Metropolitan PEEL 2018

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

At all levels, the force has a culture of treating people with fairness and respect. The commissioner regularly emphasises the importance of treating people with respect and writes monthly blogs with these messages. There are chief officer strategic leads for inclusion, engagement, use of force, and stop and search.

There has been a significant reduction in public complaints, which could suggest that the force is engaging with the public more appropriately. The force has several strategies to address how it responds internally and externally to minority and under-represented groups. We found many examples of positive engagement with different community groups. These collectively help increase the force’s legitimacy in the eyes of the public.

The redesign of the local policing model has included the implementation of new engagement hubs with the force’s partner organisations, especially in high-violence areas. Initiatives such as ‘cuppa with a copper’ and ‘#Together team’ demonstrate how the force is working with local authorities, blue light partners, businesses, residents and the youth sector to prevent crime. The force has the largest cadet programme in the UK and its success lies in its diversity: 57 percent BAME, 50 percent female and 30 percent vulnerable youths. The force currently only has 619 volunteers and may benefit from increasing this number, especially as the number of dedicated staff in each neighbourhood has reduced because of the restructuring.

The effectiveness of community engagement varies. There are positive examples of proactive initiatives, such as volunteer and schools’ officer patrols, volunteer weapon sweeps and volunteer test purchasing activities. In contrast, residents appear less interested in attending the police liaison groups, though local councils regularly take part. The force doesn’t appear discouraged by such variability and continues to seek new and innovative ways to connect with local communities.

The force is good at using the many digital platforms to engage with the public. It has Twitter, Instagram and Facebook accounts at all levels of the force. It supports the new neighbourhood watch website, OWL (online watch link), as well as the ‘Nextdoor’ app. It also has ‘your area’ pages on its own website. However, aside from the public confidence survey and Twitter, the force does not centrally monitor what engagement activity takes place. It needs to get a better understanding of how different activities affect levels of public confidence.

The force has trained the workforce on unconscious bias and communication skills. However, we still found a varied understanding of unconscious bias. The force should consider how effective its training is and what guidance it provides to its staff.

Using force

The force is fully compliant with the National Police Chiefs’ Council’s use of force recording requirement. Use of force is a central element in the officer safety training provided to recruits, regular officers, special constables and PCSOs. BCUs also conduct local inputs and the force intranet has pages dedicated to legislation, effective deployment and access to relevant forms. Officers are aware of the relevant legislation and confident in recording its use and submitting the required forms.

In some BCUs, supervision is ad hoc where use of force doesn’t lead to an arrest. The force needs to ensure consistency of supervision in such circumstances. It has a robust process that provides oversight and scrutiny of the use of force and submission of the appropriate forms when linked to arrest. Supervisors now review all forms in custody and make checks before closing a custody record. The force uses body-worn video footage to hold officers to account and as an investigation tool. However, the use of body-worn video cameras isn’t mandatory for officers when force is used. There is an online interactive use of force dashboard available to all staff, but the force doesn’t audit the use of the dashboard by frontline staff. It is, therefore, unable to assess its value.

Local IAGs externally review and discuss the use of force and body-worn video, which also feature quarterly on BCU performance information. The performance dashboard is also available to the public and is scrutinised at IAGs and the MOPAC challenge panels. The force assesses the data it collects on the use of force and uses it to make organisational improvements including the provision of new personal safety equipment.

Not all officers are up to date with their officer safety training. It is important that officers are current with their first aid training, as well as with the legislation and practice in the use of force and stop and search. We note that the force’s risk and assurance board is addressing this.

Using stop and search powers

The force has strict processes in place regarding the recording of stop and search. It focuses on dealing with crimes that cause Londoners the most concern. The commissioner provides clear direction on the use of stop and search, with the full support of the MOPAC. The force expects that at least 20 percent of all stop and searches should target weapons and 40 percent should target neighbourhood concerns. Following a stop and search, the force requires the relevant forms to be inputted into the system within 24 hours. Officers can do this via mobile devices. However, poor connectivity means the force has not yet achieved the full benefits of this. Officers regularly must use paper records and then re-input the data electronically when they return to the station. This is inefficient and causes unnecessary duplication. In response to the increase in knife crime and the increasing use of stop and search, the force has invested significantly in instruction and refresher training on the use of stop and search powers. However, the force needs clearer messaging on its increasing use of stop and search to ensure that officers understand the reasoning. Frontline staff in some BCUs are concerned that the force is beginning to set performance targets. This could ultimately affect the quality and legality of the searches they do.

There are inconsistencies in supervision of the stop and search record. As an example, force-wide supervisors dip-sampled 18,540 records in March 2019, amounting to 69 percent of records. However, we identified one BCU having 370 records unsupervised since November 2018. The force needs to maintain consistency in supervision to ensure that officers are using their powers legitimately.

The introduction of 22,000 body-worn video devices has given officers more confidence in conducting stop and search. Some 88 percent of the force’s stop and searches have corresponding body-worn video footage.

We reviewed a representative sample of 100 stop and search records to assess the reasonableness of the recorded grounds. We found that 88 percent or those records contained reasonable grounds. Our assessment is based on the grounds recorded by the searching officer and not the grounds that existed at the time of the search.

In our 2017 legitimacy report, we recommended 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 has complied with some of this recommendation. It has an online interactive dashboard containing a comprehensive set of data, which can be broken down in a variety of ways. It does identify the extent to which find rates differ between people from different ethnicities but it doesn’t do that across different types of searches (and it doesn’t separately identify find rates for drug possession and supply-type offences). It also isn’t clear that the force monitors enough data to identify the frequency of possession-only drug searches, or the extent to which these align with local or force-level priorities. The force’s website doesn’t mention what analysis it has carried out to understand and explain reasons for disparities or any subsequent action taken.

MOPAC’s stop and search community monitoring meeting provides effective external scrutiny and challenge on the use of stop and search. This is a large meeting with members of the public and representatives from each of the local policing areas. Panel members are willing to challenge the force during the meeting. MOPAC is seeking to make the panel more diverse to ensure that it is more representative of the communities the force serves. Similar external scrutiny groups exist at a local level, specifically within IAGs.

‘Walk in an officer’s shoes’ is an innovative educational exercise based on various scenarios. It asks its audience whether it would ignore the subject, stop and talk, or stop and search. The force has rolled this out in trials across the pan-London monitoring group, with a limited version to schools and the wider community. Not only does the exercise educate the public on their rights when being stopped, it shows the decision making undertaken by officers in considering the deployment of the tactic. Feedback has been so positive that the force’s stop and search lead is considering taking it to City Hall for further implementation. We consider this an example of good practice by the force.

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

Leaders act as role models for ethical behaviour in the Metropolitan Police Service. The force continues to promote the Code of Ethics. However, there is some confusion among its senior leaders as to what takes priority. They told us that the force focuses on its values and Met Direction, rather than the Code of Ethics. If senior leaders are uncertain, then it is unsurprising that the workforce is struggling to understand the force’s focus. The force’s policies and procedures comply with the Equality Duty and reflect the Code of Ethics.

The Metropolitan Police Service is part of a strategic partnership group with British Transport Police and City of London Police. The forces discuss ethical issues at their tri-force ‘London Police Challenge Forum’ meeting. Now in its third year, the panel meets quarterly to consider ‘ethical dilemmas’, which anyone from the three forces can submit. However, the force hasn’t been effective in telling frontline officers and staff about the ethics panel. Many staff don’t know how to raise ethical dilemmas, where to review the findings of previous ones raised, or what changes have been made as a direct result of ethics committee consultation. Some senior leaders also don’t know about the ethics panel. This is a problem, because the force may be missing opportunities to promote its ethical approach to decision making as a result.

The force considers ethics seriously in discussions involving significant operational decision making. Recently, this discussion has been about the decision to increase its use of stop and search. It has focused on ensuring that the tactic is used ethically and lawfully so that it doesn’t lose the confidence of the community. It has increased its internal and external scrutiny of stop and search encounters to improve safeguarding. The force reports that public complaints involving the use of stop and search powers have significantly reduced. It publishes complaints data monthly and this is available to the public as part of the force’s publication scheme through its directorate of professional standards (DPS). The force reports that stop and search generated just 4 percent of the total number of public complaints received in 2018/19 (320 of 8,919). This is a reduction of 35 percent on the previous year. This has helped leaders be confident that the public accept the use of stop and search to tackle violence and other neighbourhood concerns.

Vetting

The force doesn’t comply with all aspects of the vetting APP and Code of Practice. It has adopted several minor deviations from the national policy, which the force vetting board has approved. The board meets quarterly. It considers vetting refusals and monitors clearances. Figures from December 2018 show that the force had a significant backlog of approximately 16,000 staff who did not hold appropriate vetting. Vetting issues have directly affected the potential workforce pool for the force. The December 2018 intake of new recruits was 40 officers short, because the force couldn’t complete the vetting checks in time. It has since decided to prioritise police officer recruit vetting. This means other cases – including re-vetting of existing staff – have been delayed. As of April 2019, 37 percent of the overall workforce – 33 percent of officers, 72 percent of PCSOs and 45 percent of staff – don’t hold up-to-date security vetting. We understand the force response given the context, and recognise that it has taken steps to increase the size of the vetting team to cope with this increased demand. This will take some time to become fully effective.

The vetting unit cannot say how many people require enhanced vetting. It relies on each department to manage its own staff re-vetting. There is, therefore, no corporate governance and no one can provide details of the total number of staff who need re-vetting. In response to our previous recommendations to renew vetting status for all police officers and staff, the force has initiated a two-year completion plan and recruited more staff to deal with the backlogs. However, there remains a significant risk to the integrity of the force due to the number of people who still require vetting. During our inspection, the force was unable to provide any information regarding the vetting refusal rate for all candidates with protected characteristics. We have since found that the force is now able to run reports in respect of failures broken down by ethnicity and gender at all pre-employment checks including vetting. It is, therefore, able to actively report on and identify disproportionality through recruitment.

The force complies with its obligations to provide details to the College of Policing for any people who should be on the barred and advisory lists. These lists prevent people who have left the force while under investigation for gross misconduct, or who the force has dismissed, from re-joining or working in law enforcement. Similarly, the DPS checks the barred list when considering new joiners.

Standards of behaviour

The DPS sets the required standards of behaviour for the force. It has reorganised its command structure and designed an enhanced ‘professionalism portfolio’. Its prevention and reduction team is responsible for:

• organisational learning in relation to professional standards;
• creating bespoke training packages for new recruits;
• promotion courses;
• high-volume specialist operational command units; and
• those performing the role of appropriate authority.

While there are some performance challenges among the workforce, the focus is on individual and organisational learning rather than blame. The force encourages and supports staff to use the national decision model and make ethical decisions through its Leading for London training to all supervisors. It has created green and red card behaviours to help people understand the Code of Ethics, ethical behaviours and expected values. The aim is to develop a learning culture, with individuals promoting the five acceptable (green) behaviours that the force wants from its leaders. The force reinforces certain standards of behaviour through random substance misuse testing and with-cause alcohol testing.

The force shares lessons learned and reinforces the standards expected of all staff through various methods of communication. The DPS provides training inputs and has a dedicated intranet page. It also publishes notices on the intranet and external website showing outcomes of misconduct hearings and dismissals. It shares these with the wider organisation to promote learning and act as a preventative measure for others. The DPS is currently developing a process to make sure that the force consistently records learning from complaints and misconduct cases, because it recognises that information may be lost before it reaches them.

The workforce uses the force’s integrity policies involving gifts and hospitality, declarable associations and business interests. However, levels of knowledge vary. The policies aren’t easy to access because the force intranet requires searches to be word-specific. BCUs and departments play an important role in recording and approving these procedures. The DPS now oversees gifts and hospitality for staff at management board level. BCUs maintain their own registers of gifts and hospitalities, but there is no central register.

The DPS manages business interests and any associated risks, and returns rejected applications to local supervisors for information. However, the directorate doesn’t have enough staff to monitor compliance proactively. It records all declarable associations on its intelligence platform. The integrity assessment unit within the DPS manages all high-risk declarable associations. Business interests and declarable associations are included in the annual performance and development review (PDR) process.

Tackling corruption

In our 2016 legitimacy report, we said the force should produce a local counter-corruption strategic assessment and control strategy every year to identify the risks to its integrity. It has done this, and its professionalism board has approved both documents. The force now has an overall DPS strategic intelligence assessment (SIA), which looks at all professional standards issues rather than just corruption. It completed this in February 2017 and it has a review date of January 2018 (which is therefore outstanding). While the SIA includes corruption threats such as unauthorised disclosure of information, sexual misconduct and inappropriate associations, it doesn’t use the nationally recognised corruption categories. This makes it more difficult to compare findings with other forces.

It is unclear whether the force has completed any of the actions identified in its 2017 DPS strategic threat assessment. The lack of a meaningful strategic control strategy means that it is far more likely to be reactive than proactive in its approach to corruption.

The force doesn’t routinely use early interventions as part of its intelligence work to support those at risk of falling into corrupt practices. Some BCUs are starting to do this, but their focus has been on managing existing complaints. The force does conduct integrity interviews if it deems it necessary. It could improve on how it manages employee information. It currently considers indicators such as working hours, injuries at work and sickness rates to monitor wellbeing. The force could combine these with performance and conduct data such as complaints, grievances, business interests and any other intelligence known to the anti-corruption command. This would help it identify opportunities to intervene early with those at risk of corruption.

Within its anti-corruption command, the Metropolitan Police Service has the necessary staff (and access to appropriate tactical options) to address known corruption threats. It is entirely self-sufficient in assessing, developing and dealing with corruption-related intelligence. Its approach to identified high-level corruption is outstanding. However, the way the force identifies potential ‘internal insider threats’ is only reactive. When it revised its borough intelligence units in 2014, it lost its local proactive capability to manage officers’ activity. Dip-sampling individual use of ICT is no longer feasible and ICT monitoring systems are inadequate. Together with the high number of unvetted staff within the organisation, this leaves the force in a vulnerable position and is a significant organisational risk, because it cannot fully protect the information within its ICT systems.

The force only responds reactively to the abuse of position for a sexual purpose. Its approach to ICT monitoring may be hindering this. It hasn’t yet completed the necessary actions regarding our 2016 recommendation. However, it now treats this type of abuse as serious corruption and the cases we examined had been appropriately referred to the Independent Office for Police Conduct. The force must work better with external organisations to encourage reporting, seek intelligence and safeguard potential victims. The force provides full briefings to new recruits and employees to ensure that they are aware of this type of corruption. It has given its supervisors guidance on the warning signs to look for that might suggest an individual is abusing their position for a sexual purpose.

The force is good at building confidence with communities by publishing the outcomes of misconduct hearings.

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

The workforce is generally positive about how force leaders seek feedback and invite challenge from across the organisation. Leaders and staff can share feedback in different ways. These include the traditional annual staff surveys, a vibrant online force forum, senior leader blogs, as well as local BCU initiatives. Staff told us they don’t feel restricted in what they can say, they are confident about raising concerns and there is no climate of fear. The 2018 ‘Building better Met staff’ survey showed that 57 percent of staff feel it is safe to speak up and question the way things are done.

The commissioner holds monthly question-and-answer sessions where matters can be raised by anyone in the force, and staff value these sessions. The commissioner’s visibility at all levels of the organisation and her personal style mean that the workforce believes its commissioner is a leader who is true to her promises.

Frontline officers and staff representatives are involved in change networks. The force regularly briefs these networks on the transformation portfolio. It uses these networks to test concepts, support implementation and provide review and feedback. But while staff were told about significant organisational change because of the BCU mergers, many felt they were given wrong messages about new postings and shift patterns. This left them feeling that change was being imposed on them, with little consideration of their wellbeing.

The force makes improvements based on feedback from the workforce such as introducing spit guards and making changes to mobile devices. Staff told us they recognise change is slow in such a large organisation and that its size and complexity make influencing decisions difficult. They welcome the responses to their feedback. There has been a positive response to the commissioner’s one-off payment for recognition of the difficult times faced by officers over a two-year period. The officers appreciate the gesture and it has assisted in raising staff morale.

The force has invested significantly in improving its grievance processes. It has reviewed and recently revised its grievance procedure. It has also created a grievance management team, a helpline for staff to ask for advice and a new database to record grievances. Newly appointed grievance facilitators who are trained in mediation help local staff and officers. The latest grievance policy focuses on early resolution. It is perceived to be fair by the workforce and staff have confidence in using it. There is also a strategic board to examine lessons learned from complex matters, such as disproportionality and grievance procedures involving mental health, to identify future improvements. This is supported by a strong network of staff associations. This is positive.

One of the force’s strategic priorities is to make sure that its workforce is representative of its community. It is addressing under-representation with a programme of work supported by its people strategy and its diversity and inclusion-enabling strategy. In September 2016, the Equality and Human Rights Commission (EHRC) published the findings of their investigation into how the Metropolitan Police Service managed internal complaints of discrimination. While the EHRC found no evidence that the Metropolitan Police Service had committed unlawful acts, they made several recommendations. Since the EHRC investigation, the force has made many improvements. It has introduced new policies, created a discrimination investigation unit within the DPS and dedicated teams of specialists to respond to internal complaints of discrimination. It has launched a telephone helpline for staff and managers, trained locally based mediators and grievance resolution champions, and implemented a new performance scorecard to measure success. The force is investing in improvements to the way it records internal discrimination complaints so that it is better able to identify victimisation. It has also increased sanctions for those who are found to have victimised a colleague.

The force has a positive and strong approach to diversity, led by the commissioner who chairs a quarterly STRIDE (strategic and inclusion) board. This is a well-attended group with senior representation from MOPAC, community leaders and staff associations. They scrutinise workforce information and focus on areas such as recruitment, promotion and retention. A delivery board holds chief officers to account and there have been many initiatives to address disparity in the workforce and encourage people from under-represented and minority groups to consider a career in the organisation.

The force is more diverse and representative than ever before. Fourteen percent of officers are from BAME backgrounds. This is half of all BAME police officers nationwide. Twenty-three percent of police staff and 38 percent of PCSOs are BAME and 56 percent of volunteer police cadets come from BAME communities. Women account for 39.5 percent of officer numbers, 59 percent of police staff and 37.5 percent of PCSOs. This is positive, and the force has plans in place to increase this diversity further.

Supporting workforce wellbeing

Health and wellbeing provision for officers is improving. A consistent theme in force communications and strategy since 2011 has been to improve wellbeing for operational officers. Since the launch of its first health needs assessment in 2018, the force developed a new wellbeing strategy, which has been audited and measured against the Oscar Kilo Blue Light Wellbeing Framework. The force is implementing this strategy force-wide and has a dedicated wellbeing strategic lead. MOPAC and the force’s risk and assurance board audit the outcomes from the wellbeing strategy. These improvements are positive. We will assess the success of the wellbeing strategy over the next 12 months.

The force has significantly invested in the Leading for London programme to improve supervisors’ skills in managing staff welfare and accessing support services. Its 2018 health needs assessment identified that a lack of local HR provision left supervisors as the only wellbeing link for its officers. This meant early intervention opportunities were being missed and few preventative services for mental health issues were offered. However, the force has since invested in several other services to improve wellbeing and staff told us they can see some improvements already. In 2018, the following were implemented:

• increasing the network of blue light champions;
• recruit training about managing stress and mental health;
• a MIND contract for managing mental health and resilience for sergeant to chief superintendent; and
• a fatigue study commissioner with Surrey University.

At the end of 2018, the Metropolitan Police Service allocated further funding for new health and wellbeing services. These are being implemented during 2019 and
will include:

• a dedicated support line for supervisors to access advice from healthcare professionals; and
• a new employee assistance programme that includes a 24/7 helpline.

The force has experienced unprecedented demand for its services in recent years. Significant challenges were the two terrorist attacks at Westminster and London Bridge, the Grenfell fire, responding to serious violence in the capital and numerous public protests. This means that senior managers have had to choose between workforce wellbeing and public safety, using overtime and cancelled rest days to meet this demand. We recognise that public safety must come first in these circumstances. However, the effect of this demand on workforce wellbeing is significant and the force doesn’t fully comply with the working time directive or police regulations. The force scrutinises how it manages demand through its health, safety and wellbeing board, and holds frontline policing managers to account for their use of cancelled rest days and overtime. The force is aware of the risks of their approach to meeting unplanned demand, and senior officers and managers review the risks regularly.

Current occupational health service provision isn’t valued by the workforce generally. The requirement to complete questionnaires before speaking to someone is seen as impersonal and there were seen to be limitations on the number of counselling sessions available to staff. The force is reviewing its response and has committed extra funding so that staff have better access to counselling services.

The force monitors management information to understand wellbeing issues. It considers traditional proxy indicators such as working hours, injuries at work and sickness rates. These indicators could be better used to identify early intervention opportunities for those at risk of work-related stress or even corruption.

The force recognises that improving the wellbeing of its workforce isn’t a quick fix and the transformation portfolio is a long-term strategy. The force has only just completed its initial structural changes and must continue work to achieve the cultural changes it needs for success. Once the immediate effects of the change start to stabilise and the new wellbeing strategy is fully functional and embedded, the benefits the force anticipates should be realised.

Managing performance and development of officers and staff

The force manages staff performance and requires supervisors to complete PDRs every year for officers and staff members. These reviews need more structure to properly track someone’s performance and support their future development. The force has made changes to its PDR process and is enhancing the skills of its supervisors through its Leading for London programme and the leadership performance portfolio for its managers. The force needs to make sure that its workforce clearly understands, values and uses its approach to the appraisal process.

Poor performance isn’t consistently identified and addressed. Because of the significant challenges involved in dealing effectively with poor performance, it is often ignored by staff. Managing unsatisfactory performance has also been adversely affected by the centralisation of HR resources and support. Staff are confident about using management action, but the force needs to make sure that there is a place to store the results to prevent them being lost.

The force restructure has reduced the number and availability of supervisors. This results in line managers having less time with their staff, little time to consider managing talent, and missing early warning signs and opportunities to intervene early to improve staff performance or consider wellbeing properly. Supervisors are deferring performance reviews because they must prioritise according to risk and manage their staffing responsibilities against increasingly competing operational demands.

The force uses the national Competency and Values Framework and role profiles to recruit and develop officers. The people strategy has set out plans to build specialist and lateral career pathways for officers including creating advanced practitioner roles. There will be three pathways: response, community and investigation. Recruits will be allocated to career paths at the point of entry by matching applicants’ skills, potential and aspirations to availability and capability requirements. There is direct entry into two entry points: inspector (manager) and superintendent (senior manager) ranks, enabling more diverse and specialised leaders. This is positive, and we will check progress of these plans over the next year. The force’s graduate offer, in partnership with Police Now, is the talent pathway from constable to chief officer and is well established.

However, police staff told us there is little opportunity for career progression or lateral movement into other roles and they feel undervalued. The force needs to address
this disparity.

The force has considered potential barriers that prevent the workforce from applying for promotion. The senior leadership team reports that it is confident that selection is based on competence and welcomes the involvement in the processes of members of staff associations who frequently act as observers. Uniformed officers feel that the promotion process is generally fair and open with no explicit barriers.

The force recognises that people from under-represented groups often experience more barriers. In response, it has developed an online career development service to support BAME and female officers. This and other schemes are monitored and reviewed at strategic meetings to consider applications to join the schemes and identify any practice that could be considered unfair. This is very positive.