A Final Follow up on the Report Into the Accessibility of Police Complaint Handling in Scotland Published April 2012

A final follow up on the report into the accessibility of police complaint handling in Scotland published April 2012

A final follow up on the report into the accessibility of police complaint handling in Scotland

Priorities and assurances The Commissioner published his follow up report on the accessibility of police complaint handling in July 2011. Accessibility follow up Report July 2011 Following the report all eight police forces provided an updated action plan recording how the recommendations in the report would be considered and implemented. These have now been analysed along with any additional evidence provided.

The PCCS assessed the relative impact of the related risk on the organisation; the more serious the risk to the force, the higher the priority that was assigned.

Issue subjecting the organisation to material risk and which required to be PRIORITY 1 * brought to the attention of the force executive. Issue subjecting the organisation to significant risk and which should have PRIORITY 2* been addressed by senior management. Matters which if addressed would enhance the efficiency and effectiveness of PRIORITY 3* the force. Observations that the force might have wished to consider in order to OBSERVATION* enhance its efficiency and effectiveness. The recommendation is not or is no longer applicable to the force as it has NOT APPLICABLE been discharged.

* For the purpose of this follow up, recommendations are not prioritised and when complete they are moved to Observation or Discharged completely.

An overall assurance level that considers the weaknesses highlighted and detailed later in this report has been assigned. The assurance level for accessibility to the police complaints system in Scotland is as follows:

Substantial Assurance

This is because in general, the accessibility of the complaints management process was found to be operating effectively. While some weaknesses remain, many of the weaknesses identified in the original report have now been improved or are no longer applicable. Where they remain it is acknowledged that the move to a single police force does not support further significant development of individual force websites for best value reasons. PCCS will work to ensure that the recommendations contained within the original report are incorporated into the design for the website of the new Scottish Police Service.

FULL Sound system of control designed to achieve the system objectives. Essentially a sound system but with weaknesses that put some system SUBSTANTIAL objectives at risk. LIMITED Weaknesses in the system of controls put system objectives at risk.

NIL Control is weak leaving the system open to significant error or abuse.

Analysis by recommendation

Recommendation 1 – Functionality and accessibility

This remained outstanding as an observation for Central Scotland, Grampian, Tayside and Strathclyde Police.

It was recommended previously that Central Scotland and Grampian Police give further consideration to improving immediate access to complaint information from the homepage of the forces website.

Strathclyde and Tayside Police were asked to give consideration to providing a full range of web services for those who experience difficulty in accessing information and to offering a translation service to those who require it.

Central Scotland Police

The updated action plan for Central Scotland Police states that a link entitled ‘complaints and compliments’ has been created on the homepage which navigates users to the information page. On review this is found to be sufficient.

• This observation can be discharged from Central Scotland Police

Grampian Police

The updated action plan for Grampian Police states that there is now a link providing immediate access to “ how to complain” has been added to there homepage. On review this is found to be sufficient

• This observation can be discharged for Grampian Police

Strathclyde Police

Strathclyde Police are currently working on a new force website that will take into account the recommendations made, the force are also consulting the Scottish Accessibility Forum. In relation to the provision of translation services they state are going to use Google translate on their site, which will provide the ability to translate the website into numerous languages.

• This therefore remains as an observation for Strathclyde Police

Tayside Police

Tayside Police have added the ability to use different language options through a link to Google translate on their homepage and have added accessibility options. On review this is found to be sufficient.

• This observation can be discharged for Tayside Police

Recommendation 2 – Process details and explanation

This remained an observation for Central Scotland, Strathclyde, Fife, Lothian and Borders Police and Northern Constabulary. This recommendation was that a full explanation of the complaint process be available including: the definition of a complaint; the process for criminal and non‐criminal complaints and complaints about senior officers; information regarding outcomes; and information about learning should all be provided on the police website.

Central Scotland Police

Central Scotland Police have now demonstrated that they have completed the recommendations and have added a submenu entitled ‘complaints against senior officers’. They have also made their learning outcomes which are presented to the joint police board available through a link on their website.

• This recommendation can therefore be discharged for Central Scotland Police

Fife Constabulary

Fife Constabulary have put information of likely outcomes on their complaints webpage. They have not yet provided information on learning points and, due to the changing landscape and the future move to a single website for the new force, they have no current plans to address this point.

• This therefore remains as an observation for Fife Constabulary

Lothian and Borders Police

The recommendation previously advised that there was little information on learning identified or implemented by the force arising from complaints and little information regarding quality of service complaints. The updated action plan states that information on learning is available on their intranet site and links to the PCCS case handling reviews in relation to the Lothian and Borders area. On examination there have been improvements made to include detail of the types of complaint, including quality of service.

• This recommendation remains as an observation for Lothian and Borders in relation to links to learning from complaints

Northern Constabulary

Previously Northern Constabulary had two issues outstanding before the recommendation could be considered fully discharged. One was to include possible outcomes of complaints on the website, this has been added. The other was to provide additional information in respect of the role of Northern Joint Police Board in relation to complaints about senior officers, this has also been added to the website.

• This recommendation can be discharged for Northern Constabulary

Strathclyde Police

Strathclyde Police, who are currently working on a new website, have added a complaint definition, information on how to complain about a senior officer and are currently working on inserting a link from the Strathclyde Police website to the PCCS learning point publication on the PCCS website.

• This therefore remains as an observation for Strathclyde Police

Recommendation 3 – Contact options

This recommendation was only partially discharged by five forces previously. This recommendation was outstanding for Central Scotland, Dumfries and Galloway, Fife, Grampian Police and Northern Constabulary.

The recommendation was to ensure a range of online contact options were available to access the complaints system including: an online form, an email link, a direct telephone number and the address for the Professional Standards Department, and give consideration to a mobile text facility.

Central Scotland Police

Do not have an online complaints form, however there is an online contact form, which can be used by members of the public to contact the Professional Standards Department. However, this has not been designed as a specific online complaints form as it is not a secure link. A direct telephone number and address has been added.

• This recommendation can be discharged for Central Scotland Police

Dumfries and Galloway Constabulary

Dumfries and Galloway only had one recommendation outstanding which was to implement an online complaints form. It was agreed previously that due to the cost and practicalities of this that it was left to the forces to decide whether to implement it or not. Dumfries and Galloway have taken the decision not to implement it at this time.

• This recommendation can be discharged for Dumfries and Galloway Constabulary

Fife Constabulary

The recommendation for Fife Constabulary was that a direct address for Professional Standards Department was added, this has now been completed. A further point to this recommendation was that a direct telephone number for the Professional Standard Department should be added. However, as these lines are not manned outside office hours, they have kept a single non‐emergency number for all calls to Fife Constabulary.

• This therefore remains as an observation for Fife Constabulary

Grampian Police

Grampian Police had no direct contact number for the Professional Standards Department or a direct telephone number. There is now a direct email address for the Professional Standards Department but currently no direct telephone number.

• This therefore remains as an observation for Grampian Police

Northern Constabulary

The recommendation for Northern Constabulary was that they had an online complaints form and a direct telephone to the Professional Standards and Conduct Unit. The telephone number is now online and there has been an online reporting tool since September 2011.

• This recommendation can be discharged for Northern Constabulary

Recommendation 4 – Links to other relevant sources

At the last follow up, this recommendation remained out standing for four forces: Fife, Lothian and Borders Police and Northern Constabulary.

This recommendation aimed at ensuring that forces were providing enough assistance for those potential complainers who may have additional problems in accessing the complaint system. For example, those who are vulnerable or have difficulty with literacy or language.

Fife Constabulary

Fife Constabulary have added links to Citizens Advice Scotland, the Citizens Advice Bureau and the police authority (Fife Council Police, Fire and Safety Committee) as previously recommended.

• This recommendation can be discharged for Fife Constabulary

Lothian and Borders Police

The updated action plan for Lothian and Borders Police states that a link has been added to the Citizens Advice Bureau website and the Police Complaints Commissioner for Scotland website. The Scottish Government ‘Complaints about the police’ leaflet link points to the PCCS ‘Complaints about the police’ leaflet, rather than the Scottish Government leaflet.

• This recommendation therefore remains only partially discharged for Lothian and Borders Police.

Northern Constabulary

The updated action plan for Northern Constabulary states that the errors in respect to the link to PCCS leaflet and the postal address have been amended. On review this is found to be the case.

• This recommendation can be discharged for Northern Constabulary

Recommendation 5 – Satisfaction and feedback

The recommendation was an observation to adopt good practice in providing facilities to capture feedback. This recommendation was made only to Fife Constabulary. The updated action plan advises a feedback section has now been added to their website. This is found to be sufficient.

• The recommendation can be discharged for Fife Constabulary

The opportunity to provide feedback presents one of the most effective ways of identifying learning for the organisation. It is therefore encouraging to see that all forces now have this in place.

Part B – Recommendation 1 – People who choose to complain

This recommendation concerned the provision of information to complainers at the beginning of the process and ensuring that complainers were advised of their right to appeal at the end of the process. This recommendation was outstanding for Tayside Police and the right to appeal decision is discussed after the initial stages have been made.

• This therefore remains as an observation for Tayside Police

Part B – Recommendation 2 – Potential complainers who do nothing

This recommendation was aimed at making the police complaints system less intimidating and more accessible for those who may wish to complain, but do not know how to or who may be reluctant to do so.

This was previously an observation for Lothian and Borders, Strathclyde and Tayside Police to consider. All of these forces have made use of Twitter, YouTube or Facebook to communicate to a wider audience.

• This recommendation can be discharged for all forces.