Caught red-handed: Why we can't count on Police Recorded Crime statistics - Public Administration Committee Contents

5  Monitoring and audit

Monitoring of crime recording since 2002

100. The National Crime Recording Standard (NCRS), introduced across England and Wales in 2002, makes clear that "an essential element of the National Standard is the need for regular and on-going local and national scrutinisation at all stages of the process."[91]

101. Primary responsibility for the maintenance of crime data quality lies with each force's nominated Chief Officer. They are responsible for the accuracy and integrity of crime recording processes. In their leadership role, Chief Officers are encouraged to make an "unequivocal statement and clear commitment" to the maintenance of consistent and victim-oriented crime recording standard, and to ensure "on an ongoing basis that each force's position on crime recording [is] clearly articulated throughout the organisation".[92]

102. Each Chief Officer appoints a Force Crime Registrar (FCR) to have day-to-day responsibility for accurate and consistent implementation of the NCRS. The FCR is an NCRS specialist and acts as the final arbiter of the force's internal audit process, the interpretation of the counting rules and assigning outcomes. The FCR also acts as the Force representative and Home Office contact on the subject of crime recording. The FCR is answerable to the relevant Chief Officer, but must be outside operational line command, to ensure that NCRS implementation is not subject to operational or managerial pressures that may compromise data integrity.

103. The Force Crime Registrar position is not defined consistently across police forces and the people holding that position vary in rank. For example, Sir Bernard Hogan-Howe told us that the Metropolitan Police FCR is a Chief Superintendant, a senior middle manager. However, Chief Constable Farrar observed in his evidence that at present FCRs "vary greatly in their status and grade across the country and their engagement levels with Chief Officers is also inconsistent."[93]

104. In respect of external monitoring, there has not been the same imperative. There has not been a consistent 'regular and on-going […] national scrutinisation' of crime recording practices across forces since 2007. During the first few years of NCRS implementation, the Audit Commission conducted a series of annual reviews of police data quality, to monitor and assess each force's progress towards compliance with the new standard. Their findings were published in three reports (for 2004, 2005 and 2006-07). By the time of the final report, the Audit Commission concluded that good progress had been made in improving the quality of recorded crime data and in increasing user satisfaction:

    Thirty-eight police authorities and forces (88 per cent) have good or excellent crime data quality. This is a significant improvement from 12 (28 per cent) in 2003-04. Since 2005-06, no police authority or force has poor crime data quality. There has been a sustained improvement in crime data quality. Compliance with national standards is now built into the activity and processes of most police authorities and forces.[94]

105. The Audit Commission ceased its annual monitoring work on the implementation of NCRS in 2006/07. As we have discussed in this report,witnesses and the ONS have identified the discontinuation of regular annual audit as a possible contributor to the subsequent faster fall in recorded crime compared with the trend indicated by the CSEW.

106. In 2009, following the discovery of inconsistencies in the way the police were recording grievous bodily harm with intent, HMIC conducted a one-off quality review into the way in which police forces record most serious violence (which at the time was part of a central Government target). The resultant report found some variation in recording which they partly attributed to the lack of independent monitoring of crime records, following the cessation of the Audit Commission's regular reviews.[95]

107. Prompted by the cessation of the Audit Commission's involvement, and informed by the findings of HMIC's 2009 inspection, UKSAnoted its concern over the cessation of periodic external audit in its 2010 monitoring report,"Overcoming Barriers to Trust in Crime Statistics":

    There seems to be broad agreement that inspections by the Audit Commission over several years contributed to improvements in police crime recording, but these inspections have now ceased. […] The more recent HMIC review of the way police forces record most serious violence considered that the current lack of independent monitoring was a possible contributory factor to the error rate, and concluded that there is a need for better quality assurance.[96]

108. In January 2011, HMIC was commissioned by the Home Office to examine how the police record, investigate and resolve crimes and incidents of anti-social behaviour.[97] This review looked at a small sample of crimes and incident records across all English and Welsh forces (fewer than 6,000 records in total) and found:

·  Three-quarters of forces made correct crime recording decisions from incidents 90 per cent or more of the time-an average of 92 per cent of incidents correctly finalised, indicating a good overall national standard;

·  Whilst the majority of police forces performed well, there remained a wide variation in the quality of decision making associated with the recording of crime (a range of between 86 and 100 per cent from the lowest to the highest performing force) which was a cause for concern;

    Limited evidence of forces directly assessing whether their own crime quality audits provided confidence that their crime figures gave an accurate account of their performance, and few forces compare crime audits with crime performance in any meaningful way.[98]

109. HMIC's inspection work on crime recording during 2009-2013 found that forces which demonstrated high standards of data quality possessed the following key attributes:

·  A clearly identified chief officer lead acting as the force champion for data quality and sending consistent and unequivocal messages to officers about the importance of maintaining high standards in crime and incident recording;

·  A strong, independent Force Crime Registrar, enjoying unequivocal chief officer support and with a reporting line not subject to operational pressures.

Chief Constable Farrar noted in his evidence that "regular, clear and consistent Chief Officer engagement with FCRs is believed to be important in providing FCRs with independence from target cultures and so enabling them to ensure crime is accurately recorded."[99]

HMIC's 2014 Crime Data integrity inspection

110. In April 2013 HMIC announced plans to conduct a crime data integrity inspection in all 43 forces as part of its 2013-14 inspection programme, and confirmed this commitment to the Home Affairs Committee in May 2013.[100]The inspection was prompted by the HMIC's findings in Kent, which we consider earlier in this report.[101]The Home Secretary wrote to HMIC in June 2013 to approve of the HMIC's initiative, remarking that "it is vital that the public have access to transparent and trustworthy statistics on recorded crime […]. It is clearly critical a report on this is published within the new inspection period."[102]Initial findings will be provided in an interim report (as requested by the Home Secretary) in April 2014, with a final report to follow later in the year.[103]

111. The HMIC's previous inspections of data quality across forces were limited in scope-both Crime Counts (2009) and The Crime Scene (2012) only considered crime and incident records resulting from telephone calls to force crime centres, and examined only a small sample of such records. HMIC has assured us that the current inspection will encompass the various routes by which crimes can be reported to the police. It will address key issues such as the quality of leadership and governance, the quality of internal audit processes and the role of the Force Crime Registrar, how effectively victims are placed at the centre of crime recording decisions, and the extent to which no-crime decisions correctly adhere to the NCRS.

112. In December 2013, the Home Office announced £9.4 million funding for regular annual all-force audit by HMIC.[104] Tom Winsor told us that "I have every expectation, although we are still doing the planning on this, that the integrity of crime recording will be part of [the annual audit]".[105] Although HMIC were unable to confirm for us how much of the £9.4 million would be devoted to crime data integrity, they did tell us that "this year's crime data inspection is costing just over £1 million, to give you an order of magnitude."[106]

113. This intensified scrutiny of police recording practices and the focus on compliance with prescribed procedures may lead to concerns that the police are being burdened with additional red-tape and distracted from their core role of fighting crime. However, reliable crime recording is a bedrock of core policing work and of the service provided to the public, a point emphasised by several witnesses. Sir Andrew Dilnot, Chair of UKSA, told us:

    My own view is that the imposition of rigorous external independent audit should not be a red-tape exercise.That is not what it is.Internal audit can be a red-tape exercise, but external audit is something coming in that should not take very large and significant resources from the police.[107]

Ed Humpherson, head of assessment at UKSA, stressed that:

    the systems of assurance that we have been describing—such as the regular auditing—are not add-ons simply for the purpose of satisfying the Authority for designation as an official statistic; they are operational needs to support decision making in every police force.[108]

WhilePeter Barron[retired Detective Chief Superintendent,]at the Metropolitan Police Service, considered that:

    those that describe HOCR [Home Office Counting Rules], NCRS [the National Crime Recording Standard] and NSIR [the National Standard of Incident Recording] as unnecessary bureaucracies do so because they provide a level of accuracy and consistency that challenge unsustainable claims of enhanced performance.[109]

114. We welcome HM Inspectorate of Constabulary's decision to undertake a data integrity inspection in 2014, and its commitment to reinstituting an annual external audit programme. We welcome the extra funding provided by the Home Office for regular annual audit of all forces.

115. We recommend that HMIC confirm that a rigorous audit of crime recording integrity will form a permanent part of these audits. Audits should ensure that the senior leadership within each force articulates the importance of data integrity to its officers. It is therefore essential that the Force Crime Registrar has not only had the requisite training but the necessary authority within the force to do their job. HMIC should identify a minimum suitable rank for FCRs, such as Deputy Chief Constable or equivalent, and FCRs should report directly to the force Commander.

116. We recommend that the current audit should examine the reasons for misrecording, such as the effect of performance culture (identifying instances where targets drive perverse incentives), poor understanding of counting rules, inadequate training and deliberate malpractice.

117. The Chief Inspector of Constabulary assured us that HMIC is "completely independent" in its judgements and has "no allegiance, other than to the public interest and to the law."This is not self-evident, given the numerous instances of HMIC inspectors moving from and into senior positions within police forces. It is therefore vital to the credibility of HMIC's annual audit of crime recording that this independence of judgement be maintained and be seen to be maintained.

91   Home Office, National Crime Recording Standard Back

92   As above, para 4.1 Back

93   Q310, CST24, CST36 Back

94   Audit Commission, Police data quality 2006/07, p2 Back

95   HM Inspectorate of Constabulary, Crime counts: A Review of Data Quality For Offences of the Most Serious Violence, October 2009 Back

96   UK Statistics Authority Overcoming Barriers to Trust in Crime Statistics, Monitoring Report, May 2010, para 38 and 79 Back

97   HM Inspectorate of Constabulary, The Crime Scene - a review of police crime and incident reports, January 2012 Back

98   HM Inspectorate of Constabulary, The Crime Scene - a review of police crime and incident reports, January 2012 Back

99   CST24 Back

100   Home Affairs Committee, Third Report of Session 2013-14, Leadership and standards in the police, HC 67-I, Q602-603 Back

101   Q411 and Q416 [Tom Winsor] Back

102   Letter from Home Secretary Rt Hon Theresa May MP to Chief Inspector of Constabulary Tom Winsor, 10 June 2013 Back

103   Q21 [Tom Winsor] Back

104   HC Deb, 18 Dec 2013,col 111-118WS Back

105   Q416 Back

106   Q439 and Q445 Back

107   Q509 Back

108   Q509 Back

109   CST03 Back

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Prepared 9 April 2014