Directorate of Professional Standards Thematic Performance Report

Report: 9
Date: 3 December 2009
By: Director of Professional Standards on behalf of the Commissioner

Summary

This report identifies current and future strategic work for DPS; development of working practices; DPS contribution to confidence agenda; performance issues; performance oversight mechanisms; and financial and resource systems and processes.

A. Recommendation

That the report be received and members be invited to comment on the contents of the report.

B. Supporting information

1. This report provides an overview to the committee on key performance issues for the Directorate of Professional Standards (DPS), including development of DPS working practices and a description of how the directorate is contributing to the confidence agenda. The report also contains a summary of performance issues; an explanation of oversight mechanisms, including how DPS reports to and works with MPA; and financial and resource systems and processes.

Current and future strategic work

2. The draft Professional Standards Strategy for 2010 - 2013 has recently been circulated for consultation and is currently subject to review following feedback. The draft Strategy sets out five future priorities for DPS with supporting activities outlined in paragraphs three to nine below. The priorities are:

• Promote professional standards
• Identify individuals/patterns of concern and risk triggers through the effective use of intelligence
• Prevention through intervention
• Enforcement of standards through successful investigations leading to appropriate outcomes
• Best use of resources

Summaries of work for each of the five priorities

3. Promote professional standards: A range of activities will take place to ensure that the high standards of behaviour expected from MPS officers are promoted at pre-determined stages of the police officer life-cycle. A network of single points of contact at Association of Chief Police Officers (ACPO) level is being established across MPS Business Groups to facilitate a better exchange of information between DPS and Business Group command teams. DPS also intends to increase the use of internal publications to highlight the standards of behaviour expected. In addition to this the membership of the MPS Professional Standards Strategic Committee (PSSC) has been revised to raise the profile of professional standards and is now chaired by the Deputy Commissioner with Deputy Assistant Commissioner level representation. The MPA is also represented on this board.

4. Identify individuals/patterns of concern and risk triggers through the effective use of intelligence: It is recognised that effective use of information and intelligence is central to DPS performance. The intelligence function was realigned within the Prevention and Learning Command to bring the intelligence and prevention teams together. This will enable targeted prevention activity based on the intelligence picture. Effective use of intelligence requires identification and collection of information from a wide range of areas, accurate evaluation, interpretation through analysis, robust decision making processes and immediate dissemination to the most appropriate people for action. To achieve this DPS will develop an Intelligence Management Unit. This will have oversight of all intelligence within DPS, including sensitive intelligence obtained from other enforcement agencies. To enhance the management of risk the Intelligence Bureau will establish a Risk Identification Unit and processes to identify risk triggers and potential misconduct and/or corruption in relation to individual officers, teams or locations. The unit will combine disparate data sets to analyse and identify organisational, thematic, unit and individual risk. Information on risk gathered from this system will contribute to the Professional Standards Risk Management Structure which incorporates a fortnightly meeting, with ACPO level representatives from across all business groups. A core task of the Intelligence Bureau is to conduct the Strategic Intelligence Assessment (SIA) and the next interim SIA is due to be completed for April 2010. Additionally the Intelligence Bureau will be designing an easily accessible suite of performance information to meet the needs of other MPS business groups.

5. Prevention through intervention: DPS will aim to maximise the opportunities for prevention activity, ensuring that learning from conduct/complaint matters, corruption investigations and critical incidents is used to improve customer service delivery. DPS will maintain the focus on prevention and learning and will develop prevention and reduction initiatives designed in relation to key areas of learning either on a themed or geographical basis focused on risk areas identified by the Intelligence Bureau.

6. Enforcement of standards through successful investigations leading to appropriate outcomes: We will continue to ensure that investigations conducted by DPS are effective, proportionate, timely and fair. Following the introduction of the new police conduct regulations resulting from the Taylor Review, DPS will be supporting B/OCUs to deal with lower level public complaints in a timely and proportionate manner.

7. Best use of resources: This will enable DPS to continue to achieve against the backdrop of significant funding challenges by improving financial management and accountability, improving finance systems, processes and controls, managing our people resources more effectively and managing our resources to minimise environmental impact. Financial and resource issues are expanded upon in paragraphs 28-34.

Development of working practices

8. The increase in recorded public complaints and the introduction of the Taylor Reforms has necessitated a review of how we manage public complaints within the MPS. A small project team has been formed to examine current practices within the DPS Customer Service Team and Borough Support Units, to ensure that an appropriate business model is introduced to deliver a high standard of service that the public can expect from the MPS in dealing with their complaints. It will also ensure that resources and skills are appropriately deployed to support the new working approach, which is likely to be introduced during 2010, in preparation for the introduction of the revised Independent Police Complaints Commission (IPCC) statutory guidance.

9. The IPCC are undertaking a consultation exercise for the introduction of the revised statutory guidance for the police service during 2009/10. The IPCC’s ability to issue statutory guidance to the police service is a key part of its guardianship role; the statutory guidance is a tool through which the IPCC sets the standards for operation of the complaints system, including how those cases that the IPCC doesn’t deal with should be handled. The consultation will focus on the following revised areas; access, initial handling, resolving, outcomes and monitoring and development. The IPCC first published statutory guidance for the police service in 2005 and with the introduction of the Taylor reforms in 2008 and the recommendations stemming from the IPCC ‘Stock Take’ report published in 2008, the IPCC felt the time was right to build upon the greater experience to achieve increased public confidence. In October 2009, the MPS responded to the first draft of the IPCC statutory guidance along with the rest of the police service and key stakeholders.

DPS contribution to the confidence agenda

10. The primary purpose of the Directorate of Professional Standards is to build trust and confidence in the integrity of the MPS by the continued improvement of professional standards, to promote professional standards and to ensure the learning from conduct/complaint matters, corruption investigations and critical incidents is used to improve customer service delivery. We strive for contact with the public to be conducted professionally, where all individuals are treated fairly and with respect. This will contribute towards the MPS delivering on the confidence agenda and increase levels of public trust and confidence. Detailed below are specific examples of how DPS is contributing to the confidence agenda.

11. Prevention and Reduction Team (PaRT): The DPS ‘core business’ of learning from DPS investigations and, recommendations from IPCC, MPA and Coroners continues to grow. PaRT has responded to this increase by appointing an Organisational Learning Manager and introducing systems that ensure Organisational Learning is captured and passed to the MPS unit best placed to identify learning points. Where learning points are identified, PaRT disseminate these to the wider MPS audience. This continual development improves service delivery, thereby contributing to public confidence.

12. Professional Standards Support Programme (PSSP): Seeks, through prevention-focused presentations to staff, to prevent the behaviour of police officers and PCSOs that leads to public complaint. This process incorporates the identification of recurrent topics of complaint, officers who are attracting a high number of complaints and any trends and patterns of behaviour. The current package addresses incivility, IT misuse, inappropriate relationships, information leakage, use of force and social networking. Before working on any B/OCU, PaRT engages with B/OCU managers and agrees PSSP delivery in line with the needs of the B/OCU. Through the Community and Partnership lead, local community engagement work of DPS and PSSP is also promoted. Examples of this are Lambeth Community College, Lewisham -Racial Equalities Action Group and Youth IAG.

13. Borough Support Units (BSU): Are responsible for investigating public complaints and misconduct of a more serious nature (gross misconduct).In addition to their interface with complainants, BSU staff are actively engaging with Boroughs and sections of the community to promote confidence in the complaints system and the MPS in a variety of innovative ways. This ensures that ‘hard to reach’ groups are made aware of the police complaints system. For example:

• Church End Youth Club Brent. North West BSU staffs have been attending one Thursday each month for over a year. Having secured the confidence of the group, they have worked with teenagers to explore the role of the police, the complaints system and the IPCC. The youths have, as a result of these interactions, been involved in attending Hendon Training School in the summer months and being actively involved in role plays with recruits around key issues such as stop and search. Further visits are planned in the next school holidays to role play new scenarios. Other departments such as dogs, mounted branch, Territorial Support Group, Territorial Policing Gang Unit have also had their attendance secured by BSU staff at the Youth Club. The positive impact of the interaction has resulted in four youths from the club joining the Police Cadets.

14. Specialist Investigations (SI): Investigate death following contact with police. It is vital that these enquiries are open and transparent as these tragic events often generate significant community interest and emotion, as well as local and national media attention. Consequently, it is vital that accurate information is provided to those best placed to cascade it..

15. To this end, SI gave a presentation to an audience of Independent Advisory Group (IAG) members from all MPS B/OCUs, in May this year. The event was organised to provide an insight into the workings and remit of SI. It included input from DPS Family Liaison Officers, DPS PaRT and IPCC. The event served to highlight how SI seeks to support those most affected by such tragic circumstances and how the organisation seeks to learn and improve. It also provided an opportunity to enhance confidence that SI is best placed to undertake such critical investigations due to specific training and experience in this area. The audience was asked to cascade this message to their respective communities.

16. Anti - Corruption Command (ACC): Conduct covert operations against corrupt members of the MPS, and those who seek to corrupt them. ACC works with other parts of the DPS to ensure that Organisational Learning and best practice are shared to prevent and reduce corruption. It also works with staff associations and support groups to ensure that staff are aware of the mechanisms to report wrongdoing via the Right Line to either DPS or MPA internal audit team.

17. In the past year corrupt officers have been imprisoned for a broad range of offences such as blackmail, drug trafficking, theft and sexual offences. Corrupt police officers and staff have a significant and corrosive effect on public confidence, and the MPS has allocated resources to combat the threat of corruption. ACC's experience in targeting the corrupt is seen by many agencies as an example of best practice, and the ACC works closely with IPCC, Crown Prosecution Service, Home Office and European Union partner agencies to share experience in prevention and investigation of corruption.

Performance issues

18. Since the introduction of the ‘Taylor’ reforms in December 2008, there have been a number of changes in performance, primarily due to the shift in emphasis for misconduct matters to be dealt with ‘locally’ as opposed to ‘centrally’ by DPS. The following comments relate to performance data to the end of September 2009.

19. There has been reduction in the percentage of allegations Locally Resolved, from 34% in the 12-months to the end of Sept 08 compared with 30% to the end of Sept 2009. Correspondingly there have been increases in allegations investigated from 31% to 37% over the same period. In part this change is due to Boroughs choosing to undertake ‘proportionate’ investigations, supplying the complainant with an outcome to an investigation letter, rather than pursuing the Local Resolution route. However, it is noted that of those Local Resolutions being obtained an increasing proportion (66%) are being undertaken by Boroughs and Business Groups and a decrease in the proportion of those dealt with by DPS (34%).

20. More significant is the affect on timeliness. There has been in the increase in time taken to complete all cases, rising from a yearly average of 49 days in 2008/09, against a target of 64 working days, to 56 days average for Q1 and Q2 in 2009/10.

21. Similarly the time taken for Local Resolutions has risen from an average of 38 days in 2008/09, against a 43 working day target, to just over the target with 44 days average in the financial year to date 2009/10.

22. DPS Performance Management Framework (DPS PMF): DPS are currently in the process of developing an internal performance management framework to monitor the process and take action to improve performance. PMF provides similar information to that provided to MPA within the ‘Professional Standards Performance Indictors’, with the difference being that PMF data is further broken down to a local level. The DPS PMF will be split into those elements of process undertaken by the DPS Customer Service Team, each of the four DPS Borough Support Units, the 32 Boroughs and finally the Business Groups/other locations. This will enable any issues to be targeted directly to those areas where accountability lies and a performance improvement is required.

23. The PMF will track the volume of workload (public complaint cases and conduct matters) from receipt within the MPS; to how they are distributed between the areas responsible, the timeliness of each part of the process and how long, on average, cases currently being dealt with have been in the system. It will further illustrate how the cases have been dealt with, by outcome e.g. local resolution or investigation etc and where applicable, the number of appeals to the IPCC, by type and whether they have been upheld or not.

24. The intention is for the DPS PMF to be piloted in December 2009, where issues of data quality can be addressed, thus enabling performance measures and targets to be set, which are based on accurate information. It is anticipated that this preliminary work will enable the final DPS PMF to be fully implemented in January 2010. Where appropriate, the performance measures and targets will be based on those appearing in the IPCC Performance Management Framework.

25. IPCC Performance Management Framework (IPCC PMF): The Independent Police Complaints Committee (IPCC) Performance Framework Joint Project Board is introducing a performance management framework in 2009/10 that will enable comparisons to be made between forces in England and Wales. Performance results contained in the framework will be compared to one of the following:

• The average performance results for the most similar forces
• Direction of travel (i.e. changes in performance result since the last quarter)
• The national average
• An existing performance target or standard

The MPS is due to report in quarter 4 of 2009/10 along with the remainder of London and South Eastern Regions. Data will be collected on a quarterly basis using the electronic process already in place to support the annual data collection by the IPCC.

Performance oversight mechanisms

26. The ‘Professional Standards Performance Indictors’ report is provided to the MPA SOP Committee on a quarterly basis updating on key performance measures. A variety of other performance reports are regularly provided to MPA Officers. Additionally the protocol has been revised for the dip sampling of closed MPS complaints / misconduct cases by the MPA. The reporting and monitoring arrangements for the Professional Standards Strategy would be as follows A DPS Strategy and Performance Board, chaired by the OCU Commanders, will sit on a monthly basis to drive, monitor and review progress towards the implementation and delivery of the strategy. A management information report will be provided to the Board to measure progress on the activities outlined above. Commander DPS will review the work of the Strategy and Performance Board on a quarterly basis to evaluate its effectiveness and ensure the strategic direction is maintained. Commander DPS will provide progress reports in relation to the Professional Standards Strategy to the quarterly Professional Standards Strategic Committee (PSSC) chaired by the Deputy Commissioner and attended by the chair of the MPA Professional Standards Committee.

Financial and resource systems and processes

27. In the current economic climate there is a clear need for greater productivity against a backdrop of significant challenges. DPS strives to deliver more despite there being fewer resources.

28. DPS has delivered significant efficiency savings of over £1 million pounds per year over each of the last 3 financial years. It has also identified a further £1.2 million of efficiency savings for the 2010 - 11 financial year, to be delivered by the general improvements in the efficiency and effectiveness of our core deliverables. Further efficiency savings for 2010 - 11 are to be delivered through the reduction in the size and consolidation of several teams. These include the Intelligence Bureau (£150,000), Risk Management (£438,000) and Support (£237,500). Additional general efficiency savings of £201,357 are also being delivered as a result of better use and management of resources such as vehicles, overtime and running costs.

29. The budget profile and staffing numbers for DPS over the past 2 years and forthcoming year is shown below in Table 1.

Table 1

30. DPS will seek to continuously improve our financial management and accountability, our financial systems and controls. To achieve this, activities being undertaken include devolving budgets to individual Superintendents, greater scrutiny of spend and implementing a system of intrusive supervision across all cost categories. Monthly meetings take place with our support cluster to review progress and agree on working arrangements.

31. DPS are managing people resources more effectively, realigning vacancies to other areas within the command to address the impact of rising complaints. For instance, a review of working practices within the Customer Service Team is being undertaken to identify areas for improvement, current staffing levels and training needs.

32. We will manage our resources to minimise environmental impact by encouraging good practice in energy consumption, increased re-cycling and reducing vehicle usage.

33. Other relevant Information

DPS have conducted a number of investigations into incidents that impact upon public confidence and have submitted a number of reports presented to the MPA. Corporate Business Card - Amex Enquiry was first reported to Full Authority on 22 November 2007 and quarterly updates have been provided to Corporate Governance Committee during 2008/09. The DPS have also contributed to reports including G20, where AC Allison attended Full Authority on 30 April 09 to provide a briefing to members who also had the opportunity to submit written questions. The MPA have been updated on G20 at other Committees including Strategic and Operational Policing Committee on 9 July 09 where AC Allison attended and provided an update to members on Adapting to Protest - HMIC report.

C. Race and equality impact

1. At a strategic level, the DPS Professional Standards Strategy will incorporate the development of a full Equality Impact Assessment.

2. Across the MPS, PSSP Borough reports include profiles of both officers subject to complaint and complainants. Complainant data is considered in terms of local groups being over or under represented compared to the demographics of the Borough. Any issues of apparent disproportionality are then explored with the BCU community team. In partnership with local IAG, a comprehensive series of briefings and presentations are actioned to meet the identified local need. The purpose of this work is to increase local confidence in the complaints system. A recent example is engagement with Muslim elders and youth groups within Waltham Forest.

D. Financial implications

DPS budgets are outlined in paragraph 27. These budgets include all activities outlined above.

E. Background papers

None

F. Contact details

Report author: Chris Maguire, DCI Intelligence Bureau

For information contact:

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

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