4 Police-led IT Company
134. In this chapter we consider the current
state of IT within the police service, the progress that has been
made so far in improving IT procurement and converging different
IT systems, Lord Wasserman's review of police IT, and the Home
Secretary's recent announcement about the creation of a new police-led
company with responsibility for police IT.
The problem
135. Sir Hugh Orde, the President of the Association
of Chief Police Officers, described the current state of IT within
the police service as "a bit of a mess" and added "I
think everyone would accept that."[176]
The main reason for the mess is that the 43 forces have, between
them, a multiplicity of different IT systems and IT contracts.
The Home Secretary certainly accepts that there is a problem.
In a speech to the Association of Chief Police Officers conference
on 4 July 2011, she commented: "It is absolutely clear that
the current system is broken."[177]
She stated:
Good ICT systems and services are vital for modern
policing. ICT supports the police on the front line, through
items like portable radios and PDAs. It supports the middle office,
through things like criminal records databases, intelligence and
crime mapping. And it supports the back office, through HR, finance,
accounting and payroll systems.[178]
She said that across the police service there were
currently about 5,000 staff working on 2,000 different ICT systems.
136. The Home Secretary noted that the police
currently spend £1.2 billion a year on information and communications
technology, but said that this did not represent good value for
money and stated: "The way we do things now is confused,
fragmented and expensive."[179]
She gave the example of one supplier that has more than 1,500
contracts across the forces. Terry Skinner, Chair of the Justice
and Emergency Services Information Communication Association Group
at Intellect, the UK trade association for the IT, telecoms and
electronics industries, told us that he believed that the "the
police overspend on IT by at least 20%."[180]
Nigel Smith, the former Chief Executive of the Office of Government
Commerce, said that he agreed that a saving of 20% was possible
across police IT, and indeed that such savings were possible "across
Government, not just in the police service. "[181]
Intellect subsequently submitted additional written evidence
to us describing 20% savings across ICT in the police services
as "a conservative estimate of what could be achieved."[182]
We discuss Intellect's proposals for how this money could be
saved in paragraphs 165 to 167 below.
137. A contributory factor to the problems with
IT procurement in the police service, and a significant problem
in its own right, is the fact that different forces are using
different IT systems, many of which are incompatible with each
other and some of which have been replaced by newer and more efficient
technology. Mick Creedon, the Chief Constable of Derbyshire,
described this as the problem of "the way legacy systems
have developed on a piecemeal basis."[183]
Over the years, 43 forces have developed 43 different sets of
IT solutions. The Home Secretary stated: "Officers have
told me about IT systems that require multiple keying of the very
same information, are incompatible with systems doing the same
basic job in neighbouring forces, or are even incompatible with
other systems in their own force."[184]
138. IT across the police service
as a whole is not fit for purpose, to the detriment of the police's
ability to fulfil their basic mission of preventing
crime and disorder. The Home Office must make revolutionising
police IT a top priority. This is one area of policing where
direction from the centre is not only desirable but vital in order
to effect change. It is accepted in the
information and communications technology industryand is
becoming increasingly accepted across the private and public sectorsthat
information and communications technology and internet-related
issues are now central to any organisation, whether concerned
with commercial success or providing a public service, and that
the buck must stay firmly on the desk of the Chief Executive when
it comes to ensuring that efficiency and effectiveness are achieved.
We asked the new Permanent Secretary at the Home Office whether
she shared this perspective and we were pleased that her response
was clear, focused and positive. The history of Government and
Whitehall over the last 20 years or so has demonstrated that this
is about not just having the right policies but also having a
good understanding of the strategic direction, achieving the right
partnerships, and mutual challenge between policy-makers and delivery
organisations.
Progress so far
NATIONAL POLICING IMPROVEMENT AGENCY
139. It would be unfair to imply that no progress
has been made to date on improving information and communications
technology in the police service. Sir Hugh Orde qualified his
remark about police IT being a mess by adding: "I think there
was a lot of progress made when it was taken into the NPIA."[185]
The National Policing Improvement Agency currently has responsibility
for IT-related procurement (as well as non-IT procurement, which
we consider in the next chapter), and for the commercial management
of national police information and communications technology systems,
such as Airwave. It also provides a number of IT systems directly
itself, such as the Police National Computer, which enables the
sharing of information about crimes between police forces. The
future of some of the information and communications technology
functions currently provided by the National Policing Improvement
Agency, such as the management of the Airwave contract, was a
particular concern among our witnesses, as we discussed in Chapter
1.
140. The National Policing Improvement Agency
has achieved some successes in making savings from police IT procurement.
On 24 February 2011, the Agency reported that it would exceed
the savings targets that had been set for it by the Home Office:
for IT procurement, the target is £25 million and the Agency
is on track to deliver savings of nearly £30 million.[186]
In written evidence, the Agency drew attention to the launch
of compulsory national frameworks for some aspects of police IT.
It stated:
In mid-March [2011], we rolled out a national framework
agreement for forces to buy off-the-shelf IT equipment and general
computer software. The Government has made it compulsory for forces
to use this framework agreement to get the IT they need from one
pre-approved supplier, without having to go through costly and
lengthy procurement processes. The three-year framework agreement
provides a cost effective and joined-up approach to help forces
make significant savings. This will save forces up to £18
million over three years.[187]
141. The National Policing Improvement Agency
is also responsible for delivering the Information Systems Improvement
Strategy, known as ISIS. The Agency describes ISIS as follows:
Currently, each force owns and operates its own ICT
resulting in duplication of investment and effort. Working in
partnership with ACPO, the Home Office and the private sector,
ISIS will incrementally replace hundreds of systems with nationally
available services which forces will pay for on the basis of consumption.[188]
This is clearly a massive undertaking. ISIS has
the potential not only to transform ICT in the police service,
but to contribute towards the reduction of bureaucracy. The Metropolitan
Police Service commented: "Converging ICT through ISIS and
moving to a nationally led police procurement would address some
of the bureaucracy experienced with some of the fragmented and
dysfunctional systems and processes currently in place."[189]
Nick Gargan, Chief Executive of the National Policing Improvement
Agency, described ISIS as "a sensible pragmatic plan incrementally
to converge police IT and save substantial amounts of money while
delivering increased interoperability, with which few would disagree."[190]
PROJECT ATHENA
142. Project Athena is also intended to improve
levels of ICT convergence. It aims to facilitate the sharing
of information in four key areas: intelligence, crime investigation,
managing offenders, and preparing files for court. It is a collaborative
project involving nine police forces: Bedfordshire, Cambridgeshire,
Essex, Hertfordshire, Kent, Suffolk, Norfolk, the British Transport
Police and the City of London Police. Kent Police have indicated
that they will be the first to use the framework agreement that
the project is developing. The agreement is eventually intended
to be used by other forces. Assistant Chief Constable Beautridge,
Head of Kent and Essex Serious Crime Directorate, commented: "Project
Athena is set to be the biggest champion-challenger product of
its kind nationally and we have made massive progress in trying
to deliver this product for the benefits of communities and our
front-line staff."[191]
143. Not only is the current
state of information and communications technology in the police
service unsatisfactory, the National Policing Improvement Agency
is being phased out and a successor must be found for many of
the information and communications technology functions that it
fulfils. This provides an additional urgency to the imperative
for a new approach to police information and communications technology.
However, in devising this new approach the Home Office must not
neglect those few elements of the existing landscape that are
working well. In particular, the Home Office must secure the
future of ISIS and continue to support Project Athena.
Lord Wasserman's review
144. In autumn 2010, the Home Secretary commissioned
Lord Wasserman to, as she put it in a letter to us, "begin
a process of considering the scope for radical and cost-effective
options in providing national police IT functions in the future."[192]
Finding out details about Lord Wasserman's review has been difficult.
Lord Wasserman is an unpaid special adviser to the Government
on crime, policing and criminal justice matters. He reports directly
to Ministers.[193]
No terms of reference for Lord Wasserman's consideration of the
future of national police IT were published and the Home Secretary
confirmed in a letter that Lord Wasserman would not be producing
a report. However, she stated:
The consideration of his work will be a core part
of the decisions the Minister for Policing and Criminal Justice
and myself are taking with regards to police IT, beyond the current
arrangements led by the National Policing Improvement Agency,
and as part of the wider reforms of the national policing landscape.[194]
145. Given that the recommendations made by Lord
Wasserman would be central to the future of police IT, we were
keen to hear oral evidence from him. We made it clear that we
were prepared to wait until after he had completed his review
if he thought this more appropriate. The Home Office initially
told us that he would be available to give evidence, but then
changed its mind and said that the Minister for Policing and Criminal
Justice would be able to update us on this aspect of the policing
landscape instead. The Minister told us that Lord Wasserman "has
been giving advice on a range of policing matters" and commented:
"It is not normal for such advice to be made public or for
advisers to appear before the Committee.[195]
146. Both this and the previous
Government have at times claimed that there is a convention whereby
special advisers do not give evidence to Select Committees. However,
special advisers have given evidence to Select Committees in the
past. Considering the significant advice that Lord Wasserman
has provided to the Government, we believe that it was an error
of judgment to prevent us from hearing from him about his proposals
for the future of police IT: this is a vital element of the new
landscape and he is a key figure in determining its future.
The outcome of the review
147. Several pieces of written evidence gave
us an indication of what the likely outcome of Lord Wasserman's
work might be. The Metropolitan Police Service, writing to us
in April 2011, stated:
Lord Wasserman has laid out his proposals for a GovCo
[Government-owned company] to be established. ACPO expressed a
unanimous view that the new organisation should focus on building
the future state and should not be burdened by the existing national
systems and contracts. It was proposed that this Legacy (both
in house and existing contracts) was transferred to the MPS [Metropolitan
Police Service] whilst the 'to be' organisation was put in place
and there is no reason why this would not be a practical proposition.[196]
Written evidence submitted by the Association of
Police Authorities also mentioned that Lord Wasserman was likely
to recommend the creation of a Government-owned company. The
Association commented: "we are bemused by early indications
from the current Wasserman Review to replace the NPIA with another
'GovCom'/quango to deliver procurement and other functions regarding
IT infrastructure currently provided by the NPIA."[197]
148. On 28 June 2011, we asked the Minister for
Policing and Criminal Justice whether there was a plan to set
up a Government-owned company to be responsible for police IT.
He replied: "No. There is no plan for a Government-owned
company, but, as I have explained, we will be announcing shortly...how
the functions of the NPIA will be[handled]".[198]
Less than a week later, on 4 July 2011, the Home Secretary announced
at the Association of Chief Police Officers conference: "we
will help the service to set up a police-led ICT company".
She continued: "I will not be prescribing what the company
should look like. But its design should be based on a number
of fundamental principles."[199]
The principles she outlined were:
- the company should be police-led;
- the company needs to be staffed by ICT professionals;
- the new company must have a culture that allows
it to attract and retain individuals with the skills and capabilities
needed, and that encourages those individuals to innovate and
deliver success;
- the new company must exploit the purchasing power
of the police service as a whole.
While we do not disagree with these points, the experience
of letting IT contracts within Government demonstrates that it
is important to be highly flexible and nimble, and have a good
understanding of how best to harness the professionalism available
within business. Too many information and communications technology
projects in Government have taken place without a 'gateway-zero
review' and this has seen the most capable companies choose not
to bid because the procurement processes do not look right, efficient
and professional. We urge the Home Secretary to ensure that these
issues are fully understood by those responsible, whether within
her team in the Department or in a police force or agency.
149. The Home Secretary stated that it was the
Government's intention that the new company would be formed by
spring 2012 and said that she had asked Lord Wasserman "to
lead the work of setting up the new company." She said that
Lord Wasserman would chair "an interim or shadow board of
the new company on which all stakeholders will be represented",
and commented that Ailsa Beaton, the Chief Information Officer
of the Metropolitan Police and the lead on IT for the Association
of Chief Police Officers, had agreed to serve on the interim
board as the senior police IT professional.
150. The proposed new body is not entirely a
Government-owned company, so the Minister's answer to our question
was technically correct, although it might have been helpful
if he had told us more about the Government's thinking at that
point, given that the announcement about the IT company was made
only days later. The Home Secretary said in her speech on 4 July
2011 that the company would be "police-owned" and commented:
"I expect the Home Office, and possibly the private sector,
will also own shares in the new company, alongside police forces."[200]
A letter to us from Ailsa Beaton makes it clear that this was
one of three models under consideration. She writes that on 25
May 2011 Lord Wasserman and officials at the Home Office presented
a paper to the National Policing Improvement Agency Transition
Steering Group:
Three possible future options were outlined for taking
on the NPIA's responsibilities for national police ICT on its
demise; transferring it to an independent company owned by the
Home Office, police authorities, forces and a private sector partner;
transferring it to a police ICT Mutual, a similar construct largely
police owned; or transferring it to the Home Office. The preferred
model was the Mutual option.[201]
151. On 8 July 2011, we wrote to the Home Secretary
seeking further details about the new company. Her response confirmed
the previous announcement that Lord Wasserman would act as Chair
of the shadow board of the new company, but, notwithstanding her
earlier statement that Lord Wasserman would "lead the work
of setting up the new company," she commented: "Day-to-day
direction of the work of forming the new company will be the responsibility
of Bill Crothers, the Home Office Group Commercial Director, who
has been appointed Senior Responsible Owner for the Project."[202]
She stated that "precise legal form of the entity has yet
to be decided", but commented that the intention was that
"the majority of shares in the company will be held by police
forces." She stated: "These shares will be allocated
to them by a formula to be agreed by the parties concerned. There
is no question of forces having to buy shares."[203]
She commented that "Police and Crime Commissioners will
be represented on the board of the new company and will thus have
a close interest in all aspects of the company's activities including
procurement."[204]
It is not yet clear how the relationship between the company
and individual Police and Crime Commissioners will work in practice.
152. The Home Secretary commented that "Lord
Wasserman has had a long and distinguished career in public service
including several roles that qualify him for this role [of Chair
of the shadow board]." She stated that from 1983 to 1995,
Lord Wasserman was Assistant Under Secretary of State for Police
Science and Technology in the Home Office, a post in which "he
was responsible for the provision of all national police IT systems",
that he "directed the preparation of the first national strategy
for police IT" and worked as a "Special Adviser on Science
and Technology to the Police Commissioner in New York City, Senior
Adviser and Chief of Staff to the Philadelphia Police Commissioner
and adviser to the US Department of Justice."[205]
153. We note again that Lord
Wasserman has had a long and distinguished career in public service,
but we note again that it would have been helpful if we could
have spoken to him in person as part of our inquiry, given his
central role in shaping the new police IT company. We give notice
that we intend to invite Lord Wasserman to give evidence to us
in the autumn on these issues and on recent developments.
154. The Home Secretary's letter sheds some light
on the scope of the new company's functions. She comments:
The current plan is that the new company will take
on those functions of the NPIA relating to procurement and commercial
management of national police ICT systems. It will also assume
responsibility for ISIS. The operation of the PNC [Police National
Computer] and a number of other IT systems provided directly by
the NPIA will be transferred to one or more police force(s) for
the period until they are replaced by new systems. It will be
the new company's responsibility to manage the process of negotiating
contracts to replace them and subsequently to manage those contracts.[206]
It might appear simple to transfer responsibility
for the existing information and communications technology systems
provided directly by the National Policing Improvement Agency
to the Metropolitan Police Service, particularly in the light
of the Metropolitan Police's willingness to take on this task,[207]
but there are serious and systemic issues regarding the governance
of the Metropolitan Police, as well as regarding the governance
of information and communications projects, which is an important
issue in itself. We note that the Association of Chief Police
Officers did not want any new police IT body to be burdened by
responsibility for existing national systems, and can see some
logic in this. However, we repeat our concern that the Metropolitan
Police Service is currently in a state of some uncertainty, with
a new Commissioner who faces major challenges on a variety of
different fronts.
155. We seek clarity from the
Home Office on which police force or forces it has in mind to
take on responsibility for the existing IT systems provided directly
by the National Policing Improvement Agency and an assurance that
the force in question will be given the necessary resources to
take on this task. In addition, we seek clarity on precisely
which IT systems will become the responsibility of a local force
and which will go directly to the new police IT body. We expect
that Airwave will become the responsibility of the new police
IT body, but we would like this confirmed.
156. The Home Secretary also gives an explanation
of why the Home Office decided to set up a company rather than
a non-departmental public body. The Home Secretary stated: "The
Government sees major advantages in setting up a new company rather
than an NDPB." The advantages she lists are that the new
company "will be allowed to recruit staff and pay them market
rates based on their performance" and that the "direct
link between the company and its owners, who are its principal
customers, will make the company responsive to, and directly accountable
to, police forces."
157. Sara Thornton, the Chief Constable of Thames
Valley Police, gave us another reason why the Home Office might
have chosen to set up a company rather than a non-departmental
public body. She said that it was "very early days"
and the plans for the company were "hazy", but stated:
my understanding is that if the company is set up
correctly, it would be able to go to market in a very different
way than is currently the case. It would be able to rapidly find
out what forces' user requirements were and then go with that
requirement to the market. If it was set up as a company, it could
then be exempt from EU rules about procurement, which could make
the whole process much speedier because it would be acting like
a commercial company.[208]
There are EU procurement directives that apply to
purchases above certain monetary thresholds made by the public
sector and some utilities companies, but which would not apply
to purchases made by a company. Where the directives apply,
contracts must be advertised in the Official Journal of the EU,
hence they are sometimes called OJEU processes.
158. Our witnesses had different views on the
usefulness of the EU directives. Tracey Lee, Head of Emergency
Services at Steria, suggested that the rules might be making police
forces unnecessarily wary about engaging with suppliers: "many
of the forces are rightly accountable for the public money and
the EU legislation, as it stands, makes people concerned about
improper relationships with suppliers pre-procurement."[209]
Of course forces should be concerned about forming improper
relationships, but the worry would be if the fear of forming improper
relationships was preventing them from forming any sort of relationship
with their suppliers. Tracey Lee commented: "the supplier
community, if managed in an appropriate market testing way, has
access to all sorts of ideas about the art of the possible...and
I think that gives a lot more firmer foundation for any procurement
thereafter."[210]
159. Terry Skinner, from Intellect, the UK trade
association for the IT, telecoms and electronics industries, said
that in his experience forces were very risk averse and tended
to use EU processes even when the contract they were awarding
fell below the required monetary threshold . He suggested that
some small and medium sized enterprises were put off applying
for contracts because the EU processes cost so much money.[211]
160. Nigel Smith, the former Chief Executive
of the Office of Government Commerce, said that there were "major
problems" with the EU processes.[212]
He stated that the thresholds were too low and "we should
look at how we could go to the European Commission and raise those
thresholds".[213]
He also commented that the processes took a long time.
161. When on 5 July 2011, immediately after her
speech announcing the setting up of the new company, we asked
the Home Secretary whether the company would be subject to the
Freedom of Information Act, she replied: "I would expect
so, but we are looking through exactly what the structure is going
to be and obviously working with the police because we want this
to be police owned and police led."[214]
In her letter of 14 July 2011, she expanded slightly on this
statement, commenting: "Because the company will be owned
by public bodies themselves subject to FOIA, we expect the company
will be made subject to the provisions of the FOIA."[215]
We note that this falls short of a definite assurance that the
company will be subject to the Freedom of Information Act.
162. There is so little detail
currently available about the police-led IT company that we find
it difficult to reach a conclusion about its viability. There
are advantages to creating a single body with the sole purpose
of overseeing information and communications technology in the
police service, provided that it has the right degree of commercial
and technological expertise, a clear focus, clarity about resources,
and a good relationship with the wider police service. However,
it seems that a key reason
for it being considered that a company is the best kind of body
to perform this role is that it will not be subject to EU procurement
rules. If the body is set up as a company, it is important that
it is made subject to Freedom of Information legislation. The
people setting up this body have a great deal of work to do in
a short space of time, if it is to be up and running by spring
2012. We recommend that the Home Secretary updates Parliament
no later than December 2011, by means of an oral statement in
the House of Commons, on the progress that is being made.
Priorities for the new body
163. Clearly one of the main priorities for the
new body will be to try to converge IT systems and contracts across
the 43 forces. The Home Secretary has indicated that the new
body will have responsibility for ISIS, which provides a good
starting point. However, Ailsa Beaton, Head of the Information
Management Business Area at the Association of Chief Police Officers,
gave some indication of the size of the challenge this represents.
She commented that, in discussing proposals for the new body
with Home Office officials, chief officers raised "the fact
that forces have different end dates for IT contracts, which could
potentially impact on transition plans, and also that some forces
are already consolidating IT services with other local partners."[216]
164. On IT procurement, Dr David Horne, Director
of Resources at the National Policing Improvement Agency, said
that the National Policing Improvement Agency had made four key
points about its future: first, that it be "closely aligned
to the ISIS programme", secondly that there should be "proper
commercial leadership to deliver against what is a very hard-edged
market", thirdly that there should be close working with
Government IT "because of the huge drive and changes that
will be coming forward", and fourthly that there should be
close working with the police service.[217]
Those people in the new body who are responsible for IT procurement
should ensure that they work closely with their colleagues who
are responsible for ISIS and the convergence of IT systems. They
should also build relationships with colleagues involved in IT
procurement in Government Departmentsas well as with police
forcesand particularly the Home Office.
165. As we mentioned above, Intellect, the UK
trade association for the IT, telecoms and electronics industries,
stated: "Through regionalising IT capability, having more
national procurement for commoditised technology and re-thinking
solutions delivery, savings up to 20% could be achieved."[218]
Its written evidence outlines how these savings could be achieved
and provides a useful starting point for procurement-related priorities
for the new body. It commented that the "reduction of procurement
timescales should be a priority and would produce cost-savings
for both Government and its suppliers."[219]
Terry Skinner stated: "the average time from a contract
notice to an award of contract for a UK police force is 77 weeks.
In Germany and in Italy that is about 44 weeks, so it take nearly
twice as long to procure [in the UK]."[220]
The new IT body should make reducing procurement timescales a
high priority.
166. Terry Skinner also emphasised the need for
a recognised list of approved suppliers and said that having to
complete a pre-qualification questionnaire for each contract
put off small and medium-sized enterprises who could bring value
to the police service. Intellect stated:
the Government should create a single simple and
straightforward national register of approved and classified suppliers
which any supplier can apply to join if they clear an agreed set
of financial, business and regulatory hurdles (with an annual
refresh to check continued compliance). This would be used for
local and national procurements which will not exceed the EU/Official
Journal of the European Union (OJEU) limits.[221]
We see merit in Intellect's proposal
that there should be a single national register of approved suppliers
to be updated annually, so long as it is an alternative to separate
pre-qualification processes rather than an additional requirement,
and urge the Government to consider setting up such a list, covering
both IT and non-IT suppliers to the police service.
167. Intellect also suggested that:
Locally and nationally, each significant project
should be required at the outset to undertake an independent review,
reported to the governing authority for approval, as to whether
the business aims can be met by an alternative evolutionary approach
at lower risk and/or cost.[222]
Certainly consideration of whether business aims
could be met by an alternative approach would be particularly
valuable when letting lengthy and high value contracts, such as
the Airwave contract. Dr Horne, Director of Resources at the
National Policing Improvement Agency, commented that the contract
was awarded 15 years ago and that the costs he saw going out to
Airwave year after year were "very different from what the
marketplace is for mobile technology."[223]
The new
IT body should consider at an early stage what processes should
be involved before deciding that awarding a major new contract
is the best way of meeting the business aim in question. It should
give particular consideration to how it will ensure that contracts
that run over many years, such as Airwave, deliver value for money
throughout this period.
176 Q 158 Back
177
Speech by the Home Secretary to the Association of Chief Police
Officers conference in Harrogate on 4 July 2011, http://www.homeoffice.gov.uk/media-centre/speeches/ Back
178
Ibid. Back
179
Ibid. Back
180
Q 275 Back
181
Q 348 Back
182
Ev118 Back
183
Q 149 Back
184
Home Secretary's speech to the ACPO conference, 4 July 2011 Back
185
Q 158 Back
186
Update on NPIA procurement activities, NPIA press release, 24
February 2011 Back
187
Ev164 Back
188
Ibid. Back
189
Ev181 Back
190
Q 434 Back
191
Q 533 Back
192
Letter from the Home Secretary to the Chair of the Home Affairs
Select Committee, 7 June 2011 Back
193
HC Deb, 11 May 2011, col 1221W Back
194
Letter from the Home Secretary to the Chair of the Home Affairs
Select Committee, 7 June 2011 Back
195
Q 695 Back
196
Ev181 Back
197
Ev160 Back
198
Q 702 Back
199
Home Secretary's speech to the ACPO conference, 4 July 2011 Back
200
Ibid. Back
201
Ev169 Back
202
Ev150 Back
203
Ibid. Back
204
Ibid. Back
205
Ibid. Back
206
Ibid. Back
207
Ev181 Back
208
Q 724 Back
209
Q 291 Back
210
Ibid. Back
211
Q 291 and 294 Back
212
Q 349 Back
213
Q 352 Back
214
Oral evidence to the Home Affairs Committee, The Work of the
Home Secretary, 5 July 2011, Q 68 Back
215
Ev150 Back
216
Ev169 Back
217
Q 237 Back
218
Ev118 Back
219
Ibid. Back
220
Q 291 Back
221
Ev118 Back
222
Ibid. Back
223
Q 259 Back
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