Implementation of IPCC recommendations in investigation reports

Report: 13
Date: 17 March 2011
By: Chief Executive

Director of Professional Standards on behalf of the Commissioner

Summary

With reference to Chapter 5 IPCC revised statutory guidance paras 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

Systems to monitor IPCC recommendations

1. 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.

2. 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.

3. 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.

4. 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.

5. 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.

6. 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.

7. 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.

8. 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.

9. 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.

10. 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.

11. The DPS act as the point of contact between to MPS and the IPCC, as all the learning lessons recommendations are made following a public complaint or a misconduct investigation, which is DPS core business. It is best practice and the most efficient and rational method of working within an organisation the size of the MPS, to have a single point of contact who deals with all such communication. This role as SPOC is one of the functions the DPS organisational learning team performs.

12. The DPS organisational learning teams are not subject matter experts in all areas of policing. DPS does not have governance over the policies, SOP's training etc that the IPCC recommendations look to address. Therefore the DPS OL team must consult with those experts, e.g. Firearms, Custody, Officer Safety training etc. The decision making, implementation and timeliness is then not within the control of the DPS team, but with the business group/OCU owning the matter of issue. The DPS team carries out a supportive role, seeking to assist the implementation, having become experienced in such matters and maintains communication of information throughout the process. The DPS team reports fully to the IPCC at the end of the process and maintains all documents and a full audit trail of any IPCC learning received.

System to monitor impact of learning

13. 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

14. Adjustments to policy or practice follow a stringent format in order that it can be ‘key worded’, monitored and provide a corporate memory of any learning implemented. The following sanitised example is provided to assist the committee of this process:

• 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 has instigated an Action Plan to review and improve all aspects of their call handling procedures - including this recommendation.

Notes of training / support from IPCC

15. 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.

16. 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 (including Health and safety) Implications

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

D. Background papers

None

D. Contact details

Report author: Chief Inspector Adrian Baxter, MPS

For information contact:

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

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