Monitoring of Handling of Complaints by the Chief Constable

The Angiolini Review Preliminary Report recommended 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. The Final Report, furthermore, notes that the Committee should consider which areas should be the subject of audit, and do so in consultation with the PIRC, as well as outlining a number of specific recommendations in respect of audit more generally. The Final Report 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.

In March 2021, the Committee were advised of the proposed introduction of a joint SPA/PIRC annual audit process, as a new method of auditing Police Scotland complaints which would serve to meet the respective obligations of both organisations in terms of oversight and review of Police Scotland complaint handling arrangements.

The Final Report 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 the 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.

While the complaint triage is designed to ensure that Police Scotland’s response to a complaint is proportionate to the nature of the complaint made, it is not without risk. If a complaint has been incorrectly assessed and, therefore, not progressed, processed or disposed of in the appropriate manner, it can serve to increase the level of dissatisfaction experienced by members of the public. This can have significant ramifications, not only for the member of the public making the complaint, but also the officer who is the subject of the complaint, as well as the organisation as a whole. Ultimately, if Police Scotland gets it wrong, it has the potential to undermine public confidence.

Correspondingly, an initial joint SPA/PIRC audit commenced in March 2022, seeking to examine the initial triage of complaints by Police Scotland. The aim of the audit was to examine 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 providing assurance of 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. Police Scotland welcomed the report, accepting its findings and committing to taking on any relevant learning, but highlighted that significant improvements have been made following the period on which the audit focussed and that many of the recommendations have already been discharged. Whilst acknowledging this, the Committee have sought future assurance outlining action taken or planned in response to the report, and to understand when a repeat of the audit will be carried out in order to assess the impact of changes made.

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 recommendation in Lady Elish Angiolini’s preliminary report, that:

“All the audit arrangements, in relation to policing in Scotland, 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.”

Aligned to the above, following engagement with Police Scotland and the PIRC and as reported to the June 2023 meeting of the Committee, the SPA Complaints Team will, in 2023-24, reintroduce its quarterly dip-sampling of Police Scotland complaints (a process previously paused during the COVID-19 pandemic). This will involve regularly assessing a sample of complaints, in line with recognised auditing techniques, for compliance with the Police Scotland ‘Complaints about the Police’ Standard Operating Procedure, and the underpinning PIRC Statutory Guidance, as well as undertaking a corresponding assessment in relation to any complaints which relate directly to the Police Scotland Professional Standards Department.