Further Detail

The Prioritisation Framework

The framework intends to promote equality, diversity and inclusion within the organisation and strengthen its capacity to make fair, transparent, and accountable decisions. It acknowledges that significant work is already underway and safeguards these programmes within the resulting priorities.

The framework includes a range of factors and weightings to determine outputs balancing data with human judgement to ensure no single methodology has dominance. Where personal judgement, preference, bias, and lived experience can influence scores, the views of wider stakeholders (Staff Associations, Trade Unions and Diversity and Inclusion Staff Associations) have been sought. ACC Duncan, Bond, and Houston have been provided the opportunity to inform the recommendations within the context of Policing Together and Sex Equality, Tackling Misogyny (SETM).

There are five decision making factors included in the model. These are:

1. Legal and Regulatory Assessment
o Looks at what new laws, regulations or codes of practice will impact policy in the coming period.
o Considers any work required to meet existing legislation, regulation, or codes that have been identified.
o Considers changes linked to entitlements, terms, or conditions of employment.

2. Strategic alignment
o Considers gaps and clashes in organisational policy.
o Assesses what work has begun to advance organisational strategy outcomes or objectives.
o Considers accessibility, changes in practice, inaccuracies, efficiency, and best practice.

3. Risk & Audit
o Identifies risks associated with policy, what effect these could have on the organisation and what risk management strategies are in place.
o Considers the likelihood of removing a risk or action, and how likely it is that the work will achieve the expected outcome.
o Considers recommendations, and actions that have been made.

4. Scheduled review
o Looks at when the material was last reviewed.

5. Resources
o Considers what resource implications exist in doing the work. This includes:
 whether the resource requirements of the work are proportionate to the benefits from doing the work,
 the period over which the resources will be needed, and
 the availability and willingness of stakeholders to engage in the process.

Equality Diversity and Inclusion in the Framework

In line with agreed governance arrangements, clear guidance on the rules and conventions for the creation and review of policy are in place through our ‘Governance of the Police Scotland Record Set’ guidance. Opportunities for individuals and diversity staff associations exist both formally, through the mandatory consultation process and informally through a Post Publication process to provide feedback and inform the development of material. All new and revised documentation is subject to an appropriate level of engagement and consultation which includes the completion of an Equality and Human Rights Impact Assessment (EqHRIA).

These documents look at policies and procedures through the eyes of those with protected characteristics, helping to identify opportunities to promote equality and/or foster good relations within the provisions, criteria, or practices.

The EqHRIA Framework outlines key success criteria for EqHRIA’s to:
• be built into organisational decision-making and action.
• be undertaken sufficiently early.
• be supported by robust and reliable evidence.
• include effective and proportionate consultation/participatory processes.
• include clear conclusions, recommendations for action and identification of action owners.
• have a review period that allows the review of ongoing impact of policy/practice.

P&D has an excellent record in the use of EqHRIA to inform policy development, publishing assessments religiously as part of its processes. It recently reviewed the number of mitigating actions it holds against employment policies and removed thirty-six based on updates, refining several others to ensure each has a clearly defined outcome and accountable person attached. As part of this exercise, it was recognised that some mitigating actions and their completion rely heavily on assumption rather than evidence. To illustrate - unconscious bias may be identified as a risk in grievances with training being identified as mitigation, which is intended to raise awareness and empower individuals to recognise and address it. The metric used to assess 'completion' is the participation rate in the training which may or may not mitigate the risk. Even if a course is well attended and well received, it might form part of a mitigation strategy, but it cannot be relied upon to fully mitigate it. In an effort to advance the effective delivery and continuous improvement of EqHRIA within its record set, P&D is considering proposals to ensure updates are regularly provided and that mitigations are appropriately written, with appropriate measures so that they can be evidenced as delivered.

Legal / Regulatory Element of the Framework

The first activity within the model is to assess the legislative landscape, identify actions that need to be taken and apply a score based on known or anticipated implementation dates.

Strategic Alignment Element of Framework

An assessment of how policy or procedures enables or supports strategic workstreams is then required. A score has been applied on the following basis in recognition that work has started under the umbrella of Policing Together. It is anticipated that the definitions in this table (avaiblable in the PDF document) will need to be revised in a future iteration and may allow data insights to be included as a means of informing policy selection:

Risk Element of Framework

Force risks are given a score based on impact alone in line with the Police Scotland Risk Management Framework categories. Policies with the highest impact on risk score five and lowest impact score one. Where procedures present risk across multiple categories the highest score in any category applies. The categories assessed are:

• Finance
• Health & safety
• Wellbeing
• Legal
• Public Confidence
• Service Delivery / Police Scotland Priorities

This is added to the scores given to the number of open EqHRIA mitigations for the policy and any actions identified through audit, inspection, or programme. A weighting is then applied to the total score.

Review Date Element of Framework

All policies and procedures are reviewed regularly as part of the corporate governance process. This includes an assessment of corporate and operational risk based on the principles set out in the Risk Management Framework. These assessments create a cyclical review of documentation spanning one to five years allowing a score to be applied to each based on its scheduled review date. Documents that are past their scheduled review are allocated higher scores than documents with future reviews and this ensures that subjects not promoted under strategy are forced into consideration based on the time passed since the last review.

• review due three or more years ahead: Score 0.
• due next 1-2 years: Score 1.
• due current or previous year: Score 2.
• due 3-4 years previous: Score 3.
• due 5 or more years previous: Score 5.

Resourcing Element of Framework

Finally a score for resources is applied. The average time taken to conduct policy revision including all consultation and governance is 140 working days. This demonstrates the importance of identifying programmes of work that achieve the most impact with limited resource. While P&D has dedicated staff to author and progress work within its own record set, service delivery documents are subject to the availability of specialist resources within operational departments. In practical terms this means service delivery policies and procedures take longer to be delivered and are progressed based on available capacity.

 In allocating a resource score we consider how likely the work is to achieve its desired impact. In some cases, a relatively small likelihood of success could be a reason not to progress, but in other cases the risk may be so large that that work must be undertaken despite there being no output against strategic priorities. On this basis it can be difficult to assign a score based on statistical analysis. Instinct and experience are often the best measure of evaluation informed by well-defined outcomes and expectations. Scores have been applied based on the expected ask and the anticipated outputs using the following decision tree.

This has produced a hierarchy of work, but not a schedule of when the work should be done. Any schedule must consider the wider organisational context; what resource is needed and what other projects may be underway with opportunities to review both priority and capacity at relevant points.

Any schedule of delivery is entirely dependent on factors both controllable and uncontrollable and would be misleading if presented at this time. The priority assessment does not account for material that may be required, but not yet included within the record set. E.G. (Recruitment & Selection (Officers)). What we can say from work already underway is, that it is our ambition to complete reviews of Grievance, Recruitment & Selection (Staff) and Acting Ranks before the end of this calendar year. Quarter one activities are then likely to include Allowances and Expenses (Staff) and Organisational Change. Quarter two will have to include Flexible Working provisions.

New priorities added to the schedule of work will inevitably have the effect of pushing others outside capacity and updates against agreed priorities can be provided to the People Committee by exception to allow members a means of monitoring progress.