Complaints, investigations and misconduct in policing - recommendations: progress report - December 2022
Fourth thematic progress report following publication of the independent review of complaints, investigations and misconduct in policing in Scotland, setting out implementation progress with details of the status and lead responsibility for each recommendation.
Theme 5: Equality, Diversity and Inclusion
The recommendations under this theme can be implemented without the need to make legislation. Many of the recommendations have now been signed off as completed as can be seen from the tracker and updates are also provided below on the ongoing work in relation to those that are still in progress.
Diversity Data
Police Scotland and SPA continue to take steps to expand collection and publication of diversity data in relation to Recommendation 5 and Recommendation 60 which remain ongoing. In addition to the Data Owner Group set up by Police Scotland, a Data Working Group has now been formed to take forward actions, including the review of data requirements and systems to ensure they are fit for purpose.
The health check of the Professional Standards Department IT system, Centurion, has now been completed and an upgrade to the system is currently underway. A short life working group is also being established to progress a second upgrade in 2023 which will further enhance Centurion’s capability in identifying trends and analysis to drive improvement across the organisation.
Improvements to the IT system will increase the organisation’s understanding of complaints across communities. Capturing of diversity and demographical data will allow analysis and a proactive approach in the overall Policing Together initiative and the Preventions and Professionalism Programme. As part of these improvements, the appointment of a new Data Assurance Co‑ordinator is also in progress whose remit will include the capture, analysis and reporting of diversity data.
All of the work undertaken in relation to Recommendation 5 above supports progress of Recommendations 19 and 60 ensuring data capture is relevant across the organisation. Further collaboration is ongoing with SPA, COPFS and PIRC in order to align the data that each organisation captures and ensure that information collection and analysis is meaningful and informative.
Unconscious bias training
Unconscious Bias training is now part of Police Scotland’s online training module, ensuring that all Police Scotland officers and staff receive training on unconscious bias, equality legislation and diversity. Following feedback from staff associations, unconscious bias training has also been included within Operational Safety Training. In addition, unconscious bias training now also forms part of Chair and Assessor training for conduct meetings and hearings which links with Recommendation 16 below. Recommendation 66 has, therefore, now been fully implemented.
Police Scotland has instigated a review of processes in respect of panel availability and selection to ensure diverse panels for disciplinary hearings can be put in place as far as reasonably possible. As mentioned above, a programme of training, including unconscious bias, has been implemented with a view to having all chief superintendents, superintendents and chief inspectors trained in chairing and assessing panels. A diversity monitoring form has also been produced to record decision making in respect of panel members. Recommendation 16 is, therefore, now fully implemented.
Workforce impacts and diversity
Since the last reporting period, Police Scotland has expanded its interpretation of Recommendation 17 to improve awareness, understanding and impact across the organisation. The Policing Together Initiative (with new strategy and implementation plan referred to in Recommendation 18 below) brings together communications, learning and improvement and training mechanisms and provides a focal point and platform for equality and inclusion imperatives. Examples evidenced are the establishment of the Wellbeing Hub, the Equality, Diversity, Inclusion & Human Rights (EDI & HR) Independent Review Group and Sex, Equality and Tackling Misogyny Working Group. Investigative Wellbeing guidance is now published. In September 2022, Police Scotland published the Policing Together: Equality, Diversity and Inclusion Strategy and Implementation plan. Its vision is to ensure Police Scotland is welcoming, inclusive and representative of the communities it serves and that our people demonstrate our values, know that they belong and can fully be themselves. The four overarching outcomes encompass being an anti-racist organisation, EDI and Human Rights being central to everything it does, creating an inclusive culture and that its employees represent and reflects the communities it serves. Recommendation 17 is, therefore, fully implemented.
Independent review
As mentioned above, an Independent Review Group (IRG) has been established to provide critical oversight of equality matters, guide strategic direction and scrutinise activity. The IRG was originally due to report in September 2022 but, due to changes in membership and an extended discovery phase in its workplan, it will now provide a full report to the SPA by the end of 2023. The refreshed group has undertaken an assessment of the timescale required to deliver on the key outcomes and its aim is to ensure that the workstreams established to implement the review conclude their work by autumn 2023. The group also welcomed the proposal within the new Policing Together: Equality, Diversity and Inclusion Strategy to have a standing IRG going forward. Recommendation 18 is, therefore, still in progress.
Further updates
Details on progress against all recommendations under this theme are set out in the tables below:
Progress Overview for the period 1 April to 30 September 2022
Recommendations
5 Police Scotland and SPA to consider expanding collection and publication of diversity data.
Lead
Police Scotland & SPA
Current Position
In progress
The health check of the Professional Standards Department IT system, Centurion, has been has been completed and an upgrade to the system is now being progressed.
A short life working group is in the process of being established to progress a further upgrade in 2023. Appointment of a new Data Assurance Co‑ordinator is also in progress whose remit will include the capture, analysis and reporting of diversity data
Work within SPA has included the addition of equality and diversity monitoring to online complaints forms to enable greater understanding of diversity of complainants. This also links to recommendation 60.
Recommendations
16 More diverse panels for disciplinary hearings.
Lead
Police Scotland
Current Position
Completed
Police Scotland has instigated a review of processes in respect of panel availability and selection and a programme of training including unconscious bias has been implemented with all chief superintendents, superintendents and chief inspectors trained in chairing and assessing panels. A diversity monitoring form will record decision making in respect of panel members and unconscious bias training now also forms part of Chair and Assessor training for conduct meetings and hearings.
Recommendations
17 Appropriate support for anyone who is subject to internal or external discrimination.
Lead
Police Scotland
Current Position
Completed
The Policing Together Initiative provides a focal point and platform for equality and inclusion imperatives along with the establishment of the Wellbeing Hub, the Equality, Diversity, Inclusion & Human Rights (EDI & HR) Independent Review Group and Sex, Equality and Tackling Misogyny Working Group. In addition, Investigative Wellbeing guidance has been published.
Recommendations
18 Independent review of equality matters within Police Scotland.
Lead
Police Scotland
Current Position
In progress
As reported previously, an Equality, Diversity, Inclusion & Human Rights (EDI & HR) Independent Reference Group (IRG) has been established to provide critical oversight, challenge, review and assurance. The IRG reported to the SPA Board in February and in September 2021, and September 2022.
The final report from the Group is now expected to be submitted to the SPA Board by the end of 2023.
Progress Overview for the period 1 October 2021 to 31 March 2022
Recommendations
19 Police Scotland should develop its diversity data collection and analysis to inform a proper understanding of issues related to discrimination.
Lead
Police Scotland
Current Position
In progress
Work being undertaken to progress Recommendation 5 also supports progress of this recommendation. In addition, discrimination training is also being actively progressed, linking to Recommendation 17 and to the work of EDI groups to ensure data capture is relevant across the organisation.
Recommendations
60 Police Scotland to analyse complaints data to gain a better understanding of different groups and communities' experience of the police.
Lead
Police Scotland
Current Position
In progress
Work being undertaken to progress Recommendation 5 also supports progress of this recommendation. Capturing of diversity and demographical data will allow analysis and a proactive approach in the overall Policing Together initiative and the Preventions and Professionalism Programme.
Recommendations
66 Recommendations
All Police Scotland officers and staff to receive training on unconscious bias, equality legislation and diversity with refresher courses.
Lead
Police Scotland
Current Position
Completed
Unconscious Bias training is now part of the organisation’s online training module. Following feedback from staff associations, unconscious bias training has also been included within Operational Safety Training. In addition, unconscious bias training now also forms part of Chair and Assessor training for conduct meetings and hearings which links with Recommendation 16.
The following is a list of recommendations within this theme which have already been signed off by the Ministerial Group as completed:
Signed off by Ministerial Group as completed and reported in the 23 June 2022 Thematic Progress Report
Recommendation
15 Police Scotland to use staff surveys, meetings and focus groups to understand the experience and impacts of discrimination, prejudice and unconscious bias on all minority groups in the workforce.
Lead: Police Scotland
Recommendation
50 Third‑party reporting centres for hate crime, including those representing minority groups, to offer support to complainers.
Lead: Police Scotland
Signed off by Ministerial Group as completed and reported in the 16 December 2021 Thematic Progress Report
Recommendation
44 PIRC should ensure that discrimination issues are considered as an integral part of their work.
Lead: PIRC
Signed off by Ministerial Group as completed and reported in the 24 June 2021 Thematic Progress Report
Recommendation
PR12 Police Scotland to reflect on the culture of the new service, address any long-standing issues and consider how everyone in the organisation can help to change that culture for the better.
Lead: Police Scotland
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