Home Affairs CommitteeWritten evidence submitted by the Police Federation of England and Wales [LSP 14]


Since 1990 the Police Federation of England and Wales (PFEW) has been calling for a wholesale and fundamental review of policing as a consequence of the piecemeal and disparate approaches to reform that have characterised the recent past, invariably creating more problems than they solved. The fact that Lord Hutton’s review of public sector pensions, Tom Winsor’s reviews of police pay and conditions and Peter Neyroud’s review of leadership and training in the police service all reported within a relatively short period of time is indicative of this piecemeal, disjointed and reactionary approach. The comprehensive spending review and cuts in the region of 20% to policing have further exacerbated the situation.

In December 2011, the Home Secretary announced plans to establish a police professional body to further professionalise policing, which will be known as the College of Policing (CoP), has added to the uncertainty in the minds of police officers. It should not be overlooked that the support of the 135,000 police officers of federated ranks would be vital for the success of the Home Secretary’s proposals. Officers therefore need to be convinced that there is a benefit for them and not only for the Government and ACPO in the level of service they provide to the public.

Against this backdrop of uncertainty and change we have chosen not to answer the specific consultation questions suggested by the Home Affairs Select Committee (HASC), but rather to provide the views of PFEW on the key factors likely to affect training and leadership in the police service in the near future.

The PFEW support the promotion, development, possession and use of professional practice for all officers within the police service while ensuring standards of recruitment, training and promotion are quality assured, mandated to forces and monitored for compliance.

Is a College of Policing needed to achieve this?

The police service does have a number of elements of a profession already in place or under development. As a general rule it is not necessary for a profession to have a professional association or registration body if sufficient identity and coherence is provided through employment, or formal organisation has few benefits.

Police officers are already highly accountable to the public they serve. As holders of the Office of Constable they must exercise discretion, judgement and responsibility to the public. With the Office of Constable comes personal accountability and responsibility for the protection of life and property, the prevention and detection of crime, the maintenance of law and order and the detection and prosecution of offenders. This office allows for the protection that other professions sought to achieve through their professional bodies.

It is not clear to us how membership of a professional body such as a CoP would further enhance public confidence in police officers. If introduced, a CoP for the police service would be untried and untested and the consequences of it failing are unknown.

The PFEW’s view remains that it does not support the need for a CoP. We do, however, support the aim of increasing professionalism in the police service through nationally accredited standards and continue to engage in discussions at this time.

The urgency to introduce a professional body brought about by the Government’s desire to terminate the National Police Improvement Agency (NPIA) has been disquieting and, we believe, inappropriate. However, we are cognisant that vital elements of the NPIA’s work relating to learning, training and development of police officers must be transitioned to its successor organisation with as little disruption as possible to our members.

Whilst PFEW continues to attend the various meetings associated with the development of a CoP there remain numerous aspects of the interim body proposed by the Government which cause us significant concern.

How could professionalism be improved?

Police officers are required to undergo a significant amount of training to both qualify as an officer, and then to progress in a chosen specialism or to gain promotion. The largest failings in the existing provisions for training and leadership in the police service are the inconsistencies that exist between forces and the lack of strong governance.

Some excellent training programmes already exist. A number are already linked to a form of accreditation, where appropriate from external providers. Developing more training programmes, which follow these principles, would gradually increase the professional status of police officers.

A CoP is not necessary to implement this. Nevertheless, the disbanding of the NPIA provides a real opportunity to re-define the role of the central provider for police training, development and promotion whilst de-cluttering the bureaucratic landscape.

We suggested that the training, learning, development and promotion arms of the NPIA should be incorporated into a new National Standards Agency, which could continue much of the good work undertaken thus far by the NPIA in programme design. It could have been charged with devising a “cradle to grave” system of training, providing recruits with clear career pathways.

It could have possessed the power, authority and resources to impose quality assured, mandatory, national standards upon forces and to monitor their compliance with those standards, either via its own compliance arm or potentially via more robust Her Majesty’s Inspector of Constabulary (HMIC) inspection.

There would need to have been oversight of the functions of the proposed agency. One potential solution for this would be for the Police Advisory Board for England and Wales (PABEW) to have taken on the oversight role. The PABEW already provides oversight on recruitment standards for the police service and makes recommendations to the Home Secretary as appropriate. This mandate could have extended to standards of training, leadership and promotion.

We believe national standards should continue to be developed in conjunction with Skills for Justice.

We have no objection to the accreditation of training programmes which we believe could help to ensure that training is delivered to a consistent and high standard across all forces.


The final draft of the CoP Skeleton Blueprint document {3.8–6/7/12} states that one representative on the Board of the CoP will be a constable, sergeant or inspector.

We believe it is unacceptable that federated ranks, which characterise the vast majority of police officers, will be represented by one seat on the CoP Board. Our members will expect to have a greater influence on the leadership of the organisation if they are persuaded it represents any benefit to them.

We believe a rigidly top-down structure is not a sustainable means of engaging everyone in the police service in what should be creative and worthwhile relationships. The Board, as it stands, is too hierarchical to be successful. Equal representation of the three main representative bodies in the service should be the aim. For the PFEW to have just one seat on the Board is incompatible with the tripartite nature of the Federation. We expected to have had four seats on the Board—the PFEW Chairman and one representative from each of the separate rank committees.

It is important to stress the difference between ranks and their differing training requirements. For instance, 80% of constables will probably remain constables and without direct representation on the Board there is a concern that their voice will not be heard, and the CoP will concentrate on leadership and promotion to the exclusion of their training needs as the biggest constituent part of policing.


The Home Office has stated that:

“Services transferring from the NPIA will move with their existing budgets until the end of the current spending review period in 2015. This will give the Police Professional Body the opportunity to decide the requirements of professional training in the future while providing some training continuity after the NPIA closes in December 2012.”

We welcome that the Home Office has recognised that central funding cannot be removed with immediate effect. However, there is clearly a fundamental question to be answered in how the body will be funded after 2015. The Home Office has repeatedly stated that the decision on how to fund the body will be the responsibility of the Board of the CoP. We feel strongly that the Home office should not be able to abrogate or absolve itself of such critical areas of decision making without recognising the importance of this to the future success and delivery of the new College.

A critical concern of the PFEW and its members is that, in practice, once the central funding is discontinued in 2015, the CoP is likely to have little option but to begin charging members for services. The possibility that the CoP might at some time charge police officers fees for access to the College and occupational training is for the PFEW completely unacceptable and a red-line issue from the outset. We believe it is disingenuous of any government to delegate the cost of developing professional police officers and that it is unethical to expect individuals to pay for any training necessary to make them into fully rounded officers.

We believe members of the police service need to be convinced that the CoP will provide services to them which are meaningful and beneficial without increasing bureaucracy, cost and burden. We are unconvinced from what we know how this will work.

The core mission of the CoP will be to “safeguard the public and support the fight against crime by ensuring professionalism in policing.” We are concerned that the emphasis placed by the Government on the need for the CoP to implement a national and international commercial strategy could be contradictory to its core objective of providing the best possible outcome for the public. Public service should not be a commercial enterprise. Asking the CoP to raise its own funding could create a conflict of interest with its main objective of service delivery.

We support the improvement of efficiency in training provision such as the use of more cost effective locations.

National Standards

The CoP Skeleton Blueprint sates that the professional body “will have a powerful mandate to enable the service to implement the standards it sets for training, development, skills and qualifications.”

We continue to have concerns that national standards will not be mandatory and that there will be no sanction on forces that do not adhere to them.

In our experience there is no evidence from the past behaviour of chief officers that they will want to have the same accredited standards as neighbouring forces. Indeed, this increases officer’s portability and is often contrary to the interests of an individual force. Hence, we have seen an increase in in-house training provided by forces but not nationally accredited, and therefore not recognised by forces elsewhere.

Pre-qualification Requirements for recruitment

Any requirement for a candidate to “pre-qualify” could lead to a decrease in the diversity of police officers. The service already has a tried and tested national assessment process pre-entry in the form of the SEARCH assessment centre. We believe the SEARCH process is sacrosanct and it should also be undertaken by special constables before they take on policing responsibilities.

We resist any suggestion that forces should be able to decide upon their own pre-entry qualifications. Any move towards national standards of pre-qualification outside of SEARCH must be the subject of a thorough equality impact assessment.

Training Provision

We believe training necessary to carry out the role and duties of a police officer should always be funded by the officer’s force and not the individual, and there should be a commitment from forces that time will be given to officers to attend role specific training during duty time.

Whilst the use of further and higher education establishments may be an attractive financial proposition for the Government, there is no firm evidence to indicate this is the best approach for officers or the public. We believe that training, coaching and mentoring must be delivered by appropriately qualified individuals, who have had the exposure to real operational police work which gives them the practical as well as cognitive ability to share learning needs in a fast moving world.

Consequently, any move towards the outsourcing of training needs should be approached with extreme caution.

Privatisation of Police Training

The Home Office has stated:

“The body will underpin all future police training and delivery. While it will continue to deliver some training, in those areas where it is best in the interests of the police service to do so, it will also play an active role in assessing the very best training other sectors can offer.”

This would seem to confirm that increased outsourcing of training is envisaged. It is hard to see how the involvement of an external organisation that will be looking to profit from its involvement with the police service could ultimately benefit the public.

It is envisaged that the CoP’s ethos will be to ensure the best possible choice of training provision. Again it is hard to see how this is likely in an environment of reduced or non-existent central funding and the need for significant further cost-saving.

The present structure of recognised national standards for vocational police training, accredited at the appropriate level of the national curriculum framework, is a sound and properly constructed qualification framework which is fully aligned with the high skills officers require.

This has been recognised for some time as the acceptable standard and is delivered at the local level through a system of assessment and skills auditing. There is natural order to the system.

We are unclear and unsighted how higher education bodies or private companies will deliver anything better. Whilst it may generate revenue for such institutions, what perceivable benefit will it offer to the operational officer, the force or the public? The regulation of control and the quality of input must be a key cornerstone to training standards and we fear a real diminution of those standards as the delivery options become more varied and widespread within the private and commercial sectors and further education and higher education sectors.

We continue to believe that core training, coaching and mentoring is best delivered by experienced practitioners from the police service.

Leadership Development

We support the development of leadership programmes which encompass all police officers from constable through to chief constable.

We would recommend that the development of leadership programmes for the police service in the future should be both robust and evidence based.

We support the continued existence of a National College of Police Leadership (NCPL) and the development of leadership programmes based on strategies that are relevant to the police service.

We acknowledge that a significant amount of work has already been done to improve the existing provision of leadership programmes.

We strongly support the continuation of the Core Leadership Programme (CLP) and Senior Leadership Programme (SLP) and recommend a link to recognised accreditation is available to all officers.

We support a fast-track scheme that would include those with the potential for high rank from the public and private sectors, or armed forces, who have had real exposure and proven experience in organisational management and strategic leadership to complement the revised High Potential Development Scheme (HPDS). This should not override the requirement for officers to have served in all prior ranks at the point of promotion.

Leadership development programmes should link in to promotion processes to ensure consistency and avoid duplication.

The geographical location of the NCPL is less important than the quality of the product it offers. Training needs to be accessible to all officers with leadership potential.

We support the provision of training via multiple training centres provided they are able to deliver training to the same quality around the country.

We consider it necessary that all training centres are dedicated solely to police training rather than being subsumed into a university campus.

It is crucial that the frontline ranks of constable, sergeant and inspector are properly recognised and resourced to meet the demands of operational policing.


We believe that every officer promoted must have served at every rank below that to which they are promoted.

We acknowledge that the existing process for promotion is less than perfect and accept that the service needs to invest in open promotion procedures that enable those with the relevant skills and abilities to become the future leaders of the service and which supports officers from all minority groups to reach senior ranks.

The promotion system should be underpinned by the following principles: It must be standardised nationally and compulsory for forces; effective governance and compliance procedures must be put in place to ensure forces comply; the system of PDR and assessment must be robust, national and non-bureaucratic; the promotion process adopted must be fair and seen to be fair by those seeking promotion; it should meet expectations and demands commensurate with modern policing requirements.

There should be some way of managing the numbers of officers achieving promotion and consequently managing the expectations of officers during the promotion process. Therefore, a national, transparent and fair assessment filter needs to be introduced, which will identify candidates based on the objective criterion that they are likely to develop into good leaders.

We believe the promotion system needs to measure a candidate’s legal knowledge and recognise abilities to manage at different levels.

We therefore support the development of a new national assessment, which tests legal knowledge and leadership qualities in the context of an operational policing environment. The promotion process also needs to be subject to scrutiny. We believe it rests most appropriately with the PABEW.

The Role of the Chief Constable’s Council

In response to Peter Neyroud’s original proposal for a professional body the Association of Chief Police Officer’s (ACPO) recognised that:

“As leaders of the service we recognise such a body must be open to all who deliver policing and its inspiration shared across all ranks and grades.”

We believe the latest proposal to allocate ACPO ranks three seats on the Board of the CoP, in addition to the Chief Executive Officer (CEO) who “will have been a senior police officer”, would give ACPO too much influence in the new body and make it unrepresentative of the police service as whole.

It is exacerbated by the increased influence of the Chief Constable’s Council in endorsing proposals before they are put to the Board for approval.

Police Conduct

The conduct of police officers is regulated by the Police Conduct Regulations 2008 (as amended) and the Police (Complaints and Misconduct) Regulations 2004 (as amended). These regulations confer the power to impose a number of outcomes on officers, including dismissal. Therefore no body responsible for the setting of standards of recruitment, training and promotion should have the disciplinary power to remove officers from a central register or prevent them from practicing. The Independent Police Complaints Commission (IPCC) and police forces should continue to have responsibility for investigating and dealing with the conduct of police officers or complaints against them.

College of Policing and Existing Consulting and Negotiating Machinery

The CoP Skeleton Blueprint document states that a new model of reward is required which incentivises officers and staff based on their expertise. Discussions on this matter are currently ongoing through the Police Negotiating Board (PNB), and due to a failure to agree by both sides, are the subject of a pending Police Arbitration Tribunal (PAT) hearing. It is unhelpful and inappropriate for such statements to be included in the document before they have been fully discussed by the relevant stakeholders via the PNB.

We would make a similar comment about the references to direct entry on page 9 of the document. It is certainly not a consensus view of the constituent members of the Developing Professionalism Working Group (DPWG) that Winsor’s recommendation on entry could allow the service to draw upon the best pool of talent available. Indeed, the PFEW and the Police Superintendent’s Association of England and Wales (PSAEW) have explicitly raised their objections to Winsor’s proposals on direct entry via the PABEW.

Police Federation of England and Wales

October 2012

Prepared 19th July 2013