality and Diversity Sub-committee in October 2009.

Objective D11 To provide to Deaf and hard of hearing people an enhanced, but non-emergency, accessible local police service, that will assist to remove the communication and attitudinal barrier they routinely face when trying to contact their local police

12. Activities relating to this objective are described within the call handling, MPS language programme and Deaflink sections of the report.

Objective D17 To give disabled people the opportunity to be involved in the MPS Emergency Planning process to ensure that the needs of disabled people are met.

13. Activities relating to this objective are described within the event and contingency planning sections of this report.

Appendix 2

MPS Equality Scheme Objective D4

The MPA report ‘Disabled People and the Police – a new relationship?’ also known as the Greater London Action on Disability (GLAD) report, was published following wide consultation with disabled people and organisations representing disabled Londoners.  The report included a 12-point ‘Disability Agenda’ and 48 recommendations.

Since the publication of this report, the MPS Equalities Scheme (ES) has been published, and builds upon many of the recommendations contained within the GLAD report.  Objective D4 of the ES requires any outstanding recommendations to be identified and progressed in line with the ES action plan.

This report takes account of the aforementioned ‘Disability Agenda’ and sets out which GLAD recommendations are:

• Embedded within the existing ES Action Plan.  This does not necessarily mean that the recommendation is complete, but that activity is being progressed within the ES and corresponding governance arrangements.
• Embedded within other existing policy or practice, with the same caveat as above.
• Outstanding.  A proposal is put forward in each ‘outstanding’ case.

More detail on implementing each recommendation was provided within the EODB report of 4 October 2007.

In providing answers to the below recommendations and in order to now close this report the EODB report of 4 October 2007 has been updated and where applicable links have been made to the indicators within the Equality Standard for the Police Service (ESPS).

Recommendation 1

The Commissioner of the MPS publicly adopt the Social model of Disability as the policy foundation by which the MPS undertake a plan of action to address the policing concerns and needs of Disabled people.

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 2

The MPS take steps to ensure that there is no hierarchy of equalities issues.  Disability as an equality issue must have equal status and importance.

This recommendation is embedded within the Equality Scheme as stated in the report to the EODB 4 October 2007 and is complete.

Recommendation 3

Review and broaden the current equalities impact assessment process to ensure that disability issues are fully addressed.

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 4

Officers and middle managers receive training to engage with and effectively interface with the disability community.

Activities relating to this objective are described within the training section of the main report.

Recommendation 5

Play a mediating role on behalf of disabled people between the various agencies involved in the Criminal Justice System.

This recommendation has been embedded within Operation Emerald’s standing operating procedures and practices and the Codes of Practice for Victims of Crime.

Under the Codes victims of crime are expected to receive a minimal standard of service from criminal justice agencies. There are 47 obligations for the police and these obligations must be complied with within either 1 or 5 days depending on the victim’s vulnerability. The MPS must record its contact correctly on CRIS and breaches of the code can be reviewed by a Parliamentary Ombudsmen.

The codes of practice for victims are produced by and available from the Office for Criminal Justice Reform.

Recommendation 6

The adopted principle of the Social model inform all policy and practices and that all existing policies and organisational set up be reviewed within the MPS to ensure they are in conformity with this principle.

This recommendation has been embedded within ES Objective C3 “to ensure the Equality Impact Assessment (EIA) process is managed in line with an identified prioritisation plan.”

Governance arrangements are in place for the quality assurance of corporate EIAs.  In order to ensure that local EIAs are being completed DCFD is carrying out a scoping project to identify the range and extent of EIAs that are being carried out locally in BOCUs, the reason why they are generated and the impact the EIA is having on service delivery.  In addition to this a new EIA form and SOP will be published in October 2010.

This recommendation is complete.

Recommendation 7

Review old policies and ensure new policies are DDA compliant, which responsible staff must perform in terms of action and implementation of policies.

This recommendation has been embedded within ES Objective C3 “to ensure the Equality Impact Assessment (EIA) process is managed in line with an identified prioritisation plan”. (See Recommendation 6)

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 8

Learn from the implementation of the Race Relations Amendment Act and build on this to implement the next stage of the DDA.

This recommendation has been met by the Equality Scheme 2006 -2010.  The ES has been built around the progress made through the MPS Race Equality Scheme, and demonstrates how the MPS complies with the various equality duties laid out by legislation including the Disability Discrimination Act 2005.

This recommendation is complete.

Recommendation 9

That the MPS develop and disseminate clear strategic policy guidance from the centre to ensure there is consistency across boroughs.

This recommendation has been embedded within the Equality Scheme and the Equality Standard for the Police Service (ESPS).

This recommendation is complete.

Recommendation 10

That appropriate training be developed on the social model for policy makers and be integrated where appropriate in existing training and development programmes.

This recommendation has been embedded within ES Objective C3 “to ensure the Equality Impact Assessment (EIA) process is managed in line with an identified prioritisation plan” and Objective C10 “delivery of the National Police Race and Diversity Learning and Development Programme (PRDLDP)”.

Recommendation 11

Disability Equality Training (DET) for all staff be delivered by disabled expert trainers.

The PRDLDP delivers diversity training to all staff.  This recommendation is complete.

Recommendation 12

Senior Managers to be first to receive Disability Equality Training.

The PRDLDP delivers diversity training to all staff.  This recommendation is complete.

Recommendation 13

Disability Equality Training be custom designed to fit the roles and responsibility of the learner.

Activities relating to this objective are described within the training section of the main report.  This recommendation is complete.

Recommendation 14

The feasibility of delivering Disability Equality Training for all Met Police Federation Leads.

The PRDLDP delivers diversity training to all staff.  This recommendation is complete.

Recommendation 15

Ensure that adequate training time is devoted for every officer for every year.

This recommendation has not been agreed by the Management board.

Recommendation 16

MPS Procurement Services review the organisation’s supplier pool and proactive steps to market the MPS purchasing needs to disabled people’s organisations and businesses.

Answered under Recommendation 17.

Recommendation 17

Procurement services review its purchasing procedures to ensure that they are fair and not disabling and take proactive steps to encourage and support the participation of disabled people’s organisations in meeting the purchasing needs of the MPS.

The MPA adopted the Responsible Procurement (RP) policy in 2006, providing a high level framework for the implementation of more sustainable procurement practices.  In January 2009, the elected members of the MPA agreed a Four Year RP Strategy.  Within the MPS, Responsible Procurement is championed by the Director of Resources who is part of the Commissioner’s senior management team. Operational lead for Responsible Procurement rests with the Director of Procurement who also has the national lead on Responsible Procurement for all police forces in England and Wales through the Association of Chief Police Officers (ACPO).

Procurement Services review its purchasing procedures to ensure that they are fair and not disabling and take proactive steps to encourage and support participation of all organisations including disabled led, BME led, women led and SME's in meeting the purchasing needs of the MPS. A full summary of Procurement Services practices was submitted to the Equal Opportunities and Diversity Board – 4 October 2007.

Procurement Services encourages key suppliers to engage with a programme called ‘Diversity Works for London’ which is funded by the LDA.  Diversity Works for London is a Mayoral programme that encourages and supports businesses to realise the benefits of London’s diversity. By providing a comprehensive suite of tailored business support products the programme enables companies to improve their diversity proficiency.

This recommendation has been embedded within ES Objective C6 “to ensure equality is embedded into all procurement and tender specifications and contract processes.”  This recommendation is complete.

Recommendation 18

School liaison officers work in every borough to reduce harassment and hate crime of disabled people.

This recommendation is embedded within existing School Liaison activity.

A Safer Schools Partnership is a collaborative approach between a school, police and other local agencies working towards the following aims:

• To reduce the prevalence of crime, anti-social behaviour and victimisation amongst young people and to reduce the number of incidents and crimes in schools and their wider communities.
• To provide a safe and secure school community which enhances the learning environment.
• To engage young people, challenge unacceptable behaviour, and help them develop a respect for themselves and their community.
• To ensure that young people remain in education, actively learning, healthy and achieving their full potential.

This recommendation is complete.

Recommendation 19

Record and analyse all hate crime against disabled people and consult with local disabled people organisations in addressing identified trends and issues.

Details of activities conducted to meet this objective can be found within the MPS’ submission to the EHRC.

Recommendation 20

Create a database to monitor crimes against disabled people including the outcomes.

CRIS has been updated since October 2008 to enable the monitoring of crimes against disabled people.

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 21

Voice recognition systems are made available for visually impaired people.

The author of this report, Ossie Stuart confirmed that this recommendation was aimed at assisting people outside of the MPS.  Currently the technology does not exist to do this.  DoI does have a wide range of access technology available for MPS staff including the latest version of Dragon voice activated software.

This recommendation is complete.

Recommendation 22

In consultation with Disabled people develop the capacity to treat disabled people as responsible adults.

The author of this report, Ossie Stuart confirmed that this recommendation related to such engagement activities as for example speaking to the disabled wheelchair user directly and not their personal assistant.

The PRDLDP delivers diversity training to all staff.  This recommendation is complete.

Recommendation 23

Consult disabled people about different ways of reporting crime and developing best practice structures such as third party reporting.

Activities relating to this objective are described within the reporting crime section of the main report.

This recommendation has been embedded within ES Objective Objective C8 “to ensure the opportunities for people to report crime through ‘Third Party’, Assisted or Online arrangements are accessible and relevant to people’s needs.”

This recommend is complete.

Recommendation 24

Each MPS Borough Command Unit establish formal consultative relationships with local disabled peoples organisations.

Activities relating to this objective are described within the partnership and community engagement section of the main report.

This recommendation has been embedded within ES Objective Objective C18 “to produce and implement an organisational community engagement strategy” and Objective D18 “develop, maintain and co-ordinate effective relationships with disabled people in the widest sense, i.e. visible, non-visible, hidden and learning disabilities and organisations to assist the MPS in identifying and addressing disability issues.”

Recommendation 25

MPA scrutinise and monitor through its committee processes the established formal consultation processes using performance indicators and the MPA link member role.

This recommendation is the responsibility of the MPA.

Recommendation 26

In the process of consultation, the MPS recognise they must go to where organisations of disabled people are and be aware of access requirements and the cost of consultation.

This recommendation has been embedded within ES Objective Objective C18 “to produce and implement an organisational community engagement strategy” and Objective D18 “develop, maintain and co-ordinate effective relationships with disabled people in the widest sense, i.e. visible, non-visible, hidden and learning disabilities and organisations to assist the MPS in identifying and addressing disability issues.”

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 27

In consultation with disabled people, develop a campaign to highlight crimes against disabled people, both in terms of the service the MPS offer to victims and to highlight the seriousness of the crimes to the perpetrators.

This recommendation has been embedded within ES Objective Objective D9 “deliver the policing elements of the Greater London Authority’s Disability Equality Scheme and Action Plan, including our response to Hate Crime.”

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 28

Crimes of harassment and burglary against Disabled people to be placed as a formal local priority.

This recommendation has been embedded within ES Objective Objective D9 “deliver the policing elements of the Greater London Authority’s Disability Equality Scheme and Action Plan, including our response to Hate Crime.”

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 29

Follow up and inform disabled people who are victims of crime; especially those disabled people who communicate in different ways; always tell disabled people what is happening, even if there is no progress.

This recommendation has been embedded within ES Objective Objective D9 “deliver the policing elements of the Greater London Authority’s Disability Equality Scheme and Action Plan, including our response to Hate Crime.”

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 30

Undertake proactive steps in taking seriously disabled people as victims of domestic violence.

This recommendation has been embedded within ES Objective Objective D9 “deliver the policing elements of the Greater London Authority’s Disability Equality Scheme and Action Plan, including our response to Hate Crime.”

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 31

In consultation with Disabled people develop the capacity to be able to implement policy and procedures for an enhanced level of response for vulnerable people in the community.

This recommendation is embedded within the Safer Neighbourhoods approach, the Central Communications Command’s Diversity and Citizen Focus Programme and the Safeguarding Adults policy.

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 32

Ensure training deals with expected action after an officer has wrongfully stopped or arrested a disabled person.

This recommendation is embedded within the Custody and Stop and Search SOPs and the contextualisation of the PRDLDP.

Recommendation 33

Provide named officers in each police station that disabled people can come to recognise and have confidence in.

This recommendation is embedded within Objective C19 “consider the development of the role of Equalities Liaison Officers (ELOs), to include the roles of LGBT and Faith LOs, on each borough and within each directorate.”

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 34

Review appropriate adults procedure. Disabled people as appropriate adults have expertise to be utilised.

This recommendation is embedded within the Custody SOP.

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 35

Undertake a comprehensive access audit of all its police stations and consult existing access committees of disabled people to evaluate building accessibility in compliance with the DDA.

This recommendation has been embedded within ES Objective Objective D7 “improve information on, and access to, existing and future MPS buildings, for disabled people.”

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 36

Provide people who use police buildings with the opportunity to feedback on accessibility.

This recommendation has been embedded within ES Objective D7 “improve information on, and access to, existing and future MPS buildings, for disabled people.”

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 37

Ensure suggestions made in the access audits and feedback are acted upon.

This recommendation has been embedded within ES Objective D7 “improve information on, and access to, existing and future MPS buildings, for disabled people.”

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 38

That the MPS ensure that a disabled person in custody has access to their familiar personal assistance.

This recommendation is embedded within the Custody SOP.

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 39

A disabled person in custody has access to their drugs with the appropriate precautions being taken.

This recommendation is embedded within the Custody SOP.

This recommendation has been achieved.

Recommendation 40

Custody suites be fully accessible.

This recommendation is embedded within the Custody SOP and Objective D7 “improve information on, and access to, existing and future MPS buildings, for disabled people.”

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 41

Officers be trained how to take a disabled person into custody.  Physical contact could place the disabled person at considerable risk.

This recommendation is embedded within Officer Safety Training and will be included within the review of the ACPO Personal Safety Manual.

Recommendation 42

Disabled people with learning difficulties have access to a chosen appropriate advocate.

This recommendation is embedded within Operation Emerald practices.

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 43

Custody policy to be part of MPS Impact Assessment Scheme.

This recommendation has been embedded within ES Objective C3 “to ensure the Equality Impact Assessment (EIA) process is managed in line with an identified prioritisation plan.”

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 44

In collaboration with disabled people, the MPS review the custody policy.

This recommendation has been embedded within ES Objective C3 “to ensure the Equality Impact Assessment (EIA) process is managed in line with an identified prioritisation plan.”

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 45

The complaints procedure be accessible to disabled people and how to access it be made public to organisations of disabled people.

This recommendation has been embedded within ES Objective Objective D8 “to ensure any MPS Communication Strategies take account of the needs of disabled people” and Objective C7 “to ensure that public access to our information and data about all our services is inclusive, open and effective.”

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 46

Disabled people be part of recruitment reviews.

This recommendation has been embedded within ES Objective D13 “reduce barriers experienced by disabled people:

•  in applying for employment within the MPS
•  who become disabled whilst employed by us.

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

Recommendation 47

Recruitment barrier review panels be configured to ensure disabled people are involved in the decision making process of progression and career structures for staff.

This recommendation has been embedded within ES Objective D13 - Reduce barriers experienced by disabled people:

•  in applying for employment within the MPS
•  who become disabled whilst employed by us.

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

GLAD Recommendation 48

Review career paths and development opportunities for the disabled staff to create meaningful promotion opportunities.

This recommendation has been embedded within ES Objective D14 “integrate the direction provided by: Disability and the Police – The Complete Works (Home Office Guidance) into organisational policy and practice.”

As stated in the report to the EODB 4 October 2007 this objective has been achieved.

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