Publicising the Complaints - Process to the Public and Internally

Report: 5
Date: 10 February 2011
By: Director of Professional Standards on behalf of the Commissioner

Summary

This report provides a brief explanation of how the Directorate of Professional Standards (DPS) leads the MPS in providing an effective means for the public to make complaints whilst remaining mindful of London’s diversity.

A. Recommendation

That

1. Members note the current position of the Directorate of Professional Standards and the strong emphasis on customer focus.

B. Supporting information

1. The MPS is committed to ensuring it provides a professional service, as part of this it is necessary to have an effective complaints system that is accessible to all. To ensure this is achieved there are a number of avenues open to the public to bring these concerns forward.

2. First and foremost of these is the DPS Customer Service Team. This team consists of seven Police Sergeants supported by police staff, and has recently been expanded with a view to early intervention and improved customer satisfaction levels. The overriding objective of this team is to provide a centre of excellence and a dedicated single point of contact via which the public can initiate complaints direct with DPS. This improves both accessibility and consistency around the recording and early resolution of low level concerns. Members of the public can contact the CST through the MPS internet website by using an e-complaint form, a direct telephone line with a 24-hour answer phone service and published mailing address.

3. If complainants do not wish to raise their concerns via DPS, they are able to do so at any police station. All police stations provide leaflets explaining how to complain, and the complaints procedure, which are readily accessible in the public area. There are six such leaflets addressing the various queries that may exist in relation to complaints against police. These are a national IPCC publication, and are produced in English. The IPCC web site has links to the most common languages to assist complainants for whom English is not their first language. They explain the process for making a complaint, resolving complaints, the outcomes of complaints and the complaints process. The appeals process for the police investigation into complaints, the local resolution process and the complaint not being recorded under the Police Reform Act 2002 is also covered. Statutory Guidance is also available on the IPCC website should people require it.

4. There is no distinction as to whether people should complain to either the IPCC or the DPS. Complaints can be made to either and information is exchanged between the organisations by means of secure email.

5. In order for forces, police authorities and the IPCC to comply with their Human Rights Act 1988 obligations, certain incidents and complaints must be rapidly referred to the IPCC for it to decide the appropriate mode of investigation and, in some cases, undertake an independent investigation.

6. The appropriate authority (for complaints and conduct matters in relation to police officers up to and including the rank of Chief Superintendent and for all levels of police staff is the chief police officer; for others above that rank it is the police authority), must refer any complaint where there is an allegation that the conduct complained of has resulted in death or serious injury. This includes any complaint which alleges that the police failed to take action which could have prevented someone's death.

7. The appropriate authority must also refer complaints and conduct matters that include the following allegations:

• Serious assault by a person serving with the police
• Serious sexual assault by a person serving with the police
•  Serious corruption
•  Criminal offence or behaviour which is liable to lead to a disciplinary sanction and which, in either case, is aggravated by discriminatory behaviour
•  That a 'relevant offence' has been committed i.e. any offence for which a person of 18 years and over (not previously convicted) may be sentenced to imprisonment for seven years or more
•  Complaints or conduct matters which are alleged to have arisen from the same incident as anything falling within these criteria.

8. To further increase accessibility, DPS has increased focus on proactive community engagement. Borough Support Units (BSUs) frequently attend public meetings and address Borough Independent Advisory Groups (IAGs), Police Community Consultative Groups (PCCG) and other such forums. An example of this work in action is in the NW area of London, where the regional BSU attends regular public events where BSU staff publicise the complaints process and invite their audience to ask questions in relation to the subject matter. Individual BSUs strive to identify good practice in the area, which is then shared between the other units. The complaints process is also advertised on the MPS and IPCC Internet sites.

9. In addition the DPS Prevention and Reduction Team (PaRT) proactively engages with communities across London by attending IAG meetings, police and community meetings and colleges, they deliver talks and information on the complaints process to these groups. On occasion the PaRT Team and BSUs will attend such events together, and there is regular liaison between these units to ensure a consistent message is given to the community.

10. The agreed Directorate of Public Affairs (DPA) approach to promoting the complaints process is to include references to how we facilitate the reporting of complaints in our press lines. When MPS offer the media information in relation to cases where conduct has fallen below that expected of a police officer, or where we provide lines to the media about officers who have been dismissed or disciplined, we make specific reference to the fact that complaints can be reported. Similarly it is standard practice for any Freedom of Information (FOI) responses about officer misconduct to include references to the seriousness with which allegations of wrongdoing or police officer misconduct are taken by the MPS, and that we will investigate all such allegations thoroughly. By including this in all FOI responses the message about complaints and the gravity with which the complaints process is treated is continually reinforced in the public domain.

11. The DPS has recognised the need to engage at the earliest opportunity with those who wish to complain. The development of an early intervention approach to dissatisfaction of service/complaint handling by the CST has identified the importance of face to face communication. As a result, any needs identified at an early stage can be responded to e.g. disabled people can be visited by CST Staff, negating the potential anxiety of the complainant as to obtaining access to the police station or office. A hearing loop mini com system is sited within the CST. Individual needs can also be identified through the facilities on e-mail or telephone.

12. When it is identified that a complainant does not speak sufficient English to make a complaint the use of a friend or relative to translate is a potential course of action. Third parties are often used to facilitate the making of complaints. The time and resources invested in engaging with them improves communication channels and helps to alleviate fears about the complaints process. The use of language line can also be considered, and the MPS Interpreter Service is available to assist. In addition the IPCC has information on its website in various languages, which further improves accessibility of the complaints process.

13. Local Borough Operational Command Units (BOCUs) are also encouraged to use their own staff under the MPS ‘Own Staff’ initiative to provide language services.

14. Via the ongoing and developing work of the BSUs and the CST, which is informed and supported by the DPS Equalities forum, the DPS is actively working towards an ever improving appreciation of cultural differences in relation to complaints.

15. Diversity data collection is completed monthly by the DPS Performance Analysis Unit in a consistent method. Out of the diversity information collated regarding complainants, it is noted that the proportions of complainants by ethnicity has remained stable for the last three years, with figures for 1st January 2010 to 31st December showing that 30% of complainants were white, 15% were black, 7% Asian and 1% other. A further 47% were recorded as unknown. This has been compared with census data and, whilst this does not show any impact on race and diversity in the current Professional Standards Performance Indicators they will be subject to continuous analysis, monitoring and review. The DPS Equalities Co-ordinator is addressing the issue of diversity data collection. Ideas being explored include sending the complainant a form with diversity information contained on it in a self addressed envelope at the conclusion or during the investigation. This would then enable us to further address identified trends or issues thereby improving service delivery.

16. This diversity report is published monthly by the DPS Performance and Analysis Unit and provides information to support development for the DPS Equalities
Co-ordinator.

17. Areas for improvement are recognised in this paper. They include modifying the MPS website complaints facility and increasing the flexibility of the online form, to encourage wider comment. They further include actively engaging with the IPCC to ensure diversity data is captured, and the CST and BSUs conducting a meaningful customer satisfaction process. To support this process, a customer feedback questionnaire has been developed to gauge confidence and satisfaction levels in relation to the CST. A new Customer Satisfaction Strategy has been prepared and awaits introduction. The development mentioned paragraph 11 will assist in matching satisfaction with diversity monitoring. This is a specific action for the Equalities forum.

18. Customer Insight Groups (CIGs) are a development area for the MPS. Currently there are 4 groups with the vision of conducting 10. They are held by the Confidence Satisfaction and Standards Unit (CSSU) at Lambeth Central Command Complex (CCC). They provide an opportunity to engage with hard to reach and disadvantaged groups and those who have had a negative experience with the MPS. Attendees are invited to discuss their personal experiences where any concerns or areas for improvement can be identified, and inform future learning. They can also discuss corporate issues.

19. Should a member of the public approach a frontline member of police staff or police officer in order to make a complaint, that person is advised to either attend the police station in order to speak to the Duty Officer or if easier for them, their details are taken, a CAD message created and contact is made at a convenient time. The process can then commence. This course of action is addressed at recruit training and is reiterated to officers and staff on Borough by the local supervising officers.

20. Internally, the DPS PaRT delivers an intelligence led, interactive programme of raising awareness of officers and BOCUs identified through the Professional Standards Support Programme (PSSP). This programme includes relevant learning captured through the DPS and IPCC ‘learning lessons’, in order to promote best practice in operational policing.

21. Detailed below is the work of the Directorate of Professional Standards in the area of disability and this demonstrates the measures that have been put in place to ensure that all communities are afforded an equitable service.

•  A dedicated Diversity and Equalities coordinator is available to give specific advice and guidance e.g. on assistive technologies.
•  The DPS Equalities Forum monitors performance information supplied from the Performance and Analysis Unit and recommends where necessary, remedial action in areas of all strands of diversity. The Forum Chair is DSU Jonathan Tottman. The membership is made up of officers and staff from the DPS and the DPS SPOC from Diversity and Citizen Focus Directorate (DFCD) (Savi Bhamra). The Forum addresses all strands of diversity issues.
•  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 who may be querulous or vexatious. They ask callers diversity monitoring questions. These include whether the caller is disabled and if they have any particular requirements to aid communication, 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.
• Deaf and Disability Awareness Training have been provided to all CST staff, officers and supervisors.
• The CST has assistive technologies installed to aid communication e.g. Mini com.
• First line managers have attended a one day workshop on ‘Dealing with Diversity’ to familiarise themselves with potential diversity issues.
•  A Diversity and Citizen Focus Directorate advisor works closely with the DPS and has a direct input into the work of the Equalities Forum.
• All complaints are monitored by Inspectors to ensure a consistent service is being provided.
•  The CST and BSUs provide advice and liaise with (B)OCU personnel to ensure consistency across the MPS.

22. All complainants have a right of appeal in relation to the outcome of their complaint. This applies regardless of whether the complaint is investigated, locally resolved or not recorded. When complainants are informed of the result of their complaint they are sent a letter explaining the outcome. Enclosed with this letter is the relevant IPCC appeals leaflet. This explains how and in what circumstances they can appeal any decision they are dissatisfied with. The IPCC deal with the appeal and, if upheld, the IPCC issue instructions to the MPS about any additional actions required.

C. Other organisational & community implications

Equality and Diversity Impact

1. There will be diversity issues identified in the work that this report depicts. The impact in relation to these should be positive. In continuing to engage with local community groups and addressing the quantity of unknown categories on the diversity report, the results should be able to be used strategically by the Equalities Co-ordinator to inform DPS work.

Consideration of MET Forward

2. Two strands from the Met Forward initiative are applicable - Met Connect and Met Standards.

3. The complaints system needs to be one that inspires confidence in the public and internal partners alike. The work currently being undertaken by the CST is designed to increase public satisfaction in relation to the complaints process. The DPS PaRT, DPS BSUs and (B)OCU Professional Standards Champions will ensure the key causes of complaints are identified, analysed, prioritised and appropriately actioned through organisational learning or enforcement in order to proactively reduce the number and causes for complaint. Any implementation will be subject to regular monitoring and review.

4. The PaRT contributes to the achievement of standards through the DPS Learning Lessons programme.

Financial Implications

5. All costs in relation to the activities described within this report are covered within existing budgets as contained and approved in the 2010-13 Business Plan.

Legal Implications

6. This report provides information as part of Governance process and no legal implications arise.

Environmental Implications

7. There are no environmental issues in relation to this report.

Risk Implications

8. There are no significant risks identified within this report. There are opportunities that may present themselves from the ongoing work and these should be managed by the DPS Equalities Co-ordinator

D. Background papers

1.  Confidence and Satisfaction - Development of a Customer Service Strategy - C/I Nigel Roberts 31.03.10
2.  Customer Service Strategy - Commander Eastaugh 15.04.10
3. IPCC Statutory Guidance
4. MPA Paper - Professional Standards Performance Indicators 2009/10 - C/I Sharon Heyes 11.11.10
5. MPA Paper - MPS Service Delivery to Deaf and Disabled People - 21.10.10
6.  DPS BSU NW Surgeries - C/I Sharon Heyes

E. Contact details

Report author: Inspector Guy Wilson, MPS

For information contact:

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

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