Monitoring of the Handling of Complaints by the Chief Constable

The Angiolini Review recommended that there should be regular audits of Police Scotland complaint handling procedures with a view to ensuring that they remain both efficient and effective, whilst identifying opportunities for learning and improvement, as well as outlining a number of specific recommendations in respect of audit more generally. The Review further notes that the Committee should consider which areas should be the subject of audit, and do so in consultation with the PIRC.

At its June 2023 meeting, the Committee was advised of the commitment to adopt a prioritised and co-ordinated approach to a broad multi-agency audit plan, co-ordinated through the National Complaint Handling Development Group (NCHDG) which aligns with the Angiolini Review recommendation that all audit arrangements, including regular dip sampling designed to identify poor practice, good practice and emerging trends, should be prioritised and co-ordinated to support the common objective of improving standards and service to the public.

Complaint Triage Audit

The Angiolini Review specifically highlighted that the arrangements Police Scotland has in place for complaint triage/assessment need to withstand robust internal and external scrutiny and require regular and meaningful audit by Police Scotland, the SPA, and the PIRC. Complaints triage is the process of assessing information in order to decide how serious allegations are and how they should be dealt with. It is a critical stage in the complaints process, as it determines the route and processes that apply to each complaint. It includes the initial assessment on whether a complaint is a relevant complaint about the police and, if so, whether the complaint is a quality of service issue, or has arisen due to poor individual performance, or is a potential misconduct issue or a criminal allegation.

An initial joint SPA/PIRC audit was undertaken in 2022, which examined complaint triage during the three month period prior to and following the introduction by Police Scotland, in May 2021, of a new national complaint handling operating model (whereby all non‐criminal complaints are recorded, assessed and managed within the Professional Standards Department), providing a baseline against which the new model could be assessed and assurance as to its effectiveness, with a view to identifying opportunities to strengthen and/or improve those new arrangements.

The Committee welcomed presentation of the resulting report on the audit findings and recommendations at its meeting in June 2023, the report identifying concerns around inappropriate attempts at frontline resolution, failure to correctly categorise matters as relevant complaints, and incomplete record keeping, and identifying a number of areas for improvement, including more specific training, clearer guidance on complaint classification and more accurate, streamlined recording processes.

An update on progress against recommendations was presented to the Committee in November 2023, at which point all remained ongoing, but with 5 (of 8) recommendations anticipated to be completed imminently, and with 2 of the remainder dependent on updates to the Police Scotland Centurion IT system. It is expected that a further report will be presented to the Committee in 2024-25. The Committee have also sought to understand when a repeat of the audit will be carried out in order to assess the impact of changes made.

Six-Stage Complaint Handling Process Audit

The Angiolini Review also highlighted the need for the PIRC to independently audit Police Scotland compliance with the six-stage process set out within its statutory guidance. PIRC undertook a resulting audit considering a sample of complaints closed during quarter 2 of 2023-24. Its resulting report identified increasing delays in Police Scotland responding to complaints, as well as issues around communication. Commenting on the report, the Commissioner stated that “Overall, the audit has shown a complaint handling system that demonstrates areas of good practice and highlights opportunities for further improvements.  We have made ten recommendations that are aimed at improving the service to the public and streamlining processes to enable complaints to be dealt with more quickly.” The Committee will consider the report and update from PIRC on Police Scotland progress in discharging recommendations during 2024-25.

Dip-Sampling

Following engagement with Police Scotland and the PIRC, in 2023-24 the SPA Complaints Team reintroduced its quarterly dip-sampling of Police Scotland complaints (a process previously paused during the COVID-19 pandemic). This involves assessing a 5% sample of closed complaints each quarter, in line with recognised auditing techniques, for compliance with the Police Scotland ‘Complaints about the Police’ Standard Operating Procedure (CAPSOP), and the underpinning PIRC Statutory Guidance. Three quarterly samples were undertaken during the year, covering quarter 3 of 2022-23 to quarter 1 of 2023-24, with findings and recommendations reported to the Committee. Given the planned 2023 PIRC Audit, amendments were made to the scope of dip-sampling activity during 2023-24 to avoid duplication.

As with the earlier joint audit (and more recent PIRC audit), this found examples of delays in Police Scotland making contact with complainers (identifying that this was a likely contributing factor in a sizeable minority of abandoned complaints each year), as well as instances of incorrect complaint categorisation and inaccurate or incomplete record keeping.