Complaints recording audit Central Scotland Police November 2011 Dumfries & Galloway Constabulary Fife Constabulary Grampian Police Lothian & Borders Police Northern Constabulary Strathclyde Police Tayside Police Central Scotland Police Contents Summary and key findings page 1 Summary of recommendations page 1 Commissioner’s role page 2 Introduction and scope page 2 Background page 3 Methodology page 3‐4 Findings and recommendations page 4‐6 Conclusion page 6 Summary and key findings Three Complaint About the Police cases were identified from the period audited 2010 – 11 as not having been recorded. This represents 0.6 % (3/510) of the total sample size examined and as such is the non – recording rate of complaints about the police in respect of Central Scotland Police. Reflecting the audit findings an overall assurance level has been applied to the initial recording of complaints about the police by Central Scotland Police as follows: Substantial Assurance This is because the initial recording of complaints about the police was considered to be generally robust, supported by sophisticated procedures for the handling of correspondence and well trained staff. However, the lack of a formal audit process to ensure consistency in recording practices is viewed as a weakness. The recommendations made provide an opportunity for the force to enhance confidence in their overall recording practices. Assurance level Definition Sound system of control designed to achieve the system FULL objectives. Essentially a sound system but with weaknesses that put SUBSTANTIAL some system objectives at risk. Weaknesses in the system of controls put system LIMITED objectives at risk. Control is weak leaving the system open to significant NIL error or abuse. Summary of recommendations • That the three complaints are recorded on the force police complaints database. • It is recommended that the force considers introducing procedures to establish an audit regime for correspondence received by the force, to further enhance their confidence that complaints about the police are captured and recorded. 1 Commissioner’s role Section 42 of the Police, Public Order and Criminal Justice (Scotland) Act 2006 gives the Commissioner the power to secure that suitable arrangements are maintained (and adhered to) for the handling of relevant complaints within Scottish police bodies. He must ensure that these arrangements are effective, efficient and contain an appropriate degree of independence and can make recommendations and give advice on their modification and practice. This report is issued in line with this power. Introduction and scope In his Statutory Guidance published in March 20111, the Commissioner stated: “accurate and consistent recording of complaints about the police will help ensure public confidence in the system.” This will also “contribute to a strong evidence base from which to assist the development of future policy.” To support this, the Commissioner is working with the Scottish police service to develop a consistent approach to recording complaints. The Commissioner also commented in his publication Police Complaints: Statistics for Scotland 2010 – 112 on variations in recording levels inconsistent with the size of forces. This issue was also identified recently by Audit Scotland and HMICS during a best value inspection of Strathclyde Police3. This audit of complaint recording practices carried out in Central Scotland Police during November 2011 is therefore intended to assist in explaining these variations, while providing assurance in respect of initial complaint recording. It is not intended to be an audit of all aspects of complaint recording. For example, work is already being undertaken by the Association of Chief Police Officers in Scotland following a recommendation by the Commissioner to develop rules and conventions around categorisation and finalisation of complaints and the individual allegations that are identified. Training in the new six‐stage complaint system is also being developed by the Scottish Police College; this will include recording and assessment. It is intended to ensure that when a member of the public contacts the police, by whatever method, to make a complaint that it is formally recorded as such, whatever action follows thereafter. 1 http://www.pcc‐scotland.org/quality_assurance/2011reports/statutory_guidance‐from_sanctions_to_solutions 2 http://www.pcc‐scotland.org/quality_assurance/statistics/police_complaints_statistics_for_scotland_2010‐11 3 http://www.scotland.gov.uk/Topics/Justice/public‐safety/Police/local/15403/publications/BVStrathclydePolice 2 Background A complaint about the police is defined as “a written statement expressing dissatisfaction about an act or omission by a police authority, by a joint police board, by a police force, by the Authority, by the Agency or by a person who, at the time of the act or omission, was a person serving with the police". Police, Public Order and Criminal Justice (Scotland) Act 2006. The PCCS Statutory Guidance notes that ‘Complaints about the police in Scotland are made through a variety of media: by letter, email, telephone or face‐to‐face to various departments. Complaints are also received by telephone in any department or service centre.’ The Guidance goes on to comment that ‘Although the definition of a complaint is a written expression of dissatisfaction, there is a need for the police complaints system to be user‐focused. The individual needs of all complainers or potential complainers must be identified and accommodated. Therefore, when a complaint is made by telephone or face to face, a written record should be made by the person receiving the complaint. …. The Commissioner is content that such a record amounts to a written expression of dissatisfaction.’ For 2010 – 11, Central Scotland Police recorded 211 Complaint About the Police cases from members of the public. Within each case there may be one or more allegations. As indicated this audit focuses on the robustness of initial recording not analysis/disposal of the case once recorded. MethodologyMethodology The audit consisted of two elements. During pre‐visit, the PCCS audit and 510 pieces of correspondence information was sought regarding the force’s were examined by PCCS. Statistical matters are correspondence procedures and volumes to assist in discussed in more detail later in this report, but it was understanding how and where complaints might be accepted that 510 pieces of correspondence would communicated to the force by the public. The force was also be examined in Central Scotland Police. asked to provide appropriate supporting documentation such as Standard Operating Procedures (SOPs), for the Falkirk Area Command, in Falkirk, was visited first and handling of correspondence, if they existed. staff there provided PCCS with correspondence which had been received addressed to the Area Commander. The force has a comprehensive SOP for the handling This area command covers a number of stations of mail and uses a document handling system known including Falkirk, Grangemouth, Larbert, Denny and as Laserfiche. This is currently being reviewed and a Maddiston. new SOP entitled Mail Management will be issued in 2012. It was explained that correspondence addressed to the Superintendent or Area Commander was not At the heart of these procedures is the use of the subject to Laserfiche, on the grounds of Laserfiche Document Management System, which is confidentiality, and was opened by the used to capture, record, forward and track, the Superintendent’s personal assistant. PCCS majority of correspondence received by the force. All concentrated on mail received from members of the correspondence addressed to Central Scotland Police, public, councillors, MPs and MSPs. It was apparent is forwarded to the Business Support Unit at Falkirk, that the level of correspondence received was fairly where it is opened and processed using Laserfiche. low and documents covering the period 1 July 2010 to There are some exceptions to this and mail which is 31 March 2011, were examined. considered to be sensitive or confidential would not be subject to Laserfiche. PCCS then visited the Business Support Unit (BSU) at Falkirk and were able to examine correspondence The force provided PCCS with an extract of all 211 received across the force and which had been recorded complaint cases in 2010‐2011 to allow captured and retained on the Laserfiche system. All verification checks to be made from sampled correspondence addressed to Central Scotland Police, “correspondence” including letters, emails and with some exemptions, is forwarded to the BSU for incident logs. processing. In addition, emails received by the force Command and Control Centre and forwarded to the The second element consisted of a 2 day visit to the Business Support Unit were examined. Force. Fife Constabulary acted as the pilot force for 3 Methodology continued On the second day of the audit PCCS visited the resulting in a minimum sample size per audit of 456 Complaints and Conduct Unit and were given records applying the same confidence and accuracy access to the force Command and Control levels. For the purposes of this audit 510 records were system, STORM, and examined a wide range of examined recorded incidents. In order to examine a sufficient number of records in In developing the audit methodology, advice this case the audit concentrated on the period 1 and guidance on sampling was taken from the January 2011 to 31 March 2011, with the exception of