PIRC Audit Recommendations Update

Recommendation 1 – Police Scotland should review the accessibility of the complaints system for members of the public whose first language is not English.

After a positive meeting between PSD and the Channel Development Lead within Corporate Communications an ICT request has been submitted to update the ‘Contact Us’ and ‘Complaints’ tabs on the Police Scotland website with instructions on how to access and navigate these sites in the user’s preferred language. This request is pending approval.   

Recommendation 2 – Police Scotland should review the existing online complaint form, with a view to introducing more options in relation to recording gender.

At present the functionality on Centurion Version 4 and the associated DPIA does not support the recording of more options in relation to gender. Work is actively ongoing to develop the existing online complaint form, Centurion Version 8 and an updated DPIA which will enable the introduction of more recording options in relation to gender.

Recommendation 3 – Police Scotland should revise the initial complaint investigation acknowledgement letter and include an explanation on next steps as the complaint passes through the complaint process, when complainers should expect to be contacted, and estimated timescales.

An initial draft letter is at an advanced stage. Once complete, a period of internal consultation will be required. Discussions remain ongoing in relation to estimated timescales.

Recommendation 4 – Police Scotland should enhance the existing six stage form to prompt NCARU to secure perishable evidence at the earliest opportunity.

A draft of a revised six stage form, which includes the prompt to secure perishable evidence, has been circulated for internal consultation. The next phase will be ICT testing prior to going live.

Recommendation 5 – Police Scotland should consider separating the complainer contact and the enquiry log into two distinct logs that require to be updated by EOs.

The draft revised six stage form has separated the complainer contact and enquiry log. As outlined in the previous recommendation a period of consultation is underway prior to ICT testing and going live.

Recommendation 6 – Police Scotland should develop supporting guidance to accompany the new six-stage form that is being developed by PSD.

Supporting guidance is currently being drafted with a recognition that there is a dependency on the revised six stage form that is subject of consultation and testing.

Recommendation 7 – Police Scotland should revise their guidance to provide greater clarity on the processes for dealing with complaints involving a mix of criminal and non-criminal complaints.

A complaint determination code of ‘pending – criminal proceedings’ has been created on the Centurion test site. A template letter has been created to advise the complainer that the complaint has been recorded but will not be progressed until the conclusion of criminal proceedings, and, at that time, if they wish to pursue the non-criminal complaints, they should re-contact PSD to request that it is progressed. Guidance to support this recommendation is in draft format and will be part of the consultation phase previously referred to.

Recommendation 8 - Police Scotland should conduct a performance data review taking account of the increased demand and the existing resource to establish an evidence-based proposal around new timescale KPI’s for dealing with different types of complaints.

An internal meeting took place with the PSD analyst to understand what metrics are required to be measured throughout the six-stage process. It is suggested that consideration of establishing a baseline for the time taken to investigate the recently implemented complaint categories is required to provide meaningful KPIs. Centurion Version 8 is in the early testing phase.  Part of this testing includes additional functionality to record times at various stages during the complaint process.  This will require full testing to ensure it meets the needs of the Scottish process. Further discussions are planned.

Recommendation 9 – Police Scotland should revise the guidance on the identification, recording and dissemination of learning, including the use of positive terminology that aligns with the culture of learning. The complaint disposal codes should be amended to include categories where upheld complaints lead to improvement action or individual/organisational learning.

An internal review of current processes of identifying, recording and disseminating learning has taken place which has highlighted areas for improvement. The revised complaint handling form will contain tabs to record where individual and organisational learning has been identified. A separate form is being created to ensure there is an auditable trail for the dissemination of learning from PSD, with a focus on confirmation from the relevant Division that this has been implemented. Positive terminology that supports a culture of learning will be included within the narrative of the form and associated guidance. Discussions are ongoing regarding complaint disposal codes.  

Recommendation 10 – Police Scotland should strengthen the current guidance on the QA process and seek to ensure that all complaint files contain an auditable trail of QA by a senior officer.

Development of the revised complaint handling form seeks to incorporate a tab confirming that QA has been completed by a senior officer. A list of mandatory actions and guidance is being drafted to support this.

A meeting between PSD and PIRC is scheduled for 20 November 2024 to provide assurance and evidence of the work undertaken to enable next steps towards potential implementation of several recommendations.