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South Wales PEEL 2018

Legitimacy

How legitimately does the force treat the public and its workforce?

Last updated 27/09/2019
Good

South Wales Police treats both the public and its workforce fairly.

The force recognises the importance of working closely with communities. Officers and staff understand the importance of treating people with fairness and respect. However, frontline officers and staff varied in their knowledge of unconscious bias.

The force needs to improve the extent to which it understands the use of force. It would benefit from analysing its data more effectively, to increase its understanding of how officers and staff use force. It also needs to give all officers feedback about their use of force.

The force is good at using stop and search powers. The force trains its workforce on the ethical use of stop and search tactics. Officers understand the need to apply these powers lawfully and ethically.

The force is good at developing and maintaining an ethical culture and has clear processes for promoting ethical decision making.

The force is good at identifying and managing corruption risks and is developing an overarching control strategy in line with the authorised professional practice for counter-corruption.

The force is good at treating its workforce fairly, and workforce wellbeing is a clear priority for its leaders.

The force needs to improve the management, performance and development of its officers and staff.

Questions for Legitimacy

1

To what extent does the force treat all of the people it serves with fairness and respect?

Good

Areas for improvement

  • The force should ensure that appropriate members of its workforce receive training in, and understand, unconscious bias.
  • The force should ensure that it monitors a comprehensive set of data to enhance its understanding of fair and effective use of force.

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 South Wales Police are committed to working with the people they serve, and to treating them with fairness and respect. The force’s culture recognises the importance of working closely with communities. The chief constable’s delivery plan defines how the force identifies and responds to people’s views of policing services.

Policies, procedures and training all reinforce the importance of fair decision-making and treatment with reference to the Code of Ethics. The deputy chief constable chairs the internal confidence and legitimacy group (CALG). CALG meets quarterly to scrutinise information on levels of public confidence and force legitimacy. This is measured through data such as complaints, victim satisfaction surveys, use of force and stop and search information.

The force actively works with its communities in a range of ways, including regular neighbourhood policing meetings and other public events. It complements these methods with increasing use of social media, mainly Twitter and Facebook, to give information about local policing activities. The force’s approach is supported by a network of community cohesion groups (CCGs) that offer useful feedback about the force’s approach to local concerns. The force also uses environmental visual audits to help reduce anti-social behaviour. In the AWSLCP, officers give a series of organised lessons to raise awareness among children of the dangers of cyber bullying and internet usage, as well as educating about drug and alcohol awareness, and safe relationships.

The workforce shows an understanding of the importance of treating people with fairness and respect. Operational officers and staff had received some training on unconscious bias. While we found examples that indicated an understanding of the importance of making fair and impartial decisions, frontline officers and staff varied in their knowledge of unconscious bias. This was an area for improvement in 2016 which has yet to be fully addressed. The force has identified this as an area to which it must give greater attention. Further training for the workforce was planned for March 2019.

Using force

South Wales Police needs to improve the extent to which it understands the use of force.

The force gives training and guidance on the use of force. Those who use force understand how to use it fairly. Officers and staff described the importance of effective communication in de-escalating incidents involving conflict. Officers and staff also make good use of a mobile application that enables accurate information to be collected about the use of force in a timely way. This information complies with NPCC recording standards, and the force submits relevant data in line with national requirements. 

CALG monitors use of force information as part of its scrutiny of strategic assessment reports. The reports contain a range of data on the use of force and stop and search. However, the force would gain greater benefit by identifying trends in the data it collects, to increase its understanding of how its officers and staff use force. This data should include information about:

  • the officers and teams who use force most frequently;
  • the extent to which different tactics and techniques prove most successful; and
  • identifying disproportionality in respect of the ethnicity of those on whom different types of force are used.

An internal working group on use of force gives a further level of quality assurance.

We identified examples of the force changing the training syllabus because of such scrutiny and review. Such changes include greater use of tactical communication to de-escalate conflict.

The force expects supervisors to review how their officers and staff use force. It has effective systems in place to check that the use of force is recorded. These include daily reviews. However, the approach to supervision is inconsistent. Some officers do not receive feedback about their use of force.

South Wales Police has two external groups that consider the use of force and stop and search as part of their agendas. They are:

  • The police accountability and legitimacy group (PALG). The PCC established the PALG. In addition to the force, membership includes staff from the office of the PCC, and external organisations such as the Welsh Government, Disability Wales, Gypsies and Travellers Wales, the Older People’s Commissioner for Wales and other third sector organisations. The group enables external organisations and independent advisers to act as critical friends to South Wales Police. The South Wales PCC’s chief executive chairs its quarterly meetings.
  • CCGs in each BCU area. As well as the force, membership includes a good cross-section of the community. These meetings are independently chaired.

The PALG receives the same strategic assessment report as the CALG meeting. This report includes use of force and stop and search data. The PCC team has carried out a stop and search audit using body-worn video and presented areas for improvement to the PALG. The same has not been done for use of force. Minutes of the PALG meeting are not published.

CCGs receive data on use of force and stop and search for consideration. There is some evidence of the groups questioning this data, but there is limited evidence of any in-depth scrutiny of it. The force has carried out a review of the CCGs and agreed there needs to be more consistency across the force, with standardised terms of reference and agendas.

The force could derive more benefit from these external scrutiny groups if it invited greater degrees of feedback and challenge from members on the use of force and stop and search powers. This could, in turn, allow it to improve understanding, and show the extent to which it uses force in a legitimate way.

Using stop and search powers

South Wales Police is good at using stop and search powers. The force trains its workforce on the ethical use of stop and search tactics. Officers have a good level of understanding of their obligation to apply these powers lawfully and ethically. Supervisors are expected to scrutinise all stop and search records submitted by officers on their teams, but these checks are inconsistent.

We reviewed a representative sample of 139 stop and search records, to assess the reasonableness of the recorded grounds. We found that 71 percent of 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.

While the CALG monitors stop and search data, the equality, diversity and human rights board receives comprehensive data on stop and search under the following headings:

  • Trend analysis in comparison to previous years, geography and officer type.
  • Analysis by ethnicity with comparison to community demographics and outcomes.
  • Analysis of disproportionality of stop and searches by ethnicity / location.
  • Analysis of data by age.
  • Analysis of purpose of search by geography, ethnicity and outcomes.
  • Analysis of relationship between search reason compared to outcome.
  • Data of stop and searches recorded on body-worn video.
  • Stop and searches vs the number of crimes committed across geographical areas.

The force has identified disproportionality in the number of stop and searches conducted of black, Asian and minority ethnic (BAME) people. It completed a review of BAME stop and searches and found no evidence of stop and searches being carried out in an unfair or discriminatory manner. We said that this was an area for improvement in 2017.

In our 2017 legitimacy report (PDF document), 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.

South Wales Police has complied with some of this recommendation. The force is monitoring find rates. However, it is not monitoring the extent to which find rates differ between people from different ethnicities and across different types of searches. Additionally, it isn’t clear that it 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. Furthermore, the force has published neither the analysis it carried out to understand and explain reasons for disparities, nor the detail of any subsequent action taken.

The force’s arrangements for external scrutiny of stop and search are described above.

Summary for question 1
2

How well does the force ensure that its workforce behaves ethically and lawfully?

Good

Areas for improvement

  • The force should monitor its vetting decisions to identify disparities and disproportionality (e.g. BAME groups), and act to reduce them where appropriate.
  • The force should ensure it has both a counter-corruption strategic threat assessment and a control strategy to enable it to understand and manage the risks that corruption poses to the organisation.
  • The force should ensure that its counter-corruption unit (CCU) can fully monitor all its computer systems, including mobile data, to proactively identify data breaches, protect the force’s data and identify computer misuse.

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

South Wales Police is good at developing and maintaining an ethical culture. The chief constable chairs a quarterly senior leaders forum, in which ethics and standards inputs regularly feature. The force has clear processes for promoting ethical decision making. These include regular ‘Lessons Learned’ bulletins, the production of material for discussion at team briefings, chief constable events, and various training courses. All force policies include equality impact assessments. These are readily accessible via the force intranet which is called BOB.

New staff are issued with an ethical passport as part of their ‘Standards and Values’ training. Available on BOB, this pocket-sized aide memoir gives staff important information about abuse of position, data misuse and integrity policies.

BOB features a dedicated page for the professional standards department (PSD), which gives the workforce a wide range of information and guidance on key issues. Examples include senior officer blogs about ethics, expected standards of behaviour on debt management, and warnings on the inappropriate disclosure of information to third parties.

The force has a joint independent ethics committee. It has both internal and external members, including professors (one of whom chairs the committee) and a doctor and solicitor. Internal representation is broad, including operational policing, specialist crime, professional standards, legal services, BCUs, corporate services and the Commissioner’s team. Individuals also attend to present ethical dilemmas to the committee. The force is an active member of both regional and national ethics committees.

BOB also features a dedicated page for ethics. It includes a route by which the workforce can refer matters for discussion at the ethics committee. It also has minutes of ethics committee meetings and summaries of ethical dilemmas that have been debated. This level of access helps the workforce to understand and learn. The force also circulates minutes of these meetings and shares them with the public, through the force’s external website.

The workforce has a good understanding of ethics. People who we spoke to referred to a series of 60-second videos on BOB. Supervisors have used these during briefings, to encourage discussion and help staff to make ethical decisions. Archived dilemmas, and appropriate responses, are recorded on the ethics intranet page as a point of reference. This reference material further helps the workforce to understand and learn.

The force has achieved our 2016 recommendation on vetting. This stipulated that, within two years, all members of the workforce should have received at least the lowest level of vetting clearance for their roles. At the time of our visit to the vetting unit, only five staff had outstanding vetting, none of whom were active in the workforce. The force is compliant with the national vetting code of practice and authorised professional practice. However, it does not routinely monitor vetting decisions to identify potential disparities affecting under-represented groups such as BAME people. The force has acted to reduce disparities in under-represented groups where appropriate. But, currently, this is a reactive approach in response to a problem or complaint, rather than through routine monitoring.

The force complies with its obligations to give details to the College of Policing for the barred and advisory lists. These lists prevent people who have left the service under investigation, or who have been dismissed, from re-joining or working in law enforcement.

The force publicises the outcomes of misconduct investigations to help the workforce understand expected, and unacceptable, standards of behaviour. The force shares high-profile cases with the public through proactive media campaigns to raise levels of awareness, trust and confidence.

Tackling corruption

South Wales Police is good at identifying and managing corruption risks. It has a local strategic counter-corruption threat assessment. This assessment lacks some detail on areas such as potential corrupters, higher-risk roles, locations of concern and meaningful focus on employee types. The force was due to review its strategic assessment in April 2019. Currently, it is using a series of action plans instead of a control strategy. It would benefit from having an overarching control strategy in line with the authorised professional practice for counter-corruption. There are plans to develop a control strategy when the strategic assessment is refreshed.

The force uses employee information to identify those at risk of corruption. This information helps the force to put effective support and interventions in place through the early intervention programme. One such example involved a member of staff who was experiencing financial difficulties. This person was given advice to help them, which reduced the potential risks.

The force uses early interventions appropriately, and all criminal allegations were investigated fully. Of the 60 items of intelligence we reviewed, there were no cases where early interventions had been used inappropriately. But we did find three cases where early intervention could have assisted an individual to avoid corruption risks.

The force is taking positive steps to increase the capacity and capability of its counter-corruption unit (CCU) and has recently recruited a new systems auditor. This has already had a positive effect by increasing audit functions.

At the time of our inspection, the force was not able to monitor all its IT systems. However, it is examining ways in which this could be done. Such a facility would mean it would be better equipped to make sure that all use of its data is lawful and appropriate. Further assessment may be needed by the force to make sure it maintains enough proactive capacity.

Effective links exist with those who support vulnerable victims. Members of the PSD have visited all existing support agencies, including those who support sex workers, independent sexual violence advocates and independent domestic violence advocates. This engagement has resulted in disclosures which have led directly to investigations and dismissals of officers and staff who have abused their position for a sexual purpose.

Effective processes exist through which officers and staff can report wrongdoing confidentially. These include the provision of an anonymous phone line to the PSD and CCU which can be used to report concerns. The force promotes the reporting line in several ways, including through the professional standards intranet page, the monthly bulletin and ‘Standards and Values’ training events. Officers and staff have a good understanding of how to access the facility and are generally confident that they can do so anonymously.

The force views abuse of position for a sexual purpose as serious corruption, and the behaviour features as an organisational risk within the CCU strategic threat assessment. Of the 60 cases we reviewed, seven required a referral to the Independent Office for Police Conduct (IOPC). The force appropriately referred six of these cases. The PSD routinely discusses cases for potential referral to the IOPC as part of its daily management meeting. In 2017, the force submitted a plan to address our 2016 national recommendation on abuse of position for a sexual purpose, but this has not yet been fully implemented.

The PSD has given guidance and training to the workforce, designed to prevent the development of inappropriate relationships with victims of crime. Generally, the workforce had a good understanding of the warning signs of such behaviour.

The workforce also has a good understanding of integrity policies. This includes business interests and notifiable associations, together with the processes that need to be followed for these to be assessed, authorised or refused. Staff generally understand the need to declare gifts and hospitality, but there were variations in knowledge of the processes.

In our 2017 legitimacy inspection, we said that South Wales Police had five areas for improvement to address in responding to public complaints. We carried out a specific visit to the force in December 2018 to assess the progress the force had made. We are pleased to confirm that the force has successfully addressed all five areas. In January 2019, we published further details of this work on our website.

Summary for question 2
3

To what extent does the force treat its workforce with fairness and respect?

Good

Areas for improvement

  • The force should ensure that its grievance procedures are conducted in a timely way and are perceived by the workforce to be fair.
  • The force should ensure it has effective systems, processes and guidance in place to manage individual performance in a way that is valued by
    the workforce.

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 force seeks to ensure fairness at work, but it needs to address the timeliness of its grievance processes. The force seeks workforce feedback through a variety of ways. These include a staff survey, which was last conducted in 2017 and will be revisited in 2019, and the chief constable’s ‘100 things in 100 days’ initiative (which involved the chief constable inviting feedback during his first 100 days in post).

The chief constable holds roadshows to tell officers and staff about what is happening in the force. Staff who attend the roadshows can post questions anonymously for the chief constable to respond to. The chief constable gives feedback on any changes that have been made as a result of workforce suggestions. (For example, changes made from ‘100 things in 100 days’ include the introduction of free flu jabs, and an independent trust, blame, confidence and legitimacy project to better understand organisational culture.)

Chief officers give prompt answers to a question and answer section on BOB. The force has produced a specific strategy which outlines how it will engage with the workforce. Strands include supportive leadership and employee voice.

The workforce told inspectors that chief officers are open to feedback and will try to address problems. The force’s CALG also considers workforce feedback to identify, understand, prioritise and resolve workforce concerns.

We carried out a review of grievance cases as part of our pre-inspection activity. The force is not dealing with grievances in a prompt and efficient manner, nor is it acting in accordance with its own guidelines. We also found that the workforce lacked confidence in the grievance procedure. The force is now trialling a new way of managing the procedure to address the issues we raised. But it needs to make sure that it prioritises the resolution of workforce concerns at the earliest opportunity, in order to address alleged unfairness and improve productivity across the whole organisation.

The equality and human rights board oversees several important areas of performance, including workforce representation. The force is working to address fairness and respect, for example, by coaching female candidates for promotion, and raising awareness of the menopause, so the workforce has a better understanding.

Effective processes exist to identify workforce disparities. A specific team has been established to address under-representation. The force has carried out a BAME impact review of external selection processes and numbers of BAME applicants have increased. The South Wales Black Police Association has held a number of community events, including visiting mosques for special constable recruitment days and visiting schools to talk to students. The force takes part in Pride Cymru and uses this as another way of attracting new recruits.

The force monitors grievance, complaint and misconduct information to identify problems relating to fairness and respect.

Supporting workforce wellbeing

The force is good at supporting workforce wellbeing and this is a clear priority for leaders. The health and wellbeing of staff is a priority for both the chief constable and the PCC. The force has a health and wellbeing delivery plan which has been shaped by workforce feedback. This plan outlines the commitment to improving the wellbeing of all staff. The force has appointed ‘blue light’ mental health champions who follow the programme and are supported by line managers. Mind, the mental health charity, has trained those champions. Supervisors see wellbeing as part of their role. They consider and promote the benefits of workforce wellbeing, and support officers and staff when concerns are identified.

The force has implemented an absence wellbeing project to improve the health, wellbeing and attendance of officers and staff. This project addresses sickness absence, as well as monitoring and evaluating the effectiveness of wellbeing initiatives. It also improves communication for managers, providing them with better access to information and guidance. A strategic group, chaired by the deputy chief constable, oversees the project to identify absence trends and review wellbeing provision.

The force has also implemented an absence wellbeing project to improve the health, wellbeing and attendance of officers and staff who have problems with long-term sickness absence.

Examples of initiatives include the recruitment of a mental health nurse, a BOB health and wellbeing portal (which is a point of reference for sickness and wellbeing matters), and health and wellbeing roadshows. Health and wellbeing champions are also in place across the force. There has been an improvement in attendance rates.

The occupational health unit is staffed well enough to meet the force’s needs. But some of the workforce indicated that there can be delays in getting appointments. This impacts on the unit’s ability to give early support and prevent escalation. However, the force has recently increased staffing in the unit.

Staff in posts that are identified as high risk receive annual psychological and wellbeing screening. Supervisors can refer staff for additional support following difficult incidents or traumatic cases. Anyone who is the subject of misconduct investigations or grievance processes is offered a colleague supporter.

Managing performance and development of officers and staff

The force is aware that it needs to improve the management, performance and development of its officers and staff. The importance of supportive leadership is part of the chief constable’s delivery plan for 2018/21. The People and Organisational Development Strategy (2018–21) is key to the successful delivery of this improvement. It will assist to both better define future skills and identify how it will recruit and develop the workforce.

Supervisors oversee and review the work that staff are doing and have informal one-to-one conversations. But formal performance meetings are inconsistent across the force. Some staff have monthly meetings with their manager; for others, such meetings take place every six months, or less frequently. The workforce does not feel that the current performance development and review process is effective. The force recognises that performance management processes are inconsistent, and a new approach is now in development.

Appropriate policies exist for the management of poor performance and, in the main, the force follows them through.

There are some examples of leadership programmes, such as Policing Futures and Springboard. But the force is aware that it needs to do more to make sure that all members of the workforce have access to leadership opportunities. It is therefore developing a new leadership development programme as part of its People and Organisational Development Strategy. This programme will be available to all officers and staff. It seeks to identify and develop staff with leadership potential at all levels in the organisation. This is included as an area for improvement in the section ‘Planning for the future’.

The force uses the competency and values framework to recruit, develop and progress staff through promotion processes. It publishes promotion schedules well in advance, so that staff have sufficient time to prepare. The force has tried to remove barriers to promotion, including adopting a positive approach to postings on promotion, so that staff do not always have to travel significant distances to work. While many members of the workforce indicated that they considered promotion processes were fair and based on competence, this view was not consistent across the force.

Summary for question 3