Further detail

POLICY ASSURANCE PROCESS

A six monthly SPA assurance process is in place ensuring the SPA Chief Executive, Director of Forensic Services and SPA Whistleblowing Champion (SPA Board Member) receive an update of the effectiveness of the policy against set out criteria. The table below provides a summary of key areas from the two six monthly assurance assessments during 2022/23.

TABLE

CASE LEARNING

In the previous annual report it was confirmed that a lessons learned exercise was progressed for a single case that closed during 2021/22. A supporting action plan was developed and recognised the case was multi-faceted and had elements related to grievance, discipline and whistleblowing. A progress update is included below.

TABLE

POLICY/PRACTICE SELF ASSESSMENT

Following a self-assessment the 2020/21 annual report confirmed that the SPA approach was well aligned to the Whistleblowing Commission Code of Practice. In the 2021/22 annual report it was confirmed that a further review of SPA whistleblowing policy/practice would be undertaken considering this against ISO 37002, the whistleblowing management system standard published in July 2021.

This assessment has now taken place and has identified that policy/practice strongly aligns with the ISO standard. In the spirit of continuous improvement, areas for development were identified linked to the ISO standard and a progress update is outlined below.

TABLE

TRAINING PLAN

Following positive engagement and work with the Police Scotland E-Learning team, e-learning training has been developed to support both those who raise and those who receive concerns. This package is currently going through user testing before being finalised for use in Q2/Q3 2023/24.

This package will be provided to all members of staff within SPA Corporate and Forensic Services with plans to embed these as part of induction and refresher training.

In line with Section 3, a specific training session has also been developed for the SPA Complaints Team to support the ability to effectively identify when a concern does or doesn’t meet the definition of whistleblowing irrespective of whether it formally comes through the formal whistleblowing channel.

The proposed training session has been developed jointly by SPA Workforce Governance and Legal and has been shared with the SPA Complaints and Conduct Manager and will be delivered to the SPA Complaints team in Q2 2023/24.

MEASUREMENT OF KNOWLEDGE AND CONFIDENCE RELATED TO WHISTLEBLOWING

SPA Corporate

The confidence and knowledge to raise whistleblowing concerns has rightly been a key area of interest for the ARAC. SPA Corporate staff have been surveyed on their knowledge of and confidence to raise whistleblowing concerns through pulse surveys in February 2022 and May 2023. A comparison of the results is outlined below.

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Positively the percentage of staff that strongly agreed increased for both questions, however there has also been an overall decrease in those that strongly agree/agree overall.

Whilst knowledge of the process is still at a high level it is anticipated that the introduction of the e-learning package will improve on the current position. Whilst confidence to raise concerns will be considered as part of the broader SPA Corporate response to the pulse survey it is anticipated that the positive messages around whistleblowing within the E-Learning package, which will be reiterated by the Chief Executive when launched at a Staff Briefing will contribute to increased confidence to raise concerns going forward.

SPA Forensic Services

SPA Forensic Services do not currently have an equivalent survey that measures knowledge and confidence associated with whistleblowing. However what has been confirmed is that 96% of all staff have read and acknowledged the policy. The policy is also included in the Forensic Services Quality Policy Manual with the last issue of this being sent out in early April 2023.

Inclusion in overall Staff Survey for Policing

Following discussion at the ARAC in January 2022 the ACC Professionalism and Assurance committed to ensure relevant questions are included in the next Staff Survey for policing. The SPA Workforce Governance Team are also engaging with Police Scotland to ensure this commitment is delivered. The timing of the next survey has yet to be confirmed.

ASSESSMENT OF EFFECTIVENESS

This assessment considers the policy and practice, based on the detail above.

Policy

Policy very clear in relation to benefits of raising concerns and encourages individuals to raise concerns
Policy was developed in line good practice and has been subject to self-assessment with conclusion re alignment to the Whistleblowing Commission Code of Practice and ISO Standards
Evidence that lessons learned in practice will continue to inform policy development

Practice

Self-assessments demonstrate alignment with good practice
Steps have been and are being taken to make improvements based on lessons learned from previous cases and consideration of ISO standards

Training and Awareness

Current Policy easily accessible
Sustainable and comprehensive approach to training in final stages of development for those who raise and those who receive concerns
Positive steps being taken to ensure increased capability and quality assurance process that identifies whether a concern does or doesn’t meet whistleblowing definition irrespective of whether it formally comes through whistleblowing channels

Staff Confidence
Whilst levels of confidence and knowledge in the whistleblowing procedure for SPA Corporate remain high the results demonstrate the need to ensure sustainable approaches to training are put in place along with clear demonstration from senior leadership that raising a concern is a positive act.
There remains a continued commitment to ensure all staff within SPA fell comfortable to raise concerns
Steps still require to be taken to ensure consistent and effective approach to measuring knowledge and confidence to raise concerns across policing.

In summary the SPA whistleblowing arrangements are effective with evidence that steps were taken in 2022/23 to make improvements, with further improvements planned in 2023/24.