Dyfed-Powys PEEL 2018
How legitimately does the force treat the public and its workforce?
Dyfed-Powys Police requires improvement in how legitimately it treats the public and its workforce.
The force is good at treating the public fairly. Its policies emphasise fairness and respect. The force values community engagement but could address community concerns more effectively by evaluating all its engagement activities.
The workforce understands how and when to use force and stop and search. The force needs to collect more data to monitor its use of these powers.
Dyfed-Powys Police requires improvement in behaving ethically and lawfully. The force needs to improve how it spots and manages risk of corruption. It also needs to make sure it has enough people and resources to do this work.
The force is good at encouraging ethical decision-making. Leaders promote the force’s code of ethics and the workforce feels leaders set an ethical tone.
Dyfed-Powys Police requires improvement in how fairly it treats its workforce. Leaders are open to feedback. However, although the force acts on feedback, it doesn’t always tell the workforce what it has done. Some members of the workforce feel that poor performance is dealt with inconsistently.
The force is good at looking after its workforce’s wellbeing, but needs to improve how it selects for leadership roles. The workforce doesn’t believe the selection process is always open and accessible.
To what extent does the force treat all of the people it serves with fairness and respect?
Areas for improvement
- The force should ensure it monitors a comprehensive set of data on its use of force to enhance its understanding of fair and effective use of this power.
- The force should ensure it monitors a comprehensive set of data on its use of stop and search to enhance its understanding of fair and effective use of these powers.
We set out our detailed findings below. These are the basis for our judgment of the force’s performance in this area.
Treating people fairly and respectfully
Leaders in Dyfed-Powys Police foster an organisational culture that values engagement with local communities. The police and crime delivery plan emphasises the importance of ‘fairness and respect in all that we do’.
Force policies relating to interaction with the public, such as those for domestic abuse and hate crime, emphasise fair decision-making and respectful treatment. If leaders understand the importance of this, the workforce is more likely to do so.
The force uses a range of formal and informal channels to engage with its communities. In this way it finds out about local concerns, develops an appropriate response and tells the public about the results. This includes regular chief constable and PCC public engagement events. The force uses social media, too. Chief officers and other senior staff all have Twitter accounts, which they use to engage with members of the public. There are also more traditional engagement methods such as:
- Police and Communities Together (PACT) meetings;
- beat surgeries;
- ‘cuppa with a copper’; and
- ‘walk abouts’ with partners in housing estates.
A recent engagement project, Operation Cynefin, is helping the force to evaluate the success of engagement methods in different communities. The results of this should help develop the force’s engagement and policing priorities in both rural and urban areas. But these initiatives are developing in isolation with little consistency throughout the force. A more structured and co-ordinated approach would ensure that the force addresses community concerns more effectively.
We heard examples of the force tailoring its approach to improve communication with groups or individuals who are traditionally harder to reach. For example, it has started a youth forum. And it has engaged with the Polish community in Llanelli. We saw it considering communication needs of members of the public through Operation Pegasus. This is a scheme that enables people with learning disabilities or communication difficulties to register their details with the police. The stored information helps call handlers to communicate more effectively with people. The force has special constables and police volunteers who help to create a link between the police and local communities.
The workforce has varying levels of understanding of unconscious bias. Not all have received effective training. Officers and staff in relevant roles have received specific unconscious bias training which forms part of stop and search training and this has raised awareness in most frontline officers. However, we found PCSOs and enquiry office staff with limited understanding of the potential effect of unconscious bias on their interactions with the public.
The force provides all its PCSOs with dementia-friendly training. It trains its call handlers in communicating with people with learning difficulties. We heard from staff who have found this training helpful in improving their conversations with vulnerable people.
The workforce understands the fair and appropriate use of force. All officers receive use of force training as part of officer safety training. In some parts of the force, supervisors give feedback to individuals and teams about their use of force, but this was not consistent. Dyfed-Powys Police is planning to increase the level of line-manager supervision of use of force forms once the process for mobile devices has received a technical fix. The force records and submits data on use of force in line with National Police Chiefs’ Council requirements.
Dyfed-Powys Police needs to improve how it monitors the use of force by its officers. A regular meeting about use of force reviews data on this. It has recently considered more detailed information about use of force to improve its understanding. But this needs to be developed even further to make sure it includes all of the data available for scrutiny.
Examples of where it needs better data are in the use of force against people from BAME (black, Asian and minority ethnic) backgrounds, and the age of those people subject to force. Dyfed-Powys Police acknowledges that its processes to examine and understand this data are still maturing. It has effective arrangements for the external scrutiny of use of force and stop and search. The force has designated school community police officers and is involved in the All Wales Schools Liaison Programme. Lessons include information on stop and search powers.
The quality assurance panel, which is led by the PCC, is made up of members of the community. This group has primarily scrutinised stop and search. But it has recently started to examine use of force. The panel reviews a selection of use of force and stop and search forms along with the associated body-worn video camera footage.
The force acknowledges that the membership of this panel is not as representative of the community as it could be. But it does provide independent challenge to the force. The PCC is setting up a youth forum to obtain feedback from young people.
Feedback from the panel goes to the use of force governance group which, in turn, can change and improve processes. The quality assurance panel also publishes the results of its scrutiny on the PCC’s website.
Using stop and search powers
The workforce understands the ethical use of stop and search. The force has provided online training to ensure officers understand how to use the power fairly and respectfully. This is positive because it was an area for improvement in 2017.
We reviewed a representative sample of 227 stop and search records to assess the reasonableness of the recorded grounds. We found that 85 percent or those records contained reasonable grounds. This was an area for improvement for the force in 2017. Our assessment is based on the grounds recorded by the searching officer and not the grounds that existed at the time of the search.
All stop and search records go to a line manager and there is a section for supervisor comments. We heard from some officers who had received feedback from their supervisors about the quality of their records, but this was not consistent. The force needs to continue to improve how it monitors stop and search.
The use of force meeting also reviews stop and search data. It has recently changed the data and information it uses in its scrutiny of stop and search. The force considers data on age and ethnicity. But it acknowledges that the dataset should include other factors such as:
- the frequency of the item sought being found; and
- a comparison between use of drug search powers for possession only and for supply offences.
The scrutiny also identified disproportionality in the use of stop search powers on people from BAME backgrounds. The force has not yet finished the work that has been started to understand the reasons for this disparity. No information has been publicised to reassure communities, nor has the disparity been addressed. Therefore, the force has not complied with our 2017 legitimacy recommendation that all forces should:
- monitor and analyse comprehensive stop and search data to understand reasons for disparities;
- act on those; and
- publish the analysis and the action by July 2018.
The force’s arrangements for external scrutiny of stop and search are described above.
In 2017 we identified that the force needed to ensure it has external scrutiny groups at force and local levels, which should have a diverse membership that represents all communities, including young people. Members should also receive sufficient training to be able to challenge leaders with confidence. While the quality assurance panel does not have a diverse membership, the independent advisory group (IAG) now does.Summary for question 1
How well does the force ensure that its workforce behaves ethically and lawfully?
Areas for improvement
- The force should ensure that its counter-corruption unit:
- has enough capability and capacity to counter corruption effectively and proactively; and
- can fully monitor all of its computer systems, including mobile data, to proactively identify data breaches, protect the force’s data and identify computer misuse.
- The force should monitor vetting decisions to identify disparities and disproportionality (e.g. BAME groups), and to reduce them where appropriate.
We set out our detailed findings below. These are the basis for our judgment of the force’s performance in this area.
Maintaining an ethical culture
Dyfed-Powys Police is good at promoting ethical decision-making at all levels. But there are areas where it could improve this.
Leaders in the force promote the code of ethics. Examples include the chief constable’s roadshows, the whistleblowing policy and random drug-testing for substance misuse. We heard from the workforce that the chief officers are good at setting an ethical tone and this is permeating through the workforce.
The workforce can access policies on the intranet. These policies are all equality impact assessed. All new policies have a certification of compliance with the code of ethics.
Dyfed-Powys Police has a monthly ethics committee which meets monthly. It gets referrals from the force through the intranet. At the time of our inspection fieldwork the ethics committee is co-chaired by a police inspector and by an external academic. When it receives the referrals, the committee decides whether a topic constitutes an ethical issue. If it does, it commissions further research and obtains legal advice, if needed, to determine the response. Recent examples of topics the committee has advised on that have led to changes to policy and practice include the:
- consistent application of uniform policy about visible tattoos; and
- recruitment and selection process.
The force acknowledges that some ethical dilemma referrals take longer than appropriate to resolve. This is in part due to the infrequency of other meetings to which the ethics committee needs to refer specific issues, such as the people’s board which meets quarterly. More recently, due to high levels of operational demand, low attendance at the ethics committee has meant that there are too few members to make a formal decision and this has caused delays.
The force also needs to improve how it communicates the work of the ethics committee, and the outcome of the committee’s deliberations. Not all members of the workforce knew about the committee.
Training for newly promoted sergeants and inspectors includes ethical dilemmas. But we found that supervisors don’t discuss ethical dilemmas with their own teams to reinforce the workforce’s understanding of ethical issues.
The force has vetting procedures in place to ensure only appropriate people are employed. But there have been backlogs in vetting renewals. During our inspection fieldwork, we found that the force had substantially reduced the number of staff who do not have the correct level of vetting clearance for their role.
In line with our recommendation from 2016, the force cleared its vetting backlog in full by the end of December 2018. It must ensure it keeps working to prevent future backlogs.
Dyfed-Powys Police can’t single out applicants with protected characteristics during vetting, so it can’t identify potential disparities in its processes. The make-up of the force is not fully representative of its local BAME communities. However, the force is representative of its Welsh-speaking population. The force’s positive action officer has a strategy and delivery plan for the force to engage with local communities. This might encourage more applicants from under-represented groups for officer and staff roles.
The force complies with its obligations to give details to the College of Policing for the barred and advisory lists. This stops people who have left the service under investigation or who have been dismissed from re-joining the police or working in law enforcement.
The force has effective channels for regularly clarifying and reinforcing acceptable and unacceptable behaviours. One method is banners on desktop computers which reinforce messages about ethics and professional standards. Another is Film Friday. This is a monthly piece to camera with a chief officer providing important messages, for example about the introduction of the substance misuse random drug-testing policy.
The force has a learning the lessons group. This considers the lessons learnt from local incidents and complaints. It also explores external material such as bulletins from the Independent Office for Police Conduct (IOPC). Learning from this group has already influenced some changes to practice. The group published the first issue of its quarterly bulletin during our inspection. This is encouraging. The force must now make this a regular communication so that it consistently and regularly reinforces expected standards.
We found the workforce had a good understanding of acceptable standards of behaviour.
The force requires improvement in how it identifies and manages organisational corruption risks. But we found some areas of effective practice.
The anti-corruption unit does respond to reactive intelligence. But we found limited evidence of proactive intelligence being developed or proactive work to seek out corruption intelligence.
At the time of our pre-inspection insight work in July 2018 the force did not have a current counter-corruption strategic threat assessment or control strategy. However, by the time of our inspection fieldwork one had been prepared. Such an assessment, maintained over some years, should help to identify the main corruption threats in a systematic manner. This should enable the force to identify trends and patterns in corruption as they develop. This should support the force to intervene to prevent corruption and/or reduce corruption threats more effectively.
We found the management of business interests to be effective, particularly the internal communications to raise awareness of the requirement for the workforce to register potential business interests. We saw some evidence of dip-sampling for compliance.
Gifts and hospitality are managed well. A clear system is in place and the workforce is aware of it.
The force requires improvement in how it looks for and assesses intelligence about corruption. It regularly and consistently uses IT monitoring in its response to intelligence. But it makes only limited proactive use of its monitoring software. The software in use at the time of the inspection fieldwork did not extend to monitoring all mobile devices. So the force cannot be confident that the workforce’s use of data within its systems is appropriate and lawful. The software was extended to all mobile devices on 5 November 2018. While the force can now monitor all mobile devices, this will also bring additional work for the anti-corruption unit. The force needs to ensure sufficient capacity to undertake this important work.
The force has two confidential reporting systems for officers and staff to report internal wrongdoing. The force uses the Safecall service and it also offers the internal Bad Apple confidential online reporting application. The workforce uses both mechanisms to report potential wrongdoing, but we heard mixed views about them. Some people were sceptical about the anonymity of the Bad Apple system. To get the most from this facility, the force needs to raise confidence in the process.
Dyfed-Powys Police is making progress with identifying and tackling the problem of abuse of position for a sexual purpose. But further improvement is needed. The force recognises the abuse of position for a sexual purpose as serious corruption. We reviewed 60 files and the force had referred all relevant cases to the IOPC. The force submitted a plan in 2017 to address our 2016 legitimacy recommendation in this area. Although we recognise the positive work the force has done, it has not completed all the necessary actions required to comply with the main elements of our recommendation.
The force has now started to proactively monitor IT systems to identify risks related to abuse of position for a sexual purpose. This was made possible through the introduction of software that can monitor mobile devices. Previously such activity has only taken place in response to intelligence received.
The force provides material and briefings to its workforce to ensure they are aware of the problem. It trains supervisors on the warning signs that can indicate if someone is abusing their position for a sexual purpose. We found that the workforce was generally aware of the warning signs of abuse of position for a sexual purpose and knew how to report it.
The force has also educated external organisations. It has sent letters to social services and to health and education partners. These letters describe ways to report concerns about abuse of position for sexual gain.
Dyfed-Powys Police had two areas for improvement following our 2017 legitimacy inspection in relation to complaints. We found that officers and staff investigating complaints have the knowledge and skills to support people who want to complain. Also, the force has improved the quality and timeliness of updates to complainants in line with IOPC guidance.Summary for question 2
To what extent does the force treat its workforce with fairness and respect?
Areas for improvement
- The force should ensure its grievance procedures are accessible, transparent and perceived by the workforce to be fair.
- The force should ensure that it has effective processes in place to identify and understand the causes of potential disproportionality and to take effective action to address these causes in the:
- recruitment, retention and progression of its workforce; and
- treatment of officers and staff with protected characteristics, who are subjected to complaint and misconduct investigations.
- The force should ensure it has effective systems, processes and guidance in place, in which all officers and staff are engaged, to manage individual performance and development.
- The force should ensure that its promotion and selection processes are accessible, transparent and perceived by the workforce to be fair.
We set out our detailed findings below. These are the basis for our judgment of the force’s performance in this area.
Improving fairness at work
Dyfed-Powys Police needs to continue to improve its approach to fairness at work. We found that chief officers are open to feedback from the workforce.
The chief constable encourages direct questions through an ‘ask the chief’ email address that any of the workforce can use. The workforce sees the chief officer roadshows as an opportunity to meet chief officers and ask questions.
The force encourages feedback through workforce surveys. There was a high response rate of 62% to the Durham Culture and Wellbeing Survey that was being carried out during our inspection and we understand it compares favourably with other forces. The full results of this have not yet been released, however early indications were that people are motivated to serve the public and support their communities. It also carries out a health survey, local suggestion schemes, ethics committee and exit interviews. In most areas of the force, local reference groups collate workforce concerns and raise issues with senior managers.
The force does take some action in response to workforce concerns. But some of the workforce did not feel that action was always taken or effectively communicated. For example, the force recently improved the promotion process. But this was not communicated well enough to the workforce. Also, the workforce has an inconsistent understanding of the matters considered by the ethics committee. Some of the workforce think that the force does not always act on the feedback it asks for.
Dyfed-Powys Police needs to do more to ensure that its grievance procedure is perceived as fair and that grievances are resolved satisfactorily in line with the ACAS Code of Practice. We carried out a review of seven grievance files as part of pre-inspection activities and identified that the force’s recording and retention of documents was poor. The force has subsequently reviewed its grievance procedure and it is now contained within the fairness at work policy published in July 2018. The force publicised the results of the review and the fact that the procedure would now be fair and timely. But this was very recent. There is still a lack of awareness of the fairness at work policy. And some members of the workforce feel that they wouldn’t use the grievance procedure because they don’t see it as fair. This was an area for improvement in 2017. If the workforce is not aware of, or has limited confidence in, the grievance procedure, they will be less likely to use it. So, the force will not have a full understanding of workforce concerns.
The force needs to improve the way it analyses force data to identify issues that affect perceptions of fairness and respect. We found no evidence that the force analyses workforce disparities about complaints and grievances. And we found no arrangements to identify and understand potential disparities in recruitment, retention and progression for different protected characteristics and worker types. This was an area for improvement in 2017.
Dyfed-Powys Police published a progression strategy in May 2018 which described workforce composition and the potential barriers to promotion. It then developed an action plan.
Similarly, the force published a positive action strategy in August 2017. This again analysed workforce composition in terms of protected characteristics. The force developed an action plan for this, too.
These are positive steps, but they are very much a snapshot in time of the issues and do not involve continuing analysis. There is a lack of force data analysis to identify the problems that can affect perceptions of fairness. And there is a lack of workforce information, too. So the force will be unaware of any trends or, potentially, where there may be disparities.
Supporting workforce wellbeing
Dyfed-Powys Police’s leaders are good at understanding and promoting the benefits of wellbeing in the force. Wellbeing is a strand of the force leadership and wellbeing strategy and this is monitored by the wellbeing group. Physical and mental wellbeing have equal importance within the force.
The force’s occupational health unit takes account of accredited good practice. It follows NICE guidance on workplace health and meets its Equality Act obligations. The force has signed up to the Blue Light Wellbeing Framework. Supervisors discuss wellbeing with their officers and staff, but these conversations are unstructured. The force’s approach to wellbeing support ensures that, on the whole, people feel supported. Officers and staff have access to a range of physical and mental wellbeing support resources, if they need them.
The force is good at identifying and understanding workforce wellbeing issues. The occupational health unit takes wellbeing road shows throughout the force area, covering topics such as mental health.
The force undertakes wellbeing surveys for all members of the workforce. These include additional psychological wellbeing questions for those in specialist roles. This ensures occupational health unit staff are aware of any potential problems, but there is no wider analysis of those results. There is a perception that stress is likely to be the greatest risk. The force does have ways in which it can identify and understand wellbeing concerns, but robust analysis of the data would provide a richer source of information. It would also make it easier to identify trends.
Dyfed-Powys Police is good at taking preventative action to improve workforce wellbeing. As mentioned earlier, it uses road shows to promote wellbeing among the workforce. And supervisors are trained to more effectively manage workforce wellbeing. Flu jabs are available free to all members of the workforce. The force has a trauma risk management process in its post-incident procedures in which wellbeing issues are considered. The force occupational health unit is fully staffed and able to meet the demands placed on it. The unit can draw on additional nurses and counsellors if necessary. Waiting times for appointments are between two and four weeks.
The force supports absent officers and those who have raised a grievance through line managers and occupational health, where appropriate. People facing misconduct processes receive support through a designated welfare representative. Taking early action to improve workforce wellbeing should result in the workforce feeling supported. In turn, this should support people to continue in their role, or, if they have to take time off, to return to work more quickly.
Managing performance and development of officers and staff
Dyfed-Powys Police needs to continue to improve how it develops and manages individual performance. The force tracks individual performance and progression using the development assessment profile (DAP). This is a newly developed system that was introduced in October 2018. The DAP system has replaced a previous performance system which was no longer meeting the force’s needs. At present the force cannot monitor individual or personal performance throughout the workforce, but this should soon be possible with the new DAP system.
Some supervisors have regular conversations with their officers and staff to discuss performance. There is some evidence of poor performance being effectively managed, but this is not consistent throughout the force. The workforce’s perception in some areas of the force is that poor performance is not addressed.
The new DAP system is expected to address many of the current problems with consistency of performance management throughout the force. But there is still a cultural issue about performance management. Some of the workforce feel that the force does not always address poor performance. This was an area for improvement for the force in 2017. One result of ineffective performance management is a view among the workforce that not all are treated equally.
The force is good at identifying members of the workforce with high potential to become leaders. It is working towards using the competency and values framework role profiles for performance, recruitment and selection processes.
Dyfed-Powys Police is working with other Welsh forces to establish agreed rank profiles rather than individual role profiles. The new rank profiles will be built into the DAP process. Forces will use them formally in selection and promotion processes.
The force has a talent scheme. It takes many forms and can result in the individual being part of a recognised 12-month process of development. The force also offers a variety of other development and career pathway options. The current talent scheme relies on people nominating themselves. In future, both the line manager and the officer or staff member will be able to nominate. Selection will be based on the evidence in the DAP. The force has not yet assessed the system to establish if there are barriers to the talent scheme, but this should be possible as part of the DAP.
Identifying and supporting future senior leaders will ensure the force has enough talented individuals to take these roles on in the future.
The force needs to continue to improve the way it selects people for leadership roles. It has made good progress in identifying some of the barriers to promotion. In May 2018 the force produced a progression strategy which asked the workforce to identify barriers to promotion. The force has also asked female officers about potential barriers to progression.
To overcome barriers to progression for female officers, the force held a female officer development event in September 2018. This included external speakers. Senior female officers in the force ran a question-and-answer session about overcoming obstacles to development and career planning.
To address problems with promotion, the force tried a new system for a recent sergeant’s process. The system involved a process of application, independent moderation of anonymised applications and then a local panel interview. Many perceived this to be a fairer approach, but inconsistencies occurred because panel members varied. Next time the force will use a single interview panel that will operate in different locations so that the process remains accessible.
The force did not communicate the change in promotion process widely. There is still a view among some members of the workforce that the promotion process is unfair. This was an area for improvement for the force in 2017. Where selection is based on competence, promotion processes are seen to be fair by the workforce and ensure that the right person for the job is selected.Summary for question 3