Directorate of Professional Standards dip sampling procedures

Report: 5
Date: 18 October 2010
By: Director of Professional Standards on behalf of the Commissioner

Summary

This report provides:

• An outline of MPS quality assurance processes, policies, and protocols in relation to dealing with complaints and conduct matters against police officers;
• How any lessons learned are disseminated throughout the MPS;
• Specifics of any training that MPS staff have received on these processes, policies and protocols; and
• An update on the progress of professional development training of Professional Standards Champions in dealing with public complaints, as was reported to the Strategic and Operational Policing Committee at its meeting on 1 July 2010.

A. Recommendations

That Members consider the information in this report.

B. Supporting information

MPS / DPS complaints quality assurance processes.

1. A cornerstone of the MPS approach to managing public complaints is the provision of positive customer service. The MPS has learnt from the experience of the retail customer service industry, that building strong and constructive relationships with complainants helps promote confidence in police services and the MPS as an organisation, even though they have had cause to complain. Central to service recovery is an appropriate and confident response to the complaint and effective communication with the complainant, with a commitment to resolving concerns expeditiously and pragmatically. This has been achieved in the MPS by ensuring that first contact with the complainant is managed positively by the customer service team, empowered to resolve concerns and restore confidence; more complex misconduct allegations referred to Boroughs for resolution by local managers with knowledge of officers and their community, and the most serious complaints of criminality and gross misconduct are investigated by specialist complaints teams. In all cases, the complaints processes are closely monitored and reviewed to ensure that action is proportionate, balanced and fair and meets the exacting standards set by the Police Reform Act, MPA targets and IPCC statutory guidance.

All data gathered from the complaints, including stages of investigations, are inputted onto the TRIBUNE system and managed by the DPS Performance Analysis Unit (PAU) who provide weekly quality audits to ensure accuracy and efficiency. The audits are the subject of regular performance management team meetings to quality check the accuracy of data and to ensure that investigations are progressing properly in a timely manner.

Critical also to successful complaints and misconduct management is the commitment to learn lessons. There has been significant investment in the DPS Prevention and Reduction Team who manage a cradle to grave system on the TRIBUNE complaints system to accurately capture and document IPCC recommendations and organisational learning from other sources. They also disseminate learning to Boroughs through the medium of outreach presentations, and identify key areas for improvement and prevention in respect of complaints misconduct. Again, all actions and interventions are recorded for the corporate memory.

The focus upon ensuring that cases meet Police Reform Act, investigative, risk and customer service quality standards are part of the DPS managerial culture and are described below:

• Line managers within the DPS Customer Service Team (CST) perform the first quality assurance check. An initial review of all cases is made to ensure the staff have correctly identified the issues and made an accurate risk assessment. Each month a quantity of complaints are further scrutinised to ensure accuracy of data standards, compliance with processes and professionalism of staff. Line managers also have responsibility for the quality call-back system - designed to check upon the quality of service that complainants have received.
• DPS Team Detective Inspectors (DI) conduct further assessments to determine the appropriate response to complaint and misconduct cases and document the risk value to the public, officers and the organisation. Cases of high risk are captured in a Risk Register for consideration by senior management. This register is reviewed and discussed at bi-monthly intelligence operations meetings for the consideration of further resource and assets. Team inspectors have an ongoing responsibility to ensure that all cases are conducted in a proportionate, balanced and fair way, and promulgate any identified learning to the Prevention Reduction Team (PRT) for dissemination.
• As “Appropriate Authority”, DPS Detective Chief Inspectors have responsibility for carefully considering all completed cases and endorsing recommendations made by the investigating officer. They determine whether there is sufficiency of evidence to justify criminal or misconduct proceedings and whether those proceedings should be heard at formal hearings (where the ultimate sanction is dismissal) or local meetings (where the ultimate sanction is a final written warning). In crime cases, the files are submitted for further consideration by the Crown Prosecution Service.
• DPS Hearings Office is responsible for reviewing gross misconduct cases referred to them to examine whether the recommendations and findings of the investigation warrant a Misconduct Hearing;
• The IPCC review ongoing investigations intrusively for Supervised and Managed investigations. The IPCC also review cases where an appeal has been made against the investigation, Local Resolution or non-recording. The appeals process provides an independent level of scrutiny to MPS complaints processes and outcomes. It ensures additional areas of learning are identified and fed into the MPS.
• The ‘Learning Lessons’ programme, acts on findings and recommendations from investigators and is specifically designed to reduce individual and organisational risk. This is achieved through systems and processes being put in place to facilitate learning, prevent misconduct and unprofessional behaviour, and to ensure that risks, once identified, are quickly and effectively managed.
• The DPS Performance and Analysis Unit (PAU) interrogate the Tribune complaints database to quality assure the recording of complaints. This information is then disseminated to the DPS departments involved in the recording of complaints, so that any remedial work can be undertaken.

In respect of complaints referred to Boroughs, the development of Professional Standards Champions (PSC) has led to improved ownership of complaints, misconduct and performance management by Borough management teams and nurtured a close and effective working relationship with the DPS. DPS investigators meet regularly with their appointed PSC’s to discuss specific complaint trends, officers of concern and other related issues. Specific focus is placed upon monitoring and reviewing progress of complaints being dealt with by Borough personnel, to ensure compliance with the Police Reform Act, investigation timeliness and commitment to the customer service ethos.

The introduction of dip sampling proposed by the MPA presents a further opportunity for the MPS to demonstrate its commitment to customer service and quality assurance. Provision to accommodate this partnership initiative with the MPA will be provided by the Prevention and Reduction team, who will also be in a position to capture any resulting learning.

How any lessons learned are disseminated throughout the MPS

2. Over the last 4 years the role of identifying and disseminating learning has become a core function of the DPS Prevention and Reduction Team. An Organisational Learning Manager’s appointment drives this area of business. Learning recommendations received resulting from complaint investigations are robustly recorded and actioned to all business areas of the MPS. Accountability for change and improvement is also monitored through these processes. The learning points are reviewed and disseminated in the same manner as intelligence strands. The learning then reaches wider audiences informing training, policy and process reviews and decisions. Learning has increasingly become a process by which risk is identified and suitable interventions can be put in place to mitigate such risks.

The DPS Prevention and Reduction Team manages learning recommendations from a number of sources including IPCC, Coroner and DPS investigations. Each learning recommendation received has a unique reference case number, created on the MPS complaints database (Tribune). The recommendation is then forwarded with supporting documentation to a named person within the business area where the learning is aimed. The business area owner selected will be sufficiently senior within the business area to effect decisions and changes. An audit trail is then maintained throughout the consideration and implementation of any learning. All correspondence, documents, reports and policies are attached to the learning case file. Where a learning point is rejected a full written response outlining the rationale for the decision is requested and again attached to the file. All interested parties in any learning case are notified of the final outcome by the DPS team.

The learning database is searchable to identify themes and areas of risk. The cases created allow 'key word' searches, therefore subjects e.g. "firearms" can be searched and all learning in relation to the subject located. Business groups and BOCU searches identify areas of business or locations where learning has been identified most frequently. Learning identified is also captured by the DPS Prevention and Reduction Team when delivering the Professional Standards Support Programme (PSSP). Throughout 2010 a key learning theme of supervision has been delivered through all PSSP presentations and products.

Specifics of training MPS staff have received on processes, policies and protocols

3. DPS investigators receive bespoke training to equip them to perform their role. In the case of the customer service team, staff participated in a BTEC recognised externally run course to develop communication and complaint management skills. Complaints investigators receive internal training upon appointment to the DPS, focusing upon investigative skills, communication and complainant contact and complaints legislation and procedures.

An update on progress of training of Professional Standards Champions (PSC)

4. To perform the role of a Professional Standards Champion (PSC), an officer must have been professionally trained by the DPS. A total of 396 officers have been trained under the 2008 Police Conduct Regulations as PSC as part of the ‘Taylor Training’. This is in addition to the Superintending ranks and ACPO officers who have been trained to be panel members. This training was initially delivered by an accredited law firm, who were commissioned specifically to perform this role, with every PSC attending this two day course. There has been continual ongoing periodic training to address the changing needs of the PSC’s and to train newly appointed PSC. This training is now delivered by police trainers

The PSC are supported by DPS in a number of ways. The Borough Support Units maintain contact with the PSC to offer advice, support and to ensure there is a corporate approach. Additionally, the Misconduct Office is also available to supply advice and assist in decision making. The DPS Civil Actions Investigation Unit also maintain regular contact with the Professional Standards Units (PSU) and Champions in matters relating to civil actions and Inquests. Once again, advice support and identification of best practice can be identified through these forms of contact.

Since the training of PSC across the MPS pre-December 2008, there have been two refresher/update days for PSC. These took place in July 2009 and January 2010. Training of new officers to the PSC role, who have not had previous training, took place on 21 September 2010 and a further session is scheduled for 19 October 2010.

C. Other organisational and community implications

Equality and Diversity Impact

1. The processes involved in quality assuring cases, are designed to ensure the investigation of complaints does not have an adverse impact on those involved in the process, because of race or diversity issues. The management of public complaints and conduct matters are also reviewed by the MPS Diversity and Citizen Focus Directorate to ensure this.

Consideration of MET Forward

2. Two strands of the Met Forward initiative are evident within the dip sampling process and benefit from it. They have been identified as Met Connect and Met Standards.

The complaints system needs to be one that inspires public confidence in the MPS. The IRT helped the MPS work towards this by helping it to maintain the standards of investigations into complaint and conduct cases and achieve a level of consistency. This is now something that is being put into practice by the Prevention and Reduction Team.

The Prevention and Reduction Team, through the DPS Learning Lessons program, contributes to the achievement of standards, as well as allowing the MPS to communicate how it learns from experience, and that it is willing to make necessary changes to delivery a quality service to the community.

Financial Implications

3. All costs are met by the DPS budget. The ongoing training of Professional Standards Champions and all other costs associated with the above activities are covered from within the existing DPS budget.

Legal Implications

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

Environmental Implications

5. There are no environmental implications.

Risk Implications

6. The DPS systematic approach to recording and managing complaints against police ensures regular monitor and review of complaints and the identification of cases that pose a risk to the public, officers or the organisation. Regular quality assurance interventions by managers at various stages of the process, ensure that cases are managed correctly to meet the expectations of the complainant and in accordance with the Police Reform Act.

D. Background papers

None

E. Contact details

Report authors: Campbell McKelvie, Inspector, Directorate of Professional Standards, MPS.

For more information contact:

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

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