Police Reform and Social Responsibility Bill

MEMORANDUM SUBMITTED BY CONSUMER FOCUS (PR 75)

About Consumer Focus

Consumer Focus is a statutory body that champions the needs of consumers across England, Wales, and Scotland and, for postal services, Northern Ireland. We operate across the whole of the economy, persuading businesses and public services to put consumers at the heart of what they do. Consumer Focus has the power to take action where markets are failing consumers and to ensure a fair deal for all – especially the vulnerable and disadvantaged. As well as highlighting problems for consumers, we work with a range of organisations to champion creative solutions that improve consumers’ lives.

1 Introduction and summary

1.1 Our evidence is primarily concerned with Part 1 of the Bill. This establishes police and crime commissioners (commissioners) for each police force, and police and crime panels (panels) for each police area, and their functions, remit and responsibilities.

1.2 Consumer Focus has a long standing interest in the quality and effectiveness of public services, and their accountability to the public. Being responsive to service users, putting their needs at the heart of service design and delivery is fundamental to achieving high quality services. In order to do this service providers need to engage with people in meaningful two-way communication. This helps them to gain real understanding and insight, and to build relationships between providers and the public.

1.4 Policing, more than many other public services, relies on the tacit support and active cooperation of local communities. The police service, like other public services, needs to know what their service looks like from the public's perspective, whether it meets their expectations, and how to meet and to exceed that standard. As Julie Spence, the former Chief Constable of Cambridgeshire, told us, 'a responsive and bespoke service which enhances public confidence is the lifeblood of policing and justice in a civil society'.

1.5 Research conducted by Consumer Focus into consumer experiences of the police service suggests that consumers do not feel their local police force is responsive to their needs or concerns, or that they are accountable to the public. Consumers are often in the dark about the standards they can expect, how the police set priorities, and how they deal with feedback and dissatisfaction. This undermines people's confidence in the local force.

1.6 The Policing Reform and Social Responsibility Bill (the Bill) provides an important opportunity to address this weakness by making police and crime commissioners responsible for the customer service aspects of local forces [1] . Holding chief constables to account for delivering high quality and responsive local services will at the same time improve the commissioners' own accountability to local people and, coupled with improved public reporting, enhance openness and transparency about the police and policing.

1.7 Elections alone will not convince local people of the commissioners' public accountability, so strong, visible, ongoing public reporting and accountability mechanisms need to be built into the role and remit of the new commissioners. The duties of police and crime panels to scrutinise commissioners will in turn need to cover this remit.

1.8 Currently the Bill sets out the broad responsibilities for commissioners. The Bill should go further and make explicit that the commissioners' remit in regard to local forces includes:

· customer service

· handling feedback and complaints

· public engagement and two way communication

2 Consumer Focus evidence

The Consumer Focus evidence draws on:

· research looking at people's experiences of the police service and how local forces respond to dissatisfaction [1]

· our long-established interest in accountability, making services more responsive to users' needs, and good practice in complaints and redress mechanisms

· a belief that involving people in decisions about how public services are designed and delivered improves service outcomes and efficiency.

3 Research into consumers and the police service

The research looked into consumer experiences of the police service, aiming to find out more about consumer satisfaction with police services and what can be done to improve feedback, complaints handling and redress processes.

3.1 Key findings

Good communication, customer service and being responsive to local needs are important to the way people perceive the police. They want to feel the police do a good job, and it is important that the public has confidence in the service. In terms of customer service the police have the same responsibility as other public services to get things right first time and to put things right when something goes wrong.

3.2 People don't expect anything exceptional from the police in terms of customer service and responding to dissatisfaction:

· 75% say they want to be treated with dignity and respect

· 73% want to be listened to

· 57% want the police to get things right first time so they don't need to complain in the first place.

3.3 In practice, however, there is a wide gap between consumers' expectations and their experiences of the police. Customer service often falls below expectations of good practice.

· Nearly a third (30%) of consumers who have contact with the police are dissatisfied.

Most dissatisfaction stemmed from frustration about poor access to the police in the first place, and the unhelpful attitude of the police when they do respond, often making people feel their concerns are a low priority. There was a strong feeling among consumers that they are wasting their effort or time in trying to contact the police or pursue a complaint [1] .

3.4 Complaint handling

Just over a quarter (28%) of those who are dissatisfied with their contact with the police complain about it. Consumers do not complain because they see no point, they don’t think it would be treated as important or taken seriously, and don’t know what to do or who to contact. A small number of people are also concerned about possible repercussions if they do complain.

3.5 Around two-thirds (63%) are unhappy with the way the police deal with their complaint, rating the police response as bad at:

· keeping them informed throughout the process

· making it easy to find out or understand how to give feedback

· making it clear what would happen at each stage of the process

3.6 Making the police more responsive and accountable

The research identified three key issues that stand out as barriers to improving police responsiveness and accountability, each of which reduces opportunities for the police to connect with the public:

· poor access and accountability: this goes much wider than 'visible policing' and includes how the police respond to people

· negative attitude and culture: rude and unhelpful behaviour of police officers and other police staff

· mismatch in priorities: people feel the police do not take their concerns seriously

3.7 Overall, the research showed how important it is for the police to become more people- focused, more approachable and responsive. Poor communication between police and the public, perceptions of the 'closed' culture within forces, and direct experiences of a poor response discourage people from raising concerns or getting involved.

3.8 This lack of responsiveness undermines public trust and confidence in the police. Consumer Focus believes that making the police more responsive and accountable through improved customer service feedback would help them to connect with the public.

3.9 The Bill should lay down specific responsibilities for commissioners, and for the local crime panels, in respect of customer service, and communication.

4 Role and remit for police and crime commissioners

4.1 The Bill states the basic duties of police and crime commissioners. These include:

· holding chief constables to account

· representing and engaging local communities to identify their policing needs and make sure those needs are prioritised in the crime plan

· publishing a police and crime plan, setting the local police and crime objectives

4.2 Consumer Focus feels that promoting and monitoring best practice in customer service and 'informal' complaint handling should also be specified in their remit. This duty should include taking the lead in driving and supporting effective customer service strategies in local forces, holding the chief constable to account for developing and implementing them.

4.3 Commissioners will be able to support chief officers to make sure there is an effective and consistent way of separating out complaints that fall under the Police Reform Act and therefore automatically become 'recordable' and reported, from the kind of dissatisfaction and complaint that is best dealt with much more immediately and informally.

4.4 The commissioners' remit should specify responsibility for monitoring the effective implementation of local forces' complaints handling procedures to ensure that they serve the local people and community well.

4.5 Commissioners can also help chief constables to provide the right kind of support to allow staff sufficient scope to use their initiative to solve problems and deal with mistakes when they arise. This will extend to ensuring that forces have a system for valuing all kinds of complaints for what they are - useful management information that they can use to increase sensitivity to local priorities and drive performance.

4.6 Giving commissioners a duty to monitor compliance with good practice principles in customer service and feedback handling will ensure that local forces are responsive to local needs, and that people's rights are more transparent and accessible. This fits with the Commissioners' obligation to oversee the implementation of Equalities and Human Rights legislation and increases overall accountability.

4.7 Effective complaints handling and feedback systems are important for the police service. They can't do their job as effectively without good local relations or the support, trust and confidence of their local community. Investing in effective customer service has many benefits in terms of reputation, public confidence and service improvement.

4.8 Developing an organisational culture to support the process of being open to public feedback and encouraging complaints is a challenge for some local forces. A consumer - or citizen - focus needs to be backed by real commitment to address the concerns people raised in our research about attitude, access and priorities.

4.9 Police and crime commissioners will be well placed to provide the necessary lead to improve accountability. Improving customer service, feedback and complaints handling in the police will be a cost-effective way of collecting intelligence about local issues to drive service improvements, building links with individuals and communities, and raising local awareness of the service and how it responds to local needs. All of these support the development of local police and crime plans.

4.10 There are good practice examples to draw on - both within the police and in other services - and many police forces are experimenting with new ways to communicate and engage with people [1] . Commissioners can help to identify, reward and spread best practice in the interests of greater efficiency and accountability.

5 Police and crime plan

5.1 The Bill requires police and crime commissioners to issue and publish a police and crime plan for the financial year, including crime reduction objectives, and the policing which the chief constable is to provide for the police area.

5.2 The plan should also be required to include objectives for customer service, complaints and feedback handling.

6 Engaging the public

6.1 Consumer Focus welcomes the requirements for chief officers to engage with local people to obtain their views about crime and disorder. Involving local people in discussions and decisions about the services they use is essential for building trust and credibility.

6.2 The Bill refers to neighbourhood beat meetings, and other forms of engagement to allow all groups to give their views and hold their local police to account. In addition commissioners will be required to represent and engage local communities to identify their policing needs and make sure those needs are prioritised in the crime plan

6.3 Public engagement done effectively delivers a good return on investment. It helps to develop good communication and a better understanding of policing priorities and the way they work, simultaneously reducing barriers and generating confidence in the service.

6.4 But our research indicates that many people feel the police are remote and closed to comment. Whatever the reason the findings indicate a more strategic and comprehensive approach to engagement is required. Engagement has the potential to improve public confidence and inspire others to get more involved. Conversely - when badly designed and poorly managed - it can alienate people, reducing confidence and support [1] .

6.5 Police and crime commissioners and chief officers will need to adopt and drive best practice in effective service user engagement in their role to identify local policing needs. Effective user engagement takes time to plan and needs to be well managed by people who can build up expertise and local relationships over time. Engagement also needs to prove its value, especially in a period of increasing pressure on resources.

6.6 The Bill should therefore provide for commissioners, under their role to identify local policing need, to take responsibility for ensuring chief constables and local forces adopt and drive best practice in effective service user involvement and engagement.

7 Public reporting

7.1 The Bill requires police and crime commissioners to publish information as necessary to allow local people to assess the performance of the body itself and also that of the area chief officer of police.

7.2 Commissioners should be required to involve local people in deciding the content and frequency of such information, and how to make it accessible.

7.3 As our research indicated, people want to know more about what to expect from the police, and are interested in what the police actually do about local issues. The findings suggest that data on feedback and complaints should be part of their regular public reporting on local forces. As one of the people in the research said, this needs to be more than summary figures on the number of formal complaints.

'They should publicise more on complaints that have happened. [...] They don’t need to put the nature of it, they could say, ‘15 complaints were made this week, 10 of them were dealt with satisfactorily’.

7.4 'Informal' complaints and feedback are an integral part of intelligence gathering and will be of critical value to commissioners who need to check on how responsive local forces are to local need. Commissioners will also be able to make sure that forces are operating their feedback processes effectively, and that the data is captured and taken seriously so that forces learn from it. The information will also inform local crime plans and reporting on performance.

8 Commissioners' offices and staffing

8.1 To help them fulfil their duties, the Bill should require that the teams appointed to support commissioners include:

· at least one individual with expertise in customer service responsiveness and feedback handling

· at least one individual with expertise in effective public involvement and engagement.

9 Public information and HMIC - standards & benchmarks

9.1 The Bill focuses Her Majesty's Inspectorate of Constabulary's (HMIC) role on reporting for the benefit of the public at large, with a view to providing the public with information on policing outcomes and value for money to help them see how well their local force and local commissioner is performing.

9.2 Consumer Focus feels strongly that the only way to do this effectively is to engage with the public directly in an ongoing two-way dialogue, to find out what information the public need as information 'wants and needs' vary enormously. Local forces and HMIC will not be able to second guess what information the public value or need.

9.3 Our research suggests that the public would prioritise public reporting about customer service, complaint handling and redress within local forces. This is a critical part of accountability and should be included in the HMIC’s remit as it was during the period of the national policing pledge inspections. Government and commissioners will not wish to lose sight of the focus on consumer experiences and the resulting positive impact on local police-community relations.

9.4 The Bill provides for the annual report prepared by the inspectors to include an assessment of the efficiency and effectiveness of policing in England and Wales for the year in which the report is prepared. The Bill should require the reports to include an assessment of how well chief officers perform on customer service, complaint handling and redress, and how well people think commissioners represent local communities and prioritise their policing needs.

10 Police and crime panels

10.1 The corresponding police and crime panels, to be drawn from local councillors and lay members, will have an overview role at force level to act as a check and balance to the power of the commissioners. These panels in turn should have an explicit responsibility under the Bill to hold commissioners to account for the quality and effectiveness of public engagement, customer service and feedback handling, and public reporting within the police area.

January 2011

Annex 1

Good practice cases [1]

1 Using feedback

Hampshire Constabulary database to record expressions of dissatisfaction and search for trends which are followed up.

Thames Valley Police logs dissatisfaction and trawls for examples from calls to the communications centre and from press articles. They have recognised that where service is poor, contacting the complainant promptly to find out what went wrong, and trying to make amends is key to repairing the situation.

In a trial in Kent, officers with Blackberries talk to local people about their concerns and automatically download the information to help inform responses and set priorities.

2 Strategic Hertfordshire

Hertfordshire has been described as a leader in citizen focused policing by Her Majesty's Inspector of Constabularies (HMIC) It is one of the top performers for confidence and satisfaction and one of only three forces assessed by HMIC as 'Exceeding the Standard' in the Citizen Focus category.

Their strategy includes:

· implementing a set of priorities based on citizen focus and a commitment to following up feedback through contact management

· Investing in a purpose built contact centre as the core of the force's customer service delivery. It has over 300 multi-skilled staff and a budget of £11.5 million to deal with single tier call handling, crime recording and despatch.

· Enhancing the Constabulary website where the public can make a complaint or comment about a service via an electronic form. The force responds to feedback on an ongoing basis and acts when negative trends appear

3 Responding to local priorities in Cambridgeshire

In 2008 Cambridgeshire Constabulary commissioned a survey of local residents to find out what they value about their police service. In response to the findings, they are implementing a programme aimed at meeting people's needs.

The Putting People First programme was introduced to address the need for a professional attitude and behaviour - which was the top priority for local residents. The programme provides ongoing training, coaching, and mentoring to all police employees to make sure they deliver the best possible service to the public, resulting in a drop in the number of complaints in 2009.


[1] Our evidence applies to Commissioners and Panels proposed for outside London and to the parallel arrangements for London

[1] Report available at http://consumerfocus.org.uk/g/4mn

[1] Consumer Focus defines a complaint as any expression of dissatisfaction that needs a response. The research included dissa tisfaction with issues such as misinformation, rudeness or incivility, poor information, lack of follow up and administrative problems but the findings have a wide relevance to local policing .

[1] See Annex 1

[1] See for example our work on the post office network consultation : http://www.consumerfocus.org.uk/assets/1/files/2009/06/How-was-it-for-you.pdf

[1] Extract from http://consumerfocus.org.uk/g/4mn