Report Summary
This report provides members of the Complaints & Conduct Committee with an overview of the PIRC Joint Audit – Progress and Implementation report.
Meeting
The publication discussed was referenced in the meeting below
Complaints & Conduct Committee - 14 November 2023
Date : 14 November 2023
Location : online
Recommendations Update
Recommendations 1 – 6, ongoing
Complaint Handling Form (CHF) to include protected characteristics, vulnerability, individual need(s) relevant to complaint and whether any reasonable adjustments are required.
PIRC, SPA and NCARU should work together to revise the existing CHF.
A working group has been established and is chaired by the PSD NCARU Inspector; membership includes PSD, ICT and the PIRC. The CHF has been reviewed, however, full use of the form is dependent on the implementation of Centurion V7. Progression of Centurion upgrades V4 and V7 currently is ongoing. On 26 September 2023 SPA Complaints and Conduct confirmed two representatives are to join the working group. Information relating to protected characteristics and reasonable adjustments to be included in the updated CHF.
Recommendation 2, anticipated completion January 2024
Police Scotland should review the timescale for acknowledging receipt of complaint and making initial contact.
The PIRC audit highlighted Police Scotland handle on average 6500 CAPs per year – this figure does not cover the additional correspondence received by NCARU and by 2023/24, it is projected NCARU will process almost 13000 pieces of correspondence.
The PIRC audit highlighted the CAP SOP timescale, which stipulates that PSD contact complainers within 3 working days of the receipt of the complaint, was not being met.
It has been proposed at the Complaint Handling Group (CHG) that a 10-working day timescale be reflected within the SOP. CHG members agreed with above proposal and consultation is ongoing to update the Complaints SOP with PSD Service, Support and Delivery.
Recommendation 3, anticipated completion December 2023
Police Scotland should standardise training provided to NCARU.
PSD have implemented an in-depth induction training course for new members of staff. This 4-day course will be held every six months and provides operational insight of all PSD business areas with inputs from SPA and the PIRC.
Bespoke complaint handling training was piloted with an external company SANCUS – Complaint Handler’s workshop; positive feedback was received, and this will now form part of the induction training.
The induction training course was trialled in October 2023. Feedback is awaited from the course which will thereafter be evaluated.
Recommendation 4, ongoing
Police Scotland should develop guidance on the classification of complaints with practical examples, including what constitutes excessive force.
PIRC have provided clarity and it was stated the crux of the recommendation surrounded the number of allegation categories.
Members agreed a Short Life Working Group (SLWG) is best placed to review the suitability of current allegation categories. Police Scotland PSD will engage with relevant stakeholders to discuss SLWG proposal. In light of this additional information, no anticipated completion date has been included in this recommendation as this will require engagement with a number of internal and external stakeholders.
Recommendation 5, anticipated completion January 2024
Police Scotland should provide guidance on appropriate timescales to issue a 14-day letter and what constitutes all reasonable efforts.
PSD are developing the current risk-based triage approach for NCARU complainer contact for inclusion in CAP SOP. This will initially be placed through the PSD Complaint Handling Working Group (internal) for review.
It is proposed that for low-risk complaints, dependant on the complainer’s preferred contact method, NCARU make two phone calls on different days at different times and send an e-mail (if provided). Depending on the nature of the complaint, if no contact is made within two to three days, a 14-day letter will be sent. This is considered proportionate.
Recommendation 7, anticipated completion January 2024
Police Scotland with input from PIRC and the SPA should develop a training module that includes guidance on what constitutes a relevant complaint.
Additional training has been provided by PIRC (7 June 2023) to ensure current PSD staff members were upskilled in relation to relevant complaint criteria. For those unable to attend inputs were cascaded locally. This training has been incorporated by PIRC into the PSD Induction Training (October 2023). Evaluation of training to take place now course concluded to determine its suitability.
Recommendation 8, anticipated completion January 2024
PSD should review and revise the MI Assessment Sheet.
NCARU now ensure they record their rationale as to why a complaint is not recorded. The additional training as per recommendation 7 has ensured the longevity of the wider knowledge of the criteria in terms of relevant complaint.
Dip sample review of MI files to be undertaken to ensure compliance.
