North Wales PEEL 2018
How legitimately does the force treat the public and its workforce?
North Wales Police needs to improve some elements of how it works to ensure that the public is treated fairly. It is good at ensuring the ethical and lawful behaviour of its workforce, and at treating its workforce fairly.
Senior officers demonstrate a clear desire to lead a force that treats all communities fairly and with respect. This would be enhanced by more structured conversations with the public, listening and responding to their views and reporting back on the effect of changes made when concerns are raised. This happens in some parts of the force but needs to be more widespread and consistent.
North Wales Police needs to have a full picture of how its officers are using force in the course of their duties. Officers are given appropriate training, but there are problems with how the use of force is recorded and checked. Scrutiny processes for both the use of force and of stop and search powers need to be reviewed and improved.
Ethical behaviour is valued in the force. The workforce understands the standards expected of them as the leadership works to move away from past perceptions of a blame culture. The risk of corruption is managed effectively, but could be better still if more proactive work was undertaken in this area. The force has no backlog of vetting checks, but it should monitor the effect of vetting decisions across the full diversity of the workforce.
The force supports and engages well with its own workforce. Conversations between senior leaders and the workforce are regular and productive. The wellbeing of officers and staff is a priority and an area where the force continues to make good progress. There is more work to do before the diversity of the workforce reflects the community it serves, but the necessary commitment to make this happen is in place. The force needs to better understand any disproportionality in how members of the workforce are treated. It also needs to improve how it monitors the performance of individual officers and staff and has advanced plans in place to achieve this.
To what extent does the force treat all of the people it serves with fairness and respect?
Areas for improvement
- The force should review its approach to community engagement, ensuring engagement influences local priorities and communities are informed about the action taken in response to the concerns raised.
- The force should ensure that, in relation to its use of force:
- all relevant officers and staff are recording when force is used and there is effective supervisory oversight;
- it monitors a comprehensive set of data so that effective internal scrutiny and learning can take place; and
- effective external scrutiny takes place.
- The force should ensure that, in relation to stop and search:
- it monitors a comprehensive set of data to enhance its understanding of fair and effective use of the power; and
- regular external scrutiny takes place.
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
North Wales Police is committed to treating the communities it serves with fairness and respect. Its leaders are clear about the importance of maintaining community support and engaging positively with local people. The police and crime plan priorities were agreed in consultation with the public. There is a strong focus on the Welsh language and culture in internal and external communications. Training for officers and staff includes the need to use police powers fairly and to consider the effect of the decisions they make on individuals and the wider public. Two recent public surveys show good levels of support for the force, with high levels of public confidence and a view that people are treated fairly by officers and staff.
Officers and staff show a good level of understanding of unconscious bias. A combination of formal learning sessions, team discussions and annual operational safety training has increased understanding of the importance of treating the public fairly. Some officers and staff were able to explain how a greater awareness of unconscious bias, which can negatively affect fair treatment, has made them think and act differently when doing their jobs. This can be seen, for example, through showing greater understanding of the addiction problems experienced by some repeat offenders or by making a conscious effort to learn more about cultural sensitivities in a minority community. The force has made good progress in addressing workforce understanding of unconscious bias, which was an area for improvement in our last inspection.
Officers and staff understand the need for effective community engagement, however the force would benefit from a more co-ordinated approach. Engagement plans in each of the ten policing districts are tailored to local community needs. Much of the current engagement work is undertaken by neighbourhood teams, often in person or through social media. Police officers and PCSOs are active every day in local communities but the approach is too often unstructured and the effectiveness of local activity is unclear. We found little evidence of a connection between the views of communities, local policing priorities and reductions in crime and disorder. This is an area for improvement.
Much of the social media contact with local people appears one-way. There is no consistent feedback telling communities what police work is achieving in their area. The results were better where it was clear what was needed, such as in the work of the diversity team and its engagement with minority communities. The force is reshaping its neighbourhood policing teams, increasing the emphasis it places on problem solving, and expanding its work with local partners through the VARM project. A better approach, introduced at the same time, to community engagement will enhance this work.
The Citizens in Policing project shows the positive difference that a structured approach can make in local communities. A small group of police staff co-ordinates the work of trained volunteers, local cadet schemes and special constabulary officers. Volunteers lead on initiatives such as community speed watch and the bike safe scheme. Cadet groups focus on involving less advantaged young people in policing in different parts of the force area. The special constabulary is growing. Some special constables receive specialist training, allowing them to support the force where extra resources are needed, such as in rural roads policing, trouble spotting at football matches and sex offender management. The breadth of projects, and the way in which they are concentrated to achieve the biggest positive effect, is encouraging.
North Wales Police needs to improve how it records and reviews the use of force by its officers and staff. The force provides appropriate training and guidance to its officers and staff about how to use force fairly. Annual training includes the practical use of tactics and how to apply them using the national decision-making model and force policy. Officers we spoke to understood how to use force correctly, their obligations about when to do so and how to record their actions.
The force complies with the national recording requirement in terms of the categories of force used. However, levels of recording are substantially lower than in other forces, suggesting a large degree of under-recording. Officers and staff admitted to us that a record is not always made when force is used. The reasons for this include the time it takes to complete the form, lack of effective supervision and insufficient audit processes. Supervisors do not review submitted forms for quality and accuracy. The force does not have an accurate picture of how its officers and staff use force in the course of their duties.
Because reporting is inconsistent, the force is not able to effectively monitor and scrutinise the use of force. The conflict management board reviews use of force information and data every three months to identify trends and address problems. The data sets it uses are incomplete and not broad enough to be effective. For example, it does not have good information about the officers and teams who use force most frequently or which tactics are most effective. Data on the use of body-worn video, complaints information and public feedback is not consistent enough to help inform the meeting. Internal scrutiny processes are not effective.
There are no external scrutiny meetings where the public can examine use of force data or hold North Wales Police to account. Neither members of local communities nor interested parties from outside the force attend the conflict management board. Use of force information is published on the force website, but the under-recording problem means that the data does not represent the full picture. There is no meaningful external scrutiny.
Our inspection found no evidence that officers and staff were using force inappropriately. The clear gaps in recording and scrutiny seem to be due mainly to failure to follow recording requirements and lack of supervision. Use of force training is adequate, well managed and incorporates some learning from operational incidents. Attendance rates at initial training courses and annual refresher training are high, with 85 percent of officers correctly certified (legitimate exceptions were in place for most of the remainder).
Senior leaders acknowledge the need to improve how the force records, understands and scrutinises its use of force. The work to address the gaps highlighted here began during our inspection. The force knows the problems raised must be tackled to improve performance in this area and maintain public confidence. We will continue to monitor the speed and quality of changes made.
Using stop and search powers
Procedures for stop and search are generally more established than those for use of force, although improvement is required in some areas. Officers are given stop and search training that includes the need for fair treatment. We found that officers understand how to conduct stop and search procedures correctly, but some are not confident in using the power for fear of complaints. Supervisors monitor search forms and provide guidance to officers in how to perform stop and search procedures correctly. Some supervisors proactively review body-worn video of searches conducted by their officers, but the frequency or consistency of this practice is unclear.
The quality of the grounds recorded by officers to justify conducting a search needs to be better. We reviewed a representative sample of 254 completed search records to assess the reasonableness of the recorded grounds. Of these, 79 percent had reasonable grounds recorded. Our assessment is based on the grounds recorded by the searching officer and not the grounds that existed at the time of the search.
The reasons for the relatively high proportion of searches that were identified as not having reasonable grounds are unclear. One factor is likely to be the paper form used to record searches. There is limited space to record reasonable grounds, meaning that minimal information is sometimes included. There can also be a delay between the search being completed and information from the paper form being inputted on to a searchable database. The force acknowledges the limitations of a lack of electronic recording facilities. Alternatives to the existing paper-based system are being explored.
The scrutiny of stop and search is generally good, but with some exceptions. In our 2017 legitimacy report, we recommended that all forces should:
- monitor and analyse comprehensive stop and search data to understand reasons for disparities;
- take action on those; and
- publish the analysis and the action by July 2018.
We found that the force has complied with some of this recommendation. But it doesn’t identify the extent to which find rates – the rate at which officers find what they were searching for – differ between people from different ethnicities and across different types of searches (including separate identification of find rates for drug possession and supply-type offences). It is also not clear that the force monitors enough data to identify the prevalence of possession-only drug searches or the extent to which these align with local or force-level priorities.
We reviewed the force’s website. A report setting out data on disproportionality was published, but it was hard to find and didn’t include analysis to understand and explain reasons for disparities or any subsequent action taken.
The police and public encounters board (PPEB) meets every six months to review a wide set of stop and search data. It doubles as an internal and external scrutiny group. The PPEB is chaired by a senior officer and police attendees include the professional standards department, diversity team, training staff and the Black and Asian Police Association. External attendees are from independent advisory groups, academia, the Office of the Police and Crime Commissioner, the Crown Prosecution Service, other partner agencies and college students. In our last inspection we identified that young people needed to be part of the scrutiny process and the force has responded to this feedback.
In May 2019, we attended a meeting of the PPEB. It was constructive, with community members confident to challenge the force. In particular, there were discussions about the number of searches of 16 to 24-year-olds and the high rate of searches that ended with no further action. Public scrutiny of stop and search also takes place when members of the diversity team provide stop and search information at various public meetings, such as independent advisory groups. At the body-worn video external scrutiny group, where stop and search footage and records are reviewed, a question about the handling of search forms led the force lead officer for stop and search to review existing procedures. An independent chair for the stop and search section of PPEB meetings would enhance the quality of public scrutiny.
We reviewed how the force conducts internal and external scrutiny of stop and search. It is satisfactory in many respects, but scrutiny should happen more frequently. More in-depth work in places and greater emphasis on independent scrutiny would add value for the public. The force is clear in its commitment to conducting stop and search fairly, but improvements are needed in both internal review and public scrutiny. We recommend that the force reviews its stop and search scrutiny processes to ensure that they provide appropriate confidence for both the force and the community.Summary for question 1
How well does the force ensure that its workforce behaves ethically and lawfully?
Areas for improvement
- The force should monitor its vetting decisions to identify disparities and disproportionality for people with protected characteristics and act to reduce them where appropriate.
- The force should ensure it has enough capability and capacity to counter corruption effectively and proactively.
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
Officers and staff have a good understanding of the need for ethical conduct. The College of Policing Code of Ethics is incorporated into training, policy development and operational activity at all levels throughout the force. The chief constable and other senior leaders provide clear and consistent messages about the importance of acting ethically and to high standards. There is a stated ambition to move the force away from existing perceptions of a blame culture. The intention is to create a working environment to learn from things that go wrong, sharing positively with others to prevent mistakes being repeated. This will take time but the required leadership is in place to make this happen.
A new ethics committee is considering operational and organisational questions referred to it by the workforce. At the first meeting in April 2019 subjects for discussion included how best to deal with money handed in to the force and the appropriate use of police vehicles. Membership is broad and evenly split between members of the force and community representatives. This committee is still becoming established but will in time provide an increasingly valuable ethical reference point.
Officers and staff throughout the force demonstrate good standards of conduct. They are willing to challenge and report inappropriate behaviour. Some sergeants review body-worn video footage of operational incidents to assess with the officers involved how well they handled situations. The public can have confidence in the ethical approach taken by North Wales Police.
Vetting of the workforce to make sure they are suitably checked for the posts they hold is generally good. National guidance is followed and the force has a very low backlog for renewal vetting (required every ten years for each member of the workforce).
The planning and resources applied to this work by the force should be noted. They have a vetting backlog, as at 1 April 2019, of less than 1 percent.
Separately, the force has recently increased the number of designated (higher risk) posts such as cyber-crime and domestic abuse investigators. These designated posts need a different level of vetting, meaning that some of the post holders now need to be re-vetted. The force estimates that this self-generated increase will be cleared within six months. This is a reasonable timeframe in the circumstances.
An area where the force needs to improve is monitoring for disparities in the vetting applications from people with protected characteristics. Presently, the force does not conduct disparity monitoring, but it should begin doing so to understand whether there are any variations from the general population. Understanding whether diverse communities are adversely affected by the vetting process is an important indicator of the force’s public legitimacy. This is an area for improvement.
The professional standards department promotes the importance of demonstrating high standards of behaviour. Using regular internal communications about ‘lessons learned’ and ‘top tips’, case studies of both good and poor conduct are shared widely. Many officers and staff have viewed the series of in-house 60-second videos that provide guidance on important subjects such as alcohol and substance misuse and the acceptance of gifts and hospitality. All new members of the workforce receive a detailed briefing about the standards of behaviour expected of them. The outcomes of misconduct hearings are published both internally and to the public, along with registers of business interests and gifts and hospitality. The workforce know both what is expected from them and the consequences of failing to maintain high standards of behaviour and conduct.
North Wales Police uses an up-to-date threat assessment and control strategy to counter the corruption risks it faces. The threat assessment is prepared using intelligence gathered locally and nationally about the types of corruption that the workforce may be vulnerable to. It is an evolving document that is reviewed when new information is received, including in response to our feedback. The threat assessment informs the control strategy which in turn identifies the priorities for action. These include abuse of authority for a sexual purpose, inappropriate personal associations and computer misuse. The control measures for each priority are outlined under the headings of prevention, intelligence and enforcement. Both documents meet the needs of the force and are reviewed regularly to ensure the full range of corruption threats are being assessed and addressed.
The force generally manages internal risk well. It deals with corruption-related intelligence consistently and effectively in most cases. A single comprehensive policy provides clarity on subjects including gifts and hospitality, business interests and notifiable associations. Officers and staff are clear about their obligations. They understand both the processes themselves and the need to comply with them. A programme of annual workforce integrity checks supports this work, alongside a people intelligence meeting that reviews information and trends to spot risks. The force recognises that these measures are important. It is developing them to make sure it identifies potential corruption threats correctly and that interventions are pursued when necessary.
The force has enough people and resources managing its routine anti-corruption work, but its capacity for proactive action is limited. To manage this, new working practices have been introduced. A clear tasking process allocates resources to higher risk work. Members of the anti-corruption unit participate in meetings where organised crime is discussed to identify and flag possible corruption risks. The force is able to fully review and monitor how its computer systems are used. This makes it easier to identify officers and staff who are at risk of corruption. The force can, and does, call on neighbouring forces for additional specialist support when extra resources are needed to help with corruption investigations. Much of the force’s anti-corruption work is reactive and intelligence-led, with proactive targeting in place where the risk is greatest. More could be done with extra people, but the force is using its limited resources effectively to manage the potential corruption risks it faces.
North Wales Police rightly identifies the abuse of position by officers and staff for a sexual purpose as serious corruption. The force recognises the potential that this type of abuse has to harm victims and undermine public trust and confidence. A focused campaign, Operation Shield, has achieved high levels of awareness within the workforce. Officers and staff have the confidence to report any internal wrongdoing directly to their supervisors or by using the dedicated reporting line, Safecall. The force has also engaged extensively with other agencies and charities that support vulnerable victims, both to highlight awareness and encourage reporting of any possible corrupt activity. Significant cases leading to misconduct hearings are publicised both internally and externally. The force makes appropriate referrals about abuse of authority to the Independent Office for Police Conduct and is compliant with the recommendation on this subject that we made in our 2016 legitimacy report.Summary for question 2
To what extent does the force treat its workforce with fairness and respect?
Areas for improvement
- 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 treatment of officers and staff with protected characteristics, who are subjected to complaint and misconduct investigations.
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
North Wales Police continues to make good progress in the way leaders seek feedback and challenge from the workforce. Meaningful workforce conversations are a priority. Officers and staff are encouraged to give their views to senior leaders in several different ways. Levels of engagement are high, with online initiatives seen by the workforce as good ways to make suggestions and get involved. These include the Get It Sorted scheme, the Fy Llais/My Voice discussion site and the chief constable’s blog. These are complemented by personal contact at events such as local area consultation groups, senior leader engagement events and regular personal visits by chief officers to different departments and police stations. Workforce surveys are also used, both at departmental and force level.
Feedback from officers and staff has improved working practices. Examples include:
- a better and more consistent response when a member of the workforce is injured on duty;
- more scrutiny and consultation on the effects of changes to shift patterns on officers and staff;
- replacing worn-out furniture and equipment to improve the working environment; and
- agreed changes and an action plan to introduce changes to the force control centre following a workforce survey.
Senior leaders are promoting a growing culture of openness and approachability, with two-way dialogue evident at multiple levels. The force engages positively and productively with the people who work for it.
The force generally handles workforce concerns well. A more supportive and less bureaucratic approach is being developed. The workforce sees the formal grievance procedure used to resolve disputes as fair, but there is a feeling that it sometimes takes too long to reach a conclusion. We conducted an independent review of ten grievance files and found they had been generally managed well and in accordance with policy. A review and triage stage has been introduced to increase the number of early resolutions of grievances. More trained officers are now available to offer welfare support to those involved in grievance and misconduct processes. The force intends that these changes will resolve concerns more quickly and appropriately. However, the force does not undertake any analysis to monitor for potential disparities against different groups with protected characteristics in its complaints and misconduct processes and this is an area for improvement.
The force needs to better use the information it has to understand and respond to workforce trends and themes. It collects a wide range of people data covering areas such as attendance and grievances, but does not use it consistently to identify problems and potential solutions. For example, without sufficient understanding of the reasons behind complaints from officers and staff about how they are treated, it is harder to resolve any underlying problems. In recognition of this gap, an automated suite of data sets is being developed. Managers at different levels will have prompt access to relevant information. This will help them to deal with problems more quickly and appropriately, meaning that performance and service levels are likely to improve.
North Wales Police recognises its workforce is not representative of the communities it serves and is working to make changes. While approximately 2.5 percent of the resident population is from a BAME background, as at 31 March 2019 only 0.9 percent of officers were BAME. Under-representation of BAME and female officers is more acute in the senior ranks. It is a strategic objective of the force to become more representative in every respect, including gender, BAME and other protected characteristics. The workforce representation group and positive action officer are working to a force plan that has public backing from senior leaders. A recent conference organised by the BAME staff network and attended by senior officers and managers saw several high-profile speakers highlight the benefits of wider workforce diversity. Some successes have been achieved, with 15 percent of officers on the specialist firearms unit now being female and the recent appointment of a female assistant chief constable. The force can only have confidence that its efforts are effective when there are clear and definite results.
Supporting workforce wellbeing
North Wales Police continues to develop and improve its management of workforce wellbeing. The health of the workforce is a priority for chief officers and is considered in force plans and policies. We found that officers and staff recognise and value the importance the force attaches to having provision for good wellbeing. The analysis of force data (such as sickness and assault information), self-assessment and workforce surveys is improving the force wellbeing response, alongside dedicated investment in both people and facilities. The wellbeing approach has four themes – healthy mind, body, work-life and finances – in acknowledgement of the main wellbeing problems that officers and staff are most likely to face. There are regular health checks for those in more stressful roles. Occupational health service provision generally meets workforce requirements, with officers and staff able to access help when they need it within reasonable timescales. The force has a coherent approach to managing the wellbeing of its employees.
The force is moving towards a more preventative approach to wellbeing. Supervisors and leaders receive guidance to identify and address problems such as stress and mental health concerns in their teams. Workforce health screening is being broadened to cover more roles, such as call handlers and despatchers in the force control centre. Force messaging systems are proactively used to alert officers and staff to the help available from internal and external support networks. We found that most officers and staff have regular one-to-one discussions with their supervisors that include welfare matters, or participate in more formal debriefing after attending distressing incidents. The long-term sickness rate as at 31 March 2019 was slightly below the level seen across all forces in England and Wales and general sickness management is good.
However, wellbeing problems persist in different parts of the force. Some investigators carry high and stressful workloads. Rises in seasonal demand can increase the pressure on officers and staff working in popular tourist areas. The force is committed to maintaining a focus on wellbeing so that its workforce remains healthy and work to high standards. It is too early to assess the effectiveness of this more preventative approach, but the intent is clear and the overall direction of travel is positive.
Managing performance and development of officers and staff
The current performance development review process is used inconsistently because it is seen as complex and bureaucratic. These limited levels of engagement mean that the force cannot be confident it is tackling poor performance effectively. There are advanced plans to introduce a new process that has been created in consultation with the workforce. The new system is computer based and designed to be easier to use for both supervisors and individuals. By linking continuous professional development to wellbeing and promotion opportunities, the new process is intended to become a mainstream activity. Training will be given to support the introduction of the new process which was due to be launched in May 2019, shortly after our inspection. We will monitor its implementation to assess whether workforce performance is managed more effectively and the needs of individuals and the force are supported.
In contrast, the force has well-established talent management schemes that support officers and staff who have been identified as potential future leaders. In addition to participating in national programmes for police officers, such as Fast Track and Direct Entry to inspector rank, there are internal opportunities open to the whole workforce.
The talent support scheme recruited its first cohort of 21 members (12 officers and nine staff) in 2018. It offers training, coaching and mentoring support. Participants undertake projects designed to improve both force performance and their own understanding of how the organisation works. A second cohort will be appointed in 2019. There are also development programmes for senior leaders and apprentices. There is a layered approach to talent management that combines investment by the force with an expectation that individuals take responsibility for their own professional development. The workforce is generally positive about the opportunities available, although levels of awareness vary. Force performance should continue to improve as the reach of these programmes expands.
North Wales Police is benefitting from a more co-ordinated and strategic approach to the different aspects of workforce development. Its own assessment of strengths and weaknesses in its performance is realistic and is complemented by planning to identify future workforce needs. A recent review of the police promotion process highlighted that improvements are needed, especially in the method by which candidates are assessed and interviewed. While the current process meets national guidance and the workforce believes it to be fair, the addition of a formal interview is a positive development. Extra personal development support for female candidates to address the gender imbalance at higher ranks is also welcomed. Senior leaders have responded well to internal criticism of this positive action, explaining the benefits of increased diversity at all levels. The public will be better served by a police service that develops talent effectively, is diverse and is representative of local communities.Summary for question 3