4. Memorandum submitted by
the Police Superintendents' Association of England and Wales
1. INTRODUCTION
The Police Superintendents' Association of England
and Wales (PSAEW) represents over 1,500 Superintendents and Chief
Superintendents.
Our members lead the Basic Command Units (BCUs),
which comprise the 43 Home Office Police Forces. Superintendents
also provide many of the other senior management roles within
BCUs.
At force level they command support departments
and are responsible for managing the provision of operational
and specialist support to their BCU colleagues. In particular
our members perform the critical role of Senior Investigating
Officer for murder and other serious crime enquiries and increasingly
are not only the tactical (silver) commanders for firearms incidents
but are also called upon to undertake strategic (gold) command
roles.
At a national level our members' are seconded
to the Home Office and other national agencies where their expertise
and experience inform policy making and the delivery of high-level
national policing services.
Superintendents and Chief Superintendents are
integral to the delivery of policing at local, force and national
levels. They have a wealth of experience in:
— Working directly with communities.
— Commanding high profile policing
incidents.
— Human Resource management.
— Delivering local, force and national
policing priorities.
2. THE NATIONAL
POLICE PLAN
The PSAEW welcomed the original concept of a
National Policing Plan which we understood to be a high level
document which would contain a small number of priority areas
to be addressed by the police in a three year rolling programme.
In reality the plan became unwieldy in that
it contained almost every policing activity and gave no indication
as to their relative priorities. Consequently the document itself
is large and involved and is almost universally ignored by the
service. Following feedback on the first plan from all parts of
the service an assurance was given that the second national plan
would contain significantly fewer priorities. We were saddened
to find that whilst the numbering of the priorities in the plan
suggested that the number had decreased each priority had acquired
sub priorities the overall effect of which was no change. This
approach fundamentally undermined any credibility that remained
in the concept.
An effective national policing plan in our opinion
is one that all staff can remember and see the relevance of their
everyday duties in achieving its aims.
The police service is littered with plans, strategies
and policies that gather dust every day and are testament to an
enormous amount of wasted time and energy. We urge the committee
to think seriously about issuing advice that the next National
Policing Plan should be short, written in plain English.
3. NATIONAL STANDARDS,
PRIORITIES AND
LOCAL DECISION
MAKING
We support the concept of National Standards
and we believe that it is essential to establish consistency across
common policing activities. Even where such standards are currently
articulated they are interpreted differently across the 43 Police
Forces of England and Wales.
For example computer systems across England
and Wales should have minimum data entry standards and the ability
to allow data transfer from force to force. It is not necessary
however for the hardware, software and working practices to be
dictated in such absolute terms as the standards themselves.
A similar situation should apply across the
whole of policing. The service requires a range of absolute standards,
which it must be required to achieve. How it achieves these standards
and the relative priorities attached to the standards will necessarily
vary in different locations.
The same argument applies here as that expressed
above in relation to the National Policing Plan. If the standards
become too prolific or start to trespass on the "how"
rather than the "what" then they will destroy the very
localism which is held up as being the fabric which underpins
the British style of policing.
England and Wales is made up of a patchwork
of different communities with different aspirations, different
needs and different identities, that seek a policing style which
reflects their community's characteristics. Clearly a "one
size fits all" concept is wholly inappropriate; indeed in
the past when such an approach has been imposed the service has
been rightly accused of losing touch with the very community it
seeks to serve.
In order to achieve this level of sophistication
of service delivery it is important that decisions are made as
close to the point of delivery as possible. These decisions should
be the ones that immediately affect the local policing style and
priorities. Therefore local police commanders need to be empowered
to make these decisions, and have the resources available to satisfy
community needs. Such decisions must of course be made within
a framework of National Standards.
4. ACCOUNTABILITY—TRIPARTITE
STRUCTURE
Effective accountability works best at a local
level as close as possible to the point of delivery. Community
concerns need to be addressed promptly and effectively by the
service providers.
This type of accountability happens on an ad
hoc basis at present—there are no formal mechanisms in place
to harness the views of local communities in a structured way.
Accountability at local level seems to be working
best in some unitary local authorities, where there is clarity
of role and readily identifiable members of the authority with
the community safety portfolio.
We appreciate there is a view that Police Authorities
perform this function however the makeup of Police Authorities
does not allow a consistent representation from the diverse communities
which make up a police force. It is our view that Police Authorities
perform valuable service in maintaining an efficient and effective
police force but are less effective in transmitting community
views to the chief constable.
We believe the major ingredients of the "Tripartite
Structure" to be operational independence for the Police,
the ability of the Police Authority to hold the chief Officer
to account for the efficiency and effectiveness of the force and
the ability of central government through the Home Office to set
standards and targets for policing nationally.
Such a structure has maintained equilibrium
within the service at a strategic level but had little effect
on the quality of service delivered at the most local level.
We believe that a tripartite structure should
remain but should be applied in such a way that all the communities
are able to contribute to the setting of local policing plans
and subsequently hold the police accountable for the delivery
of those plans. Clearly such plans should not exist outside a
national framework of standards and targets.
5. PERFORMANCE
CULTURE
The police service has made significant improvements
in the inculcation of a performance culture. Beginning with simple,
blunt and often meaningless targets performance management has
been successively refined both nationally and in all forces.
There are now many examples of sophisticated
data collection and analysis designed specifically to drive up
performance. Some of our members benefit from the ability to interrogate
management information systems that allow complicated analysis
of multiple factors impinging on their BCU or Department. (eg
iQuanta data)
There needs however to be a consistency of approach
enabling all senior managers to access such information. While
all 43 forces in England and Wales remain able to determine separate
approaches to data collection and analysis the very obvious opportunities
to drive up performance will not be maximized.
We are however, becoming increasingly concerned
that some of the measures under development in some forces, based
primarily upon the American "Compstat" approach, concentrate
almost exclusively upon the personal performance of individuals.
We would of course, accept that individuals
should always be held to account for their own performance through
a properly constructed PDR process however we do not believe it
is appropriate to hold individuals to account for the performance
of others and certainly not in an environment where they are publicly
questioned in front of up to 100 peers and partners without recourse
to their own managerial support structure or systems.
Such events seem to us to have little to do
with the systematic improvement of performance and have become
a public spectacle where the ability to "survive" the
onslaught is the only thing that is effectively being tested.
6. THE ROLE
OF THE
POLICE STANDARDS
UNIT AND
THE NATIONAL
CENTRE FOR
POLICING EXCELLENCE
We believe that the role of the Police Standards
Unit is not fully understood by the Service, many parts of which
are fearful of the PSU and becoming "engaged". Experience
of colleagues who work in Forces and BCU's that are "engaged"
with the PSU are varied with many remarking upon the invasive
nature of PSU in the day to day running of their commands.
However, many trying to embrace a performance
culture have welcomed the help and assistance of PSU and it has
undoubtedly helped spread good practice across many parts of the
country.
We believe that it has been effective in successfully
co-ordinating the alcohol abuse campaign currently operating in
over 70 BCU's. It is possible that without the central role of
PSU this initiative would not have got off the ground and certainly
would not have happened in such a short time scale.
Work completed by the PSU on data standardisation,
the Police Performance Assessment Framework, BCU families and
many other areas has been of high quality and led to greater understanding
of policing.
This Association jointly funded research with
the PSU into what enables and disables BCU performance. The resulting
report has been used as a source document by academics delving
deeper into this complex subject.
The National Centre for Policing Excellence
is not widely known across the service and it is hard to bring
to mind work emanating from it, other than the National Intelligence
Model, which was really in being prior to the creation of the
NCPE.
7. IMPROVED USE
OF SCIENCE
AND TECHNOLOGY
This is a vast topic; therefore we would like
to bring to the committee's attention just a few issues.
This Association believes that time has come
to adopt a national approach towards IT. The Airwave Project,
albeit not perfect, has shown the way to achieve consistency in
this area. It is vital that in order to achieve all the business
benefits of new technology that common standards appertain across
all Forces. We believe the Home Office should take a more robust
line in directing Forces. We hope that this will come from the
action plan being developed by the Home Office in response to
the Bichard Report.
We believe it takes over long to deliver technological
solutions and we cite the case of less than lethal weapons, which
are widely used in Police Forces across the world but are still
being evaluated here, when there is evaluation evidence available
from other countries.
8. THE GOVERNMENT'S
RESPONSE TO
THE O'DOWD
REPORT ON
POLICE BUREAUCRACY
We feel that the response to this important
report has been pragmatic and effective. The Policing Bureaucracy
Implementation Steering Group has methodically dealt with all
the recommendations of the report in a way that is fully auditable.
The group is jointly chaired by an ACPO vice president and a senior
Home Office official and has included representatives from across
the service and Home Office. It appointed ACPO leads to each of
the recommendations and relentlessly followed up action.
The group has also taken on issues not identified
by O'Dowd and pursued them, eg bureaucracy associated with RIPA.
The Group has created an awards system for members
of the service who devise ways of reducing bureaucracy. This attracted
over 40 entries and the first awards were presented by the Home
Secretary at the Police Federation Conference in May this year.
The perception of the group is that bureaucracy
is not now at the top of the list of issues persistently complained
about by staff. Once the Service is "joined up" technologically
with the rest of the Criminal Justice System, we believe huge
strides will be made to reduce the bureaucratic burden on frontline
officers.
9. POLICE TRAINING
Police Training remains, as ever, a contentious
issue. The evolution of the PSSO in to the Justice Sector Skills
Council creates significant opportunities to integrate police
training standards with those of partner agencies. The completion
of a competency framework encompassing all police roles has also
created an underpinning structure for both training design and
workplace assessment through PDR. This has been a fundamental
change for the Service and needs to be embedded so that the competency
framework underpins all HR activity.
Training continues to be a substantial investment
for the service and there is an inevitable conflict between the
total training needs assessment against the abstractions levels
that can be sustained if effective operational deployment is to
be maintained. Despite the introduction of more imaginative and
flexible training methods it remains impossible to train every
officer in the plethora of new techniques, systems and legislation
without seriously impacting on the operational capability.
There is no way of knowing accurately what the
Service spends on staff development and how we can measure that
investment in terms of business benefits.
We are concerned that the budget available to
Centrex has been cut by some 30%. We believe that there continues
to be a place for centrally designed and delivered training, particularly
in those areas critical to effective performance in managerial
or specialist roles.
The trend to design and deliver more training
locally, including probationer training, raises a very real issue
of consistency, particularly in relation to quality. Whilst we
applaud the efforts being made to deliver training as close as
possible to the workplace and in as flexible a manner as possible
we are concerned that budgetary and other pressures will result
in a diminishing investment in training (as has been seen with
Centrex) and consequently standards will fall.
We are also concerned that the move away from
objective assessment methods in favour of workplace assessment
(both in training and for promotion) will again highlight issues
of consistency both within and across forces. There is a real
risk that the service will become vulnerable to allegations of
discrimination if it is unable to demonstrate that decisions impacting
on individual's careers have been based upon impartial, objective,
work related criteria.
We believe that there should be an emphasis
on Continuous Professional Development (Life-long learning) within
senior managers in the Service as a route to a more professional
approach and ultimate accreditation. Responsibility for this should
lie with the individual but there should be sufficient encouragement
from the Service to show that this is a worthwhile approach.
10. ISSUES OF
WORKFORCE MODERNISATION/REFORM
OF POLICE
PAY, CONDITIONS
AND WORKING
PRACTICES
Reforms such as competency related threshold
payments and special priority payments have not directly affected
our members with the exception of administering the systems brought
in by Forces across the country. There has been little uniformity
in the processes by which the payments are authorised and therefore
a bureaucracy has grown up around them.
Some Forces are operating outside the PNB agreement
in that SPP's have been devolved to the BCU level, something that
was never envisaged when the agreement was reached.
The pay agreement reached at the Police Negotiating
Board relating to Superintendents pay includes two new allowances.
One for those chief superintendents who have very large commands—big
jobs—and progression along the pay spine will be by way
of performance related increments from 1 September 2004.
As we saw with the Federated ranks changes,
these developments have not been approached in a consistent way
across the country. Performance related increments rely totally
on there being in place a credible a Performance Development Review
(PDR) process. To aid in the introduction of a consistent national
approach, Home Office issued guidance in 2003 (HO Circular 14/2003).
Several Forces have gone against the advice contained in that
document to create their own systems of PDR, thereby making the
application of performance related increments difficult to keep
consistent across the country. This will inevitably give rise
to dissatisfaction and possible local disputes about increments
and bonuses.
Whereas we support convergence in the terms
and conditions applicable to both police officers and police staff,
as there needs to be a move towards the unification of the workforce,
we believe that the office of constable should remain. This office
is not merely of historical and constitutional significance but
when police forces across the world are viewed there is a distinction
between those members of that force who carry a power of arrest
and those who do not. We strongly believe that distinction needs
to remain.
11. THE USE
OF COMMUNITY
SUPPORT OFFICERS
On the whole our members find community support
officers to be a very useful additional resource. Feedback from
the public is clearly in favour of their introduction.
The main advantage with them in the eyes of
BCU commanders is that they are a resource that can be relied
upon to perform the duty they are employed to do. PCSO's are not
taken away from BCU's to assist with major enquiries or other
immediate priorities elsewhere in the Force. Therefore they give
consistency of contact with communities and can be used in planned
police initiatives with certainty—something that is not
always possible with police officers.
If the extra funding that has been given to
the Service to recruit and employ PCSO's had been used to recruit
and employ sworn police officers it is probable that Forces would
not have had the same number of people to be out on the streets
in contact with communities, as there would be a great temptation
to use fully trained officers for other duties not associated
with visible patrol.
We welcome the expansion of the numbers of PCSO's
as announced by the Chancellor of the Exchequer and hope that
the funding does not require Forces to make choices between sworn
officers and PCSO's. We see this expansion as a precursor to a
change in the make up of the workforce with more variety and an
emphasis on skills to coming the fore, rather than the traditional
stance of the omni-competent police officer.
12. OTHER ISSUES
Structure of Policing in England & Wales
The Government's green paper—Building
Safer Communities—poses the question whether or not
the current structure, which has been in place 30 years, is still
applicable to today's policing environment.
There follows an extract from our paper entitled
Moving Policing Forward, which was our response to the
green paper. This extract deals with the structure of the service
as we see it and is still the view of this Association.
It is a fact that all policing activity no matter
how serious or complex necessarily occurs geographically within
a BCU. However there is a range of events and incidents that cannot
reasonably be expected to be catered for within the local BCU
policing plan. To provide an immediate and effective response
to such incidents it will be necessary to provide a defined level
of support.
Such support may either be made available to
the BCU commander to draw upon then deploy under local BCU command
or where circumstances dictate may deploy outside the normal BCU
management structures to take discrete control of the specific
incident.
These resources are specialist in nature and
rely upon specific training and equipment. They require investment
and maintenance at a level that would be impractical for the BCU
to sustain unilaterally.
There are other support functions required on
a day to day basis, eg file preparation, custody etc which can
be provided within BCU resources but which generally attract economies
of scale when they are provided on a collaborative or regional
basis.
In order to provide the BCU with efficient,
effective and timely support in these areas it is necessary for
the support services to sit within a wider police structure that
enables effective managerial control to be exercised.
We believe that this overarching structure should
empower and support BCUs, be sufficiently flexible to respond
to developing national trends and embrace minimum professional
standards across the whole of England and Wales.
A logical solution would be a national police
force deployed through a regional structure. This could be based
on the existing government regions. We recognise that the proposal
to create a national police force does not appear to sit comfortably
with the received wisdom that British policing is best provided
by local units allied to traditional boundaries. It is however
our firm view that our proposal would provide precisely such a
structure at the most local level and would simultaneously provide
the consistency of approach which is so glaringly absent at the
present time.
Whilst we appreciate that many people feel a
deep and very genuine loyalty to their current forces. The existing
structure of 43 autonomous entities aligned to boundaries which
no longer reflect government structures in the regions, or the
very local identities felt by individual communities has, we believe,
outlived its usefulness.
Individual forces have worked hard to improve
their performance, and indeed have achieved remarkable results.
However we would contend that we have now reached the point where
further significant improvement cannot be achieved without stepping
outside the current structural arrangements.
In particular, as shown in the emerging findings
of the HMIC baseline assessment for forces in England and Wales,
there is a clear gap in the way the current structure copes with
Level 2 criminality. Indeed the current performance measures and
targets reward displacement of Level 2 crime rather than encouraging
a collaborative approach.
A national structure implemented through a regional
configuration would have the capability to engage this level of
criminality and would ensure a seamless methodology for dealing
with all levels of crime from the most local to national and international
organised crime.
28 July 2004
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