Review of the standard of Directorate of Professional Standards management information systems for monitoring recommendations for organisational learning

Report: 10
Date: 19 July 2007
By: Chief Executive

Summary

The purpose of this report is to provide Members with details of work undertaken by the MPA to review Management Information Systems, as utilised by the Directorate of Professional Standards (DPS), for monitoring compliance with recommendations for organisational learning as made within the context of public complaints and conduct investigations.

A. Recommendations

That members note the progress that has been made by the MPA in monitoring recommendations for organisational learning.

B. Supporting information

Background

1. On 30 April 2007, Reshard Auladin, Chair of the Professional Standards and Complaint Committee (PSCC) and Lord Toby Harris met with the Independent Police Complaints Commission. The principal purpose of the meeting was to discuss recommendations relevant to the IPCC as contained in the MPA report ‘Counter-Terrorism: The London Debate’.

2. The meeting included a wider discussion about the role of the MPA in monitoring the implementation of recommendations for organisational learning made by the IPCC in relation to the MPS.

3. It was agreed that responsibility for monitoring the implementation of IPCC recommendations should rest with the MPA. It was further agreed that the MPA should require the MPS’s Directorate of Professional Standards to report annually to the MPA’s PSCC concerning implementation of all IPCC recommendations pertaining to professional standards.

4. In responding to action as agreed at the meeting on 30 April, the MPA’s Professional Standards Officer arranged to meet with officers within DPS Prevention and Organisational Learning (POL) Command to discuss and inspect the standard of DPS record-keeping and the response to recommendations for organisational learning as made by the IPCC.

5. In preparation for that meeting, the IPCC were invited to furnish the MPA with details of the number and nature of the recommendations they had so far made in relation to investigations of complaints and conduct matters relevant to the MPS.

6. The IPCC declined to furnish the MPA with such details. As a consequence, at the time of the visit to POL, the MPA was unable to make any meaningful assessment as to whether DPS had comprehensively recorded details of and responded to all recommendations made by the IPCC. This has signalled a need for formal arrangements to be put in place between the MPA and IPCC for provision of information relevant to recommendations made in respect of the MPS.

7. There is a need, for example, for the MPA to agree a protocol with the IPCC whereby the MPA, as the oversight body, is advised directly by the IPCC of all the recommendations it makes for organisational learning relevant to the MPS. In fact, it could be argued that the degree of information shared by the IPCC, both with the MPS and MPA, should by default also include notification of organisational learning points which derive from IPCC investigations involving provincial forces. Providing such a service would be entirely in keeping with the IPCC’s guardianship function.

8. The IPCC South Eastern Region has recently confirmed that it does not itself have a comprehensive record of the recommendations that it has made since the date of its inception.

9. Regardless, of the IPCC’s inability to provide the MPA with a record of its recommendations, the MPA has nevertheless commenced its monitoring role and has conducted a preliminary assessment of the standard of DPS record-keeping in relation to recommendations for organisational learning.

Widening the scope of MPA activity

10. Members should note that the MPA’s initial intention to focus upon the system operated by DPS for recording recommendations made specifically by the IPCC and secondly to monitor action taken by the MPS in responding to the IPCC’s recommendations changed at the inception of the visit on 23 May 2007.

11. The change in focus was in response to the MPA becoming aware that the current DPS record management system is set up on the basis that the database (an Excel spreadsheet, referred to in this report as 'D1'. The database is updated by two officers within POL) exists as a central repository of all recommendations made for organisational learning, whether arising from a local, managed, supervised or independent investigation.

12. That said, ‘D1’ by design does not capture recommendations made for organisational learning in relation to investigations of ‘death following police contact’. Such details are recorded separately on Holmes (referred to in this report as ‘D2’. This system of recording was established under Operation Grant and is a more sophisticated method of recording than ‘D1’. Some of the distinctions in the two systems are referred to below, however, the focus of this report is on the effectivesness of ‘D1’).

Database D1

13. ‘D1’ exists as a record of recommendations made in relation to ‘non-death’ cases. Crudely described, it is a basic spreadsheet with limited features. Examples of some of its limitations are explained below.

14. Unlike ‘D2’, ‘D1’ does not have an automatic review facility i.e. ‘D1’ does not automatically draw officer’s attention to outstanding actions.

15. An automated ‘bring back’ facility, which would act as a prompt that action was awaited in response to an individual recommendation, does not exist. The shortcomings in such a system can be evidenced. For example, whilst a docket had been raised for an action to be taken by an OCU, which should have been resulted in January 2007, it was apparent that the required action had not, as at 23 May 2007, been taken. Further, on the information made available to the MPA, there did not appear to be any reasonable explanation provided for the inactivity or any evidence of management intervention. The risk engendered by a failure to action a recommendation within a timely manner may in certain circumstances be high.

16. ‘D1’ does not include a formalised risk assessment facility. This again, is distinct from the capabilities of ‘D2’.

17. The integrity and usefulness of ‘D1’ appears to be overly dependent upon the capability and capacity of just two officers, both of whom have expressed numerous concerns about the shortcomings in the technological capabilities of ‘D1’. The deficiencies in the system have an obvious impact on what the officers can themselves usefully do in terms of being able to effectively manage organisational data. For the system to be properly capable of supporting an organisational learning programme, technological upgrade and additional resources would be required.

Observations on the quality of information gathering and sharing

18. As explained above, the MPA has not as yet made any assessment as to whether the recommendations as recorded on ‘D1’, or for that matter ‘D2’, are in fact an accurate reflection of the entirety of recommendations of organisational significance whether made by the IPCC or otherwise.

19. It seems reasonably safe to assume that ‘D1’ data, even if combined with the data on ‘D2’, does not represent the totality of recommendations made which are influential to future organisational practices.

20. For example, as a consequence of DPS having, through the Professional Standards Support Programme (PSSP), increased engagement with BOCU’s, awareness has been raised amongst officers at borough level of the roles and responsibilities of DPS. POL’s function in collating the lessons for organisational learning has been communicated to a wider audience and the effect of this has been an increase in the number of notifications to POL of recommendations arising out of local investigations that have organisational significance. The activity in reporting recommendations to POL is seen to peak at the time of the PSSP visit, or shortly thereafter, but with the lapse of time the extent and quality of information sharing decreases to levels experienced prior to the PSSP visit.

21. Problems with information gathering and sharing are identifiable both in inter and intra-directorate communications. However, this appears to be indicative of a wider problem within the MPS of sharing and managing diverse information.

22. Putting proper systems in place to ensure that relevant information is made available to all who have a legitimate interest in it is work in progress. At the present time, it is however recognised that there is much room for improvement in the quality of ‘knowledge management’.

Looking to the Future: Tribune Phase 4

23. The capability of Tribune to act as a database which provides ‘cradle to grave’ data in respect of all individual public complaints and conduct matters is being explored by DPS PAU. One of the issues that may be worthy of consideration is whether individual recommendations could be recorded on Tribune.

24. Unlike ‘D1’, Tribune has a search facility and could be used as a route to creating a central repository of all recommendations including when made, by whom, and when actioned / resulted.

25. There is no capacity to explore this capability within the parameters of Tribune Phase 3. However, this may warrant consideration, when developing Phase 4, which is timed to coincide with the changes in the misconduct procedures in 2008.

Who ultimately is responsible for organisational learning?

26. One final observation, which arose as a consequence of the MPA inspecting DPS Management Information Systems, concerns divisions of responsibility and the question of who ultimately is responsible for organisational learning.

27. There appears to be a lack of clarity and definition as to whose responsibility it is to capture, centrally record, and ensure that recommendations relevant to organisational learning are acted upon.

28. In some respects DPS POL are in danger of shouldering responsibility for organisational learning, when in fact the learning point is not one that sits readily within the DPS portfolio of work.

29. Whilst MPS SMT appears to be alive to the issue and are in the process of devising an MPS Organisational Learning Model, it seems appropriate that some acknowledgement should be made by the MPA of the pressures which DPS, in particular POL, may currently be experiencing in the absence of an organisational learning model being properly embodied in the MPS.

C. Race and equality impact

1. Some of the key performance targets and responsibilities for equalities monitoring which have been set for the MPS cannot be fulfilled without data being properly collated, analysed and monitored.

2. Monitoring the MPS’ response to recommendations for organisational learning increases the lines of accountability to the MPA, which ultimately strengthens the MPA’s capacity to ensure that the MPS acts upon recommendations that contribute to improvements in operational policing to the benefit of London’s diverse communities.

D. Financial implications

There would be a cost implication if Tribune’s capability were extended to incorporate a repository of recommendations for organisational learning. In order to commission an update of Tribune (within Phase 4), additional funding would be required within the 2008/09 DPS budget. However, the cost of upgrading management information systems should be balanced against the medium and longer-term benefits of improved business performance and risk management.

E. Background papers

None.

F. Contact details

Report author(s): Claire L Lister, MPA

For more information contact:

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

Appendix 1

Review of the standard of Directorate of Professional Standards management information systems for monitoring recommendations for organisational learning

1. In responding to action as agreed at the meeting on 30 April, the MPA’s Professional Standards Officer arranged to meet with officers within DPS Prevention and Organisational Learning (POL) Command. As a result, the MPA has conducted a preliminary assessment of the standard of DPS record- keeping in relation to recommendations for organisational learning.

2. Although organisational learning has been a key feature of IPCC investigations since its inception. One of the difficulties it has experienced is in presenting and sharing this data in an easy to read and accessible format. However, the IPCC has recently developed a new database, which will play a key role in ensuring that lessons from cases are made more accessible and disseminated to relevant stakeholders.

3. This forms part of a new framework for capturing learning from ‘managed’ and ‘independent’ investigations, which is currently being rolled out across all four regions of the IPCC. This will require investigation reports to be structured differently to include a separate section with the learning recommendations and relevant findings, prefaced with a brief overview of the incident.

4. With regard to ‘managed’ and ‘independent’ investigations conducted within the MPS, the IPCC is aiming to share these reports with the MPA as they become available. This forms part of a national agreement the IPCC is developing with the APA, to share learning with individual Police Authorities.

5. Changes have already been implemented within the IPCC's London and South-East region to incorporate learning reports as part of any IPCC independent investigation; and all new Terms of Reference for an investigation will now give consideration to whether there is any ‘organisational learning’ for the police service, including whether any change in police policy or practice would help to prevent a recurrence of the event, incident or conduct investigated; and secondly, whether the incident highlights any good practice that should be disseminated.

6. With regards to ‘managed’ investigations, the IPCC's London and South-East Region is working with regional forces and Heads of PSDs to ensure they are fully briefed and prepared for the new system of reporting. Implementation is likely to commence on 1st September 2007.

7. ACPO is currently considering how to develop a system for capturing all learning from local and supervised investigations and is expected to have a system in place by March 2008.

8. This work forms part of a wider initiative, which is being developed nationally by the IPCC's ‘ Learning the Lessons Committee, which is chaired by the IPCC and includes representation from the following bodies; APA, HMIC, Home Office and ACPO.

The Committee is responsible for disseminating national recommendations or points of good practice and local learning. It will do this, via the production of an e-bulletin, which it aims to produce three times a year with relevant case summaries. The bulletin will highlight the learning from cases, in terms of both good practice and recommendations for improvement. The Committee has recently published its first bulletin on the theme of domestic violence. Future bulletins may be on specific issues, like this one, or may be of a more general nature.

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