Update on the programme for the fundamental review of the Directorate of Professional Standards

Report: 6
Date: 12 January 2006
By: Commissioner

Summary

The purpose of this report is to update the Professional Standards and Complaints Committee (PSCC) on the progress that has been made to develop the proposals suggested by the review of the Directorate of Professional Standards. It details the product of command team meetings, summarises the issues examined by the project board and details the activity and plan for future engagement with internal and external stakeholders.

The intended mechanisms to promote a prevention culture are explained and an update is provided to show how the proposed changes will interface with other key MPS strategic initiatives. The timescales for the completion of various programme elements are described and reflect the need to complement other existing corporate schedules specifically in relation to finance and resource planning activity.

A. Recommendations

That Members Members approve the proposals and timescales for continuing to develop and implement the new structures and practices that are recommended by the review.

B. Supporting information

1. The Directorate of Professional Standards (DPS) Review – Detailed Aspirational Model and Interim Model upon which the programme is being developed. The timetable of events for the DPS service review (both overall time scales and key milestones), details of the consultation and engagement that has taken place with stakeholders and staff, the three high level diagrammatic representations of the proposed structures and functions for the Intelligence, Prevention and Enforcement Commands are outlined in Appendices 1-4 (circulated as a separate document with the agenda).

Outcome of meetings of the Command Team

2. The Command Team met on 17 November and endorsed the forthcoming consultation and development days that were being held with staff from the DPS senior management team and independent challenge panel. It was agreed that the outcomes from these two events would be crucial to defining the work that needed to be conducted within the coming weeks.

3. The need to be clear about budgets, resource requirements, command structure, processes and performance measurements was identified. There is a need to develop what the new DPS processes would look like and what resources would be required to implement the recommendations of the DPS Review. It was reported that the MPS was facing a challenging time in relation to finance and additional pressure would be placed on the budget by the implementation of neighbourhood policing.

4. In order to progress activity, within tight timescales, it was decided that responsibility for progressing strands of specific activity within the DPS Review would be given to staff outside of the core Review Team. It was agreed that this was necessary to allow for more detailed predictions to be made in relation to the personnel and finances that would be required to implement the model to be available by mid January 2006.

5. The Command Team acknowledged that the DPS Review will represent significant change for the DPS and will make intelligence the brain and prevention the heart of DPS business. The review presented an exciting year ahead and would give the DPS an opportunity to deliver a structure/model for professional standards nationwide.

Summary of proposals and issues examined and agreed by the Project Management Board

6. The Project Board met for the third time on 9 December 2005. They were particularly interested in obtaining the details of the minimum models outlined in Appendix 4a-c for the three new commands of Intelligence, Prevention and Enforcement.

7. The Detective Chief Superintendent representing each of the three new commands outlined their visions for their individual commands and received questions and challenge from the business group representatives.

8. It was noted that some areas of new business might provide specific opportunities to embrace the workforce modernisation principles of staff mix and allow for police staff roles in what were previously police officer posts. Further to this, historically almost all officers in DPS have been detectives and this concept should be examined further during the review.

9. The term ‘Enforcement’ command was felt to give the wrong impression of the work carried out by the teams situated in this OCU. ‘Enforcement’ was felt to be too strong a term and suggested an inaccurate representation of the commands role and purpose. The Review Team will further explore this issue in consultation with other stakeholders.

10. The concept of the DPS Reception was agreed to be the right way forward but it was recognised that it must be serviced by staff with the correct skills, who are supported and equipped with suitable Information Technology (IT). This is to be further examined in the next phase of work.

11. The appropriateness of the accident claims department sitting within the DPS was raised by the Project Board. The Review Team explained that by restructuring the commands, and bringing accident claims alongside the civil claims unit, greater use could be made of the existing proactive active investigation team. This had the potential to reduce the number and size of claims that were being made and offered the prospect of producing substantial savings in terms of legal and compensation costs for the MPS. The issue of insurance policy costs remaining within DPS was seen as a separate issue. The Review Team undertook to examine these issues further.

12. The Project Board believed that work needed to be undertaken to outline how the success of this project would be measured. It was agreed that some of the present performance measurement indicators were related to outputs, such as the number of lectures delivered, rather than outcomes that would show the effectiveness of what was being delivered. A range of outcome focussed performance management indicators will therefore be established after the OCU resource allocation process has been completed.

Consultation and stakeholder engagement

13. The Review Team has consulted with a range of stakeholders in a number of ways and situations as outlined in Appendix 3.

14. Consultation is now possible to be undertaken in a structured manner as the model and proposed structures are more defined. The key area of consultation will be to establish the difference that the changes will make in delivering a policing service that increases the confidence of Londoners and all MPS staff.

15. Whilst concentrating on the direct impact that the changes to the DPS will have on how we receive, investigate and ultimately deal with complaints and misconduct, the broader, and equally important, aspect of creating and enhancing the access, confidence and trust in communities and staff to bring matters to notice is essential.

16. The above will allow the review and subsequent full implementation of the model to:

• Identify ongoing training needs.
• Understand and identify any issues concerning the points of access to the complaints process.
• Refine the requirements in IT.
• Identify the points of greatest significance for the various groups to inform the timetable for of implementation.
• Scope the difference that the new way of working will make and create outcome measurements.
• Encourage openness and transparency around the activities of the directorate.
• Engender trust and confidence in the various activities of DPS.

Independent Challenge Panel

17. The Independent Challenge Panel met, for the first time, on the 28 November. The panel, chaired by Dr R. David Muir, was initially given a briefing as to the drivers for the review, the processes that had been undertaken to date and the proposed activity for the next phase of refinement and implementation.

18. The panel praised the team for the hard work and effort that had been put into the review so far and acknowledged that with any change programme there would be a degree of resistance and barriers to overcome. The panel then questioned the Review Team and sought clarification around certain parts of the presentation and identified issues they thought should be given further consideration.

19. There was as understanding within the Review Team that the IPCC were engaged in considering the definition of minor and gross misconduct, this being one of the criteria for deciding if a complaint should be dealt with locally or centrally by the DPS, and an important part of developing the devolved local resolution complaints model. It was clarified that the IPCC were not in the process of developing a definition of misconduct. Therefore, any planning around that definition being finalised in the near future needed to be reconsidered.

20. This matter has now been referred to the Home Office and we are awaiting their response. It is anticipated that the definition will come from one of the Police Advisory Board working committees which is due to report in October 2006. This matter will be pursued and time frames established in the coming weeks.

21. It was acknowledged that internally there appears to have been a real effort to consult staff through the staff support associations. A challenge was raised as to what wider stakeholder and community consultation had taken place. The observation was made that the MPA had been closely involved in the review but questioned if there had been any direct involvement or engagement with the GLA. It was felt this was an important issue as the effectiveness and access to the Police Complaints process would have an impact on the trust and confidence in the police amongst the communities of London.

22. To further enhance the engagement and consultation process a number of initiatives will take effect in the coming weeks. Planning has commenced to diary events to ensure that the maximum value is obtained within the tight timescales and individuals’ availability over the forthcoming holiday periods. These will include:

• Wider community engagement through the Diamond Support Group via DCC4
  • Provides the ability to survey a cross section of individuals and for their responses to be collated.
• Briefings to other interested parties
  • Major stakeholders and individuals who might hold a particular interest including, The GLA, MPA, Independent Advisory Groups (IAGs), Police Federation and Superintendents Association.
• Focus groups
  • To engage community, cultural and consultative groups to ensure communication with a diverse cross section of the communities we serve.
  • Internally to police officers of all ranks so that the impact of the changes upon them as initial recorders of complaints, investigators, persons subject of complaints or complainants themselves can be appreciated, understood and refined.

23. The panel questioned the linkages between complaints made against Police Officers and other non-warranted staff, particularly Police Community Support Officers (PCSOs). It was acknowledged that having two separate processes to resolve a matter that two individuals working alongside each other could be involved in, especially with the closer working practices created by safer neighbourhood teams, was less than perfect.

24. It was acknowledged that this is a national problem with the resolution ultimately being the responsibility of the Home Office. The review team undertook to explore the issues from an MPS perspective with the Director of Human Resources (HR).

25. The issue of potential moves to change the role of police officers to ‘employees’ under employment law was considered and it was suggested that the potential implications of that should be anticipated. This is also to be explored with the Director for MPS HR.

26. The various references to recent high profile reports was noted and the desire to ensure that recommendations from them were considered and addressed during the review. The absence of any mention of the Verdi Report by name was mentioned and the panel recommended that the progress of that report should be checked to ensure that any specific recommendations arising from it are accommodated within the new model. This issue is being researched so that any recommendations can be measured against the new model.

27. The absence of any financial information or measurable outcomes within the presentation or reports was remarked upon. The need to have a sound financial basis upon which to take the review forward and some tangible outcomes by which achievement could be measured was seen to be desirable.

28. The financial aspects are being specifically addressed in the next phase of the process. Operational Command Unit (OCU) Commanders and function leads are completing a series of templates, under the headings of personnel, finance, accommodation and IT requirements that will be used to break down costs and expenditure to allow accurate financial comparisons between the existing and proposed models. A set of measurable outcomes are additionally being collated so that the Command Team can select and specify targets and performance related indicators against which success can be measured.

29. The panel questioned if the label of ‘Enforcement Command’ was appropriate. Concern was raised that this name could send a message that may suggest the OCU was only concerned with enforcing discipline and not investigating the issues and achieving balanced conclusions. It was explained that the name ‘Enforcement’ came from the National Intelligence Model definitions and strategically defined the three commands under Intelligence, Prevention and Enforcement. It is acknowledged that perceptions play a large part in creating confidence and that the naming of the commands would be reconsidered within the wider consultation programme.

Creation of a prevention based culture

30. The DPS began working towards a prevention-based culture, with the establishment of the Prevention and Reduction Team in April 2004. The team initially focussed on prevention initiatives in respect of deaths following police contact. This remit has begun to expand and now seeks to learn lessons from all other DPS investigations.

31. Recognising the potential, the Director and Deputy Director DPS have sought to place prevention at the heart of all future DPS work. To that end a Prevention and Organisational Learning Command is being formed as part of the ‘New Way’ model. The new command, headed by a Detective Chief Superintendent, will have several key and distinct elements to progress a prevention-based culture.

Prevention and Reduction Team

32. This team will be responsible for gathering opportunities to learn lessons from DPS and IPCC investigations, other Police Forces, agencies and stakeholders. The team will have a dedicated research capability to scan and identify best practice and learning opportunities.

33. Having gathered this information the Prevention and Reduction Team will ensure learning is available on databases and promulgated to MPS staff. An auditable record will be created of the learning opportunities identified and the impact of subsequent dissemination of those lessons on performance and professional standards will be monitored.

34. Training will have a significant impact in developing a prevention-based culture. To that end it is intended that the current training undertaken by the team will be expanded to cover all aspects of DPS work including professional conduct, ethics, corruption, issues relating to deaths in custody and fatal police collisions.

35. The aspiration is for training to be delivered to all newly promoted first line supervisors including custody officers and inspectors and also to dedicated detention officers, probationers and recruits. The capacity of the team should also enable bespoke training to be delivered to individual Boroughs, according to need.

36. The Prevention command intends to deliver a series of seminars on prevention initiatives that will be open to key stakeholders including the IPCC, MPA, the medical and legal professions, Community Police Consultative Groups members and other stakeholders.

37. A number of current projects will continue to be progressed including the trial of defibrillators within the custody suites of three Boroughs, the testing of safer cutlery and safer disposable clothing for prisoners.

38. The Command will develop an intervention and target hardening capability, so that when emerging issues or patterns are identified, either corporately or at Borough level, the team will work alongside colleagues and stakeholders to ensure prevention and resolution at the earliest opportunity.

Policy and best practice

39. The Prevention and Organisational Learning Command will include staff dedicated to policy development around best practice. The unit will work alongside the corporate Policy Clearing House to ensure all DPS Policy and Standard Operating Procedures are subject of regular review and compliant with the Human Rights Act, Race Relations Amendment Act and Disability Discrimination Act provisions.

Persons of concern/adverse findings

40. Building on existing work, the Command will have staff dedicated to managing officers who are subject to adverse judicial findings, service confidence issues and those who have attracted three or more complaints in a twelve-month rolling period. This will result in confidence in the MPS evidence chain processes, consistency in how staff subject of adverse findings are deployed and how staff of concern are supported, monitored and developed.

Officer de-briefing

41. It is intended that the Command will have a new capability to de-brief officers who have been subject of criminal conviction or disciplinary finding. The aim will be to identity factors that led to criminality or breaches of the code of conduct. This will allow points of preventive intervention to be identified and then target hardening and training measures to be put in place to reduce the risks of such behaviour being repeated by others.

42. This practice will also provide for an opportunity for staff to comment on the conduct of the actual investigation, and where appropriate learn lessons for future investigations as well as identifying any development, support or training needs for officers concerned.

Diversity

43. The Command will promote good practice throughout DPS around the six strands of diversity (race, faith, sexual orientation, age, gender, and disability). Through a dedicated diversity co-ordinator, the command will advise DPS staff on diversity matters and their impact on individuals and communities and promote good practice and policy. In particular the continued development of the DPS Diversity Excellence model and review of new model practices against the Race Relations Amendment Act, Disability Discrimination Act and other key legislation will be central to ensuring that diversity is a prominent factor across the DPS. Whilst the designated diversity resource will sit within the Prevention and Organisational learning command it will operate across all three commands and ensure that there is a consistency and high standard of practice across the entire directorate.

Review

44. The Command will have ownership of an enhanced Review Unit, dedicated to a structured review of DPS investigations and identification of learning opportunities and best practice at the earliest opportunity. The unit will ensure consistency, timeliness, proportionality and fairness in DPS investigations.

45. There will be an ability to dip sample ‘closed’ investigations from across the commands in a similar way to practices employed within murder and cold case review practices. This will provide reassurance that investigations are sufficiently comprehensive and create the opportunity to re-open enquiries if necessary.

Interface with Key Strategic MPS/MPA Initiatives

46. The leads from the key strategic initiatives have been consulted and have committed to engage with the DPS review to ensure that maximum opportunity is taken to align the DPS new model with the developing MPS initiatives and ensure that benefits are realised across the Service.

47. The development of the ‘Together’ principles and behaviours are intrinsically linked to the way Police Officers conduct themselves. One of most significant areas where the DPS model will impact upon ‘Together’ will be via the establishment of the Leadership Academy.

48. It is intended that the Prevention Command will have a direct input into the courses and programmes that will be run and that training and support packages will be tailored to meet the specific needs of the target audience. The learning and development based environment is seen to be the ideal setting to ensure an understanding of legislative, procedural and ethical perspectives in addition to sharing the lessons learned and disseminating identified best practice.

49. The primary Metropolitan Police Modernisation Programme (MMP) strategic outcome that the review seeks to address is to ensure ‘Communities are engaged, confident and satisfied with our service’. The creation of the DPS reception desk and subsequent anticipated increased efficiency in dealing with complaints directly seeks to addresses the need to become more citizen focussed. The enhanced prevention activity that will be developed and be undertaken is intended to reduce the number of critical incidents and ensure that mistakes are not repeated. It is anticipated that the changes made as part of the review will inspire greater trust and confidence and show that the MPS is a learning and forward looking organisation.

50. The creation of the ‘Enforcement’ command, which will have a cradle to grave approach to investigating and managing professional standards matters, in conjunction with the enhanced DPS internal review capability, will ensure that issues are addressed in a timely, proportionate and fair way that fulfils the needs of both our staff and communities. Additionally the eventual move to having all but the most serious complaints locally investigated and resolved will increase local accountability and community engagement.

51. The review has now moved to a stage where, having identified the functions that need to be performed within the three DPS commands (see Appendix 4) the staff, finance, accommodation and IT required to support them are being identified. In line with MMP principles a bottom up approach is being adopted to ensure that the opportunities for creating a modern diverse workforce are captured. Additionally all resource and accommodation needs are being reviewed to ensure the optimum efficiency and effectiveness is being achieved.

52. Links with the Diversity Strategy have already been established with the appointment of a dedicated diversity co-ordinator. However, there are also close working practices being established at ACPO level within the Citizen Focus Command to ensure that developments and community engagement opportunities are imbedded into the review, and subsequent working practices, at the earliest opportunity.

53. The Changes that will be made as a result of the review will also address some of the key issues from the Morris Enquiry. The unification of all investigative commands together with the misconduct office will allow review and consideration of cases to take place in a more cohesive and effective way. This will allow for decisions to be made sooner and for information and details of investigations to be more readily available. The new Prevention Command will embrace the recommendations relating to learning the lessons and disseminating knowledge gained on a more timely and directed basis. Overall, by creating the reception desk facility and enhancing the internal inspection capacity alongside the measures outlined above, the DPS will have the ability to improve the timeliness, proportionality and fairness across all areas of service delivery.

C. Race and equality impact

1. All standard operating procedures developed from the review will fall under the DPS overarching policy. That policy is currently monitored quarterly in respect of equality and diversity implications. The findings of the Cambridge research into disproportionality will also be fully considered within this review.

2. As highlighted throughout the report consultation with Staff Associations and other stakeholders has been extensive and continues to take place, to ensure that an inclusive and constructive change progress is implemented. It is not felt that these changes will affect any group or section of the community, positively or negatively to a greater extent than the general population, either within or outside the police family.

D. Financial implications

This report is interim and final decisions re costing have yet to be determined. Current budgetary allocations will be worked within and greater efficiencies achieved.

E. Background papers

None.

F. Contact details

Report author(s): Steven Kershaw and Stuart Osborne

For more information contact:

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

Appendices

The following is a list of the appendices (see supporting material)

• Appendix 1 - Detailed inspirational model and interim model
• Appendix 2a - Key milestones
• Appendix 2b -
• Appendix 3 - Summary of consultation
• Appendix 4a - DPS Intelligence & Support
• Appendix 4b - DPS Prevention
• Appendix 4c - DPS Enforcement

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