City of London PEEL 2018

This question was not subject to detailed inspection in 2018/19, and our judgment from the 2017 effectiveness inspection has been carried over.

We set out our detailed findings below. These are the basis for our judgment of the force’s performance in this area.

Investigation quality

City of London Police investigates crime well. The force splits its investigative functions into three components: economic crime investigation, other crime investigation, and information and intelligence. Crime investigations are always allocated to appropriately trained officers and staff. The force has recently transferred in a number of detectives from other forces, and now has enough to meet its demand. Detectives have completed all national training requirements for their roles, and they are offered a broad range of continuing professional development, such as working on complex crimes from other forces.

Because the force area is small, officers can attend each crime scene and gather evidence early. Trained forensic staff and detectives are always on call. Our review of crime files found that in 48 out of 60 cases there had been an effective investigation, and 59 out of 60 cases had been investigated by the most appropriate team. Our interviews with officers and further testing of case files found supervision and investigations to be of a high standard.

But the force needs to improve the way it uses its system for managing case files and investigation processes. A new system was introduced in late 2017 and the force is still not using it consistently. We found mistakes in the way the force had allocated some crimes and recorded supervision and victim contact. Despite this, we found a good level of supervision, particularly in the public protection unit.

An economic crime victim care unit provides excellent support to vulnerable victims especially those who have reported a crime that was not investigated further, either due to a lack of evidence or a very low probability of catching those responsible. The victim care unit has extended this support to vulnerable victims from two other forces, in Greater Manchester and the West Midlands, and there are plans to extend the service to other forces this year.

Victims who do not fall into either of two categories (i.e. they are not victims of economic crime or vulnerable victims) reported lower levels of satisfaction with the service in 2018 than they did the year before. Officers told us this is partly due to the force disbanding the team that supports victims after a suspect has been charged. The officers who conduct the investigation now support victims and keep them updated. Officers also told us that because of increased workloads they can spend less time with victims than they used to. As part of its transformation project, the force should look for ways to address the decline in victim satisfaction.

Among all the forces in England and Wales, City of London Police has the lowest percentage of cases against known suspects discontinued because the witness does not support a prosecution. The average rate across England and Wales is 15.52 percent, whereas for City of London Police it is 5.21 percent. But while this is positive, the picture is not so good in cases where a suspect has not been identified and the victim doesn’t support a prosecution. At 9.09 percent, the force has one of the highest rates for ending an investigation compared with an England and Wales rate of 4.61 percent.

Catching criminals

Since 2016, the force has almost halved its number of ‘wanted’ persons, from 246 to 126. Supervisors regularly brief officers about wanted persons, and work closely with the public protection unit to find them.

Between 1 April 2017 and 31 March 2018, 502 suspects were released under investigation. Officers monitor them regularly. However, it has taken almost a year to put old records onto the new system. The force routinely works with the Home Office immigration enforcement team, as there are a large number of building sites and cafes in the City of London where people have been found to be working illegally.

The disclosure process in criminal prosecutions is crucial in ensuring a fair trial, and City of London Police is collaborating with the other London forces to make sure officers and staff fulfil their disclosure obligations. Police investigations must follow all reasonable lines of enquiry, including those that point away from the suspect. Prosecutors must provide the defence with any material that undermines the case for the prosecution or assists the case for the defence.

The force is part of a pan-London group of police forces and other criminal justice bodies that has been set up to deal with the disclosure problems seen in London and elsewhere in England and Wales. City of London Police now has ‘disclosure champions’ who review cases and offer advice and guidance to officers. All officers and staff attend a one-day disclosure training session and officers complete an online training course. Officers from the economic crime department attend a higher-level disclosure course, which is important in complex financial investigations.

We set out our detailed findings below. These are the basis for our judgment of the force’s performance in this area.

Understanding and identifying vulnerability

Protecting vulnerable people is one of City of London Police’s top priorities. The force has a clear definition of vulnerability and has plans in place to support vulnerable people. It works with the City of London Corporation, local health services and charities to make sure vulnerable people receive the services they need.

The force has a comprehensive understanding of the nature and scale of vulnerability in its area. Officers look out for hidden forms of vulnerability, for example modern slavery on building sites and cafes and sex workers in pop-up brothels. The force has commissioned research on hidden vulnerability and briefs its officers about what to look for. It has also assessed future demand relating to people with mental health issues and missing people and is planning accordingly.

Call handlers identify vulnerable victims promptly. Most calls for the force are taken by the Metropolitan Police Service, and the reports are sent to the City of London Police control room. Although the force’s command and control system does not automatically identify repeat callers, officers and staff manually check other systems for vulnerability. An intelligence officer is always present in the control room to look for vulnerability and risk in the open call logs, and to provide officers attending incidents with extra information. This helps officers and staff make good decisions about threat and risk.

The force attends all calls for service from the public, which is almost unheard of in other forces. It had no backlog of calls or incidents awaiting a police response when we visited the control room during our inspection. We saw call handlers giving victims good advice about staying safe and preserving evidence, and they can request expert advice easily through an on-call system in the control room.

Responding to incidents

Officers usually respond to incidents involving vulnerable victims quickly enough to keep them safe. The force covers a small area, and it has recently increased the number of officers with cycle training, because this is the fastest way to reach victims in busy traffic.

When officers arrive at a domestic abuse scene, they mostly do a thorough job of assessing the victim’s vulnerability, and also recognise the risks relating to other people in the household. We reviewed a small number of domestic abuse risk assessments and found them to be of a high quality. The force has a thorough, three-stage review process for domestic abuse risk assessments, which means it is unlikely to miss vulnerable victims. The assessments are checked by the first-line supervisor, by the duty inspector and then again by the public protection unit supervisor to make sure they include appropriate safeguarding actions and further support.

Officers from the public protection unit and the duty inspector share information about immediate safeguarding with other agencies such as health, social care and housing. These agencies told us the force shares information in a timely and efficient way.

As the force covers a busy central London area with many vulnerable people on the streets, a high proportion of the incidents it attends involve mental health concerns. It works well with other agencies to assess and respond to these incidents. A mental health nurse is deployed with the police response vehicles between 7.00pm and 3.00am each night to help deal with any cases involving mental health. The nurse can decide whether somebody needs assessment, and can access medical records and secure facilities more quickly than a police officer. The force has monitored this practice over six months to assess its effectiveness and has now given it stable funding.

Response officers use arrest and voluntary attendance, in which suspects can attend a police station at an appointed time, in line with the rest of England and Wales forces. Its use of arrest is 87.18 percent compared with the England and Wales arrest rate of 90.51 percent, and its use of voluntary attendance is 12.82 percent compared with the England and Wales rate of 9.49 percent. The force is also in line with the rest of England and Wales forces for its domestic abuse charge rate, which is 14 percent.

Supporting vulnerable victims

City of London Police safeguards vulnerable victims to a high standard. The public protection unit is responsible for safeguarding victims of domestic abuse, supported by neighbourhood officers, while the communities team safeguards victims with mental health issues. The force has an independent vulnerable victims advocate who advises officers about necessary safeguarding measures. Neighbourhood and communities teams visit vulnerable victims regularly, giving them protective advice and helping them make their properties more secure.

Last year, one of the areas for improvement we identified in City of London Police was that the force should share information with schools about children who may have witnessed domestic abuse. Work has commenced to put in place the necessary processes but is not completed yet, which means children may not receive the support they need in school after witnessing a traumatic incident. It therefore remains an area for improvement.

During 2018, the force has much improved its use of legal powers to protect victims of domestic abuse. It has trained officers in how to authorise applications for domestic violence protection orders and complete the applications. Due to the relatively small resident population in the City of London, most domestic abuse cases involve victims who live outside the force area but are within the City of London when the abuse takes place. In these cases, the force has good processes in place to make sure it carries out the initial safeguarding of victims and efficiently transfers cases to other forces.

As it is a relatively small force, City of London Police does not have a multi-agency safeguarding hub. However, its public protection unit provides the same functions, and all high-risk domestic abuse cases are referred into the multi-agency risk assessment conference.

Last year, we found that the force needed to improve how it collected feedback from vulnerable victims. This year we found that the vulnerable victims advocate collects feedback from domestic abuse victims, and attempts to collect feedback from victims with mental health concerns, but these forms are rarely returned. We did not find evidence of feedback being collected from other vulnerable victims and so this too remains an area for improvement for the force.

The force is good at sharing with other bodies the lessons it learns about its work with vulnerable people. It reviews most incidents involving vulnerable victims and shares this information with other agencies through the force’s learning forum and the City of London Corporation, which acts as the local authority for the force.

The force manages a small number of offenders who pose a risk to vulnerable victims, and it does this well. It carries out risk assessments for offenders and reviews them regularly. Most of the registered sex offenders in the City of London are rough sleepers, and the force uses its briefing page to make neighbourhood teams and response officers aware of them. Registered sex offenders are monitored by the public protection unit, which carries out regular checks to make sure that they are still in the force area and registering as they should. The force has applied for a small number of sexual harm prevention orders this year to protect victims from dangerous or sex offenders.

We set out our detailed findings below. These are the basis for our judgment of the force’s performance in this area.

Understanding threats

The force has a good understanding of serious and organised crime threats, particularly those involving fraud and cyber-enabled crime. It receives detailed information about fraud, money laundering and cyber-enabled crime from banks, businesses and the National Crime Agency, among others, which helps it to assess the threats.

It has identified other organisations that it wants to work with on this issue over the next year, from both the public and private sectors. It maps all new organised crime groups promptly and rescores them consistently and appropriately using national systems. Processes are in place to monitor or escalate the activities of organised crime groups that have been disrupted by the force or have been inactive for a time. The force has archived a large number of organised crime groups and transferred responsibility for others to different forces over the past two years. This has significantly reduced the number of organised crime groups it is responsible for and means that the force can focus more effort on those that it retains.

We found good practice in frontline policing. Neighbourhood officers look for signs of modern-day slavery, and for organised criminals who use aggressive begging tactics or who pretend to be police officers in order to steal. The force also works well with other regional organised crime units. Most recently, it collaborated with the northwest unit on tackling organised criminals from Manchester who were having an impact on the City of London.

However, the force needs to improve its understanding of other organised crimes, particularly drug dealing and county lines. The force’s drugs reduction strategy contains detailed information about the threat from drugs and sets out how the force intends to tackle county lines, but this was not yet in place. It is working with the other London forces on specific issues such as children found at train stations, who are being exploited or are vulnerable to exploitation by county lines drug dealers in the force area.

Last year, we found that the force needed to understand county lines better, and it has made some progress in this, including good work with young people at Liverpool Street station. But more needs to be done. The force told us that it did not have the same problems with county lines gangs as other forces, due to its size and location. Local partners also told us that they had not yet come across any people involved in county lines activities.

We found that a small number of officers did not understand county lines activities and were not aware of the signs they should look for. The force should make sure all its frontline officers and staff understand county lines better.

Serious and organised crime prevention

The force tries to identify individuals at risk of being drawn into organised crime. It has a small residential population of approximately 9,000 people and has identified crimes that people in the area may be drawn into, such as boiler room frauds , drug or money trafficking or sex work. People can be referred to an early help group if there are concerns about them financially or socially, including if they are at risk of being drawn into organised crime.

The force told us that there were no gangs resident in the force area, and that most gang members who frequent the City live in neighbouring boroughs and across London. This means the force hasn’t used any gang injunctions to prevent youth violence. It does, however, use dispersal orders when it receives intelligence about large numbers of youths meeting in the area if it believes this could lead to violence.

Last year, we found that the force needed to improve its approach to preventing serious and organised criminals from offending. Since then it has carried out detailed analysis of this concern, and at the time of our inspection was recruiting staff to manage a new approach. However, it does not yet have an effective approach to lifetime offender management. It does some work with prisons and probation services to actively manage organised criminals, but this is usually relating to fraud and cyber-enabled crime. It does not currently do this for other crimes, such as drug dealing and violence, but it should. This management could include using additional orders, such as compensation, disqualification or forfeiture, other agency powers and other methods to deter organised criminals from continuing to offend.

The force is taking positive steps to increase its prison intelligence capacity and capability, with a number of new officers trained to work in this environment. This has already had a positive impact by helping the force to combat crime involving online vouchers and gift cards.

In relation to serious crime prevention orders, the force works effectively with its other agencies such as HM Revenue & Customs and organisations in the banking sector to enforce these orders. The force is also good at using other techniques to disrupt organised crime. It recently identified a large number of bogus websites through proactive intelligence work with its partner agencies and took the websites offline.

The force is good at publicising successful campaigns and raising awareness about fraud and cyber-enabled crime. It produces alerts describing criminal methods and how to combat them, based on information from its economic intelligence teams. It also sends out protective advice to other forces, private and public sector organisations, and communities. Our 2018/19 thematic inspection of the police response to fraud looked more extensively at this aspect of City of London Police’s work. Our detailed findings have been published in the HMICFRS report Fraud: Time to Choose.

There are only six schools in the force area, and officers visit each one to talk to children about the dangers of organised crime, among other topics such as online grooming and road safety. This demonstrates the force’s commitment to improving the national response to organised fraud and cyber-enabled crime. We found much less evidence of awareness-raising in its wider community about other types of serious and organised crime, such as drug trafficking, organised theft and pickpocketing, however. The force should review its awareness campaigns to make sure that they are covering all the necessary areas.

Disruption and investigation

The force maintains a serious and organised crime local profile, which is used by the City of London Corporation to plan activity by the police and other services. It has an active partnership board structure in place with local partners and the City of London Corporation. It has agreed three priorities for the coming year:

• fraud and cyber-enabled crime;
• modern slavery and domestic servitude; and
• illicit drugs.

The board is supportive and helps the force to focus on these priorities. Its response to fraud and cyber-enabled crime is already good, and it is proactive in its approach to tackling modern slavery. A new drugs reduction strategy, mentioned above, focuses on a co-ordinated response to county lines-related drug dealing with its partners. We will assess the effectiveness of this strategy over the next 12 months.

In a good example of joint working, the force has recently trained all its lead responsible officers, along with officers from the British Transport Police, in how to deal with organised crime groups. Lead responsible officers have access to a broad range of specialist advisers to support them, particularly when investigating economic crimes. The force considers a wide range of covert and overt tactics when dismantling organised criminal operations with links to fraud and cyber-enabled crime. It has tackled organised crime successfully this year, working alongside the national fraud task force and the National Crime Agency.

However, the force needs to scrutinise the work of its lead responsible officers more regularly. A new serious and organised crime board appears to be effective at prioritising new organised crime groups. It has the leadership and planning in place to support effective investigations. But the meeting does not require the lead responsible officers to attend. We could not see how or where they would account for their work. The force should also make sure that all its plans have a ‘4P’ approach (pursue, prevent, protect and prepare); the plans we assessed were focused on pursuing criminals, with less detail regarding how to ‘protect’, ‘prevent’ and ‘prepare’.

The force records disruptions of organised crime groups using the national scale, but it has the lowest number of disruptions per group of all England and Wales forces. This is probably due to the fact that the force usually deals with complex economic crimes, for which disruption may be less straightforward than for other types of organised crime.

Neighbourhood teams have successfully contributed to operations aimed at tackling organised crime groups. This includes one recent case of a Romanian organised crime group involved in aggressive begging. Officers are briefed on the signs they need to look for and are taking steps to identify organised criminals who operate in the force area.

Last year we said the force needed a better understanding of the impact that it had on serious and organised crime over the medium and long term. We found some improvement in this area this year. The force is measuring its impact more accurately, but it still needs to use its partnership board to get better data from its partners and the other London forces. This would help it allocate resources to tackle all types of serious and organised crime.

The force is good at reviewing its serious and organised crime investigations. It analyses them and shares good practice with other forces. Its recent investigation of Bitcoin fraud is likely to become the standard for all forces to investigate such crimes. By the sharing of good practice, the force is contributing to the national response to serious and organised crime.

Understanding the threat and responding to it

City of London Police operates joint arrangements with the Metropolitan Police Service to provide armed policing. This means that the standards of training, armed deployments and command of armed operations between the forces are consistent.

The force has a good understanding of the potential harm facing the public. Its APSTRA conforms to the requirements of the code and the College of Policing guidance. The APSTRA is published annually and is accompanied by a register of risks and other observations. The designated chief officer reviews the register frequently to maintain the right levels of armed capability and capacity.

Last year we identified an area where the assessment of risk could be improved. We recognise that City of London Police works closely with the Metropolitan Police Service and British Transport Police to provide armed policing in the capital. However, a joint APSTRA as a single point of reference for the three forces does not exist. Such an APSTRA would focus on the entire threat in London and leave the three forces in a stronger position to address it. This remains a shortcoming for the three forces. However, there are plans in place between the forces to begin joint analysis of threats and risk in April 2019.

All armed officers in England and Wales are trained to national standards. There are different standards for each role that armed officers perform. The majority of armed incidents in City of London Police are attended by officers trained to an armed response vehicle standard. However, incidents sometimes occur that require the skills and specialist capabilities of more highly trained officers.

We found City of London Police has good arrangements in place to mobilise specialist officers should their skills be required. On these occasions, agreements are in place for the capabilities to be provided by specialist officers based within the Metropolitan Police Service.

Working with others

It is important that effective joint working arrangements are in place between neighbouring forces. Armed criminals and terrorists have no respect for county boundaries. As a consequence, armed officers must be prepared to deploy flexibly in the knowledge that they can work seamlessly with officers in other forces. It is also important that any one force can call on support from surrounding forces in times of heightened threat.

The arrangements in place between City of London Police, the Metropolitan Police Service and British Transport Police mean that armed officers can deploy quickly and efficiently in the capital.

We also examined how well prepared forces are to respond to threats and risks. Armed officers in City of London Police are trained in tactics that take account of the types of recent terrorist attacks. Also, City of London Police has an important role in designing training exercises with other organisations that simulate these types of attack. We found that these training exercises are reviewed carefully so that learning points are identified and improvements are made for the future.

In addition to debriefing training exercises, we also found that City of London Police reviews the outcomes of all firearms incidents that officers attend. This helps ensure that best practice or areas for improvement are identified. We also found that this knowledge is used to improve training and operational procedures.