Directorate of Professional Standards: IPCC Quarterly bulletin performance review - KPIs

Report: 13
Date: 13 October 2011
By: Director of Professional Standards on behalf of the Commissioner

Summary

This paper summarises and reviews key headline MPS performance data contained in the IPCC quarterly bulletin and discusses upcoming issues and barriers to performance.

A. Recommendation

That Members review and note the content of this report.

B. Supporting information

Quarterly IPCC performance bulletin and headline changes in MPS performance

1. Since April 2009 the IPCC Quarterly Performance Bulletin has been produced from data collected from forces at the end of every quarter. The report consists of a range of performance statistics against indicators agreed with forces and other policing organisations.

2. The IPCC Quarterly Performance Bulletin is already provided directly to the MPA by the IPCC and it is now also published on the IPCC website. These statistics were designed to allow the Police Forces performance to be reviewed against their most similar family of forces (in the case of the MPS this is West Yorkshire Police, West Midlands Police and Greater Manchester Police) and a national average. Previously forces managed their performance data in slightly different ways which did not allow for effective comparison or analysis of performance at a national level.

3. As agreed with the MPA in the last paper submitted to SOP the MPS will base all future reporting on these figures and focus on improving performance against these drivers. This has required changes to MPS performance data as previously produced MPS reports were not comparable with IPCC data. This shift in policy will allow for continuity to be established and the quarterly bulletin will allow more effective assessment of MPS performance by baseline comparison against the most similar force family.

4. The IPCC statistics contain headline performance figures in relation to key areas of DPS performance: average number of days to finalise investigations (local, supervised and local resolution), percentage of appeal types upheld, percentage of complaint cases recorded within 10 days, appeals to the IPCC as a percentage of allegations completed (local and supervised investigations as well as complaints locally resolved) and average number of days to finalise complaint cases (including and not including sub judice cases).

5. These figures are supported by further diagnostic information which breaks complaint data down into: number of allegations per 1000 employees, percentage of incivility, impoliteness and intolerance allegations, percentage of neglect of duty or failure in duty allegations, percentage of oppressive conduct or harassment allegations, percentage of other assault allegations, percentage of unlawful/unnecessary detention allegations, percentage of allegations discontinued, percentage of allegations dispensed and percentage of allegations withdrawn.

6. Work is ongoing to rationalise MPS performance statistics with those of the IPCC ensuring that the same counting rules are used to consistently drive performance. It is anticipated that this will be in place by the end of the next reporting period.

Key Performance Issues

7. The figures (contained at appendix A) have been provided for April 2011 to June 2011 by the IPCC and the following key areas of Table A (Key indicators in the handling of complaints) have been identified for discussion (improvements or decreasing performance, failing to meet or exceeding targets):

Average number of days to finalise local investigations

8. The IPCC figures show that it takes the MPS an average of 70 days to locally investigate a complaint; this figure is not just DPS investigations but also includes local investigations that are managed by the business areas concerned. This shows a reduction of 4 days from the last reporting period and compares very favourably to the average figure for the same period last year which was 84 days, demonstrating a continuing downward trend. It is also considerably below the MSF average of 116 days and the 130 day national average. The DPS BSU’s are working to drive performance through development of a performance management framework. The paperless system continues to develop following introduction by the Customer Services Team to allow for a quicker progression of cases from first point of contact through recording, severity assessment and allocation whether within the Borough Support Units or within other business groups.

Average number of days to finalise supervised investigations

9. The national average of days taken to finalise supervised investigations sits at 413 days showing that there are clearly issues across the country in terms of the ability to deliver quick resolutions when more sensitive investigations are supervised by the IPCC. The MPS average figure of 247 days is slightly above the MSF average but well below the national average.

10. The figures produced by the IPCC do not tally with those produced by the DPS. The IPCC were contacted and the issue was discussed, it was concluded that the figure that they produce includes the time taken when the matter is referred back to the IPCC, which considerably increases the average.

11. A full review of the statistics revealed that in addition to the time that the matters are with the IPCC, the figures are skewed by one case which was recorded in 2006. The original matter was dealt with however another issue was raised in 2011 and because the case was originally recorded in 2006 this was the start date used in producing the statistics. The matter was swiftly concluded, however it had an adverse affect on performance reporting. Without this case the figure would be approximately 182 and would still include time that the case spent with the IPCC. This would be below the MSF average.

12. To add some further context, in the reporting period 82 cases were referred to the IPCC and 12 were identified as supervised investigations. By their very nature they tend to be more serious or contentious than the norm so often require a more rigorous investigation and also require IPCC oversight at various stages.

Average number of days to finalise local resolutions

13. Local resolutions are largely carried out by the B/OCUs where the incident took place. MPS figures show that 69% of complaints that were locally resolved were resolved at a local level and the majority of these were resolved on B/OCU.

14. Over the past year the average number of days taken to finalise locally resolved complaints has risen from 53 to 57 days. There had been a slight increase from 54 to 57 in the last quarter. This general level of performance is easily comparable with the average for most similar forces which is 56 days and against the national average which is 59 days. This level of performance shows that resolutions within the MPS are being effectively managed. The ownership of the complaint sits with the borough but monitoring in terms of management of the process is carried out within the DPS Borough Support Unit in order to ensure that there is compliance within time limits.

15. The IPCC also produce figures for the average number of days to finalise complaint cases both including and not including sub judice cases. This figure is somewhat misleading as it represents the time period from point of recording to the point where the case is filed. This means that administration processes, misconduct meetings and significantly gross misconduct hearings can drastically affect these figures. For both of these figures the MPS are slightly above the MPS and national averages however this figure when compared to the performance discussed in points 6-9 show that the service provided to the complainant is good and that the delays are post ‘finalisation’ of the allegation.

Incivility, impoliteness and intolerance

16. Performance has remained unchanged for the second reporting period in succession in terms of the percentage of total complaints. Performance has also been maintained from the same period in the last financial year. The MSF and national average are both 17% also having remained unchanged. This maintenance of performance reflects the amount of work that has been done around incivility. MPS figures for incivility show that for the rolling 12 month period to the end of June the percentage of all allegations remained static, but the total count of allegations reduced by 14%. A considerable amount of work has been carried out in terms of reducing incivility complaints. The work highlighted previous reports to this meeting documented work completed with the Territorial Support Group to reduce incivility complaints.

Neglect or failure in duty

17. Neglect or failure in duty allegations continue to account for the highest proportion of total allegations. According to IPCC figures making up 33% of recorded allegations. This represents a 1% increase from the same period last year. Most similar force average in this area is 20% and the national average is 27%.

18. MPS figures on failures in duty show that in the year to the end of this reporting period there has been a reduction in terms of total allegations concerning failures in duty by 7%. The MPS category is far wider at present than the IPCC figure encompassing far more complaint areas; work is ongoing to rationalise this without losing comparative data for corporate memory.

19. Commander Zinzan is the appointed ACPO lead in this area and he works with the ten Boroughs identified as poor performers to produce action plans to improve performance. The Boroughs currently subject to this additional management are Hackney, Westminster, Redbridge, Brent, Ealing, Hammersmith and Fulham, Lambeth, Lewisham, Merton and Wandsorth. The extent of the work was detailed in previous performance papers; however it can be shown in MPS reporting for the same period that the majority of the ten boroughs had seen a substantial decrease in failure in duty allegations.

20. TP have taken a great deal of responsibility for managing their performance around complaints and professional standards. The DPS Performance Analysis Unit (PAU) produces a range of headline and diagnostic performance figures which are used by TP to identify Borough performance in terms of complaints.

21. As discussed in the previous paper recurrent topics, trends and patterns of behaviour are reported in the DPS Strategic Intelligence Assessment. The control strategy priority areas considered by this analysis are failure in duty, incivility, information misuse, integrity assurance and corrupt officers or those that would seek to corrupt. Each of these control strands has an ACPO lead ensuring activity. The strategic oversight of this work is provided by the Professional Standards Strategic Committee chaired by the Deputy Commissioner.

Review DPS performance against the old MPA performance indicator of the amount of time taken to finalise public complaints

22. The performance indicator that the MPA has previously set around the management of complaints requires that all complaints are dealt with within an average of 64 days. After this reporting period the MPS will no longer report on this figure but instead will drive performance in line with the IPCC performance statistics which contain a similar indicator. This will assist the DPS move towards corporate performance management and allow national benchmarking.

23. The average MPS figure for dealing with complaints that are submitted to the MPS is 57 days. This includes all modes of investigation and also allegations by result type. This figure does not directly compare with the IPCC performance data and therefore it is not possible to compare the figure to most similar forces and there is not a national average. The difference with the figures discussed earlier is that this figure considers all complaints not just those subject of local investigation. This figure also does not consider the administration and filing process after the investigation has been concluded.

24. As discussed above in relation to the resolution of local investigations this figure will be addressed further by the Borough Support Performance Framework which will demand more intrusive supervision of investigations and an increase in proportionate responses to public complaints.

Key challenges, successes and risks regarding the management of Professional Standards

25. As previously highlighted in earlier performance reports the MPS faces challenges around professional standards in the next year. These challenges are the Olympics, budget reductions and the implementation of the Police Reform and Social Responsibility Bill.

Police Reform and Social Responsibility Bill

26. The Bill has now received Royal Ascent and the first set of the changes will take effect from January 2012. These changes include the introduction of the Mayors Office for Policing and Crime and will see ACPO complaints fall under the Commissioner as the appropriate authority. Further changes under the Act will be introduced in November 2012 and will affect the way public complaints are handled.

27. The DPS Director is sitting on the London Transition Board and the DPS strategic lead for the Police Reform and Social Responsibility Bill is working closely with the MPA and the IPCC.

2012 Olympics

28. The volume of visitors to London for the 2012 Olympics and the volume of additional policing resources means that there will be a substantial mutual aid influx into London for the period of the games. The nature of the event is not one that automatically lends itself to confrontation or high numbers of public complaints however it must be considered and provision must be made for all eventualities to ensure that additional complaints can be effectively dealt with, without having a detrimental effect on normal business.

29. It has been determined at national level that the appropriate authority for officers working in the MPS area will be the Commissioner and therefore for the purpose of public complaints & discipline it will be the responsibility of the DPS. Work continues to provide details to forces providing mutual aid to disseminate prevention tactics and Organisational Learning prior to deployment in the MPS. The DPS strategic lead regularly attend the Olympic Strategic Co-ordination meeting to ensure that AC Allison is fully sighted on DPS issues.

August Disorder

30. In order to ascertain the level of public complaints caused by the disorder during August a snapshot has been taken of the overall number of public complaints received by the end of August 2011. It has been shown that public complaints actually decreased by 7% in the year on year figures (from 7301 to 6774). In relation to Op Withern, which spanned the disorder and also the arrest phase that followed, 25 public complaints have been recorded with 39 separate allegations. Considering the problems that occurred and the level of mutual aid deployed this should be seen as a considerable success.

31. The ethnicity of complainants has also been reviewed for this period and it can be shown that there has been a slight increase in white complainants from 31% to 32% and a related 1% drop in the number of complainants whose background was unknown.

Complaints Intervention Scheme

32. The Complaints Intervention Scheme (CIS) continues to manage officers who are subject of three complaints, civil actions, or conduct matters within a 12 month period. The scheme was described in detail in the previous paper submitted.

33. During the previous quarter there has been a further reduction in officers who are subject to the scheme. The number of staff on the scheme continues to fall, in this reporting period the number has dropped from 365 to 326. Out of this total the overwhelming majority 74% (242) have 3 events. There are 32 officers (10%) with more than 5 events. There has also been a further reduction in the number of Territorial Support Group (TSG) officers from 27 to 21 during the first quarter of 2011. This demonstrates the ongoing success of the scheme and the work that has been done by DPS Prevention and Reduction team to provide guidance to supervisors in complaint management.

BSU Modernisation

34. As part of the business planning process DPS are considering options around making savings from within the Borough Support Unit in order to contribute to the 2012-15 medium term financial plan that is currently being developed. The Project Lead, Superintendent Glenn Tunstall views this as an opportunity to modernise the business area and deliver more for less by updating working practices and business models.

35. The identified drivers for change within the BSUs are: to align with TP Development, work with PSD modernisation, increase corporacy within the Borough Support Units, develop new working practices demanded by the Police Reform and Social Responsibility Bill and reduce costs.

36. At the present time a 1 site and a 2 site options are being considered and a decision on the preferred option will be made before the end of 2011. Once the decision is made a full system/process review will be put in place to deliver the changes without having a detrimental affect on performance.

C. Other organisational and community implications

Equality and Diversity Impact

1. When complaints are taken from members of the public diversity information is collected from them to allow an accurate picture to be built up of the background of people who make complaints to the MPS. The proportions of complainants by ethnicity have remained stable over the past three years. The rolling yearly figures at the end of the reporting period showed 31% of complainants were white, 15% were black and 7% were Asian. 1% were recorded as other and 46% unknown. Compared to census data this does not highlight any issues. This figure is reviewed on a monthly basis to ensure that any potential for adverse impact can be acted upon.

2. Data has also been reviewed for the other protected characteristics of complainants for: age, gender, religion, sexual orientation and deaf or disabled people. Complainant gender and age have been reviewed against census data and there is a larger percentage of males who make complaints. In terms of age there is an even spread which is comparable with census data. In relation to the other characteristics of religion, gender and deaf and disabled people the overwhelming majority of people have not provided this information. The diversity break down of complainants will be reported on for each reporting period and work has been initiated with DCFD to obtain IAG feedback on the service provided to complainants.

3. Following the recent Equality Standards Audit all BOCUs received an action to engage with their communities around the complaints process. DPS and DCFD assembled a ‘Complaints - Public Engagement Focus Group’ consisting of BOCU representatives to assist in this regard. The aim of the focus group is to identify & develop good practice for engagement.

Consideration of Met Forward

4. Met Forward has been considered and the area of public complaints impacts quite considerably on public confidence. Met Connect, Met governance and accountability, Met standards and Met people are all affected by our ability to effectively resolve complaints against officers.

Financial Implications

5. When decisions are made about the BSU modernisation program full staff association consultation will take place before any reductions are made, and any savings that arise from this will be built into the 2012-15 medium term financial planning process.

6. When more information is available about work to be done to meet the requirements of the Police Reform and Social Responsibility Bill and the demands of the Olympics it will be reported on and the financial implications considered.

7. All other costs associated with managing and dealing with the issues set out within this report are included within existing budgets as agreed within the latest version of the Business Plan.

Legal Implications

8. There are no direct legal implications arising from this performance monitoring report which is presented for information only.

Environmental Implications

9. There are no environmental risks associated to this paper.

Risk Implications

10. There is a risk that if public complaints are not dealt with effectively public confidence could be affected. The information produced by the IPCC in the quarterly bulletin is also now available to the public via their website.

D. Background papers

None

E. Contact details

Report author: A/DI Guy Wilson - DPS, Superintendent Glenn Tunstall - DPS, MPS

For information contact:

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

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