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Merseyside PEEL 2018

Effectiveness

How effectively does the force reduce crime and keep people safe?

Last updated 21/01/2020
Good

Merseyside Police is good at reducing crime and keeping people safe.

The force is good at investigating crime. It has invested in new technology to improve the quality of investigations and has started a review to assess its effect. The force uses technology to keep track of how long people are kept on bail or released under investigation(RUI), but it should also make sure that bail is being used appropriately in cases involving a vulnerable person.

Merseyside Police is good at protecting vulnerable people. Its officers and staff understand this issue, and what their responsibilities are. The force receives a high number of calls from the public, and it needs to be more consistent in recognising and recording risk during these calls. It also needs to make sure that it considers the potential risks when delays occur or circumstances change.

It has created a new vulnerable person referral unit to improve the service provided to vulnerable people. This needs time to become established – it had some staffing and process difficulties at the time of inspection. The force frequently uses the domestic violence disclosure scheme (DVDS, also known as Clare’s Law) and multi-agency risk assessment conferences (MARACs). But it needs to make sure that it processes cases quickly enough and must ensure that it follows national guidance so that vulnerable people are protected from further harm. The force has good arrangements for managing sex offenders who pose a risk to vulnerable people.

In 2016 we judged Merseyside Police as outstanding at tackling serious and organised crime, and good at preventing crime and tackling anti-social behaviour.

Questions for Effectiveness

1

How effective is the force at preventing crime, tackling anti-social behaviour and keeping people safe?

Good

This question was not subject to detailed inspection in 2018/19, and our judgment from the 2016 effectiveness inspection has been carried over.

2

How effective is the force at investigating crime and reducing re-offending?

Good

Areas for improvement

  • The force should develop quality assurance of its bail and RUI decisions to ensure victims of domestic abuse and other vulnerable victims are appropriately supported.
  • The force needs to better understand the reasons why some vulnerable victims do not want to support prosecutions in order to effectively pursue justice on their behalf.

We set out our detailed findings below. These are the basis for our judgment of performance in this area.

Investigation quality

Merseyside Police is generally good at investigating crime with able leadership and an ambition to improve.

At the time of our inspection the force was midway into a review of its entire investigation process. This three-stage review began in 2019. It will examine all processes, from the initial call to the force through to the conclusion of the investigation. This review has a clear focus on improving service from the victim’s point of view.

Since 2016 the force has improved the accuracy of its crime recording. We now grade it as good for crime data integrity. This has contributed to a rise in recorded crime, but the force now has a better understanding of the amount and type of crime it must deal with.

The force has created a crime scrutiny panel and now conducts regular audits of its investigations. This examines about 150 investigations each month to identify areas for development, providing feedback and learning for officers.

The investigations department has a good understanding of workforce data. This helps it to manage demand by flexibly deploying officers and staff.

The force has insufficient detectives. Not enough of its detectives are accredited to the appropriate level – just 77.2 percent of investigators were accredited at Professionalising Investigations Programme level two at the time of inspection.

The force is taking steps to address this gap. In many forces this arises from too few officers applying for detective roles. Merseyside Police has enough people applying to become detectives, but it has to balance its need to increase detective numbers with the potential negative effect of losing experienced officers from other departments. Further detective training courses have been planned throughout 2019, and it is now using experienced police staff investigators to support investigative teams. 

Before our fieldwork, we completed a file review of 60 crimes from 2018. We assessed that 45 of these had been effectively investigated. And we judged that 34 of the 60 cases had been supervised appropriately. We determined that 59 were allocated correctly, taking account of crime complexity and the skills and experience of the investigator. Those investigators we spoke to during our fieldwork appeared to have the right skills for the crimes they were dealing with.

The force was provided with specific feedback on the findings of our file review and had already used this information to make improvements by the time of our inspection, such as:

  • A crime improvement governance meeting, which has identified gaps in supervision and improved leadership.
  • A crime scrutiny panel to review about 150 cases per month, to quality assure the investigation and supervision and to identify learning.
  • The force’s own analytical team has conducted five crime file reviews (of 60 cases each) using HMICFRS methodology to make sure they were conducted properly and to identify any lessons.
  • The first stage of the force’s process review of its investigations is looking at the period from the first contact with a victim until the crime is allocated for investigation. This has examined ways to make this process quicker and more efficient – an issue identified in our file review.

Merseyside Police has developed its own information system called Delphi. We examined this and noted improvements that had resulted from its introduction. The system gives an overview of crime investigations and allows supervisors and managers to check the progress of investigations being conducted by their teams. This is important as the force routinely has more than 7,000 live investigations at any time. Many supervisors told us that Delphi helps them in their daily work. This is good, and the force should now focus on improving the quality of its investigations.

The force has improved its ability to retrieve digital evidence from phones and other electronic devices. The digital forensic unit, where computers and other devices undergo detailed examinations to support investigations, is well managed. It now operates 24/7 and the quality of its work meets recognised national standards. There is a triage process for items, and they will be fast-tracked if necessary. At the time of inspection, the average waiting time for the examination of a device was nine weeks, which compares favourably with times in other forces.

When it is not necessary for an officer to attend an incident, the force will conduct telephone investigations with victims. This is done by the crime demand unit, which deals with about 900 incidents per month. The team is appropriately resourced, and it helps to reduce the demand on response officers and the investigations department. If the unit identifies someone involved in an incident is vulnerable, the incident will be returned to the control room so that officers can attend.

Merseyside Police uses a scheduled incident response team. This is a team of police officers who attend appointments with callers who have reported an incident that is assessed as low risk. At the time of inspection, there was a five-day waiting time for callers to be seen. The force should monitor this process to ensure that appointments are being allocated appropriately and that delays are not excessive.

The force has improved the initial retrieval of evidence from crime scenes. Officers told us that they generally get enough time to carry out enquiries at scenes. The force tracks the use of body-worn video cameras as part of the evidence-gathering process, and the data shows that their use is increasing.

The force has invested in a digital evidence management system. This links body-worn video footage, voice recordings from 999 calls and downloaded footage from public and private CCTV. It is expected this will improve the quality of evidence available to support investigations and allow it to be processed more quickly. The system was new when we inspected. We found that some officers and staff had not been trained in its use, but those who had been were positive about it.

In addition, the force has developed an IT system to provide greater visibility for investigators and supervisors so that updates and investigation plans are timelier. In our 2017 effectiveness report we said the force should be quicker in allocating crimes that are less complex to investigators with the appropriate skills and accreditation, and provide consistent supervision to ensure they were investigated to a good standard. The force has been working to reduce delays in allocating crimes for investigation. Its own data for April 2019 showed that 90 percent of cases were allocated within three days. However, we did find some crimes where this had taken longer, and this should be addressed.

During our inspection we examined several continuing investigations in the force. While most of them were being managed well, we found some examples where evidence had been lost, and where not enough detail had been recorded about safeguarding questions. The force should review its approach to low-level, high-volume crime investigations, where we found less experienced officers and staff dealing with the bulk of the crimes.

We found victims were updated on the progress of their case in a consistent manner. Investigations were supported by officers trained in dealing with vulnerable victims, in order to secure the best evidence. The force has invested in eight mobile kits which enable them to interview vulnerable victims locally, so they don’t have to travel to specialist suites in other areas.

We found examples of evidence-led prosecutions – prosecutions that are pursued even when victims do not support police action – including cases of domestic abuse. Several of these were supported by body-worn video evidence. The force has developed a training video for its officers to raise the profile of evidence-led prosecutions.

Catching criminals

Merseyside Police is good at pursuing criminals.

Our crime file review assessed five cases involving wanted persons. Details of all five people were circulated on the Police National Computer (PNC) and the force was actively working to find them. We examined in more detail wanted persons during our inspection. Use of the PNC appeared to be appropriate with proper supervision by sergeants and inspectors.

The workforce can now access better information on wanted persons through a dashboard on the Delphi system. The number of wanted persons has reduced from 2,400 to an average of 1,900 at any one time – including those crimes where there is a detailed description of a suspect even if they are not named. We viewed Delphi, and it contained information about people who:

  • are listed as wanted on the PNC;
  • need to be recalled to prison (for example because they have violated the terms of their release);
  • are wanted on warrant; or
  • are named suspects in an investigation awaiting arrest.

The force makes good use of the local media, and dedicated teams are responsible for locating wanted people. Cases are prioritised based on the risk they pose to the public. Wanted persons are highlighted on daily briefings, although we noted that at weekends briefing information is not updated. This should be addressed.

There is an effective process to make sure, when foreign national offenders are arrested, the criminal records office (ACRO) is checked to see whether they have convictions overseas. The force has a good relationship with the immigration service and Border Force, but criminal justice unit managers are aware they could improve intelligence sharing with them. We saw good evidence of joint working and operations at Liverpool’s ports and airport.

We examined how the force uses bail following recent changes to legislation. Information was readily available on the Delphi system regarding people who have been released on bail, or under investigation.

The number of people who are RUI is overseen by crime investigation boards. Local health checks on the use of RUI occur, and a bi-monthly performance meeting examines this in detail. There was evidence of discrepancies in the consistency and progress of lower-level RUI cases that the force needs to consider within its performance management processes.

The force carried out an in-depth review of RUI in 2018 and issued a new guidance document. This details how to use the THRIVE assessment model for making bail decisions. However, we found mixed evidence that this was being used. Force analysts reviewed 250 high-risk cases to make sure the bail/RUI framework was complied with.

We found investigators generally took account of the needs of victims when considering bail decisions. In domestic abuse cases involving people with high vulnerability, investigators tended to use bail. Some cases were changed to RUI (overseen by a supervisor), if the victim had secured a non-molestation order. For lower-level offences, RUI was frequently used. But we did find cases where RUI was used when other options were more appropriate. The force would benefit from sustained quality assurance regarding bail and RUI decisions for offences involving domestic abuse to ensure appropriate support for victims. 

The disclosure process in criminal investigations ensures fairness within the system. Police investigations must follow all reasonable lines of enquiry. Prosecutors must provide the defence with any material that undermines the case for the prosecution or helps the case for the accused. Our crime file review found that 26 out of 29 cases had complied with the disclosure requirements.

We found investigators had insufficient knowledge of disclosure requirements, and attendance at training was inconsistent. This is being addressed and training is now mandatory.

The outcome 16 rate (where a victim does not wish to pursue the case) is 21 percent, which is higher than the England and Wales average of 18 percent. Managers did not understand the reasons behind this variation. The force needs to examine this to ensure it effectively pursues justice for victims.

The force generally has a good understanding of other outcome data. The crime governance meeting is provided with enough information to enable the force to take appropriate action and set its priorities and direction.

Summary for question 2
3

How effective is the force at protecting those who are vulnerable from harm, and supporting victims?

Good

Areas for improvement

  • The force needs to record the initial assessment of risk more consistently. Risk and vulnerability should be assessed from the outset, and re-assessment should take place when delays in deployment occur, or circumstances change. These assessments should inform the subsequent attendance and investigation.
  • The force should review its DVDS procedures, continuing case-work, applications and disclosures to ensure they are efficient, follow national guidance and reduce preventable risk.
  • The force needs to review MARAC processes, so they comply with national guidance, are consistent with partners and there is no filtering of high-risk cases.

We set out our detailed findings below. These are the basis for our judgment of performance in this area.

Understanding and identifying vulnerability

Merseyside Police has a good understanding of the nature and scale of vulnerability in its area. Vulnerability is considered in daily management meetings, and this informs decisions about where to deploy officers and staff. But the force needs to improve some of its processes to protect vulnerable people and victims of crime.

The force produces a range of good analytical products, such as knife crime and violence profiles, which contain essential data. These support the governance processes for investigating crime and protecting vulnerable people.

Information is shared effectively with partner organisations, providing a wider overview of vulnerability, although working across five local authority areas is challenging. Examples include the Troubled Families programme, and violence data to support the violent crime suppression project.

The force has carried out detailed reviews of matters that affect vulnerable people, such as hate crime, domestic abuse procedures and bail. These have resulted in developments such as the RUI framework and revised hate crime procedures. Using intelligence and vulnerability data has also enabled effective operational activity.

Officers were able to broadly describe the meaning of vulnerability, although not in terms of the College of Policing definition adopted by the force. They understood it was a priority, as a result of effective communication, training and leadership. The use of vulnerable persons referrals forms (VPRFs) appeared to be well embedded with operational officers. This included the Special Constabulary who confirmed that they had received VPRF training.

Officers provided examples of identifying hidden vulnerability when attending incidents. Officers had a consistent awareness of the importance of children’s welfare at incidents they attended. Online training packages had been made available to develop this understanding.

A two-day vulnerability training course has been developed with Lancaster University aimed at call handlers, response officers and investigators. It will be reviewed and, if found to be effective, will be provided to the entire force over a two-year period. The training covers coercive controlling behaviour and the voice of the child.

Merseyside Police’s control room receives 67,000 incoming calls per month. The force has an IT system called Call Assist to identify repeat callers. Mental health partners work in the control room between 4.00pm and midnight, providing advice where there is a concern about mental health. Call handlers use set questions to help structure their conversations, although these would benefit from being refreshed.

The THRIVE model is used to make an initial assessment of risk. In our 2017 effectiveness inspection we said that these assessments needed to be more consistent. This year’s pre-inspection work highlighted inconsistent recording, assessment and re-grading of THRIVE assessments. Control room staff are scheduled to attend THRIVE refresher training between April and November 2019. We do not consider this area for improvement has been achieved. However, we do recognise the force is working hard to improve this position. It has an action plan and has introduced live-time quality assurance and training this year.

The force uses THRIVE in all priority and scheduled incidents that are identified as high risk. These are:

  • sexual offences;
  • violence offences;
  • domestic abuse;
  • hate incidents;
  • harassment;
  • ‘concern for welfare’ cases; and
  • any other opening code where vulnerability has been identified.

The force does not currently use THRIVE to assess incidents graded as emergency, because these are all considered high risk. However, we recommend that the force extends THRIVE to these incidents too, to avoid risks being overlooked if they are downgraded and to assist the continuing investigation. Limiting the use of THRIVE to certain incident categories may mean the force doesn’t identify vulnerability when it isn’t immediately apparent.

Where THRIVE was documented in command and control logs, the quality of the assessments had improved since our pre-inspection work. But more needs to be done to ensure that the initial recording of risk is consistent and visible from the outset. It should be used to reassess the level of risk when delays occur or circumstances change, and should inform subsequent attendance and investigation. The force needs to robustly supervise this process. We will revisit this area for improvement.

The force is aware the amount of time calls take and the proportion of callers who hang up before their call is answered have increased. The monthly control room performance meeting monitors this and considers improvements, such as commercial ‘queue-busting’ technology. Callers to the 101 non-emergency line are directed to the force’s social media desk, which is shifting demand from telephony.

Officers generally thought calls were graded correctly by the control room. If the scheduled incident response team and crime demand unit disagree with the grading, they can return incidents to the control room to deploy officers to the scene. When this occurs re-gradings are recorded and analysed to identify any patterns or themes that need addressing.

Our crime file review highlighted inconsistencies in flagging vulnerability within investigations, and the workforce does not flag people who are routinely victims of domestic abuse. The force is examining how it flags vulnerability in its crime recording system, NICHE. This is essential so that the force can respond consistently to vulnerable people.

Responding to incidents

Merseyside Police now has 1,120 fewer police officers than in 2010. Consequently, it is a challenge to respond to incident demand. Demand volumes have stabilised, and in some cases reduced, but increases in incidents involving vulnerability and mental health mean that the level of complexity has increased.

To manage this, the force has adjusted its operating model. It has reviewed how it protects crime scenes that take up officers’ time. It has introduced a 24/7 social media desk and adopted the single online home format for its website, to direct the public to other channels to report less serious incidents.

At times of high demand, more serious incidents are prioritised for attendance. But the force needs to make sure that vulnerability is still addressed in less serious incidents.

The force expects that its detectives should also respond to incidents and wants to make this more consistent. Officers felt that the force control room still tended to ask who was free to attend incidents, rather than giving the task to the nearest available patrol. The control room management intends to change this.

The force provided us with data on its 2018/19 attendance times.

  • It aims to attend emergency incidents within 10 minutes. During 2018/19 this was achieved for 72 percent of incidents, with 90 percent attended within the national guidance of 15 minutes. The average attendance time was 8 minutes and 32 seconds.
  • For priority incidents, 45 percent were attended within 60 minutes and 80 percent within four hours. The average attendance time was 102 mins.

When delays occur, it is particularly important that THRIVE assessments have been recorded so they can be reassessed. There is good data available to understand response times. A demand resourcing officer working in the control room oversees how officers are distributed and can redeploy them according to demand. We found senior officers were focused on response times and adjustments have been made to the shift pattern model to improve performance.

The force has reviewed its processes for scheduling appointments. It wants to improve how it deals with scheduled incidents involving domestic abuse and the securing of evidence at the earliest stage of enquiries at these incidents. Its investigations review is examining this.

Merseyside Police uses a process called MERIT as a risk assessment tool for domestic abuse. Officers understood that these assessments should be carried out face-to-face with victims. We found that body-worn video is used appropriately at domestic abuse incidents. The force monitors its use, and officers understand its value.

For other types of vulnerability, officers complete a VPRF. Officers demonstrated a good understanding of VPRFs and their responsibilities. We saw some good examples of completed VPRFs which took full account of the needs of children found in domestic abuse cases. There was a good understanding of the importance of listening to children in households where domestic violence has taken place.

Officers often refer victims to the National Centre for Domestic Violence website rather than providing leaflets, although leaflets are also available. A sergeant is available to give advice on live domestic abuse incidents and is responsible for ensuring they are dealt with appropriately and completely.

Merseyside Police has good mental health triage arrangements. Specially trained officers work alongside mental health nurses and attend incidents. We spoke to some of the force’s partner organisations, who were very positive about officers’ understanding of mental health. The force has investigators specialising in cases involving mental health problems, who work with the relevant hospitals to offer support and guidance. It uses high-demand action plans for frequent callers, in order to put in place problem solving and support. It has a mental health liaison officer who communicates legislation and policy changes to the rest of the force.

Officers did want more mental health training. They also told us it would be helpful if the triage service had longer operating hours, as they found the health services crisis team difficult to contact out of hours.

Supporting vulnerable victims

Local policing teams are involved in safeguarding vulnerable people, making reassurance visits and checking on victim welfare. The force makes good use of domestic violence notices and orders. When they are issued, officers carry out follow-up visits.

Merseyside Police uses the DVDS to inform and protect people who may be at risk from violence. The force promotes the scheme on its website, with details of how to apply. Data provided by the force shows that it makes a high number of disclosures compared with other forces and has the second highest rate of applications in England and Wales.

We were concerned to find several DVDS applications and disclosures which had not been dealt with in a timely way, with no update or explanation. The way in which the force recorded the processing time for each application was also inaccurate. This could expose people to risk. Following our visit, the force acted immediately to address the backlogs and prevent recurrence of the problem.

Merseyside Police has five co-located multi-agency safeguarding hubs (MASHs). These bring together police and partner organisations from social care and education to work together and share information, creating a richer understanding of vulnerability.

In 2019 the force introduced a centralised VPRU – a change of practice for police and partners. Some partners felt this has resulted in a loss of joint decision making and delayed referrals to the MASH, making engaging the victim more difficult. The unit deals with all VPRF and MERIT assessments. It has been addressing a backlog of assessments since its creation and had 554 outstanding at the time of our visit. Managers expected to clear the backlog and deal with the 150 daily referrals by September 2019. The aspiration is for the unit to act on each referral within 24 to 48 hours.

The force confirmed that it prioritises according to risk and cases involving children. However, the unit was at least a week behind in reviewing some assessments. The oldest case was saw had been awaiting assessment for three weeks.

Merseyside Police supports MARACs. It has one of the highest number of cases discussed at a MARAC – 58 cases per 10,000 adult women, higher than the England and Wales rate of 37 per 10,000 adult women. This is positive. Incidents are graded gold, silver and bronze depending on the level of risk. National guidelines say that all gold cases should be discussed at a MARAC. But we found some gold cases were being screened out and not being properly referred.

Some of these were repeat cases, which were not referred unless the current incident was judged to be significant. Managers told us that this was in line with SafeLives guidance on high-volume cases, but this is not correct. The force does not keep centralised records of these screening decisions, so it couldn’t tell us how many such cases may have been affected.

It was the force’s understanding that an independent domestic violence advocate would contact the victim and evaluate the MERIT assessments to understand case risks. This does not happen. We saw examples in one local authority area where advocates had removed cases from the MARAC process, apparently without contacting the victim. When the family safety unit reduced a victim to silver status, advocates no longer provided support – contrary to what the force expected. However, it does write to victims highlighting support networks, and all cases are sent to the safer communities hub. While the decision to remove the cases from the MARAC process in one local authority area isn’t police-led, this is still of concern. Better communication is needed to ensure appropriate understanding by the force and its partners in these cases. The force is trying to address this, and the local authority has agreed to a joint review of processes.

In 2017 we said that the force should improve how it surveys victims of domestic abuse. The force now uses Leicestershire Police to conduct these surveys on its behalf. Other surveys have been developed with the Open University to improve online feedback. Lessons learned can be shared through the continuous improvement board and children’s safeguarding board.

The force is effective at identifying people who share indecent images of children online and has a proactive approach to this threat. On the day we visited the abusive images unit, six cases had been referred recently, with one awaiting allocation. All are subject to risk assessment. We considered the unit’s workload to be manageable. Investigators told us that they have a good working relationship with the digital forensic unit and can fast-track digital examinations. The force has also started to use wellbeing screening for those who work in this unit, and in September will be piloting a new process from the College of Policing to support its workforce.

All abusive image cases that go to court have applications made for sexual harm prevention orders. The force is also using child exploitation warning notices to protect vulnerable children. This is positive.

The force has 2,330 RSOs, with 1,875 managed in the community. The Active Risk Management process is being used, and 75 percent of assessments have been completed. The force has made improvements to RSO management. It has recruited six additional police staff to monitor low-risk cases, enabling officers to focus on medium and high-risk offenders. At the time of our visit there were few outstanding visits.

The force also produces data to track how well it manages RSOs. This includes whether serious further offences are committed and if visits have been made as needed.

However, more uniformed officers should know about matters involving RSOs. The force wants to make this happen, and its IT mapping tool Delphi should help with this. Briefings for officers include some information about RSOs and dangerous or organised crime offenders, but local policing teams weren’t regularly involved in managing RSOs at the time of our inspection.

Summary for question 3
4

How effective is the force at tackling serious and organised crime?

Outstanding

This question was not subject to detailed inspection in 2018/19, and our judgment from the 2016 effectiveness inspection has been carried over.

5

How effective are the force’s specialist capabilities?

Ungraded

Understanding the threat and responding to it

Last year we established that the force had not published its own APSTRA and was reliant on an assessment of threats and risks affecting several forces in the North West. This has now been rectified.

The force has an adequate understanding of the potential harm facing the public. Its APSTRA conforms to the requirements of the code and the College of Policing guidance. The APSTRA is published annually and is accompanied by a register of risks and other observations. The designated chief officer reviews the register frequently to maintain the right levels of armed capability and capacity.

There are two areas where the APSTRA could be improved:

  • stronger analysis and intelligence regarding armed criminals in Merseyside who present risks in neighbouring forces within the North West region; and
  • details of how rapidly armed response vehicles (ARVs) respond to incidents. This is important to determine whether the force has sufficient armed officers to meet operational demands.

All armed officers in England and Wales are trained to national standards. There are different standards for each role that armed officers perform. Most armed incidents in Merseyside Police are attended by officers trained to an ARV standard. However, incidents sometimes occur that require the skills and specialist capabilities of more highly trained officers.

We found that Merseyside Police has good arrangements in place to mobilise officers with specialist capabilities should their skills be required. Merseyside Police has sufficient specialist capabilities in line with the threats and risks identified in its APSTRA. 

Working with others

It is important that effective joint working arrangements are in place between neighbouring forces. Armed criminals and terrorists have no respect for county boundaries. As a consequence, armed officers must be prepared to deploy flexibly in the knowledge that they can work seamlessly with officers in other forces. It is also important that any one force can call on support from surrounding forces in times of heightened threat.

Merseyside Police has effective arrangements with other forces within the North West region to provide armed policing, including Cumbria Constabulary, Greater Manchester Police, Cheshire Constabulary and North Wales Police. This means that the standards of training, armed deployments and command of armed operations are assured in these forces.

We also examined how well prepared forces are to respond to threats and risks. Armed officers in Merseyside Police are trained in tactics that take account of the types of recent terrorist attacks. Also, Merseyside Police has an important role in designing training exercises with other organisations that simulate these types of attack. We found that these training exercises are reviewed carefully so that learning points are identified and improvements are made for the future.

In addition to debriefing training exercises, we also found that Merseyside Police reviews the outcome of all firearms incidents that officers attend. This helps ensure that best practice or areas for improvement are identified. We also found that this knowledge is used to improve training and operational procedures.

Summary for question 5