City of London PEEL 2017
How legitimate is the force at keeping people safe and reducing crime?
City of London Police is judged to be requiring improvement in how legitimately it keeps people safe and reduces crime. For the areas of legitimacy we looked at this year, our overall judgment is less positive than last year, when we assessed the force as good overall. The force is judged to require improvement in some aspects of how it treats all of the people it serves with fairness and respect and in ensuring its workforce behaves ethically and lawfully. However, it is judged as good at treating its workforce with fairness and respect.
City of London Police requires improvement in the legitimacy with which it keeps people safe and reduces crime. It needs to improve some aspects of how it treats people. Although it is clear that its leadership understands the importance of treating people fairly, some officers are not effectively recording grounds for stop and search and the force is failing adequately to supervise officers’ recording of these grounds. It has not provided enough training on unconscious bias for its workforce, or completed stop and search training for all frontline officers. The workforce has good communication skills, which include showing empathy and listening. External scrutiny has improved considerably since last year but could be further developed if the force appointed an independent chair to the community scrutiny group.
More should be done to ensure its workforce behaves ethically and lawfully. Although we have seen outstanding practice from the force’s leadership in building a strong base in ethical decision-making through its ethics panel and membership of the London police challenge forum – and also through the ethical decision-making training that the entire workforce has received – this is not reflected in how the force investigates allegations of discrimination. The force learns from the outcomes of grievance cases, communicating the resulting lessons effectively to the workforce in terms of learning rather than censure. The complaints process can be easily found and understood, and additional help is offered to people who have difficulty in using it, for instance in assistance with language or with people wishing to be spoken to in their own home. However, the service that all parties receive during investigations of discrimination is unsatisfactory.
The force is good at treating its workforce with fairness and respect. Its leaders actively seek feedback and challenge from the workforce and make changes as a result. Although the force has yet to put its wellbeing strategy fully into practice, the support it offers to its workforce is good. It values wellbeing and provides good support to its workforce, although it could understand more clearly the risks and threats to its personnel in this respect, and prioritise the services it provides accordingly. The force needs to develop its system for assessing performance (performance development review process, or PDR) and link this to the career aspirations of individuals and the offer of development opportunities. The force has used external recruitment effectively to address gaps in its capability.
To what extent does the force treat all of the people it serves with fairness and respect?
Force leaders can demonstrate the value and benefits of procedural justice, and the workforce understands the importance of treating the people it serves with fairness and respect. All frontline officers receive training in communication skills, including empathy and listening. External scrutiny of the force is good and benefits from a wide and diverse membership (particularly considering the small resident population of the force area), but the community scrutiny group would be improved by having an independent chair.
The force’s recording of reasonable grounds to stop and search people must improve. Some officers do not understand what constitutes reasonable grounds or do not know how to record reasonable grounds correctly on stop and search records. The force does not have adequate internal scrutiny of stop and search.
Areas for improvement
- The force should ensure that all relevant officers have received appropriate training on the use of stop and search powers.
- The force should maintain and monitor a comprehensive set of data to understand the impact of its use of stop and search powers.
- The force should ensure that all relevant officers and supervisors understand what constitutes reasonable grounds for stop and search and how to record them.
How well does the force ensure that its workforce behaves ethically and lawfully?
We found some areas of good practice in how City of London Police ensures that its workforce behaves ethically and lawfully. Particularly useful is the London police challenge panel forum, which is supported by the strong base for ethical decision making that the force has built up through its integrity standards board and ethics associates. The force also provides initial ethics training for the entire workforce, who receive support and training when they make mistakes; leaders can demonstrate that they consider the ethical implications of their decisions in the context of an established referrals system.
The force’s policies and procedures are accessible, comply with the Code of Ethics, and have been checked for quality. Its complaints system is accessible to the public. However, the force needs to improve how it keeps complainants updated in line with regulations. Further, while the force is good at identifying allegations of discrimination, it does not always respond to them appropriately or investigate the allegation fully, and the service that people receive from the force during investigations into allegations of discrimination is unsatisfactory.
Areas for improvement
- The force should improve how it investigates allegations of discrimination and take action to ensure that all complainants and officers and staff subject to allegations of discrimination receive a good service from the force.
- The force should improve the quality and timeliness of updates to complainants and witnesses during investigations in line with IPCC statutory guidance.
To what extent does the force treat its workforce with fairness and respect?
City of London Police leaders have a range of ways to seek feedback and challenges from its workforce. Staff and officers are confident in their use of these methods, and the force has made changes as a direct result of this feedback. It has used external recruitment to address gaps in its capability and we saw improvements in the ways in which the force identifies and selects future leaders.
Although we recognise the work that the force has done to improve the way it manages individual performance, it needs to do more to improve the workforce’s confidence in its performance development review process, and to link career aspirations and progression.
The force uses outcomes from grievances to highlight learning for the organisation and for individuals, and communicates this to its workforce effectively. The force values wellbeing and provides various wellbeing initiatives to the workforce. However, the force could understand the risks and threats to workforce wellbeing more clearly and use this understanding to prioritise the services it provides, instead of attempting to address all risks and threats at once.
Areas for improvement
- The force should improve its ability to monitor and improve the fairness and effectiveness of its process for managing individual performance and development, and communicate this to the workforce.
- The force should improve its understanding of its workforce’s wellbeing and use this to prioritise the services it provides.