Oversight Board 14th October - 4b MPS Action Plan paper

Report by: Commander Helen Harper on behalf of the Acting Commissioner

1. Purpose of this Paper

This paper reports on the ongoing progress the MPS has made in delivering the items listed within the Stride Action Plan which incorporates the Mayor’s Action Plan. The Mayors Action Plan was published in November 2020 and in the subsequent 18 months, the MPS has delivered 21 of the 23 actions listed, with the remaining two on track or in progress. These actions are now incorporated within the Stride action Plan.

2. Recommendations – that the Oversight Board:
3. Note the ongoing progress made by the MPS in delivering the Stride Action pan – Mayor’s Action Plan;
4. Review how the plan and the actions are helping to focus work on the issue of the “under-protection” of Black communities as set out in the national race action plan;
5. In anticipation of the two year anniversary, consider what are the main outcomes/impact of the work to date.
6. Information for Consideration

3.1      We want our communities to have trust and confidence in us. Lower levels of trust create challenges for us with regard to policing by consent, in our work to keep Londoners safe, whether it is a reluctance to share information, to report crime, support our work to tackle violence and problem solve local problems with us-securing trust and confidence in our policing is fundamental to success.

3.2      We continue to work closely with the Mayor and his team, in respect of Mayor’s Action Plan (MAP), and have mapped across the outstanding work from the MAP to the Stride action plan for continuation into 2022-2023. 

3.3      In addition, the NPCC Race Action Plan (RAP) was launched in late May 2022. A key aim of that plan is to improve Policing for Black people. We have reviewed the plan and as part of the new Stride Action plan 2022/23 we are ensuring that it incorporates specific actions and commitments to support the National plan. Commitment 17 specifically details this ongoing work.

3.4     However to ensure a dedicated focus to the National Race Action Plan (NRAP), a steering Group has also been instigated which will oversee this specific work. We will work closely with colleagues nationally and locally to deliver the very best policing possible to our Black communities. This group will also establish a RAP working group and expand upon the existing DCDG and Stride External ref group to create a specific NRAP external ref group.  There will also be an internal ref group to ensure we reach and work with our internal communities.  The STRIDE plan and NRAP have a number of commitments and actions within them. It is important that there is a focus to develop how these actions translate into more tangible outcomes that deliver against less crime, more trust and higher standards especially for Black communities and internally for our staff.

3.5      Annex A of this report sets out our previous responses and work to each specific Mayoral Action Plan commitment. We ecognize that there is always more to do and continue to work in partnership across London to tackling violent crime, which sadly significantly affects our Black communities. The specific updates have been added in a highlighted font.

3.6      Annex B incorporates the closing report for the DCDG for reference. This reflects the work and the impact of the work. This document is the basis for the 2 year anniversary of the MAP.

3.7      It is helpful for the MPS to see the data in MOPAC’s published Action Plan dashboard[1] that draws on the Public Attitude Survey that is run by MOPAC and speaking to around 12,800 London residents each year.  The Action Plan dashboard currently shows that the gap between white and black residents for trust has increased to 28 percentage points. We note that these figures have declined in the most recent quarter and we of course want trust to be higher and we are working hard to increase it.

3.8      We continue to make strides towards making the Met more representative of the community we serve. This has involved the MPS implementing an ambitious programme of activity that has improved the overall success rates for our Black, Asian and Multiple Ethnic Heritage candidates, removing almost all of the previous disproportionality. The aim now is to ensure we attract even higher volumes of candidates into our recruitment process with greater confidence that we and they will not see levels of disproportionality.  Our programmes of support for staff, overseen locally by our senior leader cohort of Career Development Officers illustrates our acknowledgement of the need for ‘end to end’ support for Black, Asian and Multiple Ethnic Heritage officers joining the Met.

3.9     There were 23 actions generated by the MAP and over 110 MPS actions.  As noted, in the accompanying DCDG Highlight Report, only 2 of the MAP actions remain outstanding.  The misconduct and grievance action was not expected to be completed prior to 2024, so remains on track and the other action, associated with S&S BWV joint coding by the MPS/MOPAC, is due to be shared in summer 2022. The MPS generated actions are completed in the majority of cases and where not are included in the new STRIDE Action Plan 2022/2023.

3.10   The governance for the Stride plan has evolved and this board is chaired by AC professionalism with representatives from each OCU/BCU – business group attend.  A stride dashboard is being developed and this will also track our work against the objectives in the NRAP.  In relation to the under protection of black communities there is significant work with Community Safety Partners, Local communities, the VRU and voluntary groups to ensure key crime areas that affect our black communities most are a focus for prevention and diversion support. Homicide and violent crime in particular continue to be a key area of work for the MPS and stakeholders.

3.11   Work is ongoing with the Criminal Justice and investigations leads to review and understand where disproportionality exists within our processes and the wider system.  This work is closely monitored by the London Criminal Justice Board mechanisms in relation to victims in particular and improving support and care for victims and also suspects. Disproportionality is a key area of focus within the LCJB structures. 

3.12   The MPS VAWG Action Plan seeks to improve the MPS response to women and girls in London and within the action plan we specifically look at intersectionality and understanding the increased challenges faced by Black women and girls when engaging with police and the low levels of trust at present in the police. Factors relating to immigration status also add additional barriers that we, the police, need to be aware of and work to overcome to gain trust and support from women and girls.

3.13   We continue to develop our understanding of disproportionality. Working on a series of touchpoints, the SIU are conducting analyses to understand the extent to which disproportionality is driven by wider societal factors or by MPS-specific factors (decision-making or systemic factors). They also plan to develop and test solutions to address any unexplained disproportionality linked with MPS-specific factors. Finally, they will seek opportunities to use our findings to inform conversations with Londoners. Priority areas include missing persons’ risk-ratings, in-custody strip search, stop and search, and misconduct.

3.14    The MPS, through STRIDE, NRAP, VAWG and Rebuilding Trust plans ensures a focus on maintaining the work begun and embedded through the Mayor’s Action Plan. Development of performance structures to demonstrate tangible outputs are part of the work underway through the new Commissioner’s data and insight structures.

Annex A – MPS Responses to Mayor’s Action Plan commitments [2]

Action 1 – MPS to launch a new pilot project to review samples of vehicle stops conducted under Section 163 of the Road Traffic Act to identify any disproportionality relating to ethnicity. This pilot will be informed by the learning from previous studies into this issue and will enable a better understanding of how these powers are being used, and if they are being used disproportionately, to identify appropriate actions to tackle this.

 

MPS response – The MPS has completed this pilot and shared the report with MOPAC.  The MPS is finalising the report in light of MOPAC feedback. The MPS is aware that other forces nationally are considering similar pilots, and where appropriate the MPS will consider any outputs from those pilots. The National Police Chiefs’ Council and College of Policing have been considering similar work as part of their development of the forthcoming NPCC and College Race Action Plan.  The MPS will consider next steps in line with the Plan when published. 

Action 2 – A review of the use of handcuffing in the MPS. Maintaining a clear focus on officers’ safety as well as that of members of the public, the review is considering:

• the legal and policy basis for pre-arrest handcuffing;

• the training officers receive in how and when to use handcuffs;

• improving the data on the extent of handcuff use;

• accountability and recording of the use of handcuffs; and

• looking for digital solutions for improving the accountability, supervision and transparency of handcuffing.

This review will be brought forward quickly, with an update published before the end of 2020.

MPS response – A new handcuffing policy was launched on 18^th November 2021.  It is supported by the refreshed Public and Personal Safety Training (PPST) programme, which extends training contact time for all officers and is outlined in detail below under Action 13.  Sitting alongside this training programme is a mandatory digital package for all officers up to and including Superintendent, which enhances officers’ learning around the key aspects of handcuffing policy and law. 

Action 3 – The MPS in Haringey are working with Haringey Council safeguarding leads to review the safeguarding response to under-18s who are repeatedly stopped and searched. This work will identify how best to ensure that contextual safeguarding is at the centre of those interactions and where there are wider concerns these young people can benefit from timely support and interventions.

MPS response – A joint MPS and Haringey Children’s Services report was prepared in March 2021.  A key recommendation from the initial report was for the pilot to continue.  Therefore, in October 2021, its development was explored in a workshop at one of MOPAC’s Mayor’s Action Plan public meetings.  Young people’s viewpoints were captured about opportunities to address their safeguarding needs and thereby inform improvements in the MPS and local authority response.  A key improvement identified in this forum was the need to develop processes and protocols for providing ‘Early Help Services’ to young people and their families, informed by reporting and engagement from both police and Children’s Services.

Phase 2 was initiated in Autumn 2021 with an increased focus on Haringey violence hotspots and this work continues.  Police oversight and governance of this work is delivered locally through North Area BCU and reported to MPS leads for public protection and stop and search.

This project is now in its final phase and all results will be evaluated in Autumn 2022.

Action 4 – The MPS will ensure that the work of the Safer Schools Officers is monitored and assessed to ensure the positive work they do can continue and that there are no disproportionate impacts for Black children.

MPS response – Significant changes have been made in the management of Safer Schools Officers, building on the high levels of trust the public, notably the Black community, have in them.  This has included a full Equality Impact Assessment and a bespoke Safer Schools Officer Handbook.  

A Deputy Commissioner’s Delivery Group (DCDG) review of the work of Safer Schools Officer has been completed, with its findings being subject to review through the DCDG Steering Group.  Wider discussion and consultation on the role of Safer Schools Officers took place within the MOPAC Mayor’s Action Plan public meeting in January 2022, capturing specifically the viewpoints of young people, parents and teachers.  A further report has been presented and shared with MOPAC.

September 2022 a working group to review the roles and the ongoing work of the SSOs has been organised – this will generate a table top to get practitioners and key partners together to discuss this work and feed into the governance board being set up. MOPAC and CPIE leading.

Action 5 – MOPAC and the MPS have committed to work with communities to review of all of their existing community engagement mechanisms, to make them more transparent and to identify accessible opportunities for Black communities to be engaged.. CPIE and MOPAC continue to work through this work are working together and with Black thrive to accommodate interviews/surveys/meetings to inform the review.– Each BCU has written their own strategic, operational and tactical engagement plans and continue to develop an devolve these working with their local community contacts.   

In February 2022, all Neighbourhood Policing Leads undertook a day of reflection to share best practice, notably in relation to the positive work ongoing in Croydon, and build on their good work, to ensure their communication plans maximise opportunities to engage with the Black community living, working and socialising in their BCUs.

The development of Police Encounter Panels (PEPs), where a wider range of policing encounters can be reviewed by the public, has focused on recruitment from both minority ethnic groups and young people, who historically have been less well represented in similar panels. We launched PEPs in March 2022.

The first review will be held in June 2022 to capture MPS learning and share best practice.

11 out of our 12 BCUs in the Met have established their Policing Encounter Panels.

The key ethos is that recruitment must be fair and is driven by the community. The membership is reflective of local BCU communities including those most affected by adversarial police encounters, such as Black, Asian and minority ethnic communities and young people. 

The panels meet at least once a quarter but usually on a month basis. 

A small team overseeing this work has now been established and is overseen by CPIC.- continuous improvement  policing command.

Action 6 – The MPS will develop a ‘Handbook of Engagement’ which will be shared with communities, enabling better joint-working to identify further opportunities for how the Service can listen and serve its communities, and in particular Black and ethnic minority communities.

MPS response – The Handbook of Engagement is now available on the MPS website.  Its format outlines MPS structures and opportunities for being involved in the MPS; from being a Volunteer Police Cadet to being a member of an Independent Advisory Group.

It will continue to be promoted through the upcoming Grass Roots Fare planned for the 5^th November 2022.

Action 7 – Building on significant improvements over many years, the MPS is aiming for 16% of its officers to be BAME by 2022, 21% by 2024 and 28% by 2030. To support this new, challenging aim for the diversity of the MPS, new aims on recruitment of officers have been agreed. The MPS want to see as many as 40% of new recruits from BAME communities from 22/23.

MPS response – Up to December 2021 the MPS has achieved these challenging aims with 16.2% of its overall officer representation being from under-represented ethnic groups (5370 of 33,077 officers). During 2021/2022 23% of our recruits were from under-represented ethnic groups, and 4.4% were from a Black background.  To maintain this position, the MPS is monitoring closely the recruitment pipeline and where appropriate, is utilising the principles of Equal Merit to improve diversity. 

An important consideration in assessing this action, is the buoyancy of the wider employment market in London.  The MPS is responding to this challenge, which includes delivering specific media campaigns, focused on highlighting our commitment to recruiting a workforce reflective of London and ensuring the changes noted in Action 8, related to the MPS recruitment process, eliminates disproportionality. Due to its critical significance to the MPS, recruitment is monitored on a weekly basis. 

Action 8 – The MPS will set specific aims for the recruitment and promotion of black officers.

MPS response – The MPS set an aim for recruitment of Black officers as 8% of all recruits.  For promotion, aims were set for Black, Asian and Multiple Ethnic officers: 15% of Sergeants and 14% of Inspectors by the end of 2023/2024 and specifically for Black officers the aim set was: 3% of Sergeants and 3% of Inspectors.  In December 2021 recruitment of Black officers was 5.5%, 10% of Sergeants were from a Black, Asian and Multiple Ethnic heritage and 2.6% were Black.  For Inspectors, 11.4% were from a Black, Asian and Multiple Ethnic heritage and 2.6% were Black.

To address unexplained disproportionality in recruitment the MPS continues to work with the College of Policing to develop an improved assessment process.  To ensure MPS selection is in line with our values and what is required to be a police officer in London, key relevant criteria have been developed and we have increased training for assessors, including a clear focus on understanding and assessing MPS values and individual unconscious bias. This is being built on with community consultation on those key requirements to be a police officer.

Action 9 – The MPS will imminently re-introduce the London residency criteria for most new recruits. This will help contribute towards recruits having the skills and knowledge to police our diverse global city. This will be supported by targeted investment of £300,000 for new outreach work on recruitment to encourage young Black Londoners to consider a career in policing.

MPS response – The MPS introduced the London residency criteria in November 2020 alongside  bespoke Outreach Teams, aimed at recruiting under-represented minority ethnic Londoners to consider a career in the MPS. The Outreach Teams have continued their efforts to recruit under-represented minority groups, whilst assisting in the overall recruitment of the volume target required as part of the police uplift programme. The targeted investment has been utilised to establish a Community Outreach Fund, to encourage external partners to assist in the recruitment of black Londoners to consider a career in policing.   

The MPS has maintained the commitment and investment in the Outreach Teams to maintain diversity recruitment levels.

Action 10 – The MPS will ensure communities are more closely involved in the design of new police learning and development by default and a new Learning and Development Community Reference Group (CRG) will be established to facilitate this.

Action 11 – In support of broadening the conversations with communities on the use of stop and search, the MPS will mobilise a local pilot in the Central South BCU (Lambeth and Southwark). Over a six-month period, this will bring together a mix of 500 front line operational officers (new recruits and established officers) within community led workshops on cultural equality with the aim of developing a deeper understanding of real-life experiences of stop and search and its impact on both individuals’ and the wider communities.

MPS response –This in-person pilot was expected to be complete in December 2021, however timelines have had to be extended into 2022, albeit it is expected to be completed shortly.  Following its conclusion a review will be undertaken by Central South BCU and the Learning and Development Command.  Contact has already been established with the MOPAC Evidence and Insight Unit in order that they can support the review and in particular help provide an objective basis for a decision as to whether the programme should be extended to other BCUs. 

Action 12 – New recruits will spend a proportion of their initial learning understanding the history of the local area they will police, including learning the cultural history, lived experiences and the challenges the communities have faced. This will be facilitated through the introduction of a local Community Immersion Project and a new BCU Familiarisation Week. 

Action 13 – The safety training that new recruits receive will be enhanced with an extra 3 days centred on how the MPS equip recruits with additional skills to deal with and de-escalate potential conflict situations to improve the safety of the public and the officers serving them.

Action 14 – During their initial learning new recruits will spend time understanding the importance of cultural awareness and the impact of issues such as unconscious bias and disproportionality on communities across London, specifically Black communities. This includes scenario-based role plays such as ‘trading places’ exercises, where officers will be put in the shoes of the people they stop.                     

MPS response – During initial training new recruits receive inputs in relation to cultural awareness, with the concepts of procedural justice and policing by consent, woven throughout their wider training programme.  As noted above in response to Action 12, this includes the Community Impact Task, as noted in Action 13, within the enhanced Public and Personal Safety Training role-play and scenario training, and as outlined below in Action 15, the development of the Cultural Awareness Portal.

As part of a recruits ‘Passing Out Parade’ week (at the end of their initial training) a further programme has been established to ensure that officers appreciate the impact of policing on Londoners, notably on Black communities.  Members of the Black community share their experiences of policing including stop and search, through sharing the history of police/Black community relations, contextualising their own personal experiences as part of the wider Black community experience.

Training in relation to stop and search has been developed to include both digital and in-person training.  Where possible, the concept of viewing the Black community’s experiences, through ‘trading places’ with a person being stopped and searched is utilised.  The pilot on Central South BCU has specifically included this approach.  The new MPS ‘Just Another Day’ stop and search/use of force digital training package is an interactive tool to ensure all officers up to and including Superintendents, reflect on their decision making within policing encounters (also noted above in Action 2).

Furthermore, to maintain the focus on the ‘trading places’ technique in MPS training, the Learning and Development Command have invested in a full time role to develop further and maximise opportunities for Black community voices to be heard.  The potential inclusion of the community in the PPST programme is underway, noting that to deliver this requires considerable community availability due to the volume of PPST courses run daily across the MPS.

Action 15 -  The MPS has commissioned Middlesex University to develop a cultural awareness toolkit and a two-part training video, which will include an explanation and demonstration of the principles behind procedural justice – giving people assurance that they are being treated in a fair and just way by authorities – a vital concept for the legitimacy of policing. Once completed the toolkit will be made available to officers and staff through the MPS intranet. 

MPS response – This commission has resulted in the development of an in-house ‘Cultural Awareness Portal’, where all members of the MPS will be able to access relevant information about London’s communities and thereby appreciate how understanding communities and difference, underpins fair policing principles and the concept of Procedural Justice. 

The portal includes bespoke briefings about BCUs, including their history, community groups and key characteristics, aimed at ensuring all those policing have the information to be culturally competent.  Further content focuses on the wider MPS, including explanations of key events in policing London as well as timelines for relevant minority groups in London.

Action 16 – The MPS will set challenging aims to increase the number of Sergeants and Inspectors from BAME groups and will set a specific aim for Black officers. This will be supported by MOPAC committing £400,000 per annum, ring-fenced additional funding to the MPS from City Hall over and above core police funding, to build on the positive progress already made by the MPS in eradicating disproportionality within its Promotions Framework. The MPS will publish details of this scheme at the end of January 2021, following consultation with staff associations.

MPS response – This funding has been utilised to deliver 14 senior leaders as Career Development Officers, trained specifically in supporting under-represented officers achieve their potential.  They are located across all BCUs and within specialisms to support the MPS retention, promotion and selection aims outlined within this annex.  They will be a key part of the new leadership programmes for Black constables and under-represented leaders noted above in relation to Action 8.

Action 17 – The MPS is committed to significantly reducing disproportionality within the grievance and misconduct processes by 2024. The MPS has put in place a checks and balances process to review internal referrals into the misconduct process, to ensure opportunities for learning have been fully explored. The Mayor will hold the Commissioner to account for ensuring that this happens.

MPS response – The MPS has undertaken significant work to reduce disproportionality in both misconduct and grievance procedures.  For misconduct, a process of checks and balances remains, under the leadership of Commander Savell within Professional Standards.  This is added to with a pilot initiated in late 2021 on 4 BCUs, to support more developmental conversations, thereby positively shaping officer and staff performance to reduce referrals into the misconduct process; this being where disproportionality is particularly noted.  Early indications are that already this is supporting supervisors in addressing minor development needs proportionately and minimising lower level misconduct referrals.  Full implementation across the MPS took place in early February 2022. This work is ongoing and will be subject to ongoing and further reviews.

Reviews of grievances continues under the leadership of MPS Director of HR, Clare Davies.  Grievance numbers remain static, with an average of 245 per annum over the last three years.  However under-represented ethnic officers/staff are still 1.7 times more likely to raise a grievance.  Reviews of these show a believed lack of career support and training and perceptions of inappropriate early use of misconduct processes, and by default failure to use a more informal developmental approach, as significant factors.

To continue the upward trajectory in the use of mediation (increased by 50% in 2020/2021), the MPS includes conflict resolution training on sergeant and inspector promotion courses, as well as extending training on grievance management to a further 500 leaders.  Grievance Management Team support is offered to senior leadership teams identified as grievance ‘hotspots’ to develop, where appropriate, their response to all staff.

Action 18 – The MPS is expanding the support provided via Operation Hampshire to support officers and staff who are victims of all hate crime while on duty. This is to ensure that every officer or member of staff who is assaulted, or subjected to a hate crime or both, is treated as a victim and that they have meaningful support.

Action 19 – The MPS has put in place the necessary safeguards and has reinstated Body Worn Video reviews by Community Monitoring Groups from October 2020.

Action 20 – MOPAC and the MPS will start work shortly to jointly research a sample of Body Worn Video footage, to: examine the nature of stop and search interactions, particularly when there is escalation or de-escalation in the behaviour of officers or the individual(s) being stopped; and understand how different groups of people experience and interpret stop and search interactions.

MPS response – The research has required considerable review and consultation to ensure compliance with relevant legislation, policy and practice.  This has now been achieved and the research is underway.  Results are expected to be available in summer – Autumn 2022.

Action 21 – MOPAC and the MPS will run a new Complainants Survey asking about people’s experiences of the complaints process. This will enable a better understanding of how the journey can be improved.

MPS response – A Complainants’ Survey was conducted in October 2020 with 300 responses received from a potential 1700 people invited to participate.  80% of those responding indicated that the service they received was poor or very poor, with the two main aims, when making their complaint, noted as organisational or individual learning.

To address this feedback the MPS has established within the Directorate of Professional Standards (DPS), a Complaints Resolution Unit.  This unit is already in place and is operating 7 days a week contacting complainants, identifying opportunities for early resolution of concerns where appropriate, through learning and reflective practice.  Its aim is to provide a timely response and resolution to complaints and where necessary, feed in organisational learning through the Prevention and Learning function in DPS and support individual learning through local Professional Standards Units.  Where necessary the CRU will initiate a proportionate misconduct investigation.

Action 22 – Anyone who is stopped and searched is entitled to a record of the incident. In London, these are currently only available by visiting a police station. It is vital that it is as easy as possible for people to access this information and the MPS is working with other forces to find a comprehensive solution. In the interim, the Mayor has asked the MPS to make stop and search records available by email to anyone who would wish to receive the information in that way.

Action 23 – MOPAC, the MPS and the GLA will review how data sharing between organisations is working and make recommendations on how more data can be made accessible, in line with work with other London public services.

Action 23a – MPS to sign up to voluntary code of practice in line with MOPAC & GLA ensuring the data is used to a consistent and high standard by all parties

MPS response – The MPS currently is reviewing carefully the impact of the voluntary code of practice and is working with the Open Data Institute to ensure a wide capture of viewpoints are considered and any necessary changes will be considered alongside national guidance Assessing impact