17. Memorandum submitted by
the Association of Chief Police Officers of England, Wales and
Northern Ireland
1. THE ROLE
OF ACPO
ACPO[28]
is the professional association of the chief officers of the police
forces of England, Wales and Northern Ireland. It performs a number
of roles:
— It speaks for its members when appropriate.
This includes the Service's relationship with the Home Office
or to other bodies on issues where there is a common service interest.
It does not seek to comment or discuss issues relating to single
forces.
— It acts as professional advisor on
policing matters to the Home Secretary.
— It formulates guidance for the service,
eg to interpret new legislation.
— It co-ordinates the Service's response
when it needs to act as a single entity, in times of national
emergency or when there is a major or catastrophic incident. Past
examples of operations have included the fire officers' dispute
and the RAF Fairford protests during the war in Iraq, both in
2003.
In April 2003 Chris Fox, formerly chief constable
of Northamptonshire, was appointed as the first full time President
of the Association.
2. SUMMARY
1. ACPO has consistently been an enthusiastic
proponent of the reform process. After the original discussions
with the then Home Secretary, Jack Straw at the Lancaster House
meeting in September 2000 we summarised our approach to the police
reform programme thus:
"ACPO has always been willing to explore
with enthusiasm ways in which the Service can be made more effective.
We have naturally concentrated on how better to engage criminality
through a more professional career development regime; how to
approach public disquiet and insecurity; how to foster intelligence
and information technology and how to free up talent and resources
and generally create flexibility."[29]
2. Since then we have been at the forefront
of developing many of the initiatives that arose from the 2002
White Paper. The scope and extent of work contained within the
police reform processes is enormous and there are numerous projects
with a multitude of timescales, many of them very long term.
3. In the space we have available in this
submission we cannot comment on them all. We have therefore drawn
attention to some areas where, in our professional opinion, the
outcomes are not yet as positive as we had hoped. These comments
are made constructively and we will continue to work with others
to ensure that the Service can build on these early foundations
of developing excellence in policing.
The first reform process
4. When we looked a the Service in 2000
our diagnosis was that to keep pace in an ever changing world
we needed to:
— Implement the National Intelligence
Model (NIM) and bring a forward looking focus to the service;
making it fast on its feet rather than waiting for crisis.
— Professionalise and increase our
detective capability to address emerging crime trends and the
increasing complexity of society eg the ability to better present
complex evidence.
— Develop the capability to search
for excellence and incorporate it in doctrine and support forces
in complex policing operations.
5. Alongside this we developed a theory
of re-assuring the public and dealing with issues relevant to
their neighbourhood. This would be achieved through improving
visibility, accessibility and knowledge.
6. It is probably too early to make a valid
assessment of the impact of the first wave of reform; this is
hardly surprising as it was acknowledged at the time that the
changes were going to produce long-term improvement, aimed mainly
at improving the professionalism of the service. Some initiatives
have had an early impact, such as the adoption of the National
Intelligence Model (NIM). Some are not yet achieving the full
effect that they were intended to achieve; such as the introduction
of the National Policing Plan (NPP), the development of the National
Centre for Policing Excellence (NCPE) and the setting up of the
Police Standards Unit (PSU). Such issues as funding difficulties
and overlap with existing bodies, we would argue, have meant that
they have not been as effective as they undoubtedly could be.
The "second wave" of reform
7. The second wave of reform appears to
have been introduced before proper evaluation of the first wave
and this has allowed some, the Police Federation, for example
to suggest that continuing piecemeal changes are damaging the
service and that a Royal Commission is now needed.
8. We believe that our analysis at Lancaster
House is still valid. However, it is nonetheless an appropriate
time to review where we are going because we have new knowledge
about prevailing conditions.
9. The development of the NIM has given
us a much more sophisticated understanding of the national picture
of crime, criminal behaviour and communities that we ever had
before. As a result, we need to look at how we must re-direct
our resources to address what it is telling us is happening in
our communities. (Paras 34-38, below, refer.)
10. The new wave adds an emphasis on local
accountability. We wholeheartedly agree with this direction but
are concerned that the totality of policing from neighbourhoods,
through the wider area and up to national and international is
properly understood and that some estimate is made of current
capacity to deal with expanding priorities.
11. We would be concerned if proposals strengthen
central controls at the expense of flexibility and local responsiveness;
specifically an imbalance between centralised control and the
proper devolvement of power to manage. Changes should not be made
merely to demonstrate that Chief Constables are being held to
local account if these changes over-ride effective management
of the Service.
12. We would be concerned to see proposals
that introduce highly complex and bureaucratic processes, with
centralised target setting and complex lines of local funding.
We deal with this in greater depth at paras 48 and 49, below.
13. In our submission to the consultation
on the 2002 White Paper we put forward a detailed series of proposals
how to tackle re-assurance and fear of crime issues. At the time
these suggestions were not taken up. We are pleased to see the
issue has now re-emerged and is being given the prominence it
merits.
A structure to deliver effective policing
14. ACPO wants to improve the ability of
the Service to deliver the standard of policing that the public
wants. We strongly believe that our performance can only be improved
by ensuring that a system is developed where high quality leaders
have the freedom to manage resources within an appropriate structure
of national and local target setting, scrutinized by an independent
but professional inspectorate and measured by an effective performance
management regime.
15. This can be best achieved within a structure
where the stakeholders' respective roles are clearly defined.
For instance, we see Government's role as:
— Establishing the national infrastructure.
— Defining minimum standards of policing.
— Setting some performance targets.
— Scrutiny and performance monitoring.
— Producing and monitoring a National
Policing Plan.
16. Police Authorities and Chief constables,
in turn, would be responsible for agreeing additional targets
with local bodies (perhaps local policing boards) that would be
responsive to local needs in areas and neighbourhoods. Government
would then be in a position to hold one person, the chief constable,
to account for policing performance within this defined context,
rather than trying to define local processes from the centre.
3. SPECIFIC ISSUES
17. Within this overall viewpoint there
are a many specific issues that contribute to the whole. Some
of these we have summarised below. All have been the subject of
more extensive papers that have been part of our submissions to
the consultation process over the past nine months.
The National Intelligence Model
18. The NIM has been implemented and has
produced the first National Strategic Assessment. The next step
will to design and implement a national IT system to support this.
19. We are now in the process of developing
the model as one of the core definers of ACPO's business. For
example, it will be at the heart of our professional advice to
the Home Secretary in formulating the National Policing Plan.
The re-assurance agenda
20. This is being progressed, with an acceptance
of CSOs and other members of the extended policing family (accreditation
schemes are embryonic but are developing.) A major project is
being undertaken in eight forces to identify a range of tactics
most suited to local people; the aim being to improve their local
policing and reduce the fears that they themselves have identified
in their own areas. The University of Surrey is validating it
for dissemination of best practice across the country.
The National Centre for Policing Excellence
21. NCPE has completed work on four codes
of practice; Use of less than lethal firearms; PNC codification;
Serious Crime Analysis System Compliance (SCAS) and NIM compliance.
Work on others is at an advanced stage—domestic violence;
child protection; missing persons; investigation of serious sexual
offences and combating child abuse on the internet.
22. It has also delivered good practice
advise on the police use of powers to combat serious crime under
the Immigration Act and is running two projects (including a number
of pilot sites) to develop good practice in managing volume crime
and community cohesion issues.
Professionalising Investigation Project
23. Initial developments have been completed
(including pilots). The project is now being progressed by NCPE.
Different tiers of investigating skills will be accredited from,
probationer/street officers though to Senior Investigating Officers
who command the most serious and complex investigations. Core
investigative doctrine has now been written and will make a substantial
contribution to the training of investigators at all levels.
The National Police Plan (NPP)
24. We judge that the NPP is not yet an
effective driver of performance. Its first iteration was criticised
as being too general with no prioritisation amongst far too many
targets and it is perhaps worth noting that the NPP has not been
evaluated against its aims. The Home Office has recognised the
issues and we are promised a radically different plan for this
year.
25. However, we believe that the NPP cannot
be meaningful unless it is defined by a proper evaluation of what
it happening. This can only be achieved through the National Intelligence
Model (NIM) and an effective environmental scanning process. For
the first time we have an evidenced national and local picture
of the policing needs and can identify emerging trends rather
than respond when those trend become critical. ACPO is developing
The National Strategic Assessment (NSA) for this purpose and we
would like to see it form a major part of the planning cycle,
not only for the NPP and related target setting but for the National
Service Agreement setting and budget bidding.
National standards/priorities
26. We have consistently said that there
are too many centrally defined targets. This view has subsequently
been supported by the first NSA that showed local policing activity
across the country being skewed towards centrally defined targets,
away from locally identified issues. The move to localism within
the second wave proposals also seems to support this view.
27. We feel that targets should be set locally
against identified need within a context of some broad national
targets to aid consistency of standards across the country and
reflect the wider nature of criminality and its causes. An example
of this might be "To reduce crime and social harm anti-social
street behaviour" and the local target would be set according
to local perceptions and interpretations of that issue.
The role of the Police Standards Unit and the
National Centre for Policing Excellence
28. We certainly acknowledge that the existence
of the PSU and the NCPE is supporting a more robust performance
culture, which is gradually embedding itself in the Service. Both
were set up under the first wave of reform but there remains considerable
over-lap and duplication of resources with the previously existing
Home Office Departments and ACPO.
29. There is still insufficient separation
of function between these four bodies and inefficiencies result.
This is of particular relevance to ACPO as it is our members in
Forces that have to contribute to various pieces of work often
not coordinated and extra to the day-to-day performance management
role they perform.
30. The first wave of reform has included
a welcome emphasis on the development of measurement and monitoring
of performance. The growing role of the PSU in inspections and
interventions has helped to bring clarity and professional direction
to that process; the contribution by each element has been valuable
and we feel that this is a proper part of its role. We are, however,
less content with the growing remit of PSU to orchestrate national
campaigns and to work to identify the most effective operational
tactics to combat policing problems. This would seem to sit more
sensibly with NCPE or ACPO, both of whose remits are aimed at
Professional improvement.
31. We also believe that a system where
the training function (Centrex) owns the policy/doctrine making
function (NCPE) is flawed. There should be separation between
the policy/doctrine good practice part of the system and the scrutiny/intervention
arm. It is odd to see an organisation being driven by its training
function rather than its operational side where the relevant expertise
surely lies.
32. We believe that NCPE could perform a
valuable role for the Service. However the latest budget cuts
will severely damage its ability to "deliver the goods".
33. Centrex is redirecting itself as an
organisation but, as yet, the leadership programme that forms
a crucial role in the development of current and future leaders
is incomplete. We urge that it be properly funded so those leaders
inside our service from operational to Chief Officer can act as
an engine to reform.
Science and technology
34. The Service has improved its use of
science and technology but our major successes have resulted from
operational drive. Examples can be seen in the success of VIPER
and ANPR that are having considerable impact on operational effectiveness.
We would urge their continued development. Further work is needed
to establish an effective national infrastructure of critical
information technology to ensure the service is truly interoperable
in data handling.
Reducing Bureaucracy
35. The original Policing Bureaucracy recommendations
within Sir David O'Dowd's Report have, in the main, been integrated
into the wider Police Reform workstream and the Service has taken
the notion of reducing unnecessary paperwork into its everyday
activity. Many forces are, for instance using Mobile Data in different
ways to prevent officers having to return to police stations during
their tours of duty.
36. Examples of other gains include:
— 20,000 Fixed Penalty Notices issued
for predominantly public order offences. Now 600 Fixed Penalty
Notices have been issued as part of the current Alcohol Enforcement
Campaign. They are being extended into other areas such as Criminal
Damage and shoplifting;
— Officers no longer escort wide loads;
— Crime recording practices are being
standardised and streamlined;
— Video Identification Parades have
also significantly reduced costs;
— Thousands of forms have been made
obsolete.
37. There are some issues we are awaiting
national development on such as the Case Preparation and Custody
System, but overall most forces are showing significant financial
savings.
38. There are still recommendations that
require local authorities to take primacy on various issues. These
require in some cases changes in legislation and political will.
Legislation is for example waited to dealing with stray dogs and
parking enforcement (both in hand).
Workforce modernisation/reform of police pay,
conditions and working practices
39. We are in broad agreement with the principles
of workforce modernisation. Our concerns revolve around constraining
chief constables' power to manage their resources effectively.
Specifically we have asked for:
— A full review of police regulations
to bring them up to date. We want to improve our ability to deploy
properly skilled staff more flexibly.
— The removal of ring fenced funding,
as well as floors and ceilings on police numbers so that the workforce
mix can be better tailored to identified need.
— Re-negotiating discipline and grievance
regulations to allow faster flowing management resolution.
— Emphasis on leadership skills in
career/professional pathways. It is not being developed as we
had originally envisaged—and we would wish to see regional
training and development of Sergeant and Inspector ranks and their
equivalent to begin a career long process of leadership development.
— Consideration of properly managed
lateral entry to the Service—properly financed induction
processes where the skills and experience necessary for police
command are valued, understood and developed.
— Re-instatement of fast tracking is
needed; the loss of the graduate entry accelerated promotion has
been detrimental.
40. We have also been concerned that decisions
about training have been taken, not on analysis of operational
need, but rather to save resources, an example of this being the
reduction of initial probationer training from 15 to 12 weeks.
Community support officers (CSOs)
41. We see that CSOs have been a benefit
for the Service; they have improved the Service's visibility on
the streets and we would like to see the concept developed. There
is huge pressure on police budgets (with next year being especially
difficult); the conflicting demands from maintaining record police
numbers, new CSO targets and police inflation will very difficult
to resolve.
42. CSOs have a recognized but different
role from the constable—increasing the visibility of the
police to the man on the street. Extending their role and powers
too extensively could detract from that as additional training,
more paperwork, court appearances etc. would result in less "street"
time and defeat their reason for being. The CSO as seen currently
is different to the Special Constable—that valued volunteer
force that uses extensive powers and assists policing locally
this difference should remain.
Operational Coherence
43. Many of the proposals we have seen seem
to treat policing operations and the Service as if they were commodities;
something that can be segmented or compartmentalized. This allows
each discrete operation to be examined separately to see if it
can be done better by another agency or funded from a different
source etc.
44. We see this most clearly in proposals
around new localism models and our concern is that it does not
reflect our experience of the nature of crime and criminality
with which we have to deal. Some issues of crime and disorder
are purely local (albeit their causes such as drugs, alcohol,
social cohesion or coercion may require broader action). Many
types of crime, especially the most serious, are much more widespread
in their nature. Criminal activity and disorder of all types flows
and overlaps neighbourhoods, crossing local, regional and even
national boundaries.
45. In addition, organised crime is far
more prevalent than we have previously recognised. Criminals who
we had previously perceived to be local operators we now see to
be linked, through a complex of constantly shifting networks across
areas and regions in a way that we are only now beginning to map
effectively. Criminals themselves cross category boundaries, with
a portfolio of criminal activities and are often responsible for
disorder in their neighbourhood as well.
46. This picture of criminality is most
effectively disrupted by a policing organisation that can:
— Integrate wide-ranging strands of
intelligence from a variety of sources; from neighbourhoods up
to international levels;
— Deploy a range of the most appropriate
resources at the most effective point and time to disrupt criminals
and criminal activity.
47. Ring-fenced funding, over use of centralised
target setting or separate funding routes for precepted funding
all constrain the ability of chief constables to move resources
in accordance with this model of activity and therefore, in our
view, will always hamper their effectiveness.
Accountability
48. We strongly support the drive to define
a new model of local accountability with stronger local direction.
We were encouraged by the principles espoused in early consultation
but later proposals seem to move away from the view that lines
of accountability should be clear, simple and be aligned with
lines of management.
49. We would be concerned to see emerging
models of accountability which appeared overly bureaucratic, highly
complex, with multiple lines of reporting; internally focused,
rather than concentrating on service delivery and also with an
over emphasis on centrally driven targets. It is crucial that
a citizen can identify with sufficient clarity, who exactly is
accountable for success or failure to deliver policing services.
50. If accountability is to rest with the
chief constable, as we believe it should, then the policing infrastructure
should support this, with an appropriate target setting regime,
an effective performance framework but freedom for that Chief
Constable to manage resources to meet the challenges. The alternative
of excessive central target setting and tightly hypothecated funding
pulls accountability to the centre. At the moment we are part
of an infrastructure that is not clear where it is, with ring
fenced funding and rigorous performance management. For the Service
to deliver effective policing at local levels this issue needs
to be resolved. Indeed an infrastructure has no consciousness
and it is crucial that accountability rests with an individual
rather than a mechanism.
Structure
51. Whilst it has been the subject of much
debate, it seems that the case for re-structuring has yet not
been made; more work needs to be carried out to assess the possible
business benefits (reduced costs, economies of scale, performance
improvements, greater operational resilience etc) and the risks
(cost of change, disruption of performance improvement etc).
52. ACPO is developing the concept of the
strategic force. We are defining the range of capabilities needed
at Force and BCU level to be able to operate effectively against
all crime from neighbourhoods up to regional and national levels.
53. Once an agreed model is defined, a force's
ability to comply with these specifications could be assessed.
If it were to fall short then a plan would be required to show
how it could acquire them. Structural issues would properly be
part of that debate.
Resources
54. ACPO in its submissions to the reform
debate has highlighted a gap in our resources at neighbourhood
and the level where we address cross border and organised crime.
These concerns have not been addressed in the subsequent reports
that we have seen. We believe that there has to be a complete
understanding about what we can be expected to be achieved with
the resources available and specifically we have asked for proposals
on:
— Identifying new resources to develop
the necessary increase in capacity.
— Simplifying and clarifying funding
allocations.
— Greater operational flexibility in
the use of funds.
55. As part of our work on capacity we have
looked at police finances over the past 10 years and it is clear
that whilst overall resources have risen considerably, the increases
in central government funding have almost entirely been eaten
up by unavoidable cost increases such as salaries and pensions.
The rapid rise in officer numbers that we have seen has therefore
been funded almost entirely through local precept rather than
central funding.
56. If precepted funding were not to be
available at a force level, but targeted at community safety locally,
then control over the size and shape of the workforce, specialist
capability and resilience will be lost, with obvious potential
consequences.
57. We suggest that money should be delivered
through the Force level to preserve strategic aims and resilience,
as well as the ability to deliver local policing appropriate to
the area.
A Police Improvement Agency
58. ACPO has argued for the development
of an Improvement Agency structure and government has accepted
the idea. It has issued a consultation paper about its potential
establishment and operations. At the time of writing of this paper
ACPO has not had the opportunity to consider the document.
59. However, we will be looking for an organisation
that will not be over complex or tied to the notion of centrally
directed process management, ie it should help working police
officers change their culture and practices to improve productivity
and performance delivery. It should be separate from the performance
management and scrutiny regime, being seen as part of delivery.
60. We are attracted to a model that emphasises
the identification and development of better service delivery
through the use of clearly tasked, properly resourced, practitioner
teams focusing on:
— Increasing productivity (and therefore
capacity);
— Developing rational solutions in
high risk services, eg dealing with dangerous or vulnerable persons;
— Supporting collaboration or structural
change emerging from the capability work referred to at para 53.
61. The agency would work with the 43 Chief
Constables to establish how each one can deliver the aims of reform
and then coordinate a national response. The aim is to assist
each force to progress and for the Agency eventually to work itself
out of existence, as forces acquire the skills to make change
happen within a National context.
6 August 2004
28 NB: ACPO is not a staff association; the Chief
Police Officers' Staff Association (CPOSA) performs that role. Back
29
Letter to John Denham, Police Minister from Sir David Phillips,
President, ACPO. November 2001. Back
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