Complaints management information

Report: 5
Date: 13 September 2007
By: Assistant Commissioner Operations Services on behalf of the Commissioner

Summary

This report includes data for the 12 months to July 2007. It focuses on the key changes or exceptions within the data, as trends are slow to change. The majority of figures used are based on 12-month rolling averages, which ensure that the trends are less affected by natural variation.

Workload

There has been an increase of 9% in the number of public complaint allegations being recorded over the past 12 months from a monthly rolling average of 628 to 694. [NB. These rolling averages illustrate longer-term trends and contain data for 24 months, which include 876 residual allegations arising from extraordinary events such as the Pro-Hunt demonstration, and more recently the Danish Cartoon protest and Parliament Square protest].

The number of conduct matter allegations recorded over the same period shows only minor variation and the monthly average is now 92 per month.

Timeliness

The average number of days to complete a public complaint investigation remains below the threshold of 90-days. It has remained at a similar level since December 2005 and was at 78 days in July 2007.

The average number of days to complete an investigation into a conduct matter continues to improve and it also remains below the threshold of 90-days. It reduced by 11%, from a peak of 85 days in September 2006 to 76 days in July 2007.

The average number of days between the decision and the holding of a misconduct hearing or final disposal is additionally below the threshold of 100-days and, at 76 days in July 2007.

A. Recommendations

That members note the report and the illustration of trends in the report and the Borough performance information contained in Appendices 1 and 2.

B. Supporting information

1. Appendix 1 contains data relating to Borough or Operational Command Unit performance.

2. Appendix 2 contains diversity information in respect of the Borough or Operational Command Units.

MPS/DPS performance

Allegations recorded

Table 1: Allegations recorded (see supporting material)

3. Table 1 illustrates both the ‘actual’ number of allegations recorded each month together with the 12-month rolling averages. The rolling average smoothes out natural variation and is more indicative of the trends involved. Due to the process of recording allegations, it is possible that the latest ‘actual’ monthly figure may be between 10% and 15% too low.

4. There has been an increase of 9% in the number of public complaint allegations being recorded over the past 12 months from a monthly average of 628 to 694.

5. These rolling averages contain data for 24 months in total and cover the two periods August 2005 to July 2006 and August 2006 to July 2007. The following table illustrates the effect that the 876 residual allegations, arising from extraordinary events, have on the long-term trends such as the Pro-Hunt march, the Danish Cartoon protest and Parliament Square demonstration.

6. It should be noted that, although these allegations appear in the averages for the period up to the end of July 2007 they are not included in the ‘actual’ data after November 2006.

7. Over the 12 months to July 2007, the average number of conduct matter allegations recorded each month has stabilised at 92.

8. The overall average increase in public complaints in the 12-months to July 2007 is not proportionate across all allegation categories. Using the actual 12-month rolling average figures, over an extended period, it was possible to see that there was a distinct upward trend for certain types. The most significant trend appears with rises in Failures in Duty, Malpractice, Discriminatory Behaviour and Incivility.

9. This rise in Discriminatory Behaviour can be traced back to the introduction of the IPCC when there was a widening of the definition of such allegations to include Religion, Gender and Sexuality etc. This category also incorporates the new type of allegations made about ‘Fairness and Impartiality’ brought in by the Commission in April 2004.

10. Although there has been a numerical rise in these types of allegations, as a proportion, they have reduced from 6% of the total in 2004/05 to 5% at the end of 2005/06 and 2006/07 respectively. Data collected between thus far in 2007/08 indicates that Discriminatory allegations remain at 5% of the total of all allegations.

11. The following table illustrates the breakdown of Discriminatory allegations by their sub types. Generally speaking, the majority of such allegations are made about ‘Race Discrimination’ but it is interesting to note that in 2006/07 there was a greater number and proportion of allegations made in respect of Religious/Faith Discrimination.

Public complaints

12. Failure in Duty allegations have risen steadily. At the end of 2005/06, such allegations had risen by over 1000 and represented 38% of all allegations recorded against 27% in both 2003/04 and 2004/05. At the end of 2006/07 such allegations represented 37% of the total. Since the inception of the IPCC, DPS are investigating a higher proportion of failure in duty allegations that have come via the Commission, including those of failure to record or investigate a particular allegation. It is possible that, before the IPCC, some of these issues may not have been brought to the attention of DPS. Some more analysis into Failures in Duty allegations has been programmed into future work.

13. Incivility allegations have also risen in numerical terms since the inception of the IPCC in April 2004 but reduced as a proportion of all allegations from 22% of the total in 2003/04 to 18% of all allegations at the end of 2006/07.

14. Oppressive Behaviour allegations that had previously risen significantly due to the ‘Pro-Hunt’ demonstrations now appear to be on the decline as a proportion of the overall total. In 2004/05 they represented 38%, which reduced to 30% in 2005/06. This has carried through to the end of 2006/07 when they were 29% of the total. They are at a similar level 30% at the end of the first four months of 2007/08.

15. Table 2 illustrates the ‘actual’ number of public complaints recorded over the period August 2006 to July 2007 converted to a per 100 officers figure. It is also broken down by allegation sub-type, and split into quarterly periods.

Table 2: Allegations per 100 officers (see supporting material)

16. The table below illustrates the numbers of allegations by type and whether a period is above the MPS period average in which case the figures will be in both blue and bold text. The MPS total number of allegations, per 100 officers, over the 12-month period is also shown for comparison.

17. Although there are allegation types that appear above the period averages they are not significantly so and do not indicate any immediate causes for concern.

Timeliness - public complaints

Table 3: Complete full investigation & all other results (see supporting material)

Meeting target: Investigating complaints within the 90-day threshold (78 days)

18. The average number of days to complete a public complaint was 78 days in July 2007. Overall, the number of days has remained at a similar level since December 2005 and below the threshold of 90 days.

Missing target: A month on month reduction in the average number of days to complete an investigation (0% decrease on the previous month)

19. There was a reduction of 1% in the average number of days taken to complete an investigation in May 2007 but this was not sustained in either June or July where no reduction occurred.

20. This target is an aspiration but it must be balanced in that excessive speed will reduce quality and thus frustrate any gain by encouraging dissatisfaction of the complainant and subsequent appeal to the IPCC

21. Presently, the potential to improve significantly further in this area is unlikely, as the current level has been achieved through changes to business processes and practices. However, the work being undertaken by DPS in respect of the changes to legislation brought about by the Taylor Review will afford another opportunity to review these practices. Current information suggests that the legislation will not now receive Royal Assent until Spring 2008.

Table 4: Average Days Taken to Submit Dispensation/Discontinuance (see supporting material)

Missing target: Submitting requests for Dispensations / Discontinuances to the IPCC within a 60 day target (71 days)

22. Since August 2006, the average number of days taken to submit a dispensation or discontinuance request to the IPCC has remained fairly static ranging between 69 and 71 days.

Table 5: Average Days Taken to achieve a Local Resolution (see supporting material)

Meeting target: Average days taken to achieve a Local Resolution within a 60 day Target (49 days)

23. Since August 2006, the average number of days taken to achieve a local resolution remains fairly static varying between a maximum of 51 days and a minimum of 49 days. This is currently within the 60-day target.

24. Analysis of local resolutions reveals that, in the 12-months to April 2007, 51% have been achieved by DPS staff and the remaining 49% by the Boroughs themselves. The proportion of local resolutions undertaken by DPS has decreased, when compared to the previous 12 months, where it was previously 54%.

Table 6: Percentage of cases over 120-days [1] old (see supporting material)

Missing expectation: A reduction in the percentage of public complaint cases over 120-days [1] old

25. DPS has made efforts to reduce the percentage of public complaint cases over 120-days [1] old, but it has remained fairly static over the last 12 months varying between a sustained low of 21% between October 2006 and January 2007 to a current high of 26% in July 2007 (209 of 813 cases).

26. By drilling down into the figures it is apparent that the majority of the cases that now are over 120-days old are those that are the responsibility of either the Human Resources i.e. Police Staff investigations (86% or 131 cases), External/Outside force investigations (100% or 2 cases) or IPCC investigations (100% or 4 cases).

27. To illustrate the impact such cases have on this target, the performance of DPS Investigations Command has been illustrated separately on the chart. This shows that 13% of the cases (49 cases) within their responsibility are over 120-days old.

Conduct matters

Table 7: Investigation completion (see supporting material)

Meeting target: The average number of days to complete an investigation (76 against a 90 threshold)

28. The average number of days to complete a conduct matter investigation, illustrated in table 7, remains below the threshold of 90-days. It reduced by 11%, from a peak of 85 days in September 2006 to 76 in July 2006.

Missing expectation: A reduction in the percentage of conduct matter cases over 120-days [1] old

29. Conduct Matters over 120-days [1] old rose from 36% (48 of 133 cases) in June 2005 to a peak of 60% (64 of 107 cases) in November 2005. However, despite an earlier downward trend where it reached 29% (39 of 134 cases) in January 2007 it has risen in July 2007 to 43% (61 of 143 cases).

30. Research has revealed that the increase in February 2007 is due to a number of Police Staff investigations (suspensions) being recorded on the complaints system, the majority of which are over 120-days old. Such investigations should be recorded on the complaints system but this had not previously been actioned. It would appear that these cases have remained on the system since and have contributed to the continuing rise of this indicator. A recent meeting with the Police Staff Discipline Unit revealed that there are still a number of conduct cases to be recorded.

31. Cases that are the responsibility of DPS Investigations Command have been illustrated on the chart, which shows that 31% of cases (25 cases) that they are responsible are over 120-days old.

Misconduct

Table 8: Misconduct (see supporting material)

Meeting target: Average days to reach Misconduct decisions (76 against 100 threshold)

32. The average number of days between the decision to hold a misconduct hearing or reach a final disposal remains below the revised threshold of 100-days.

External partners – CPS Decision making

Table 9: Report to receipt of decision from CPS (see supporting material)

33. Table 9, illustrates the timeliness of the CPS decision-making in respect of the Specialist Investigation work, such as Deaths Following Police Contact and Discharge of Police Firearms and the more routine complaint and conduct investigations of the Borough Support Units.

External partners – IPCC Decision making

Table 10: Report submission to receipt of decision from IPCC (see supporting material)

34. Table 10 reveals the average time taken for the IPCC to reach decisions in dispensation and discontinuance cases.

Table 11: Number of appeals made to the IPCC (see supporting material)

35. Table 11 shows the number of appeals made to the IPCC where a decision has been received from the Commission within the last 12 months. It illustrates the type of appeal being made and the validity of that appeal as determined by the IPCC.

36. In future reports we intend to supply data for the current 12 months compared with the previous 12 months. To achieve this we need to ‘back record convert’ the data we hold manually to the new TRIBUNE fields. It is planned to conduct a further reconciliation exercise with the IPCC following the upgrade of TRIBUNE scheduled for Summer 2007.

Outcome trends

Table 12: Public complaints - finalised by allegation (see supporting material)

37. The average percentage of local resolutions has increased in the 12-month period from 32% in July 2006 to 33% in July 2007 but it remains considerably below the aspirational target of 50%. Whilst the proportions of the other outcomes affect this figure, it is likely to remain low until BOCUs are able to take on more responsibility for the resolution of their own complaints and undertake lower level investigations.

38. There are however tensions between the desire to see more issues being dealt with locally e.g. Local Resolutions and the scrutiny DPS is under to improve timeliness. DPS investigators losing close control over a complaint being investigated/resolved on borough can adversely impact on their timeliness and the inclination is for them to recall the file and deal with it themselves.

Borough (BOCU) / Operational Command Unit (OCU) performance – public complaints: allegations and people.

39. At each Professional Standards and Complaints Committee, members will be presented with a comparative analysis of public complaint data relating to groups of BOCUs in relation to MPS professional standards matters.

40. Like boroughs have been grouped together based on demographics and volume crime. Both of these factors are likely to affect complaints. By using these five family groups and converting ‘actual’ numbers of complaints recorded into a ‘per 100 officers’ figure enables more accurate comparisons to be made.

41. There is a further group exception to this is what DPS have called Group 6, which consists of TP non-Borough based units and non-TP Operational Command Units.

42. The ‘actual’ figures appear in the Borough Support Management Information (BSMI) report, which is made available to the MPA as a separate document and which could be circulated to members if required by MPA officers.

43. To publish the actual figures in this document would make the report unwieldy due to the amount of additional pages necessary to incorporate the expanded information. Furthermore, it would divert from the purpose for which both of these documents were designed i.e. the strategic overview of this report and the detail of BSMI.

44. This information provides a benchmark against which the Authority will be able to judge DPS’s Professional Standards Support Programme (PSSP) in the future by looking for variations in performance from this report to the next occasion the same family group appears.

45. Variations in performance of each of the boroughs when compared to their peers are highlighted in both blue and bold text. Variations could be for any number of reasons such as a particular operation/initiative being run on the borough or environmental factors such as the number of licensed premises, entertainment venues or shopping centres. The demographics in relation to both the resident and transient population and the length of service and experience of the officers concerned will also be relevant factors.

46. It should be noted that, once the ‘per 100 officers’ element is introduced to the data, some of the numbers are small which makes it difficult to draw any significant conclusions from them.

47. Because a Borough or Command Unit is different from their peers does not automatically mean that they are worse.

48. The Professional Standards Support Program (PSSP) incorporates a ‘tasking’ process whereby information in relation to public complaints, conduct matters, civil actions, accident claims and intelligence are assessed in order to ascertain what intervention activities are most appropriate to assist the boroughs with. The borough requiring the most assistance will have a ‘profile’ compiled on it based on all the information previously mentioned but in greater detail by drilling down into the data to establish the exact nature and likely cause of the variation.

49. The Prevention & Organisational Learning Command (POL) will then work with the borough in question, through the PSSP process, to define an action plan that will bring the BOCU closer to the average of similar boroughs in their group.

50. The group of boroughs under focus for this period are from Group 5. The data and associated analysis is presented in Appendix 1.

C. Race and equality impact

Appendix 2 includes MPS data in respect of diversity relating to both complainants and officers that is compared against the family of Boroughs or Operational Command Units in focus.

D. Financial implications

None.

E. Background papers

None.

F. Contact details

Report author(s): Michael Clark, Higher Performance Analyst and Hamish Campbell, Detective Chief Superintendent, MPS

For more information contact:

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

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