Progress toward the Equality Standard for Local Government (ESlg)

Report: 13
Date: 16 November 2006
By: DAC Diversity and Citizen Focus Directorate for the Commissioner

Summary

The purpose of this report is to update Equal Opportunities and Diversity Board members on the progress for delivery of the Equality Standard for local government and the identification and development of a performance management system to monitor compliance across the MPS.

A. Recommendations

That

1. Members be asked to note work in progress.

B. Supporting information

How is the organisation progressing work against the Equality Standard for local government?

1. The MPS is committed to achieving Level 5 of the Equality Standard for local government (ESlg).

2. Initial project work to deliver this objective focused on the benefits that an Information Technology performance management system would provide by recording and measuring diversity and equality activity at the Operational Command Unit (OCU) level.

3. The Improvement and Development Agency (IDeA) own both the ‘standards’ and an electronic monitoring tool (ES@T) (and through their agency - Diversity in Action in Local Government (DIALOG)) have been working with the Diversity and Citizen Focus Directorate (DCFD) to determine whether ES@T could be made fit for purpose for an organisation of the complexity and size of the MPS.

4. The initial programme of work assumed a certain usage level and included some training for staff at six pilot sites: Westminster Borough, Royal Borough of Kensington and Chelsea, Palace of Westminster (SO17), Serious and Organised Crime Group (SCD7) and the Directorate of Professional Standards (DPS) with the DCFD monitoring this activity at a corporate level (acting as a de facto sixth site) at a projected cost of some £12,000 - £15,000.

5. The pilot sites were to ‘go live’ on 18 September 2006 on the understanding that the ES@T software would be available in an amended version relevant to the MPS, that contractual Terms and Conditions would be agreed and that there would be no additional cost.

6. On 15 September, the DCFD was informed that, due to the work required to make the ES@T fit for MPS user requirements, the cost of delivery would rise to between £45,000 - £55,000. In addition, MPS Procurement Services were experiencing difficulty in agreeing a binding contract with DIALOG.

7. DIALOG went on to say that they “considered the MPS was moving from being a subscriber to a scheme being run by them to the point that they were being perceived as a software provider to the MPS”. In this respect, they wished to make it clear that they were “not in the business of software development for commercial purposes” and, on 29 September, informed the DCFD that they “no longer feel that going forward with the project on the original terms is a viable option”.

8. Despite their reluctance to enter into a business relationship with the MPS, the IDeA, who own the copyright and Intellectual Property Rights (IPR) for the Equality Standard, and ES@T suggested two options, one of which was to purchase the 142 questions contained in the Equality Standard and for the MPS to develop its own performance monitoring system.

9. A report was submitted to MPS Diversity Board on 19 October that contained a number of alternatives. The Board decided that the most cost-effective and timely option was to purchase the questions and progress a linked spreadsheet system that could be rolled out to the pilot sites before the end of 2006.

What level has the organisation reached?

10. Self-assessment, peer review and GLA assessments suggest the MPS is currently at Level 3.

11. Given that the Equality Standard fits the needs of local government, any assessment involves adapting the standard to fit the MPS as a police service.

12. The Equality Standard requires that evidence be formally collated and subject to independent scrutiny at Levels 3 and 5. The DCFD will undertake this function on behalf of the MPS and populate a Corporate Workbook, which will capture strategic policy, Diversity Board direction and good practice gleaned from (B)OCU workbooks.

13. When the corporate workbook and majority of workbooks spread across the MPS indicate Level 3 has been achieved, the Diversity and Citizen Focus Directorate will take on a role as (internal) verifier. Impact Consultants together with other (yet to be identified) DCFD staff will ensure uniformity and ensure that all questions for that Level have been answered to the extent required and that sufficient evidence has been gathered. Once DCFD are satisfied, external verification will be sort from IDeA-trained and approved verifiers.

14. The DCFD has gathered evidence that suggests the MPS has reached Level 4 or Level 5 in certain areas of policing and in some business groups. For example, the MPS has set the standard across the country in engaging a wide variety of stakeholders including minority staff associations, external partners, and critical friends. These groups are involved from the outset in policy formulation and implementation and actively encouraged to participate in Gold groups overseeing sensitive enquiries such as murder investigations. This has filtered through to operational decision-making on boroughs and other operational command units.

15. In addition, the MPS has had in place for nearly three years, Equality Impact Assessments (EIAs) to systematically assess any equalities impact in policies and practice, particularly new ones. Building upon this and after extensive consultation both internally and externally, a new, generic form was published in October 2006. Guidance notes need to standardise both approach and recording methodology.

16. Quite deliberately, the breadth of the policy and activity requiring EIA’s is expansive. The broad nature of the definition of ‘policy’ remains a matter of ongoing discussion so that it includes, for example, guidance notes. When addressed, an effective, consistent and transparent monitoring and review process will be in place.

17. Though it is accepted that on occasions both may be required, the difference between a Community Impact Assessment (CIA) and an EIA is described as follows:

• A CIA is conducted in response to a specific incident or event; and
• An EIA is conducted as part of the planning process for a proposal or response

18. The EIA and CIA are deliberately separated. As an example, a murder will require a CIA to assess community impact and feed intelligence into the investigation. As part of that investigation, decisions will be made which will require an EIA in order to assess equalities impact.

19. EIA’s especially can be viewed as the lynchpin within ESlg of a significant proportion of Level 3 – 5 activities.

20. Until mid 2006, the Equality Standard only acknowledged and evaluated three strands: disability, gender and race. Three further strands have been added: age, faith or religious belief, and sexual orientation. Local government has been given two to three years to ‘play catch-up’ on the latter three strands.

21. The MPS is ahead of the game with regard to service provision. The MPS Equalities Scheme is a framework that will, when complete, contain ‘Common’ and specific sections relating to the six recognised diversity strands. For example, the statutory requirement under the Disability Discrimination Act 2005 to publish a Disability Equality Scheme by 4 December 2006 will be incorporated into the Equalities Scheme and published with the general and disability sections complete. Other strand activity will follow into late 2007 in line with the timetable contained within the Scheme.

22. In the areas of recruitment, selection, retention, training and progression, the MPS is, through METHR, processing the comprehensive capture of lesbian, gay, bisexual and transgender (LGBT), gender, age, disability, faith and race data.

What evidence has the organisation gathered to support its achievement?

23. The MPS recognises that significant evidence exists to support its achievement within the Equality Standard and is engaged in the process of developing an appropriate performance framework to capture and measure its performance against the Standard.

24. It is anticipated that, following a six-month pilot and subsequent review, an appropriate toolkit will be rolled out across the MPS to monitor diversity and equality activity. Additionally, the imminent recruitment of Impact Consultants will provide independent scrutiny and a means of assessing the preparedness of the organisation for external verification.

How has the level achieved been verified?

25. Prior to June 2006, the MPS self-assessment of Level 3 depended upon peer review and agreement by the GLA. In developing its performance-monitoring framework, the MPS intends to incorporate external verification into this key process.

26. Whilst it is true to say that Level 5 always required external verification, official verification has never been sought.

What processes exist for measuring continuous improvement?

27. A software system is being developed for use on six pilot sites. The success of which will be overseen and evaluated by the DCFD. Once the performance measuring system is operating, the MPS will require the services of a DIALOG-approved consultant who will advise how verification is achieved, given the scale and complexities of the MPS. Formal verification will then be sought at the appropriate time. It is intended that this will be the responsibility of the Impact Consultants of the Diversity Directorate.

Has use of the Equality Standard led to improvements in performance? If so, where and how?

28. The MPS published its strategic intentions for delivering improved performance in its Race and Diversity (Confidence and Equality) Strategy in April 2006.

29. Central to the success of this strategy is the development of the MPS Equalities Scheme (ES) which will integrate actions specific to our existing Race Equalities Scheme with activity explicitly identified to deliver our obligations on Disability (December 2006) and Gender (April 2007).

30. Together with the ESlg, the MPS Equalities Scheme will define strategy and performance measures for the MPS and will be measured through the proposed performance framework.

How does the MPS ensure that all parts of the organisation, including all directorates and boroughs, are engaged in this process?

31. Notwithstanding the responsibilities of each Operational Command Unit (OCU) under legislation, all managers and personnel are subject to performance measurement in respect of diversity through the Performance Development Review (PDR) system, selection and promotion evidence. The developing structure of the Diversity and Citizen Focus Directorate, including the deployment of Impact Consultants, will further impact in this area.

32. MetHR is being developed with a self-service capacity that allows staff to update and be responsible for their personal records. This will have an additional capacity, protected by a system of 'confidential screens', which will allow the workforce to enter ‘sensitive’ diversity data on MetHR. HR Directorate is looking at a launch date in January 2007.

33. In November 2006, the HR Directorate will activate a website whereby the workforce can post questions in the months leading up to the launch. Any and all queries/concerns will be posted anonymously on HR Business Support intranet site.

34. In addition, a census week will run towards the end of January 2007 where officers and staff will be encouraged to update their personal details through self-service. Scheduling reflects the intention that the 'confidential screens' be up –and running. Once again, this will be advertised through a range of sources such as corporate news and e-mails to HRMs.

34. Through the MPS Equalities Scheme, diversity and equalities activity will be mainstreamed into all elements of service delivery and employment. The structure is such that it will lead to a better working environment and a higher standard of service provided to communities, with the MPS demonstrating how we value and respect difference.

What has proved successful?

35. A notable success has been the Cultural Communities Resource Unit (CCRU), a Level 5 activity presently being replicated by ACPO nationally. Their success in valuing a diverse workforce, tackling crime and raising morale is significant. There is clear evidence that over 800 police officers and staff feel valued for ‘who’ they are individually, that their diverse backgrounds are valued in policing and that they are confident to offer up their life experiences to assist with operational policing needs, where they make a real difference to performance and confidence.

36. Three of the designated pilot OCUs have held ‘Race and Diversity Forum’ meetings. The attendees are external as well as internal, and the Chair is invariably the OCU Commander. A process map has been designed to guide the OCU Commander and designated staff through the Equality Standard and also shows the links between each function.

37. The MPS is recognised as being at the forefront of diversity activity to improve performance and effect change. Family Liaison, Hate Crime investigations, Community Consultation, Independent Advisory Groups (IAGs), through to Mentoring Schemes, Female and Ethnic Minority Detective Training Programme and its innovative work on gender are evidence of this and have been copied nationally and internationally as examples of best practice.

38. Staff Support Associations are frequently involved and engaged at both operational and strategic levels. The process map devised by the Diversity Strategy and Co-ordination Unit (DSCU) to run in conjunction with the Equality Standard pilot makes clear their role, not least in the area of Equality Impact Assessments (EIAs).

What has proved less successful?

39. The Equality Standard requires detailed recording of diversity and equality activity. As a large organisation delivering complex services, preparing the MPS for capture of this evidence has been a more difficult process than for local government.

40. A durable, robust Information Technology performance management system is required to provide an auditable and accountable framework for recording diversity and equality activity. Initial project work focused on ES@T (designed for local government) and its capabilities. It is recognised that the software has merit primarily as a data collection tool. It is believed that the best way forward will be by the MPS developing its own Microsoft Excel-linked spreadsheet system.

How is the work on the Equality Standard linked in to other equality work streams e.g. Disability Equality Scheme?

41. In the MPS Equalities Scheme, the Equality Standard for local government (ESlg) underpins any EIA of MPS functions and policies, coupled with legally governed drivers (legislation). The Equalities Scheme stipulates that all functions should provide a fair and equally accessible service to all our customers in line with the Standard. It continues by saying that the Standard enables us to mainstream the six strands of diversity into related policy, practice and procedure at all levels of the organisation to ensure continuous improvements are made to equality practice.

42. The ES concludes that the Standard provides:

1. a systematic framework for the mainstreaming of equalities across all of our Borough and Operational Command Units or (B)OCUs, and a structure which helps us meet our obligations under the law;
2. Integration of equalities policies and objectives with Best Value. Encouragement for the development of anti-discrimination practice appropriate to our context;
3. A platform on which to continue tackling institutional discrimination; and
4. A framework for improving performance.

43. The MPS sees the following links between the ES and the Standard:

1. The development of an equality-based performance management framework, achievement of the highest level of the Standard as an explicit element of the Scheme’s action plan;
2. Common governance arrangements;
3. The use of language common to both; and
4. Setting out where each unit is in relation to the Standard will demonstrate how well we are doing in delivering the Scheme.

44. The Equality Standard is the primary tool for achieving the aims of the Equalities Scheme. The monitoring, engagement and review processes that go with the Standard run hand-in-glove with the measurement of the Scheme’s effectiveness.

What are the next steps for the organisation in order to reach the next level?

45. An MPS Corporate Workbook will be recording data by the end of 2006. The workbook will be populated with evidence from the six pilot sites and major policies, committee reports and other strategic key diversity indictors. It will be maintained by the DCFD on behalf of Diversity Board and will enable the MPS to produce an auditable record of diversity activity across the pilot sites. After a period of assessment, it is anticipated that a performance management framework will be adopted MPS-wide to capture all (B)OCUs’ initiatives and activities.

What barriers are there to achieving the next level and how can the MPA assist the organisation to remove those and achieve further?

46. The challenge for the MPS continues to be the identification and development of an appropriate performance management system to cater for the complexities and scale of an organisation with a workforce of 50,000. Significant progress has been made in the search for an appropriate framework and the MPS are continuing to make progress in this area.

Abbreviations

BOCU

Borough Operational Command Unit

CCRU

Cultural Communities Resources Unit

DeA

Development Agency

DCFD

Diversity & Citizen Focus Directorate

DIALOG

Diversity in Action in Local Government

DPS

Directorate of Professional Standards

DSCU

Diversity Strategy & Co-ordination Unit

EIAs

Equality Impact Assessments

ES

Equalities Scheme

Esig

Equality Standard for local Government

ES@T

electronic Monitoring Tool

GLA

Greater London Authority

IAG

Independent Advisory Group

LGBT

Lesbian Gay Bisexual and Transgender

PDR

Performance Development Review

OCU

Operational Command Unit

SCD

Specialist Crime Directorate

C. Race and equality impact

The ESLG captures focused data mainly using a self-assessment process. Attaining the higher Levels represents an unparalleled opportunity for improved practice and performance across the whole MPS.

D. Financial implications

The cost to the MPS of a licence for use of the Equality Standard is likely to be in the order of £5,000 - a one-off payment to DIALOG. There are existing costs of £6,300 incurred for training days, liaison, negotiation and staff time also payable to DIALOG. Any additional cost in developing the management framework for the pilot phase will be borne by the DCFD out of existing resources. A fee for independent assessment against the Standard will be required at a future date. The exact figure is yet to be established, but the total expenditure (licence, training, etc and consultancy) is unlikely to exceed the initial agreed £15,000.

E. Background papers

None

F. Contact details

Report author: Stephen Warwick, Inspector, Diversity and Citizen Focus Directorate, MPS

For more information contact:

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

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