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Report 6 of the 18 January 2007 meeting of the Equal Opportunities & Diversity Board and presents the status of the MPS Equalities Scheme, a framework which, when complete, will contain the arrangements for achieving equality across the six diversity strands.

Warning: This is archived material and may be out of date. The Metropolitan Police Authority has been replaced by the Mayor's Office for Policing and Crime (MOPC).

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MPS Equalities Scheme

Report: 06
Date: 18 January 2007
By: DAC Diversity and Citizen Focus on behalf of the Commissioner

Summary

This report presents the status of the MPS Equalities Scheme, a framework which, when complete, will contain the arrangements for achieving equality across the six diversity strands. The first phase, published on 4 December 2006, contains details of activities that are common to all strands and the specific activity required to meet the Disability Equality Duty. The report sets out to explain how the scheme was developed, the relationship with the MPS Race and Diversity Strategy 2006 – 9 and also discusses key issues and how the Scheme’s progress will be monitored.

A. Recommendations

That Members:

  1. Note the contents of this report.
  2. Approve the Disability Specific Section of the Scheme and the approach adopted by the MPS in relation to achieving equality in other areas of diversity and the progress being made.

B. Supporting information

1. The MPS Equalities Scheme is a framework that will, when complete, contain both general (or common) and specific sections relating to the six diversity strands. In line with the statutory requirement under the Disability Discrimination Act 2005 to publish a Disability Equality Scheme by 4 December 2006, the Equalities Scheme was published with the general and disability sections complete. The other strand sections will be completed in line with the timetable contained in the Scheme and set to run through to late 2007.

2. A short summary of the Scheme is included at Appendix 1. This text has been published in conjunction with the Scheme as an overview, directing readers to the full scheme document for further information.

3. The publication of the Scheme followed its approval by MPS Management Board on 7 November 2006. It is intended that the Scheme will be presented to the MPA at its Full Authority meeting in February 2007. It was never intended that publication would take the form of hard copy books because of the developing nature of the project. Access to electronic versions is through the MPS’ Internet and Intranet sites, with provision made for the supply of the Scheme in other formats, such as Braille, that are not accessible through this approach.

4. The MPS Equalities Scheme Reference Group, which includes invited representatives from all MPS Business Groups and also key external stakeholders from, for example, the MPA, GLA and our Independent Advisory Groups (IAGs), meets regularly. Members agreed the structure, timetable, scope and contents for the Scheme and will continue to provide advice and guidance.

5. Individuals and communities from across London were involved in the development and content of the Scheme through engagement events held during June and July 2006. The Scheme was also informed by the results of parallel consultation conducted for the MPS Policing Plan 2006 – 7, and other activity conducted by the Territorial Policing (TP) business group in relation to hate crime. Further, Home Office, MPA and mayoral priorities and legislative requirements, such as meeting new specific and general duties in respect of disabled people, drive much of what the Scheme contains.

6. The first consultation draft was produced and published for comment by all stakeholders over a period of six weeks between 4 September and 13 October 2006. During this phase, the document was forwarded directly to each member of MPS Management Board, as well as other key MPS personnel and interested parties outside the MPS. Any feedback received was incorporated into the published version. The main thrust of Management Board concerns related to the need to ensure there is linkage between the overall longer-term budget setting process and the identification of any additional resources that are required to deliver what the Scheme seeks to achieve.

7. These comments also resulted in additional material being inserted. For example, a discrete section on service delivery is now included and, as is stated above, a short summary of the full Scheme is now available.

8. In meeting the general duties contained in the Disability Discrimination Act, particularly those which require organisations to pay due regard to the need to promote the participation of disabled people in public life, the Scheme is available in a number of formats. For example, Braille, Easy-Read, Audio and British Sign Language formats have been produced.

Disability elements

9. The Scheme was produced through direct engagement with, and the involvement of, disabled people. For example, disabled people:

  • Were, through the support provided by the MPS Disabled Staff Association and their own line management, members of the project team
  • Produced discrete sections of the document (e.g. performance section)
  • Continue to be members of the Equalities Scheme Reference Group, providing valuable help and guidance
  • Helped to develop the criteria for assessing corporate policy for relevance and priority
  • Worked together to screen all corporate policies, over 135 in total, for their relevance and priority
  • Worked with the project team to design consultation material
  • Attended and, in some cases, facilitated a series of seminars designed to capture what Londoners expect of the MPS in relation to equalities issues
  • Completed a questionnaire, devised to capture the views of individuals who could not attend a consultation seminar
  • Provided informed comment on the draft versions of the Scheme.

10. Through consultation, engagement and involvement with disabled people, a Disability Action Plan and a Common Activity Action Plan were drawn up; both are contained in the first phase of the Scheme. For example, specific actions are included in the Disability section in respect of:

  • The implementation of the social model of disability
  • Improved services to mental health service users
  • Access to our services and information
  • Physical access to our buildings
  • Sensitivity in the investigation of crime
  • Ensuring engagement with disabled people in our key processes, including emergency planning
  • Recruiting, training, progressing and promoting disabled people in the workplace.

11. In relation to the Common Action Plan, these are some of the areas which also have direct implications for disabled people:

  • Eradication of bullying and harassment
  • Carer responsibilities
  • Monitoring of employment and service delivery activity
  • Delivery of training for all our staff
  • Exit interview processes
  • Staff survey processes.

12. Governance and oversight of the progress towards delivering what the Scheme sets out to achieve is set out in the relevant section of the document. This describes the formation of a new body called the Equalities Scheme Steering Group, made up of key stakeholders. This will, in turn, report to the MPS Diversity Board, which is chaired by the Deputy Commissioner. A new performance management framework will regularly produce information about performance against key indicators as well as the position of each of our units and commands in relation to the Equality Standard for local government. It is intended that external oversight bodies, such as the MPA EODB, will receive regular updates on progress.

The MPS Race and Diversity Strategy 2006-09

13. MPA Full Authority formally approved this document on 23 February 2006. The key elements of this approach are:

  • Achievement of the highest levels of the Equality Standard for local government
  • Adoption of an equality based performance management framework
  • Streamlining equality governance arrangements
  • Effective engagement with all stakeholders
  • Delivery of the Police Race and Diversity Learning and Development Programme (PRDLDP)
  • Impact assessment of MPS policy, practice and procedure

14. In relation to specific diversity strands, the Strategy stated that the Equalities Scheme would set out in detail what is required in respect of each.

15. It was intended that the Equalities Scheme would, when complete, supersede the Strategy. Both approaches are congruent and contain complementary key elements. As the work to produce the Scheme commenced in April 2006, the Strategy drove activity required to achieve the key elements shown above. These activities took place in parallel to the production of the Scheme and will now continue under its auspices.

Achievement of the highest levels of the Equality Standard for local government

16. The MPS is wholly committed to the Equality Standard for local government (ESlg) and achieving the highest standard is a specific action in the MPS Equalities Scheme. Initial project work, in late 2005 and early 2006, 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 taking place across all levels of the MPS.

17. The initial programme of work focussed on an Electronic Self Assessment Tool (ES@T), an existing software package developed and used in over 80% of local authorities. This programme assumed a certain usage level and included some training for MPS staff at five pilot sites:

  • Westminster Borough
  • Royal Borough of Kensington and Chelsea
  • Palace of Westminster (SO17)
  • Specialist Crime Directorate (SCD7)
  • Directorate of Professional Standards (DPS)

18. The pilot sites were to ‘go live’ on 18 September 2006 on the understanding that software would be available to manage the process. On the 15 September, the MPS was informed that due to the work required to make the software fit for MPS user requirements that the cost of delivery would rise significantly. In addition, MPS procurement services were experiencing difficulty in agreeing a binding contract with the owners of the licence.

19. As a result, the MPS decided to adapt a Microsoft product to meet its own needs. This work will be undertaken by Diversity and Citizen Focus Directorate (DCFD) personnel at minimal additional cost and be piloted through the existing identified sites. A system is being developed to be in place in the New Year. The added benefit of this approach is that an Access or Excel database can be used in the existing MPS IT infrastructure and therefore has a greater element of security.

Adoption of an equality based performance management framework

20. The MPS Diversity Board, at its meeting in April 2006, considered proposals for the development of a performance management framework that would support the board in managing organisational performance in diversity, equality and fairness issues. It was agreed that the framework would comprise:

  • An externally focused dimension, ensuring that MPS services are delivered appropriately, fairly and equitably to all communities
  • An internally focused dimension relating to employment practices
  • A dimension that allows a number of enabling objectives (required to support the achievement of the other dimensions) to be monitored.

21. The Board agreed a set of high-level outcomes focused on identifying and addressing disproportionality or differential levels of satisfaction, confidence and treatment. A proposed set of primary performance indicators to measure the achievement of the outcomes was also proposed. The initial set of measures now identified as a result, is focused towards assessing disproportionality across ethnic groups and work will continue to enhance and develop the set of indicators to encompass other diversity areas. The inclusive framework will be fully introduced in 2007; some activity, in respect of ethnicity, has already commenced.

Streamlining equality governance arrangements

22. The new streamlined arrangements set out in the Equalities Scheme, it is planned, will lead to more effective community involvement in oversight, access to relevant information and meaningful progress. It is intended that the first meeting of the Equalities Scheme Steering Group will be set for February 2007 and this group will report to MPS Diversity Board, chaired by the Deputy Commissioner.

Effective engagement with all stakeholders

23. Throughout 2006, in line with the MPS approach to delivering citizen focused policing services, a Community Engagement Strategy, was developed, jointly with the MPA. The Strategy was formally approved on 28 September 2006. It demonstrates the commitment of the MPS to understand what communities and individuals really need, from which, services can be designed to meet those needs.

24. The MPS recognises that actively engaged communities contribute significantly to the improvement of policing services, the reduction of antisocial behaviour and solving crime at all levels. Communities can only make these contributions if the engagement is undertaken with a genuine desire to listen and learn. The Strategy and its accompanying policy and guidance provide MPS personnel with a clear framework to use to ensure that community engagement is inclusive and productive.

Delivery of the Police Race and Diversity Learning and Development Programme (PRDLDP)

25. The strategy for improving police performance in race and diversity covers the race and diversity learning and development needs of the police service in England and Wales. As well as officers at all ranks, it applies to all police staff and the wider police family, including Special Constables and Police Community Support Officers.

26. The Strategy, published in November 2004, sets out priorities and it applies to all diversity areas. An overall aim of this strategy is that, by the end of 2007, priority groups in the MPS will need to have been assessed as competent against the Race and Diversity National Occupational Standards. By the end of 2009, everyone in the police service, including the wider police family, will need to be assessed as competent against the Standards. This was enshrined in the MPS Race and Diversity Strategy.

27. The action that is required to take forward the Strategy is the remit of the MPS Race and Diversity Learning and Development Programme Board. This body has been working since 2005. The latest progress was reported to the EODB meeting of 16 November 2006. The Programme Board commissioned a Performance Needs Analysis (PNA) of MPS staff (by role) against the National Race and Diversity Occupational Standards. This is due for completion in late 2006 and early 2007. The results will dictate how the programme is delivered.

28. The PRDLDP, as a national issue, was discussed at a recent meeting between the Association of Chief Police Officers (ACPO), Home Office and Association of Police Authorities (APA) and representatives of the Commission for Racial Equality (CRE). Police Service concerns over meeting the deadlines set were sympathetically received by the CRE, who suggested that a priority be placed on training key areas, such as managers and supervisors, and that the deadline be extended nationally.

Equality Impact Assessment of MPS policy, practice and procedure

29. The new MPS Equality Impact Assessment (EIA) Policy, with its Standard Operating Procedures, was published at the same time as the MPS Equalities Scheme (4 December 2006). The intention to deliver this framework was fully set out in the MPS Race and Diversity Strategy. It is a new policy, incorporating some existing practice and providing the framework and guidance for conducting such assessments during the development of proposals. It provides the framework for measuring the adverse and positive equalities impact of policing proposals through a structured and transparent process.

30. The definition of ‘proposals’ includes corporate and local policies, corporate change, projects, procedures, functions, strategies, strategic decisions, pre-planned operations, policing plans and schemes. The policy and monitoring of EIAs will be owned centrally by the DCFD.

31. An EIA training course for MPS trainers was held on 6 - 7 December 2006, involving IODA, an external consultancy. The training will subsequently be rolled out across the MPS in 2007 by those trainers to those members of staff who are involved in the commissioning, formulation, approval, publication, implementation or review of proposals. This work is taken forward under the Equalities Scheme.

Barriers to progress

32. What the Race and Diversity Strategy set out as MPS direction has now been incorporated into the Scheme. The level of activity already conducted to take forward what is set out in both, is clearly of a significant nature. Much has been achieved in a relatively short period of time. However, there is much still to do in order that the desired outcomes are achieved.

33. In relation to the ESlg, although the task is now much clearer and an implementation plan has been devised, roll out across the organisation will require effective communication between DCFD and every MPS Unit. Making full use of the framework will be critical. Stakeholders will want to see that using the Standard is beneficial and they will also expect tangible results as soon as is practicable.

34. The performance management framework will stand-alone from the ESlg framework but each will linked to the other. The measures it contains must be relevant, congruent with all other MPS performance management systems and be inclusive of all diversity strands. Those devising the indicators to be included in the framework are fully aware of the scale of their task. The MPS will need to ensure that the information that is collected is used effectively and not collected as an end in itself. It will also require the skills of suitable analysts in order to use the data to identify areas of good practice or potential or actual disproportionality.

35. The arrangements for governance are now set out, but the membership; terms of reference and mandate of authority still require work. Clarity on these matters is important to ensure progress on delivering the Scheme, and other equality based activity continues.

36. Implementation of the new Community Engagement Strategy is key to the MPS meeting its aims. Local practice and procedure must adhere to the corporate vision and direction for engagement in order to be fair and worthwhile. There is an identified risk of disengagement by communities if what the MPS does is conducted solely on its terms and for its benefit. These matters are recognised and a structured monitoring system is planned.

37. The aspirations of the PRDLDP are currently the subject of national debate, to which the MPS contributes (see above regarding CRE comments). The MPS has over 50,000 staff. Providing training to, and assessing competence in the workplace of, identified groups, and ultimately all staff, within Home Office targets will be very challenging. Nonetheless, equipping people to manage diversity in the most diverse city there is, is critical to the MPS meeting its policing priorities. The Scheme will be a mechanism for progressing the PRDLDP in the MPS, taking into account any changes that may come about nationally.

38. Training is also a key issue for the EIA process. Although the new policy and framework have been published, unless staff are confident in its use, are aware of its requirement and criticality in addressing institutional discrimination, it will not be wholly effective. A training programme has been devised but will require time to deliver. This will have an impact on the delivery of the overall process. Although, as the PRDLDP is to be rolled out in parallel and awareness of equality duties is raised as a result, it is expected in time that EIAs will become an everyday part of MPS business, just as health and safety issues now are.

Abbreviations

ACPO
Association of Chief Police Officers
APA
Association of Police Authorities
CRE
Commission for Racial Equality
DAC
Deputy Assistant Commissioner
DCFD
Diversity and Citizen Focus Directorate
DPS
Directorate of Professional Services
EIA
Equality Impact Assessment
EODB
Equal Opportunities and Diversity Board

ES@T
Electronic Self Assessment Tools
ESlg
Equality Standards for Local Government
GLA
Greater London Authority
IAG
Independent Advisory Group
IODA
Individual and Organisational Development and Assessment
IT
Information Technology
MPA
Metropolitan Police Authority
MPS
Metropolitan Police Service
PNA
Performance Needs Analysis
PRDLDP
Police Race and Diversity Learning and Development Programme
SCD
Specialist Crime Directorate
SO
Specialist Operations
TP 
Territorial Policing
TSG
Territorial Support Group

C. Race and equality impact

Equality and diversity is the subject of this report. There are significant diversity implications arising from the Equalities Scheme, notably in the elimination of discrimination, together with the promotion of equality of opportunity, good relations between different groups, positive attitudes towards others and the participation of all in public life. The Scheme will enable the MPS to deliver an ever-higher quality service to all Londoners.

D. Financial implications

The Scheme’s Action Plan sets out the scope of the activities that need to be delivered. Some of the activities are already in train, have funding allocated, and therefore require no new resources. A calculation of projected new costs shows around £300k per year for the first 4 years for this initial phase. It is unlikely that extra funds will be available and therefore this work will result in a realignment of existing resources. As other activities are included in relation to other diversity strands through 2007, extra, but as yet unquantifiable costs may be identified. The benefits of delivering the equalities agenda in terms of staff and community satisfaction and engagement are significant. Likewise, the implications of not delivering could be financially significant in terms of, for example, notices of non-compliance, employment tribunals, levels of complaint, missed recruitment opportunities and overall organisational performance.

E. Background papers

  • MPS Race and Diversity Strategy 2006 – 9
  • MPS Equalities Scheme Phase 1 - 2006

F. Contact details

Report author: Kevin Bowsher, Diversity and Citizen Focus Directorate, MPS

For more information contact:

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

Appendix 1

MPS Equalities Scheme summary

The Equalities Scheme sets the standard for how people can expect to be treated and will help us deliver on the values of the Metropolitan Police Service (MPS). The operational benefits include an improved quality of service, increased trust and confidence within London’s communities and the better recruitment, retention and progression of talented people.

The Scheme also aims to improve the effectiveness of planning processes and help deliver best value in the allocation of resources in line with our Policing London Strategy 2006/09.

The Equalities Scheme sets out how we will meet the legal requirements already governing some areas of diversity. It incorporates all six strands, that is, age, disability, gender, race, religious belief and faith and sexual orientation, with an action plan to drive forward improvement. Equality Schemes are a statutory requirement for all public organisations. They provide a framework through which policies and procedures at a corporate and local level are assessed, reviewed and consulted on to ensure that we promote the positive aspects of the general and specific duties set out in law and also do not discriminate against people. In particular, the Scheme will address the following:

  • Age: set out requirements in terms of employment and the provision of goods and services to people of all ages.
  • Disability: remove barriers, meet the needs of disabled people in its widest sense, and aim to challenge stereotypical attitudes held about disabled people.
  • Gender: cover issues such as: women’s representation; how men and women are treated as customers; domestic violence; and forced marriage.
  • Race: deliver criminal justice fairly and make the MPS a representative organisation and employer of choice, where all can realise their true potential.
  • Religious belief and faith: that religion can be an integral part of self-identity; fully engaging with people of different beliefs helps us meet their needs.
  • Sexual orientation: build trust and confidence within lesbian, gay, bisexual and transgender communities to address their concerns.

Each unit and directorate will be locally and centrally accountable for its ownership and leadership of the equalities agenda. Each will set out and own an action plan based on the Equality Standard for local government, monitored centrally.

The success of the Scheme will be determined by how effectively we deliver our services to all Londoners, how accessible our services are to all, how it improves performance and fundamentally how it contributes to making London safer.

Our governance and oversight arrangements will make sure we deliver what the Scheme contains. Other MPS and non-MPS groups, including our Police Authority, hold us to account if we do not.

The work to include each of the strands will build on what we have conducted in respect of Disability. The Scheme already covers common activities that relate to all strands; however there will be further sections within the Scheme about:

  • Gender Equality (by April 2007)
  • Race Equality (June 2007)
  • Age Equality (August 2007)
  • Equality on Sexual Orientation (October 2007)
  • Religious Belief and Faith Equality (December 2007)

There is a statutory duty in terms of race and disability equality to review the Scheme so that it remains relevant and current. The completed Scheme will be reviewed in late 2007 and three-yearly after that date. In addition, we will provide annual updates on progress, which will include a summary of:

  • What has been done to deliver the action plan; meet targets; eliminate discrimination and promote the positive aspects of equality
  • Results from the performance framework and information-gathering processes, together with what has been done as a consequence.

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