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MOPAC's Oversight of Police Complaints

We believe that access to a fair and transparent police complaints system is vitally important to Londoners. To promote transparency MOPAC has an explicit responsibility to hold the MPS Commissioner to account for the handling of public complaints. We are further seeking to ensure that the MPS have processes in place to recognise opportunities for learning at both an individual and organisational level. 

Introduction to the police complaints system

An effective police complaints system is vital. Government reforms introduced in 2020 (under the Policing and Crime Act 2017 and supporting regulations) delivered significant changes to the complaints system. The focus was on delivering a less adversarial, simpler and more customer-focused process.  

In response to the new regulations and feedback from the public the MPS have made significant changes to the way in which they handle complaints. The 2022 introduction of a dedicated Complaints Resolution Unit (CRU) has brought a renewed focus on ensuring the handling of complaints is timely, reasonable, and proportionate.

The CRU seek to make an early assessment of all cases they log and will discuss allegations and available means of resolution with complainants to explain how the matter can be resolved. If a matter can handled by means of a ‘service recovery’ approach outside of the requirements of the formal complaints system, the MPS will endeavour to do so. 
The MPS have further improved the quality and consistency of handling by assimilating all Professional Standards Units (PSUs) into their Directorate of Professional Standards (DPS). This enables the DPS to take on the responsibility for the recruitment, training and supervision of the police officers and staff working in these specialist roles. This has also facilitated an extension of the ability to share information and intelligence between those units involved in the handling of complaints. 

MOPAC have an explicit statutory responsibility to hold the MPS Commissioner to account for the effective management of public complaints. This does not include direct intervention into the handling of individual cases. To do so could undermine the MPS role as appropriate authority and/or prejudice any future independent review of the handling of the complaint. 
The Independent Office for Police Conduct (IOPC) publish their ‘Police Complaints Statistics for England and Wales’ report annually. This report facilitates the comparison of data between the MPS and other police forces. The latest report for the 2023/24 financial year can be found here

The police complaints system is an invaluable source of intelligence for the MPS; to understand those issues and behaviours that cause concern, and to identify renewed opportunities for developing enhanced training and supervisory frameworks.

MOPAC and the MPS collaborated on an extensive survey of complainants in 2021. The MPS agreed four specific recommendations to improve the quality of their complaint handling. Further information can be found here

The MPS subsequently introduced the Complaints Resolution Unit (CRU) in February 2022. The CRU is designed to improve communication with complainants. Public complaints are assessed by specialist trained officers who seek to apply consistent standards to streamline handling and deliver fair and proportionate outcomes.  

Initial contact is now made with complainants far more quickly. The MPS average of 5 days to contact complainants across 2023/24 compared favourably with with the ‘all-force’ (England & Wales) average of 6 days. The MPS recognise that engaging with complainants in a timely manner allows officers an early opportunity to discuss and gain a full understanding of the nature of the allegations made, and to then explain the available means of resolution. Following survey feedback, the MPS have also simplified the language that they use when explaining the handling and outcomes of complaints to the public. 

Timely resolution of complaints enhances the scope for any individual or organisational learning to be recognised and implemented by the MPS.  

MOPAC officers meet with MPS counterparts each month to discuss the current caseload, key performance metrics and any emerging issues requiring further examination or scrutiny. 

The MPS logged 11,843 complaint cases in 2023/24. This represented a minor increase on the 11,779 cases logged in 2022/23, and just under 14% of the  85,458 total complaints logged by all police forces across England & Wales. 

The IOPC calculated that the average number of complaint cases logged per 1,000 employees across all forces in England & Wales in 2023/24 was 338. The MPS logged 243 cases per 1,000 employees. As the largest police force in England and Wales the MPS understandably log more expressions of dissatisfaction than any other force. But it is important to note that they receive less complaints than the ‘national average’ when those volumes are analysed on a ‘per capita’ basis. 

Each complaint case may include one or more allegations. The 11,843 MPS cases comprised a total of 21,759 allegations. Again, when considering the number of allegations per 1,000 employees the IOPC found that with 446 allegations the MPS compared favourably against the national average of 599. 

A complaint case is considered finalised when all actions relating to that case are complete. Across 2023/24, the MPS were able to finalise 37% (8,182) of allegations outside of the formal police complaints system.

A complaint can be about any matter which has had an adverse effect on the person making the complaint, that they have witnessed, or which happened to them. The MPS are required to categorise all complaint allegations logged for monitoring purposes. In this regard the 2023/24 MPS data closely reflected the national picture with the three most populous complaint categories being (in descending order) Delivery of Duties and Service (1), Police Powers, Policies and Procedures (2) & Individual Behaviours (3).  

The IOPC also publish a quarterly Police Complaints Information Bulletin (PCIB) for each force. The latest MPS data can be found here.

Our role as a local policing body is to hold the MPS to account on behalf of the public. MOPAC officers have a monthly performance meeting with the MPS Directorate of Professional Standards (DPS) to discuss a suite of data relating to the handling of complaints and conduct matters. MOPAC scrutinise any areas where there has been a deterioration in service standards and seek explanation and proposed remedial action from the MPS as required. 

The performance meetings enable us to identify and discuss any anomalies in the data and/or variations in the volume and type of complaints received. The MPS are asked to explain any fluctuations observed and set out the impact of any preventative work in which they are engaged. If the MPS are proposing any changes in governance or administrative arrangements for complaints, we will invite them to explain how and why those changes are being made. 

MOPAC also seek assurances around the type of organisational learning that can be taken from complaints received by the MPS and from any investigations that subsequently ensue. The complaints system is a rich source of such information for police forces. 

MOPAC officers meet with counterparts from the IOPC to discuss governance issues around the management and handling of public complaints as well as the scope and impact of legislative changes. We will discuss thematic issues around policing professional standards that have been observed at a national level and participate in consultation exercises in related areas. 

The MPS must provide MOPAC with a formal ‘timeliness’ notification in the event of any complaint or misconduct investigation taking 12 months to finalise. This will explain the reason(s) for the delay and advise what remedial steps are being taken to bring the matter to a conclusion. The MPS took an average of 211 days to finalise the 3,883 complaint cases recorded under Schedule 3 to the Police Reform Act 2002 (including suspension) in 2023/24. This represented an improvement of 6 days on the 2022/23 figure. 
MOPAC uses timeliness notifications to challenge the MPS around the causes of any unreasonable delays in bringing investigations to a conclusion. Some delays are unfortunately unavoidable due to matters being subject to an active criminal investigation or judicial proceedings. 

When the MPS can log expressions of dissatisfaction and deal with them outside of the formal complaints system the capacity to deliver a swifter proportionate outcome is improved. Across 2023/24 the MPS finalised 7,810 cases in such a way, with the average time taken just 19 days. 

Under 2020 reforms the Government introduced a new right to independent review for complainants dissatisfied at the handling or outcome of their complaint to the police. This was designed to further improve the transparency and integrity of the complaints process. 

Review applications are always assessed by an organisation independent of the police force concerned. For the MPS the Relevant Review Body (RRB) will be either the Independent Office for Police Conduct (IOPC) or MOPAC, depending on the nature of the complaint.  

The RRB assess whether the MPS handled the complaint in a reasonable and proportionate manner. It is not, and cannot be under legislation, a re-investigation of the original complaint. If the RRB consider that the complaint has not been handled correctly, a review will be ‘upheld’. Where MOPAC are the RRB we can also then make recommendations to the MPS about how to rectify the situation where appropriate. 

The MOPAC Police Complaint Reviews Team (CRT) is completely independent of the MPS. None of our staff are employees of the MPS. Reviews are carried out impartially and without bias.  

The number of review requests received by MOPAC has continued to fall from a peak volume in 2022, reflecting the new arrangements for complaint handling in the MPS introduced by the Complaints Resolution Unit (CRU), and an improved administrative framework. Across 2022/23 MOPAC received 499 requests. In 2023/24 this figure dropped by a further 11% to 442. 

The majority of reviews (335 of 343 completed in 23/24) assessed by MOPAC concern complaints that were formally recorded but then not subject to full investigation by the MPS. MOPAC ‘upheld’ 45% of these reviews. We also made 140 recommendations to the MPS across the same period.

We are seeking to ensure that our role as an independent review body increases public confidence in the police complaints system. To that end, we work collaboratively with the MPS to support training of officers involved in complaint handling and investigation. 

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