Policing - complaints handling, investigations and misconduct issues: independent review

Chapter Twenty‑two - Training, continuing professional development and learning culture

22.1 In the preliminary report, I welcomed the additional training and programmes that had been recently implemented, especially the training that had been undertaken across and between organisations. It is vital that people have better knowledge and empathy towards the challenges of others' roles. Improved communication along with joint training will assist in this.

22.2 Much of this report is concerned with the response to complaints but many complaints can be prevented by good psychology, empathetic engagement, a trauma‑informed approach and using techniques that de-escalate aggression and create a safer environment for everyone.

Scottish Police Authority training

22.3 The Scottish Police Authority (SPA) is charged with holding Police Scotland to account for the efficacy and effectiveness of its complaints handling practices. It is clearly vital therefore that those carrying out that responsibility for SPA are knowledgeable in appropriate complaint handling standards and responses. Both staff and members of the Complaints and Conduct Committee should receive appropriate training to allow them to carry out their functions. Best practice in public‑sector complaint handling is promoted by the Scottish Public Services Ombudsman (SPSO) and her organisation. The SPA complaints staff should be familiar with model complaint handling procedures published by SPSO and keep up to speed with developments so that they can brief SPA members on best practice and developments in this field.

22.4 There are instances where audits of organisations have previously identified gaps in their training needs. For example, Police Investigations and Review Commissioner's (PIRC's) 2017 complaints audit^[210] of the Scottish Police Authority (SPA) concluded that no staff had undertaken formal complaint handling training since taking up post, and that there was no formal or structured annual training, or continuing professional development programme made available to staff. PIRC therefore recommended more training for staff in the SPA's Complaints and Conduct Team and this has been progressed.

22.5 SPA initially relied on on-the-job training for their complaints handling staff. However, after a PIRC audit highlighted that the staff did not have any official accredited training, the SPA now offer their staff the opportunity to attend Queen Margaret University's course in 'Complaints and Ombuds Techniques'. This course looks at how organisations can respond effectively to complaints and how they can learn from complaints while reflecting on consumer behaviour and its consequences for dispute resolution. It also covers the approaches to dispute resolution used by ombudsman schemes, independent complaints handlers and adjudicators when the complaints at organisation level have failed to resolve the issue in dispute.

Preliminary report recommendation: Further training for complaints and conduct officers in SPA should be consolidated and broadened in order to ensure the right skillset and up‑to‑date knowledge of complaint handling best practice in other sectors.

Police Scotland training

22.6 This section of the report deals with three elements of Police Scotland's training programme and training needs: training for PSD officers, training for 101 call‑handlers and training for all officer ranks but with a focus on frontline constables. The first point of contact for members of the public wishing to make a complaint will often be through Police Scotland's service centres who deal with people who telephone Police Scotland and will usually pass the call to the PSD Complaints Assessment and Resolution Unit (CARU). In each of these areas the skills, empathy and knowledge of officers and staff can and do help to resolve issues for members of the public and prevent disproportionate escalation through the complaints process.

22.7 Within Police Scotland, complaints handling is dealt with by adding training on professional standards into different developmental areas across the organisation. These inputs cover the ranks from constable to chief superintendent.

22.8 As part of the national training programme, Police Scotland probationers have a 45‑minute overview into the role of the Professional Standards Department (PSD), with a focus on the statutory Standards of Professional Behaviour. This training reinforces the expectations placed upon officers in terms of their conduct and also what constitutes misconduct, both on and off duty and is focused on ensuring that new recruits have an understanding of the role and remit of PSD from the outset of their foundation training.

22.9 As a follow-up, the second probationer input from PSD builds upon the input provided in the first week of foundation training and includes reflection on the themes touched upon in the previous input, again focusing on the Standards of Professional Behaviour. Additionally, there is more information on the role of PSD in respect of criminal and non-criminal complaints and conduct matters, both on and off duty.

22.10 Police Scotland also provide sergeant and first-line manager training. This training is aimed at both police officers and members of police staff and seeks to identify best practice when dealing with complaints about the police. Emphasis is placed upon the importance of adhering to Police Scotland's Standards of Professional Behaviour. The training describes the 'Early Intervention Programme' in relation to complaints about the police. It also sets out to ensure attendees recognise the role and remit of PIRC within the framework of complaints handling and investigations.

22.11 Since the publication of the preliminary report a PSD training portfolio review was undertaken in September 2019. It concluded that a revision of the content of both the probationers course and first-line managers course was a priority. As a result, the training for probationers in week one/year one of their course has been rewritten; instead of three separate inputs on different days, students will be presented with training over five classroom periods on the same day.

22.12 The training portfolio review also examined a variety of frontline manager course training packages in use. The training review team are reviewing and rewriting this material into a single course training package which, when complete, will be used across different Police Scotland training venues.

22.13 Training is also provided to special constables, with the input similar to the training provided to probationers in weeks one and eleven. It also covers the availability of confidential reporting of concerns through the Integrity Matters process. Integrity Matters is Police Scotland's internal confidential reporting mechanism through which matters may be raised anonymously.

22.14 Custody officer training is aimed at sergeants and constables who may be required to take up duties within the custody suites as part of their daily role and seeks to raise an awareness of the type of complaints received in the custody environment, along with the most appropriate procedure to follow in handling such complaints. The course not only sets out the complaint handling procedures and the role the PIRC plays, but also outlines preventative measures to mitigate or clarify complaints, such as the efficient use of CCTV and ensuring that written procedures are followed and processes are carried out correctly. As I say elsewhere in this report, the introduction of body-worn video cameras would allow complaints to be dealt with in an accelerated manner.

22.15 PSD provide a short input to the Advanced Investigator Programme to ensure those dealing with more complex investigations have a sound knowledge of the complaints process. The input seeks to provide an overview of the complaints process, provide an overview of complaint investigations (criminal and non-criminal), raise awareness of the role of the PIRC in the complaints process and discuss the roles of PSD, the PIRC and police investigators.

22.16 Transferee training for officers joining Police Scotland from other constabularies covers the difference between the roles of PSD and the Anti‑Corruption Unit in relation to conduct on and off duty in Scotland. It also highlights a number of areas of vulnerability of which officers need to be aware, defines the main areas of regulation and explains Integrity Matters, the confidential reporting mechanism.

22.17 In the context of misconduct, the Association of Scottish Police Superintendents (ASPS) expressed the view in their evidence that those in charge of conduct procedures, especially hearings, lacked specific training, and stressed that it is important that those fulfilling independent roles are properly trained and resourced. Following the introduction of the Police Service of Scotland (Conduct) Regulations 2014^[211], the process for misconduct hearings changed so that such hearings, which by definition deal with allegations of gross misconduct, require to have a chairperson and an assessor, roles carried out by a chief superintendent and a superintendent respectively.

22.18 In my preliminary report I recommended that in future the chairs of all gross misconduct hearings should be independent legally qualified persons supported by a policing member and a lay person. The policing member role could still be carried out by a superintendent, depending on the rank of the subject officer.

22.19 PSD delivered chair and assessor training to approximately 40 chief inspectors and superintendents in June 2019. The training provided an overview of the requirements of chairperson and assessor and further provided detail on the legislation relevant to the process. Police Scotland also recognise that training is only one aspect of being a chairperson, and that experience is also necessary.

22.20 During 2020 PSD has delivered training to chief superintendents locally on a one‑to‑one basis. Police Scotland report that this individual approach has worked well and has resulted in more participation than there would have been for a defined course run by PSD.

22.21 Police Scotland are planning chair and assessor training and PSD intend to visit divisions on a rotational basis to deliver a package to the senior management team which will support them in dealing effectively with minor conduct‑related matters through to chairing misconduct proceedings. This will cover the Regulations and guidance and incorporate a continuing professional development (CPD) element based on:

• legal challenge
• the Scottish Police Federation role
• learning from internal appeals
• learning from Police Appeals Tribunals
• senior counsel and other legal advice

22.22 Service advisers (C3 call‑handlers in service centres^[212]) receive training on complaints about the police which provides direction on the definition of a complaint, on what type of complaint is being made and how to identify the appropriate method of capturing a complaint.

Preliminary report recommendation: Police Scotland should review the service‑wide capability of its line managers to line manage effectively, including the adequacy of training and mechanisms of support for line managers.

Training on diversity and unconscious bias

22.23 Police Scotland advised the Review that all probationary officers receive diversity training at the Scottish Police College on their initial training course. Following completion of this course, probationary officers return to their allocated local policing divisions where, prior to local deployment, they receive an input from representatives from a number of police diversity staff associations and other organisations.

22.24 The Review was told in a focus group that unless officers specialise in areas such as hate crime, diversity training is a "once in a career" session delivered for probationers. The diversity training that is provided by Police Scotland was described to the Review as superficial, because it does not factor in unconscious bias, and because training which used to be delivered over the course of a week has been condensed.

22.25 I recommend that all police officers and staff should receive training on unconscious bias, equality legislation and diversity and that this should be updated throughout their career, with the opportunity for refresher courses at regular intervals. The Equality Act 2010^[213] provides that it is against the law to discriminate against someone because of a protected characteristic. The nine protected characteristics prescribed in the Act are: age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex; and sexual orientation.

22.26 The values of equality and diversity and a zero‑tolerance approach to discrimination, bullying and cynicism should be reinforced at all levels and exemplified by the service's leaders.

Mental health training

22.27 In evidence to my 2017 report on Deaths and Serious Injuries in Police Custody in England and Wales^[214], Michael Brown, the national mental health co‑ordinator for the College of Policing, agreed that there was an emerging sense that the police need to see themselves as mental health professionals, but that training in England and Wales remained 'patchy'. In the same report, I noted the Police Federation evidence that: "Dealing with those in our communities who are suffering with mental ill‑health problems is considered as core police business. Police officers and staff working in public-facing roles, in particular those working with detained persons, require improved, accredited and consistent training and development in the identification and management of mental health risks; that this should be a mandatory requirement for all officers."

22.28 In discussion with a focus group of Police Scotland sergeants for this Review, it became apparent that a significant amount of officers' time was taken up dealing with mental health crises faced by members of the public. The police are increasingly being called out to deal with mental health problems, missing persons and high‑risk vulnerable individuals. A significant amount of time is spent on mental health issues because the police service is "the service that can't say 'No'". In recognition of these ubiquitous mental health issues, all officers need to have the appropriate training to deal with the complex and challenging demands they create. I comment elsewhere in this report on the tendency for people to be forced into the criminal justice system because of the lack of capacity in the health service to handle the demand.

22.29 The prevalence and prominence of mental health issues in society should be reflected in the police service's ability to deal with them and therefore I recommend that police officers should receive regular training inputs on how to deal effectively with individuals who display mental ill-health symptoms or related behaviours.

De-escalation training

22.30 Police officers in the course of their duties will encounter individuals who display florid, disturbed or aggressive behaviours. This training is not only confined to people in mental health crisis but also others without mental issues health may present in a very unpredictable way due to intoxication, drugs, alcohol or be armed or suicidal. Mental health is discussed in the Custody chapter at page 372.

22.31 Given the inherent risks to both officers and those detained in the event of the use of physical force, the ability to de-escalate circumstances which may lead to a violent encounter are paramount in the skillset of the individual officer. Compliance with an officer's instruction can be achieved through a hierarchy of approaches. Persuasion, calming techniques and negotiation, known collectively as de‑escalation, may have a more effective impact in securing such compliance than directive commands that escalate tension and the probability of resistance.

22.32 In the Accessibility and communication chapter at page 282 I say more about the benefits of being trauma‑informed when interacting with troubled or vulnerable individuals and I welcome Police Scotland's intention to develop trauma‑informed approaches to engagement.

22.33 A senior Police Scotland officer provided evidence to the Review that, as part of officer safety training, officers were being encouraged to be aware that there are different levels of response that can be deployed to avoid escalation of an incident into one requiring the use of force. Training in this area is critical not least because there have been a number of instances where members of PIRC have asserted in their reports that an incident went beyond 'excessive force' and should correctly have been classed as an assault. I comment on this issue in the Scottish Parliament Justice Committee chapter at page 64 but in the context of officer safety and public safety, Police Scotland are training officers to understand what constitutes necessary and proportionate force in any given circumstance and to feel confident about using appropriate force in an incident when these criteria are met.

22.34 Part of Police Scotland's officer safety training prepares officers for hostile situations in which their communications skills are tested in order to prevent situations from escalating further. The training course covers de-escalation strategies, components of communication, tactical communication, factors affecting communication, how to recognise occasions when tactical communications may fail, compliance and signals of submission, and the effects on the body of adrenaline, endorphins, dopamine, noradrenaline and cortisol. This training is critical to frontline policing and is to be commended for its coverage of theory, practice and insight into human behaviour.

22.35 In my 2017 report^[215] on Deaths and Serious Incidents in Custody in England and Wales I said, "In addition to law, training and guidance on how officers should approach encounters that may lead to detention, the community relies on the professionalism, wisdom and courage of police officers to approach incidents which may result in harm to the officers or others". Knowing how to talk to someone who is under extreme stress, agitated, intoxicated or potentially violent, knowing how to de‑escalate a situation and knowing how to restrain people safely is essential for the officer and their safety, but the application of that knowledge is also vitally important to the safety any such individual whom they do encounter.

22.36 We ask a lot of our police officers in the 21^st century and expect that they will be equipped with the skills to reduce, so far as possible, the threat of harm and danger to themselves. These various circumstances may require high levels of physical competence but, most importantly, emotional intelligence and empathy to diminish the need for physical restraint with all of its attendant risks.

Complaints and conduct training

22.37 PSD in partnership with the PIRC designed and delivered a new one-day module for inspectors and chief inspectors on the Established Leaders course at the Scottish Police College at Tulliallan. The aim of the one-day module is to improve the awareness of the complaints process and to generate consistency across Police Scotland. The learning outcomes for this course are:

• to understand the role and remit of the PIRC in relation to complaints about the police
• to identify the six stages of the complaints handling process^[216]
• to demonstrate the complaints handling process
• to examine the areas commonly missed from the six‑stage form

22.38 On request, PSD has also provided an overview in the form of a presentation on complaints handling best practice to a range of police specialist departments.

22.39 The Scottish Police College hosted a continuing professional development day at Tulliallan in February 2020. Representatives from both Police Scotland and PIRC spoke to approximately 150 attendees, most of whom were inspectors and above. Also in attendance were a number of staff from PIRC and members of the SPA. The event was positively received with PSD receiving a number of requests to host future, similar events. PSD plan to hold such events on a six‑monthly basis when the COVID‑19 pandemic allows.

22.40 In November 2019, Police Scotland's Risk, Assurance and Inspection team undertook an internal audit of Professional Standards Department's six‑stage complaints process. This is dealt with in more depth in the Professional Standards Department section at page 81. The audit found that there was a lack of training available to officers and staff within PSD and those at division or department dealing with complaints. At the time of the audit it was reported that there was no defined official training provided to officers or staff when joining PSD on how to deal with complaints. Most of their training comprised completing desk training with an established team member. This supported earlier evidence from members of PSD to this Review. The audit also found that members of PSD and officers/staff at division/department do not currently receive any training on systems, letter‑writing or complaints handling.

22.41 The Police Scotland action as a result of this audit has been positive. They have used the audit to instigate a continuous improvement exercise with actions being taken to ensure all the recommendations and improvement actions are progressed. PSD advised that since the audit they had introduced induction training for new members of PSD and created a training module on the six‑stage complaints process aimed at all managers in divisions.

22.42 Training in the field of complaints and conduct within Police Scotland is an important introduction to the subject, a significant element in continuing professional development and a tool to drive continuous improvement across the organisation and the service it delivers to the public.

22.43 The role of the Professional Standards Department should develop and is developing beyond involvement in situations that go wrong or involve poor behaviours, but they should continue to enhance their role in identifying training needs and in preventative work.

22.44 From the evidence provided by Police Scotland it is clear that they have taken steps to increase the breadth and depth of the training that they provide in this area to probationers, line managers and practitioners. That response to my preliminary report and their own internal audit are to be commended. It is critical that those involved in complaints handling should be immersed in best practice, fully understand and apply both the letter and the spirit of the statutory guidance, be empathetic with members of the public, manage their expectations and appreciate the power of apology.

22.45 The wide‑ranging nature of the police officer's role requires a vast array of skills. In this context officers should ideally receive training in officer safety, dealing with complaints, managing people, mediation, de-escalation techniques and plain English but achieving all of that is inevitably a challenge for the organisation.

22.46 PIRC have recognised that there should be more thematic analysis of complaints to help to develop officer training. They should therefore liaise with PSD and with the Scottish Police College over how that learning can be converted into practical training for police officers.

22.47 HMICS are currently undertaking a thematic inspection of training and development within Police Scotland^[217], and will consider a comparative overview of training and development approaches in other sectors and jurisdictions to identify any good practice. Enhancing the training and development function will be a key element in improving the service to the public and changing the culture of the organisation.

22.48 I recommend that Police Scotland should have a PSD training officer to maintain the momentum in training and development arising from the audit, and to liaise with the SPSO, the PIRC and the SPA on joint training, best practice and other relevant development opportunities.

Preliminary report recommendation: Police Scotland should consider the importance of providing all officers involved in frontline resolution with training in mediation and customer handling.

PIRC training

22.49 In year one of traineeship, trainee investigators at the PIRC attend the University of the West of Scotland (UWS) in Paisley on day release from September to December to study Scots Criminal Law. Thereafter they receive three bespoke tutorials to supplement the relevant facts of law specific to their PIRC role. The learning points covered in this course are:

• The fundamentals of establishing criminal liability ('actus reus', 'mens rea' and strict liability)
• Important doctrines concerning liability (e.g. causation, art and part and attempts) and defences
• The range of specific crimes, but focusing on the common law crimes against the person, against property, against public order and against justice.

22.50 To supplement this learning, I recommend that the PIRC should deploy the in‑house expertise that the organisation has to deliver internal training for investigators in the law of evidence.

22.51 In their second year of traineeship, trainee investigators attend the UWS Paisley campus on day release from September to December to study a science and crime module. The learning points covered are:

• Knowledge of the work of forensic scientists from the crime scene to the laboratory and their role as expert witnesses
• How forensic science has developed in parallel with other scientific advances
• Forensic science and the media
• Understanding of the application of science to a selection of forensic topics: explosives; fingerprints; drugs; alcohol; and crime scene investigation
• Basic practical exercises relating to forensic science including laboratory examinations of unknown materials, developing fingerprints and crime scene examination

22.52 In each case these modules are attended one day a week for twelve weeks. Investigators also participate in delivering training at UWS; they talk through the role of the PIRC and how investigations are conducted.

22.53 PIRC has recruited a training co-ordinator to help people focus on learning and identify their training needs, and has reported a growing appetite for professional development. The co-ordinator is also developing a number of online resources for the organisation. In terms of recruitment strategy, PIRC are now increasingly focusing on the detail of the different skillsets that they are looking for when filling vacancies.

22.54 PIRC reported to the Review that they have completely revamped their trainee development programme in the period since May 2019. They have partnered with the Scottish Police College and staff now receive training there that is accredited by the Scottish Qualifications Authority (SQA). For example, PIRC use the Scottish Police College's investigative learning development programme that is accredited by SQA. That programme is available to people in the PIRC up to the level of senior investigating officer.

22.55 Training was undertaken at the Scottish Police College on giving evidence by any PIRC staff who have never appeared in court or not had experience of Fatal Accident Inquiries.

22.56 PIRC also provide continuing professional development in the form of internet and social behaviour training.

22.57 At the focus group I held with PIRC reviewers and investigators I was given evidence that, since being reviewed, training within the PIRC was much improved. This evidence was supported by positive trainee feedback to PIRC's Human Resources Team over the relevant period.

22.58 A member of the PIRC senior management team explained to the Review that one of the challenges that they have in bringing people in to develop them up through the ranks is that the two-year training programme allows trainees, potentially, to be sent out to handle some very serious investigations that someone from a police background might not have dealt with until they had 20 years' service.

22.59 I believe that although the comprehensive training for PIRC staff is commendable, the context of an incident cannot always be taught in the classroom; police officers are aware of how dangerous situations can become, and how sometimes decisions have to be made quickly. In order for PIRC complaint handling reviewers to understand this better, it is recommended that they work-shadow police officers at peak times to see at first hand the atmosphere and environment in which officers are obliged to make decisions that can have serious implications.

22.60 The Review heard evidence that more training was being provided and taken up in the PIRC, including a bespoke training course on how to deal with abusive callers for complaint handlers and a plain English course on report‑writing. Family Liaison Officers had also been sent on the appropriate training and crime scene managers had been on the full scene management course. Training input from PIRC was also being delivered to Police Scotland's post-incident managers and in practice investigators were now getting full accounts from officers more speedily. Other courses provided include driver awareness and mental health management. PIRC have been using Civil Service online training to cover diversity and have accessed courses on unconscious bias, managing diversity and recruiting.

22.61 All the PIRC staff undertook diversity training in 2017 and in November 2019 undertook training on unconscious bias. In addition, all staff were provided with inputs on mental health awareness in January 2020. Mental health awareness is particularly relevant given the background of many people who take their complaints to PIRC.

Guidance

22.62 PIRC staff confirmed that they do refer to their statutory guidance document 'From sanctions to solutions'^[218]. However, as noted in the preliminary report, this document was first published in 2011 prior to the inception of Police Scotland, with only a minor update in 2013, so it is significantly out of date. The tenor of the document itself should be commended as it was intended to drive a move away from a blame culture relating to complaints to a culture of learning and development. The PIRC has confirmed that their statutory guidance is being updated and Police Scotland and the SPA are being consulted on the revised document.

22.63 Evidence from PIRC and PSD officers confirmed that there is no comprehensive cross-organisational guidance on complaints. There is a heavy reliance on on-the-job training, as well as using 'From sanctions to solutions' and outdated ACPOS guidance from 2011 on the recording of complaints. It was put to the Review that in general terms the guidance available had value, but that it should be routinely updated and refreshed so that all organisations are working from relevant and comprehensive guidance.

22.64 Guidance should be developed across all the relevant organisations, so that all learning and development has a consistent basis, and so that there is no ambiguity regarding the interpretation of regulations. It was also suggested by an officer from Professional Standards that consideration should be given to publishing a version of any new guidance in order for the public to make better informed decisions when considering making a complaint. In the interests of transparency all the guidance related to public complaints arrangements should be published in an easily accessible place.

Strengthening the learning culture across the organisations charged with dealing with complaints

22.65 The 2015 Review of PIRC Procedures in relation to Complaint Handling Reviews of PIRC led by Robert Gordon recommended that the SPSO should share their training materials and courses where appropriate, and that a quality assurance check of decisions issued by review officers could offer feedback to identify any training needs. The PIRC should also consider the operational and career development merits of interchange between PIRC staff and SPSO staff. The benefits of engaging with SPSO apply equally to Police Scotland and PSD officers should be encouraged to learn from their best practice and apply it.

22.66 The Scottish Public Services Ombudsman (SPSO), Rosemary Agnew told the Review that learning lessons, identifying systemic issues and rectifying them were the best way for an organisation to improve, and that training, support and advice were important elements in achieving that. This view was echoed by the Police Ombudsman for Northern Ireland who believes that efficient complaints handling depends on proper training if it is to be done properly.

22.67 SPSO provides training for public service complaint handlers. Courses have been developed for frontline staff to support the implementation of model complaint handling procedures in different sectors. The training provided by SPSO is both direct delivery and e-learning; it is available to all public sector bodies and the e‑learning is currently free.

22.68 Cross‑training between organisations, where it has taken place, has been of great value in understanding others' roles and gaining a different perspective.

22.69 Although Police Scotland is not a scheduled organisation under the SPSO legislation that should not be seen as a blockage to secondment, consultation and learning between the two organisations.

22.70 A forum is being set up with the involvement of PIRC, IOPC, PONI and GSOC to look at what training is available across their independent investigation sector. Due to work pressures and the COVID-19 pandemic this forum has yet to meet. However, I am encouraged that in future the forum will be discussing how mutually beneficial training can be developed. GSOC has also engaged with PONI, IOPC and the PIRC on trying to arrange peer review accreditation.

Training in the Police Service of Northern Ireland

22.71 In the PSNI training of officers was seen as critical to their behaviours because they would act and behave according to whatever they had been trained to do and how they had been trained to do it. Complaint handling and prevention had to be considered as part of a whole system which included training, vetting, welfare and occupational health support. Misconduct proceedings are all chaired by a chief inspector or superintendent who received barrister-level training in order for them to carry out that function.

Mediation

22.72 Scottish Mediation^[219] can advise where mediation makes a positive impact, the range of areas where mediation and the skills of mediation can help people sort out their disagreements and by doing so encourage an uptake in the use of mediation and an increase in those who understand and can use the skills of mediation on a day‑to‑day basis. In their evidence to the Review the Scottish Legal Complaints Commission extolled the benefits of using mediation. Their online guidance^[220] is designed around legal complaints but sets out excellent principles and practice.

Recommendations in relation to training

22.73 Recommendation: Police Scotland should appoint a PSD training officer to maintain the momentum in training and development arising from its internal Risk, Assurance and Inspection (RAI) team audit, and to liaise with the SPSO, the PIRC and the SPA on joint training, best practice and other relevant development opportunities.

22.74 Recommendation: PIRC complaint handling review officers and trainee investigators should work-shadow police officers at peak times to see at first hand the atmosphere and environment in which police officers are obliged to make decisions that can have serious implications.

22.75 Recommendation: PIRC should deploy the in-house expertise that the organisation has to deliver internal training for investigators in the law of evidence.

22.76 Recommendation: PIRC and Police Scotland should work together to develop training and development opportunities that take the theoretical learning from thematic analysis of complaints and embed it in practical learning for individual officers.

22.77 Recommendation: All Police Scotland officers and staff should receive training on unconscious bias, equality legislation and diversity; this should be updated throughout their career, with the opportunity for refresher courses at regular intervals.

22.78 Recommendation: Police Scotland officers should receive regular training inputs on how to deal effectively with individuals who display mental ill-health symptoms or related behaviours.