36. Second supplementary memorandum
submitted by HM Inspectorate of Constabulary
OVERVIEW
1. The Government White Paper encompasses
a wide range of reform issues and the implications of the proposals
contained within it are potentially far reaching. HMIC will be
holding a comprehensive internal consultation exercise during
December and January to elicit the considered views of HMIs and
the new Chief Inspector, when appointed. As a result, a more detailed
response to the White Paper will be submitted to the Government
before the February 2005 deadline.
2. In the meantime, however, the attached
report represents the initial comments received from HMCIC and
HMIs, having particular regard to the main proposals set out in
the White Paper. For ease of reference, comments have been grouped
under first the relevant chapter and then in the order that the
issues commented upon appear within the White Paper.
Sir Keith Povey
HM Chief Inspector of Constabulary
25 November 2004
CHAPTER 3—COMMUNITY
ENGAGEMENT
1. NEIGHBOURHOOD
POLICING
1.1 Improved collaboration and engagement
between the police and public, problem solving and tackling local
issues are key components of neighbourhood policing and building
stronger and safer communities. HMIC supports the commitment to
embed a responsive customer-focused service and to ensuring police
forces and partners are more visible and accessible within communities.
1.2 A number of forces have already successfully
adapted their policing style or introduced new measures to re-engage
with the public and provide a more localised service, however
this is not yet routine and it is recognised significant work
has to be undertaken before the concept of neighbourhood policing
is fully permeated throughout the Service.
1.3 There is recognition that neighbourhoods
are not homogeneous, "one size will not fit all" and
people will be reassured by different policing methods ie high
visible presence may reassure some residents but at the same time
be intimidating for others who may feel they are being targeted.
Clearly there are common features however it is important that
neighbourhood policing is pro-active, intelligent led and sufficiently
flexible to meet local needs. HMIC welcomes the introduction of
joint guidance provided there is a balance between setting out
general principles and over-prescription.
1.4 The policing style of "mixed economy
teams" as highlighted in the White Paper is evolving in a
number of forces and customer focus benefits are evident. Anecdotal
evidence suggests dedicated neighbourhood policing teams such
as those introduced in Merseyside Police have contributed to a
reduction in crime and increased public satisfaction however much
more persuasive would be research evidence indicating neighbourhood
policing delivers sustainable results.
1.5 Forces and police authorities who have
identified the cost of resourcing and sustaining neighbourhood
policing units will welcome the proposed Neighbourhood Policing
Fund. Whilst there may be a requirement for "smarter thinking"
and of greater recognition that local investment should bring
reward, it is currently not a "level playing field"
and subtle assistance may be appropriate in some areas.
1.6 Drawing resources from other partners
would provide greater integration and enhanced service delivery
however a major frustration within forces striving to achieve
this has been the lack of buy-in by other service providers. Unless
there is mechanism for ensuring greater commitment and contribution
from partners the police service will continue to be the main
and often sole provider of resources.
1.7 The increased numbers of PCSOs is welcomed
however as previously identified the evaluation is incomplete
and concerns remain about inconsistencies in approach and the
capacity of the police infrastructure to absorb the additional
staff. PCSOs play a vital role in providing increased visibility
and community reassurance therefore it is imperative the appropriate
structures and management support mechanisms are in place and
abstractions are monitored. HMIC recognises the requirement for
neighbourhood officer and PCSO training, but this will involve
a major piece of work requiring proper programme management, resources,
and a clear statement in respect of priorities alongside areas
such as the Professionalising Investigation, Initial Police Leadership
Development and Core Leadership Development Programmes.
2. BUREAUCRACY
2.1 HMIC supports the Government's commitment
to reducing bureaucracy and is a key partner in the Policing Bureaucracy
Implementation Steering Group established to progress the recommendations
of the O'Dowd report. HMIC welcomes the drive for greater local
accountability however new measures introduced must be of simple
construct, avoid additional bureaucracy and must not erode the
operational autonomy of chief officers.
3. CUSTOMER SERVICE
STANDARDS
3.1 The drive to improve police responsiveness
to customer needs and increase user satisfaction is welcomed however
the proposal that each force will agree a Contract with their
communities gives rise to a number of questions. More work is
required to identify what form these Contracts will take, will
they be at force or BCU level, who on behalf of the Community
will agree the contract and in reference to the increasing multi-agency
response what is the responsibility of the partners?
4. NATIONAL POLICING
IMPROVEMENT AGENCY
4.1 This is addressed in the response to
chapter 5.
5. MEASURING
PERFORMANCE
5.1 The introduction of more relevant measures
within the Police Performance Assessment Framework (PPAF ) to
reflect local issues is seen by HMIC as a positive development
but recognises that progress has been slow as almost by definition
local priorities are not amenable to the robust comparative criteria
used for PPAF measures. The main elements of the reform programme—such
as Citizen Focus which incorporates Neighbourhood Policing, Community
Engagement and Customer Service and Accessibility are incorporated
within the HMIC Baseline Assessment, allowing progress to be tracked
force by force.
6. SINGLE NON-EMERGENCY
NUMBER AND
CALL HANDLING
6.1 HMIC is in the early stages of undertaking
an in-depth thematic inspection of call handling processes, the
primary focus of which will be the police interaction with the
public and other agencies. The inspection will be conducted in
two sections, contact management—which will include initial
contact, handling and routing of calls, and response grading,
and also incident management—covering resource deployment,
scene attendance and closure. The thematic inspection will take
the opportunity to examine customer views and reactions to the
various interactions, at each sub-stage, as well as examining
the general availability of approach to customer feedback. It
is intended to produce a model template of contact management
processes and recommendations as to good practice.
6.2 HMIC continues to participate in the
Home Office project to develop a single non-emergency telephone
number (SNEN) and is fully supportive of its aims and objectives.
The introduction of a non-emergency number should assist alleviate
pressure on the 999 emergency call service.
6.3 The ACPO sponsored National Call Handling
Standards Project is currently developing a national strategy
to improve overall professionalism in call management for the
service. HMIC is very supportive of this work and has been fully
involved in the project since its inception.
7. LOCAL ENGAGEMENT
TO IDENTIFY
PRIORITIES
7.1 The formal proposal to strengthen the
relationship between local and ward councillors and the Police
is welcomed by HMIC and should build on already effective working
relationships in a number of force areas. However, as in the case
of requiring the CDRPs to oversee the delivery of local priorities
the focus should not be on creating additional levels of accountability
and bureaucracy but rather on ensuring current structures are
robust and capable of delivering an improved service directed
to local needs. Before introducing a mechanism to trigger action,
careful definition and criteria needs to be identified otherwise
attempts by BCUs, CDRPs and neighbourhood groups to plan and prioritise
may be continuously challenged or undermined.
7.2 Police authority involvement within
communities and partnership groups is still in some areas fairly
embryonic and there is a lack of clarity of their role and how
they actually can impact on delivery of service. It is difficult
to gauge what the duty on police authorities to secure the implementation
of a strategy to engage communities will mean in practice.
8. LOCAL COMMUNITIES
TRIGGERING ACTION
8.1 HMIC is supportive of the work currently
being undertaken by the PSU to produce guidance on BCU delegation
and empowerment but would caution against any proposal which introduce
the use of stronger mechanisms of accountability for BCU Commanders
who are already held to account by their Chief Officers and a
wide range of partners and stakeholders. The aim should be to
develop more coherent and streamlined processes which would assist
maintain focus and drive measurable improvements.
8.2 The investment in additional training
for all senior ranks must be related to need and should be linked
to the current Core Leadership Development, Senior Leadership
Development and Chief Police Officer Development Programmes.
CHAPTER 4—BUILDING
A NEW
WORKFORCE
1. CAREER MANAGEMENT,
ACCREDITATION AND
RECOGNITION
1.1 The Police Reform programme has provided
a platform for workforce modernisation and the continued development
of a more professional police service. As identified by HMIC's
recently published thematic inspection of workforce modernisation
a significant programme of change is required to meet the scale
and complexity of policing in the 21st century.
1.2 The Best Value Reviews of Training,
Police Authority reviews and the work on diversity currently being
undertaken by HMIC places the Inspectorate in a good position
to support the second phase of the reform programme.
1.3 HMIC welcomes the recognition within
the White Paper of the HR capacity required to deliver reform
but is of the view there urgently requires to be a co-ordinated
and strategically driven Human Resource Strategy and the necessary
resources and expertise, at a National level, to effectively drive
this work. ACPO PMBA are currently developing such a document
and when published this should provide consistency across the
Service. It will be particularly important to have clarity on
priorities and time-scales.
1.4 Recognition of the operational discretion,
versatility and the personal accountability of police officers
and of the commitment not to diminish the legal status of the
office of constable is supported by HMIC. Whilst not included
within the White Paper a key issue when considering the change
of mix of personnel within the Service is the right, or not, to
strike. This is particular relevant in areas such as Call Handling.
1.5 HMIC strongly supports the continued
focus on Performance and Development Reviews (PDRs), the proposal
to ease their completion and to monitor through the PPAF. The
effective completion of PDRs will also be monitored through HMIC
Baseline Assessment. It will be important to get the PDR system
operating properly and fully trusted by staff before it is linked
to performance related pay.
1.6 The introduction of a PDR regime for
chief officers and the PDR—linked performance bonuses for
superintending ranks have helped to embed PDR as a key HR process,
and is a contributor to individual and force performance management
and improvement.
2. NEIGHBOURHOOD
POLICING FUND,
ENHANCED POLICE
STAFF ROLES
AND PCSOS
2.1 The continued Government commitment
to the extended police family is welcomed by HMIC who supports
increasing the front line police officer strength through the
deployment of police staff. HMIC strongly believes the concept
of enhanced career development opportunities, both lateral and
promotion, for police staff is necessary to provide a professional
service, for continuos improvement and to assist retention.
2.2 As previously stated HMIC welcomes the
continued funding to support the increase in PCSO numbers and
would encourage that the lessons learned from the large scale
police officer recruitment, through the Crime Fighting Fund, are
taken cognisance of. As identified in the HMIC thematic inspection
of workforce modernisation it is imperative that robust infrastructures
are in place to effectively support and handle the increase in
PCSO numbers and that this includes national representation and
recognised terms and conditions.
2.3 The role of police volunteers, special
constables and the engagement of local members of the community
and private sector is crucial in delivering the model of neighbourhood
policing outlined. The efforts to establish initiatives to assist
recruit staff and further enhance the status of these roles is
welcomed. HMIC is of the view there is a requirement for clarification
of the long term vision for the role of the Special Constabulary
and how this meets with the plans for the increase in PCSOs.
3. BUREAUCRACY
3.1 This is addressed in the response to
Chapter 3
4. MULTI-ENTRY
POINTS
4.1 HMIC embrace the view that to meet the
demands of policing in the 21st century it is necessary to ensure
the best leaders are appointed to the most challenging roles and
that in some instances this may be police staff and not police
officers. However, such a move would be a significant change for
the service and will require careful management. Some police roles
are operationally challenging and safeguards will be required
to be built into the process to ensure the service or individual
is not compromised. Similarly the mix of staff within teams professionally
competent to undertake specific duties will have to be monitored
to ensure operational capacity and that additional burdens are
not placed on particular staff members.
4.2 The possibility of a two-tier service—multiple
entry and promoting graduate recruitment—should be avoided
at all costs. Whilst clearly there is a necessity to consider
opportunities to attract high quality people into the Service
it is also necessary to consider the core delivery functions and
responsibilities and ensure all needs are met.
4.3 There is also a requirement to identify
and maximise the potential and provide training and development
opportunities to those already in the Service in order they do
not become disillusioned.
5. TRAINING,
LEADERSHIP, MANAGEMENT
TRAINING AND
SCAS
5.1 HMIC reported to the Home Affairs Committee
on police training and recruitment in 1999 and has since undertaken
a significant programme of work in respect of recruitment, training
and personnel inspection activity. It also provides support and
advice to policy development within forces and the Home Office.
5.2 The proposal to extend work-based assessment
throughout the service as an alternative to examination raises
concern within HMIC as this would appear to undermine current
promotion trials, which have yet to be evaluated. Results and
feedback from this process should inform the direction of future
work.
5.3 The scale of the challenge of workforce
modernisation requires supervisors at all levels to be effective
both as leaders and managers. Therefore Core and Senior Leadership
Development Programmes must adequately cover both areas with sufficient
focus on personnel management skills
5.4 The introduction of the Senior Careers
Advisory Service (SCAS) to assist identify senior talent within
the Service is welcomed in principle by HMIC who see value in
the identification and early development of potential future leaders.
5.5 HMCIC strongly believes the Senior Appointments
Panel (SAP) should not be subsumed within the SCAS to ensure that
the integrity and independency for which the process is currently
recognised is retained. The SAP would also be well placed to quality
assure processes.
6. DIVERSITY
6.1 HMIC is one of the key organisations
driving improvements within policing and over the years has fully
supported the Government's efforts to modernise the police service,
taking account of the wider spectrum of diversity through the
concept of community cohesion.
6.2 Between 1995 and 2003 HMIC has demonstrated
its commitment by launching an unprecedented concentration of
inspection effort carrying out five thematics inspections, appointing
two specialist advisors and adopting a high profile within all
national bodies and committees striving to improve relationships
and public confidence.
6.3 Many of the proposals outlined in the
White Paper reflect the Winning the Race document which laid the
foundations for the police service accepting the value of cultural
auditing, to challenge institutional racism. The document also
highlighted the importance of leadership and diversity training
to underpin the development of appropriate behaviour and attitudes
towards understanding difference.
6.4 HMIC recognises the rights of individuals
under the Human Rights Act however, there are some cases where
these rights must be challenged particularly in the interest of
ensuring public trust and confidence and if it contravenes section
71 of the Race Relations act 1976. HMIC supports ACPO in its view
to amend police regulations to ban membership of, or engagement
with organisations whose constitutions, aims objectives or pronouncement
contradict the general duty to promote race equality.
6.5 Recruitment and retention of members
of the Black and Minority Ethnic (BME) communities is crucial
to the Service, which currently faces a shortfall in meeting recruitment
targets. In order to meet the requirements for policing diverse
communities there is a valid case operationally to recruit applicants
who meet the attainment standards and have the additional skills
of being bi-lingual. HMIC are currently working with ACPO to monitor
the extent and success of such strategies as part of the inspection
process.
6.6 HMIC supports the Government in the
development of the National Black Police Association(NBPA) plan
and would wish to see that in future all staff support groups
are under one umbrella and supported by the Government.
6.7 Working in conjunction with ACPO and
APA, HMIC are seeking to ensure that police authorities promote
diversity within the police force and authority and that they
comply with the provisions of the Race Relations Act and that
Race Equality Schemes are effectively implemented and monitored.
The responsibilities of police authorities in respect of diversity
are incorporated within the HMIC Best Value Review Inspection
programme.
6.8 HMIC acknowledges that the representation
within senior ranks for women and BME staff needs to improve.
HMIC are working closely on the Gender Agenda and "Breaking
Through" and welcomes the introduction of family-friendly,
flexible working patterns where possible. HMIC will, where identified
through inspection, remove barriers to the progression of women
and also ensure that appropriate mechanisms are in place to monitor
and address any disproportionality.
6.9 It is important that the proposals are
diversity-proofed to ensure that women and ethnic minority composition
of the workforce is not affected detrimentally.
CHAPTER 5—ENSUING
EFFECTIVENESS
1. TIGHTER FOCUS
FOR NATIONAL
POLICING PLAN
1.1 HMIC fully supported the introduction
of the National Policing Plan (NPP), seeing it as an effective
vehicle for identifying and communicating Government priorities,
and providing consistent strategic direction and focus to forces
and police authorities. HMIC welcomes the Government commitment
to a more strategic and concise NPP.
1.2 The NPP sets minimum standards against
which policing should be delivered and in the view of HMIC should
be linked to the ACPO and National Crime Intelligence Service
(NCIS) National Strategic Assessments, to ensure it addresses
the identified areas of risk.
1.3 HMIC welcomes the introduction of fewer
and less prescriptive Public Service Agreement Targets allowing
for greater flexibility for forces and police authorities to deploy
resources and respond to particular localised problems.
2. BICHARD ISSUES—NATIONAL
INFORMATION AND
INTELLIGENCE SYSTEMS
PLUS VETTING
2.1 HMIC gave both written and verbal evidence
to the Bichard Inquiry and was influential in shaping some of
the key proposals, now progressed further within the White Paper.
HMIC fully supports the key recommendations from the Inquiry and
has been an active member of the Home Office implementation groups
at all levels.
(a) Code of Practice for information management
2.2 Key to HMIC's contribution to the developing
Code of Practice for police information management has been to
ensure its design allows HMIC to provide a meaningful, accurate
and transparent inspection methodology.
2.3 The Code is being developed in such
a way as to prescribe clear first principles for police information
management, and, underlying these, sets of guidelines will address
how various areas, such as the emerging Quality Assurance Framework
on employment vetting, will be managed. HMIC has expressed some
concern over the use of the terminology "guidelines"
and would prefer to see these described as "standards".
This is more than simply semantics as the experience of "guidelines"
in the use of the Police National Computer has been that forces
interpret these to suit local needs and thereby make it difficult
to inspect against a common approach.
2.4 Whilst it is difficult at this stage
to prescribe the exact model of inspection which will be developed,
by the time the Code is put before Parliament in June 2005 HMIC
will have developed the Baseline Assessment protocols to ensure
inclusion in the 2006 core inspection programme.
(b) National Intelligence System
2.5 HMIC has voiced concerns around the
feasibility of Programme Impact as a vehicle for handling intelligence
nationally. There is incontestable worth in the proposed structure
of the programme as a long-term answer to information sharing.
It is built upon a corporate data model supporting a series of
nationally shared data warehouses with appropriate tasking and
briefing tools. As a vehicle for a national solution to intelligence
handling, however, there remain significant question marks over
the:
(a) lack of standardised capture of intelligence;
(b) absence of actual corporate intelligence
systems within some forces;
(c) doubts over delivery of current data
warehousing pilots more widely; and
(d) continued proliferation of smaller, localised
databases, that may "hide" important intelligence.
2.6 HMIC believes the Impact model will
not in the short to medium term do anything to provide a common
intelligence system for forces that currently do not have one,
encourage more standardised approaches nor interrogate the intelligence
held on small local systems. Until such databases are either incorporated
into a single intelligence system or accessed by Impact the danger
of another Ian Huntley slipping through the net remains a real
possibility.
2.7 HMIC remains supportive of the development
of an underlying standard intelligence system, along the lines
of the current Scottish model, which can subsequently be enhanced
by a wider information sharing solution, such as Impact.
(c) Vetting Procedures
2.8 HMIC has maintained close liaison with
both ACPO and the CRB in the development of their Quality Assurance
Framework (QAF), designed to standardise vetting procedures. This
framework addresses the issues identified within the recommendation
and provides real assurance that once fully implemented there
will be scope to have confidence in the strength of the measures.
2.9 HMIC is comfortable with the audit model
being developed between ACPO and CRB and has undertaken that,
once the framework has been implemented, appropriate questions
will be included within Baseline Assessment. In the interim HMIC
has undertaken to conduct a focused inspection of information
management issues in Lancashire Constabulary, to include vetting
using the QAF, data protection and weeding. This will provide
a template for future inspection nationally.
3. CODE OF
PRACTICE FOR
NIM
3.1 The National Intelligence Model (NIM)
is a key driver in policing activity and the police service is
working to improve the management systems around the areas of
planning, performance review, people and financial management.
Whilst progress is clearly evident HMIC are of the view that some
forces have been constrained by a legacy of obsolescent computer
systems which are not fully integrated. The provision of relevant
and timely information to managers is crucial however remains
an issue for a number of forces.
3.2 HMIC welcomes the imminent publication
of the NIM Codes of Practice that will be used as the basis for
reviewing force NIM processes and compliance during Baseline Assessment.
4. GRADING OF
POLICE PERFORMANCE
(a) Earned autonomy and inspection holidays
4.1 HMIC is committed to a proportionate,
risk-based inspection regime that gives high performing forces
relief from scrutiny and allows them to get on with delivering
quality policing services. Conversely, under-performing forces
will benefit from more intensive diagnosis, advice and support
by HMIC, often in conjunction with PSU, to help them raise their
performance.
4.2 HMIC Baseline Assessment is the foundation
for a far-reaching "earned autonomy" regime, providing
an objective and evidence-based comparison, fully integrated with
PPAF, across core policing activities. When the full PPAF-aligned
baseline assessment is completed in Autumn 2005 it will be, for
the first time, possible to identify "excellent" forces
and reward them with freedom from inspection, with minimal risk.
The risk/vulnerability factor is crucial. There is a real tension
between the concept of inspection freedoms and the "Bichard
view" that HMIC should leave no stone unturned in high risk
or mission-critical areas such as sex offenders and child protection.
Reconciliation of the two approaches is difficult but possible
if a capacity for remote monitoring can be retained; baseline
assessment provides this capacity.
(b) Single grading for forces
4.3 The 2003-04 Baseline Assessment did
not explicitly grade forces overall as excellent, good, fair or
poor but rather graded individual functions. Most forces had a
mix of grades, a few had no "excellent" marks and some
had no "poor" gradings. An overall grading for each
force would allow the opportunity to develop graduated freedom,
which is more radical, sophisticated and proportionate than simply
ascribing freedom from inspection to a small number of forces.
The baseline assessment methodologically which will be used in
the 2004-05 assessment will be sufficiently sound to ascribe an
overall grade to each force. To achieve the groupings of performance
however, there first requires to be agreement on weighting different
aspects of policing which is clearly a complex and contentious
subject.
4.4 HMIC is also working towards an accreditation
process at BCU level so that organisations with robust and proven
internal inspection and review structures are trusted to undertake
self-assessment validated by HMIC. Forces which earn this degree
of autonomy will experience a reduction in regulation and inspection.
5. REMEDIAL ACTION
AND INTERVENTION
5.1 The widened power of the Secretary of
State introduced through the Police Reform Act 2002 initially
attracted considerable debate and in some areas concern, particularly
around the balance of control. Police authorities and chief officers
viewed the changes as empowering the Secretary of State at their
expense. However, these additional powers, which have not been
exercised in full, have undoubtedly sharpened the focus on performance
and helped to improve service delivery.
5.2 The Act enables HMCIC to recommend specific
intervention by the Secretary of State if forces are not improving
their performance, or are failing to respond to HMIC recommendations.
HMIC has substantial expertise in policing and is recognised as
a trusted "intervention gatekeeper", placing performance
concerns in context and interpreting and professionalising raw
metrics which arise from a purely statistical analysis of performance.
5.3 The PSU, whilst very new to the scene,
provides a key role in data handling and in supporting remedial
work within poor performing forces. HMIC is unique, however, in
having the expertise, capacity and the ability to apply contextual
information and professional judgement to statistical performance
data.
5.4 The independence of HMIC provides the
confidence that action can not be solely generated and directed
by politicians and this is crucial to the integrity of the intervention
process. This independence, indeed the combination of these factors
ensures HMIC holds a unique credibility with all the stakeholders
involved in the process.
5.5 HMCIC is of the view that the process
to date has worked effectively and whilst willing to engage in
a review of arrangements, he is strongly of the opinion HMIC should
remain the sole gateway to any form of statutory intervention.
6. CRIMINAL JUSTICE
INSPECTION
6.1 HMIC recognises the logic of a Criminal
Justice Inspectorate and is currently involved in the consultation
process for the review of inspection arrangements for public services
and the proposal to introduce more coherent arrangements for end-to-end
inspection of the Criminal Justice System (CJS).
6.2 HMIC is of the view that, whilst there
clearly are opportunities for collaborative work in the Criminal
Justice arena, and indeed is working towards increased joint inspection
activity, the vast majority—amounting to some 80-90%—of
Police activity and of work undertaken by HMIC lies wholly outwith
the CJ sector.
6.3 The crucial role undertaken by HMIC
in inspecting police performance is paramount to maintaining an
efficient and effective police service for England and Wales and
this should not be underestimated in any form of restructuring
process.
6.4 The role of the modern police service
and the work undertaken by HMIC would suggest that to integrate
HMIC within a CJ Inspectorate would be an extremely complex process.
HMIC has recently been given, in principle, the statutory responsibility
to inspect both the Serious and Organised Crime Agency (SOCA)
and the remaining elements of HM Customs and Excise. These additional
responsibilities only serve to increase the argument that HMIC
should perhaps develop into an agency such as "Her Majesty's
Law Enforcement" or "Public Protection Agency"
or similar. There would still be opportunities for collaboration
and joint activity with members of the proposed CJ Inspectorate
but the focus would remain on core police delivery and performance.
6.5 The Royal Commission on Policing (1962)
created for HMCIC the role of senior professional police advisor
to the Secretary of State. This role has increased in importance
and impact in recent years. The lack of this crucial role in the
current demanding and challenging policing climate would leave
the Government, and in particular the Home Secretary, extremely
vulnerable and exposed.
6.6 HMIC agrees there is a requirement to
ensure a cost effective inspection service, however, as in the
case of other areas of restructuring currently being considered
changes should only be contemplated if it can be demonstrated
it will deliver performance improvement.
7. NATIONAL POLICE
IMPROVEMENT AGENCY
7.1 HMIC is a firm supporter of the concept
of a National Police Improvement Agency (NPIA) and is currently
participating in the consultation process.
7.2 HMIC is of the view there is a requirement
to rationalise the bodies currently involved in setting, implementing
and improving standards and that Centrex (which includes the National
Centre for Policing Excellence (NCPE)) and PITO, in their respective
roles, would sit comfortably under the umbrella of a National
Police Improvement Agency. All or part of the current work of
the Police Standards Unit would also logically fall within the
NPIA remit. The NPIA would act as an agent for change and drive
improvements within the police service.
7.3 HMIC should remain an independent body,
informed by the work of the NPIA, and then well positioned to
inspect and examine effectiveness. Learning and good practice
from inspections would be fed back into the NPIA, creating the
virtuous circle of continuous improvement.
8. LEVEL 2 AND
COLLABORATION
8.1 HMIC considers the proposals to explore
the creation of dedicated teams across regions or groups of forces
to tackle level two criminality is unlikely to address the problem
unless there is a significant increase in resources. Regional
Tasking and Co-ordination teams are already in existence but critically,
lack the resources to undertake cross-border operations.
8.2 In addition, the relationship between
the role of regional teams and those of the recently introduced
Serious and Organised Crime Agency (SOCA) will require to be explored.
8.3 Whilst HMIC recognises the police authority
role in ensuring effectiveness of their respective forces, it
is unclear how the proposal for police authority co-operation
with neighbouring police authorities on tackling cross-border
crime will be implemented and of the operational benefits. There
is a grave danger in introducing an additional layer of accountability
and bureaucracy into an area where timeliness can be a key issue.
9. FORCE STRUCTURES
9.1 As previously reported to the Home Affairs
Committee HMIC has been commissioned by the Home Secretary to
examine and provide a professional assessment on whether the current
structure of policing in England and Wales is appropriate to meet
present and future policing needs.
9.2 HMIC is fully aware of the sensitivities
surrounding this potentially controversial subject and had already
provided Ministers with two written submissions outlining a number
of key considerations. These have focused upon specific themes
including operational, organisational and back-office functions.
9.3 If England and Wales was a "green
field" site for policing then few doubt that it would be
structured to a more logical design. At the heart of the debate
is the need to reconcile tensions between delivering a locally
based service with a need to provide an effective response to
major crime and events and to combat organised criminality in
its various forms. Structural change is almost always accompanied
by distraction of effort and disruption—clearly it should
only be contemplated if it can be shown to deliver a step change
in police performance.
9.4 HMIC will report its findings by 31
January 2005.
10. REVIEW OF
PARTNERSHIPS AND
CRIME AND
DISORDER ACT
10.1 The Crime and Disorder Act (CDA) has
made a significant impact in terms of policing culture and the
Services attitude to working with others. However, a major frustration
has been the level of buy-in by other service providers and in
particular their recognition of their obligations under Section
17 of the Act.
10.2 The roles and responsibilities of Chief
Constables and Police Authorities in respect of building partnerships
are outlined in the White Paper, however, there is less detail
on how the Government intends, at a national level, to exercise
influence on and ensure the engagement of other key partners.
10.3 Prior to CDRPs being afforded increased
responsibilities a clear mechanism is needed to govern pooling
and sharing of resources and thereafter accountabilities. The
neighbourhood policing model envisaged will not be fully effective
unless there is a mechanism to bring partners more obviously to
account for how they make their contribution to the common agenda.
10.4 Joint Inspection in this arena would
be helpful however the trigger for inspection needs to be tightly
drafted. A number of joint CDRP inspections have taken place however
there is a critical need for joint inspection protocols to be
agreed.
10.5 HMIC is already actively engaged in
the review of the CDA and welcomes the opportunity to contribute.
11. POLICE AUTHORITIES
11.1 Police authorities working with chief
officers have a strategic role in the governance of forces and
are positioned not only to support the delivery of policing services
but also to hold the chief officers to account for performance.
HMIC recognises the often complex role of police authority members
but has, as previously reported, recognised a variability in the
effectiveness with which these roles are discharged. Similar variability
is evident in their response to recommendations of HMIs and in
the process used for chief officer selection.
11.2 HMIC welcomes the proposals to review
police authority membership and responsibilities, however, would
seek assurance that, to prevent overlap and the creation of additional
tiers of accountability, any proposals would be considered in
parallel with the work in respect of community advocates, role
of local councillors and scrutiny panels.
11.3 HMIC would wish greater clarification
in respect of the proposal to give police authorities the power
to request inspection and or intervention as this may clearly
create capacity issues and impact upon other inspection activity.
11.4 There is currently no single body with
a remit to inspect the effectiveness of police authorities, nor
to assess how well they work with chief officers. This is an obvious
gap in the regulatory coverage that could be increasingly problematic
if the proposals to increase the power and statutory responsibilities
of the police authority are implemented.
11.5 Authorities already have the key role
in identifying targets, agreeing the annual policing plan, setting
the budget and working closely with the chief officers in delivering
the policing service. It is absolutely clear that, if tensions
are to be avoided, the same body should inspect both the authority
and the police force and as HMIC are the only statutory inspectors
of the police service, it must be HMIC who inspect police authorities.
12. CHIEF CONSTABLES'
PERFORMANCE AND
SUSPENSION
(a) PDRs
12.1 HMIs are currently responsible for
carrying out the Performance and Development Reviews (PDRs) of
Chief Officers. This was originally decided because chief officers
expressed confidence in the professional knowledge and ability
of HMIs, themselves all ex chief officers, to provide relevant
and independent assessment.
12.2 It is proposed to give police authority
chairs the lead role in completion of chief officer PDRs. HMIC
acknowledges that there is a logic to this proposal, since chairs
work closely with chief officers and share a strategic role in
the governance of forces. Authorities also have a role to hold
chief officers to account for performance. HMIC certainly welcomes
the proposal that chairs would be given appropriate training before
taking on such a role.
12.3 HMIC believes that, if implemented,
there would need to be a transitional period for hand-over and
that, once achieved, chairs must be obliged to undertake formal
consultation with HMIs, who would still be best placed to provide
a professional view on the leadership, impact and professional
competence of chief officers.
12.4 It should also be borne in mind that
currently, with just four HMIs involved in carrying out PDRs,
it is easy to retain a standard approach and ensure fairness and
equity. With 43 chairs taking over the role, there would need
to be a more structured method for quality assuring the products
and processes.
(b) Selection of chief officer team
12.5 There is a logic to the proposal that
chief constables should be able to select their own chief officer
teams since they are increasingly held to account for the force
performance and the team play a major role in delivery. If this
change were made, it would be important to avoid nepotism and
ensure the right person is selected for each role. Any process
would require an independent element, such as the involvement
of the Police Authority chair and/or the HMI.
12.6 It is critical the implications of
this proposal are discussed and all alternatives thoroughly considered.
There are a number of alternatives which are open to debate—one
alternative to a complete change of responsibility would be to
retain the current process but give chief constables an absolute
veto, a further alternative might be to allow chiefs to select
ACCs while Police Authorities would retain responsibility for
appointment of DCCs and chiefs. Whatever the discussion, given
that these issues go to the heart of the tripartite relationship,
care must be taken that it does not unwittingly become less balanced.
12.7 Further clarity is required in respect
of the proposal for the selection process for members of police
staff of ACPO equivalent. It appears there are inconsistencies
between the proposal referred to in paragraph 4.33 and that outlined
in paragraph 5.112.
(c) Suspensions
12.8 HMIC supports the proposal to carry
out a review of the procedures for suspension of chief officers.
The current situation requires greater clarity and simplification
whilst ensuring fairness and proportionality. HMIC should continue
to be consulted and to provide the independent element to the
decision making.
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