Implementation of IPCC recommendations investigation reports

Report: 13
Date: 11 November 2010
By: Director of Professional Standards on behalf of the Commissioner

Summary

With reference to Chapter 5 IPCC revised statutory guidance paragraphs 593-600 (responsibilities of the MPS and role of the MPA), this report provides:

• Information on the systems in place in respect of recommendations in investigative reports, appeal decisions and other operations of the complaints system;
• Information about the recommendations made by the IPCC;
• The status of the implementation of these recommendations providing reasons;
• Details of systems in place that monitor the impact of learning;
• Details of adjustments to recommended policy or practise; and
• Information relating to training / and or support required or requested from the IPCC.

A. Recommendation

That

1. Members note the current systems in place to ensure that recommendations and learning are recorded and implemented in accord with the IPCC revised Statutory Guidance.

B. Supporting information

1. Appendix 1 (exempt) - contains learning recommendations received from the IPCC for reporting period 01/01/10 to 01/09/10 in the following format:

• The DPS OLT IX case reference.
• Date recorded on the Tribune system.
• Number of recommendations contained in the IX case.
• The recommendation recorded verbatim, as made by the IPCC.
• Source- outlines type of IPCC case.
• Case status - Implemented, Under consideration, Rejected.
• Sent to / Unit Resp. MPS area of business dealing with the implementation.
• Contact - Named MPS member of staff dealing with implementation.
• Outcome/Result - Implemented recommendations will have documents attached to case file to prove outcome. Recommendations under consideration will have on going entries outlining current stage. Rejected recommendations will have supporting rationale.

Systems to monitor IPCC recommendations

2. The DPS Organisational Learning Team (OLT), operates a case management system on Tribune (complaints and discipline computer system). On receiving learning recommendations from an investigation or inquest (IPCC, DPS, Coroner etc), the case is allocated a unique case reference number (e.g. IX/00001/10 - referred to further as an IX case) and all the recommendations recorded are on the IX case. Various administrative searches are then completed to link like cases.

3. A single IX Case may have as few as 1 or as many as 20 individual recommendations attached. Depending on the nature of a recommendation, the response may require a single line correction to a published notice by a sole decision maker, or lengthy ACPO level negotiation by various business group leads over months on matters of national policing policy. There is therefore no ‘typical’ case or timeframe.

4. Recommendations are ‘key worded’ (this is to allow some search facility later), and cross-linked to the responsible Borough or Operational Command Unit, along with relevant supporting documentation (the IPCC report and supporting MPS documentation). These processes allow some monitoring of geographical, business group and thematic trends in learning recommendations, and ‘rising trends’ of individual or local failure to be identified and proactively addressed organisationally.

5. One or more appropriate ‘Gold’ decision makers (“considers strategic impact, risk, costs and monitors”) are identified for receipt of recommendation packages comprising the recommendations and appropriate supporting documents to inform the decision maker of the circumstances giving rise to the recommendation being made. They are then in an informed position with regard to any decision making that follows.

6. Recommendations are disseminated by email and progress-tracked from DPS to the relevant ‘Gold’-level decision-makers or their nominated organisational special points of contact (SPOCs) throughout all MPS business groups, with allocated timescales for response or chase up shown on the IX case. Cases are then progress-chased with the decision makers by the DPS OLT. The Tribune system provides a facility of showing action dates and an indication when these have been reached to alert the team, further action is required.

7. The case record is used to track and store records of all contacts relating to the progress of the recommendation with the receiving decision maker, until each recommendation is either accepted, with supporting evidence of the acceptance, or rejected, with supporting rationale for the rejection (e.g. cost prohibitive), by a named decision maker.

8. The audit trail of the progress on the decision regarding any recommendation processed by DPS OLT is thus held on and capable of being retrieved from the system, offering a form of ‘corporate memory’ of organisational learning.

9. All completed cases are reviewed by DPS OLT detective Inspector before a case closure is authorised, with an option to set dates for follow up review of embedded new processes.

10. A concluding written response is supplied to all interested parties recorded on the case file e.g. IPCC Senior Investigator, IPCC Case Manager, DPS Investigator, and Coroner. This process provides a retrievable, accountable auditing of decisions by named individuals in relation to Learning Recommendations. However this is only in relation to Learning Recommendation referred to, and received by DPS OLT. The technology currently used also limits the flexibility and speed with which data held can be interrogated.

Details of IPCC recommendations received by the MPS 2010

11. For details of all IPCC recommendations received by the MPS between 01/01/10 and 01/09/10, please refer to Appendix 1 (exempt).

For ease of understanding and reference, the following sanitised example has been extracted to assist the committee:

• Case 5
• Reference: IX/55/10
• Case recorded: 22/03/2010
• Background: An IPCC managed investigation into a fatal road traffic collision involving an MPS traffic car. No criminal or misconduct proceedings against the police driver of the vehicle.
• Recommendation 4 of 5 relating to obtaining first accounts from officers involved in incidents of this nature was an issue in the case. Use of a post incident management procedure similar to those used following a police shooting. It affords the SIO an opportunity to have an account from those involved as to what occurred without officers feeing that they are suspects. It will assist the SIO in determining the status of the officers and prevent the slowing down of the investigation in the initial stages. It will also map out the investigation process to the officers involved.
• Case implemented and closed on 29/06/10.
• Result: The recommendation was considered and is included in new SOP for all post incident procedures. Recommendation complete.

Status of implementation of IPCC recommendations

12. The data supplied in Appendix 1 (Part B Exempt) has been manually extracted from the Tribune IX cases and placed into the attached spread sheet to provide information to inform MPA members of the dates and details of learning recommendations made by the IPCC to the MPS. It also outlines the current status of the implementation the recommendations. The data provided gives an overview of learning recommendations received from 01.01.2010 to 01/09/10. However any cases where recommendations have been made, but have outstanding criminal proceedings, or other proceedings that places matters into a position of sub-judice, are not included.

13. The data provided has been redacted and names of members of the public making complaint or deceased have been removed. Case outcomes are described in brief so as not to trespass on any areas of sensitivity or disclose policing methodology. All MPS Policies, Standard Operating Procedure and Intranet notices referred to are available on the MPS AWARE system.

14. The MPS has sought legal advice on the suitability of Appendix 1 for the public domain; it is considered that publishing could lead to the identification of victims or other persons involved in the incidents.

15. Accordingly, the full data spreadsheet has been placed in Part 2 (Exempt) section of the report.

System to monitor impact of learning

16. The MPS has initiated a cross-business group process to ensure that Organisational Learning (OL) is carried out within a defined, corporate process. What this means is that although the nine MPS business groups carry out vastly different functions, they will soon have an approach to OL which is broadly the same. OL is being tackled via a four stage model comprising of Capture, Analysis, Share and Evaluation. This evaluation will take two forms. Following implementation of a piece of learning, the MPS Organisational Learning Team will stimulate local OL leads to conduct an assessment of what has changed. This will be supported by periodic thematic inspections by the MPS Inspectorate Team. The findings will represent a clear audit trail of whether the measures to embed learning have actually worked.

Adjustments to policy or practice

17. Examples of adjustments to policy and practice can be found within Appendix 1. For ease of understanding and reference, the following sanitised example is provided to assist the committee:

• Case 3
• Reference IX/21/10
• Case recorded 23/02/10
• Background; IPCC National “Learning the Lessons” bulletin
• Recommendation 1 of 12. Transferring information from misrouted calls. Report of an assault in a different force area raising issues about the accuracy of information passed on, effectiveness of the process between forces and procedures for emergency operators on transferring calls to other forces.
• Implementation awaiting
• The MPS Central Communications Command have instigated an Action Plan to review and improve all aspects of their call handling procedures - including this recommendation.

Notes of training / support from IPCC

18. Close and effective partnership working exists between all levels of the IPCC and MPS to promote confidence in the complaints process and effective investigations. This was highlighted during the consultation and implementation phases of the new IPCC statutory guidance during which MPS and IPCC practitioners worked closely together and participated in joint training exercises. Additionally, the IPCC has contributed to the training of senior police managers in the management of deaths following contact with police, opportunities presented by the new statutory guidance and changing the complaints culture to one focused upon customer service..

19. Additionally, DPS Borough Support Units meet with their appointed IPCC Senior Manager and caseworkers on a quarterly basis to discuss specific cases and opportunities to improve joint working. 

C. Other organisational and community implications

Equality and Diversity Impact

1. Monitoring the MPS’s response to recommendations for organisational learning increases the lines of accountability to the MPA and wider community; this ultimately strengthens the MPA’s capability to ensure that the MPS acts upon the recommendations that contribute to improvements in operational policing to the benefit of London’s diverse communities. This report demonstrates that there is a systematic approach to continuous analysis, monitoring and review of learning recommendations arising from the IPCC and other sources.

Consideration of MET Forward

2. The capture and implementation of organisational learning following IPCC and other complaints and misconduct investigations, is key to demonstrating that the MPS is willing to listen to feedback, learn from it and evolve as a service. The system to monitor, review and implement IPCC and other recommendations supports both Met Connect and Met Standards in that there is a demonstrable link between organisational learning and service delivery improvement and sustaining and developing higher standards of professional conduct.

Financial Implications

3. All costs relating to the above activities are covered from within existing MPS budgets.

Legal Implications

4. This report is submitted as part of the governance process for the MPA to note the current systems in place to meet the requirements of the Police Reform Act 2002. The requirements of the Police Reform Act 2002 are more precisely set out in paragraphs 593-600 of IPCC revised Statutory Guidance. There are no further legal implications.

Environmental implications

5. There are no environmental implications arising from this report

Risk implications

6. There are no risk implications arising from this report.

D. Background papers

None

E. Contact details

Report author: Detective Superintendent Murray Howell (DPS), MPS

For information contact:

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

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