Policing inspection programme and framework commencing April 2022: For consultation

About Her Majesty’s Inspectorate of Constabulary and Fire & Rescue Services

Her Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS) independently assesses and reports on the effectiveness and efficiency of police forces in the public interest.

We ask the questions that we believe the public wish to have answered and publish our findings, conclusions and recommendations in an accessible form, using our expertise to interpret the evidence.

We provide authoritative information to allow the public to compare the performance of their police force against others, and to determine whether performance has improved or deteriorated over time.

Our recommendations are designed to bring about improvements in the service provided to the public.

Foreword

As policing moves beyond the immediate pressures of the pandemic, the work of HMICFRS continues to promote improvements in policing, to keep people safe and reduce crime and disorder. The inspectorate must continue to do so in a way that is very different to what has gone before.

Our police effectiveness, efficiency and legitimacy (PEEL) programme restarted last year. We have improved our practice of continuous assessment. Our inspections from April 2022 will review broadly similar areas to those in our programme for 2021/22. These are aligned, where possible, with the structure of force management statements (FMSs) that every chief constable provides to the inspectorate, specifying the demands on the force and its operating context. This approach allows us to evaluate force performance against policing plans.

Our inspections will also increasingly consider progress against national plans, including the Government’s Beating crime plan and its strategy for tackling violence against women and girls, currently being developed. We will also work with inspected bodies and others to develop the most complete, accurate and up to date collection of data relating to the performance of police forces across England and Wales.

We have reflected on how we operated during the pandemic and what improvements we can make to future inspections. We have adopted a blended approach to our inspections. This means work is carried out virtually where possible, but we continue to visit forces in person where necessary.

Last year also marked publication of our organisational strategy for 2021–2025. This sets out four objectives. A short description is provided below; more detail on our strategy can be found in our publication, HMICFRS strategy 2021–25.

Our strategic objectives are:

• A greater focus on public value – inspecting those areas where we can make the greatest difference and applying the inspection methods best suited to the problem;
• Adopting a smarter system approach – working with others nationally and locally to identify problems which are best tackled by a co-ordinated system-wide approach;
• Capitalising on our insight and learning – disseminating insight and good practice from our inspections more broadly and quickly to those who need it, using the latest technology. Using the learning from our national thematic inspections to improve local inspections; and
• More proactive in responding to major changes – identifying major common problems to inform inspection priorities, while adopting a more systematic approach to choosing between options for thematic inspections.

From April 2022, our inspection programme takes a multi-year approach rather than an annual one, setting out how we will work and the things we will inspect in the next three years. However, we intend to review it each year in light of new and emerging priorities for policing, as well as how our ability to inspect and promote improvement is affected by government funding.

What we inspect over the next three years, especially through our programme of national thematic inspections, is central to our strategy. This consultation is an important part of how those decisions will be made.

Thank you for your interest in our proposed plans for future inspection. Your response to this consultation will help make sure that we continue to focus our inspection work on what matters most to you and makes the greatest difference to the public.

Consultation questions

This document provides details of our proposed programme of policing inspections commencing April 2022. It asks for your views on whether we cover the right themes and areas of policing. In particular, we are seeking your responses to the following consultation questions:

1. Do the proposed thematic inspections cover the areas that are of most concern to you at the moment? Which do you believe are of greatest importance or urgency?
2. Are there any significant new or emerging problems in policing that HMICFRS should consider when it inspects individual police forces?
3. How else could HMICFRS adapt the way in which it acquires information to take account of current circumstances and risks to public safety?

These questions are repeated in the body of this document. At the end of the document, we explain how you can give us your views.

Introduction

This document is HMICFRS’s proposed inspection programme and framework commencing April 2022, which we envisage will run for the next three years.

It details the inspections that HMICFRS proposes to carry out and explains our inspection plans from April 2022.

Finally, our framework explains how we intend to carry out our programme.

Inspections from April 2022

PEEL assessments

The PEEL inspection programme is an assessment of the effectiveness, efficiency and legitimacy of police forces in England and Wales. Its principal aim is to promote improvements in policing. Our PEEL assessment provides graded judgments on a number of aspects of forces’ performance. It identifies where forces need to improve and helps the public understand how well their force is performing.

National thematic inspections

Our thematic inspections are in-depth examinations of particular policing practices or processes, or of the policing approach to preventing and tackling specific offences. Themes are identified through our continuous monitoring, and they are generally chosen because:

• current acute problems in policing practice are harming the public interest;
• there are inconsistencies in outcomes across England and Wales, which force‑level work cannot adequately explain; or
• further improvement in practice would benefit the most, or the most vulnerable, victims.

Expanding on the force-specific information from PEEL inspections and FMSs, inspectors build a national picture of police efficiency, effectiveness and legitimacy in the selected areas through a combination of:

• all-force data and document requests;
• interviews with national, regional and local policing bodies, government and other interested parties;
• case file audits and testing the understanding and application of policies and procedures with operational staff in forces; and
• a victim, offender or witness focus.

Whilst thematic inspections may identify areas of notable practice or specific concerns in specific forces, they will usually result in recommendations that are relevant to the police service as a whole.

Commissions from the Home Secretary and local policing bodies

The Home Secretary may, at any time, require us to carry out an inspection of a police force, part of a police force, or particular activities of one or more police forces.

Similarly, local policing bodies may ask us to carry out inspections or reviews of the police forces they oversee.

Inspection of national agencies and other non-Home Office forces

We have a statutory responsibility to carry out inspections of the following national agencies and non-Home Office forces:

• the National Crime Agency;
• the Police Service of Northern Ireland;
• the British Transport Police;
• the Armed Forces Police – Royal Military Police, Royal Navy Police and Royal Air Force Police;
• the Ministry of Defence Police;
• the Civil Nuclear Constabulary; and
• HM Revenue & Customs.

Also, at the request of the relevant dependency or overseas territory, we may inspect forces in British Overseas Territories and Crown Dependencies, such as Gibraltar, Jersey and Guernsey. Similar voluntary inspection arrangements are in place with the Gangmasters and Labour Abuse Authority. We also conduct audits of the Police National Computer.

Joint inspections

We work with other organisations to conduct joint inspections. These allow us to inspect the way in which the police approach and tackle a particular type of crime or problem as part of a wider assessment of the service provided by all the relevant agencies and organisations.

For instance, we work with Ofsted and the Care Quality Commission (CQC) to examine how local authorities, police and health services work together to help and protect children.

We work most often with the other criminal justice inspectorates: HM Crown Prosecution Service Inspectorate, HM Inspectorate of Probation and HM Inspectorate of Prisons. This allows us to assess police efficiency and effectiveness in both contributing to, and being affected by, the wider criminal justice system. The joint inspection work we conduct with these inspectorates is detailed in the separate Criminal Justice Joint Inspection Business Plan.

State of Policing report

As in previous years, HM Chief Inspector of Constabulary will produce an annual State of Policing report, which reports on the efficiency and effectiveness of policing in England and Wales.

An overview of the inspection programme from April 2022

PEEL programme

The PEEL programme has recently seen the most significant changes since it began in 2014. This has included moving to a continuous assessment model; redefining our judgment criteria; assessing forces against five, instead of four, graded judgments; improving how we report findings to the public; and making changes to how we inspect to better understand force performance and support continuous improvement.

With the easing of pandemic restrictions, we have now resumed our PEEL inspections and plan to inspect every Home Office force by the end of 2022. We will continue to evaluate and seek feedback on our approach to PEEL to identify any further necessary improvements.

We will assess how well each force:

• serves victims of crime;
• engages with and treats the people it serves;
• prevents crime and deters anti-social behaviour;
• responds to the public;
• investigates crime;
• protects vulnerable people;
• manages offenders and suspects;
• disrupts serious and organised crime;
• builds, develops, and looks after its workforce and encourages an ethical, lawful and inclusive workplace; and
• plans and manages to achieve value for money.

National thematic inspections

From April 2022, we intend to move to a multi-year programme of thematic inspections in line with our strategy, and to make best use of the resources we are allocated as part of the government’s spending review.

The timing of these inspections will depend upon our funding and capacity, and emerging priorities for policing. We have consulted a broad range of interested parties and specialists to broaden our perspective of how we can best promote improvements in policing for the public.

Some elements of planned thematic inspections may be integrated in the PEEL inspection programme. Some may also be included in the Criminal Justice Joint Inspection Business Plan.

We will complete the following thematic inspections started this year:

• digital forensics;
• race and policing programme – national leadership and governance;
• ethnic disproportionality in the criminal justice system;
• serious youth violence;
• serious and organised crime; and
• vetting and counter corruption.

Other proposed thematic inspections include:

• a continuation of our work on police engagement with women and girls through focusing on offenders;
• armed policing; and
• the prevention and investigation of homicide.

We have consulted a range of specialists and other interested parties, including police leaders and leaders of other inspectorates, to gain a broader perspective on priorities for our thematic inspection programme.

Further thematic proposals from these consultations include:

• police leadership and culture – to what extent are recent high-profile cases, as well as long-term questions about race and diversity, evidence of problems of police leadership and culture;
• recruitment and retention – how can a more diverse and effective workforce be achieved and sustained and how is the government’s programme to increase officer numbers, the police uplift programme, improving the efficiency and effectiveness of policing;
• crime prevention – how effective and economically sustainable are forces’ long-term plans when funding is mostly short-term and divided across government departments;
• changing demands – how are forces managing increasing demand and the changing nature of demand, such as time spent supporting people with severe mental ill-health;
• investigations – what are the main causes of the long-term decline in successful prosecutions and what can be done to improve the situation;
• repeat offenders – has the integrated offender management strategy to improve supervision of repeat offenders been effective in reducing crime;
• science and technology – are forces fully using science and technology to maximise their effectiveness and efficiency;
• child protection – what is good practice and how it can be achieved in a system where the police are one of many organisations responsible for keeping children safe; and
• domestic abuse – what is policing best practice to achieve the best experience and results for victims.

Most of these proposals relate to enduring and well-documented problems. HMICFRS has already published national thematic reports in some areas, such as domestic abuse and supporting people with mental ill-health.

Common to all is a need to understand what constitutes good policing practice and how all forces can
achieve it.

Vulnerability and child protection inspections

Our plans for these rolling programmes are:

1. National child protection inspections in England and Wales

From April 2022, we will continue to carry out inspections and re-inspections of forces to assess the experiences of children who come into contact with the police, and check the results have been in their best interests. We will follow up these investigations to assess the extent to which necessary improvements are made.

We will publish a separate report collating and expanding on our findings on the police approach to preventing and tackling online child sexual abuse and exploitation. We plan to carry out a similar number of such inspections each year.

2. Joint targeted area inspections in England

In November 2021, with Ofsted and the CQC we piloted a new joint inspection programme to examine how English local authorities, police and health services work together to help and protect children.

The new programme assesses:

• the response, at the point of identification, to child abuse, neglect and exploitation;
• the quality of assessment, planning and decision-making in response to notifications and referrals; and
• the leadership, management, and effectiveness of local safeguarding arrangements in relation to this work.

We have planned further pilots in 2022 and will continue to work with other criminal justice inspectorates on the evaluation and development of this approach.

3. Joint inspection of child protection arrangements in Wales

We will also continue to work with the Care Inspectorate Wales, Healthcare Inspectorate Wales, and Estyn (the education and training inspectorate for Wales).

Our joint inspection programmes focus on the experiences of children as a way of assessing the effectiveness of partnership working.

Violence against women and girls

We will inspect the police’s approach to tackling and preventing crimes that disproportionately affect women and girls, as part of several of our inspections. Our PEEL and child protection inspection programmes will continue to consider the experiences of girls who are victims of abuse and exploitation.

We will continue to monitor progress against recommendations from our previous thematic inspections of the police approach to tackling harassment and stalking, and honour-based violence, forced marriage and female genital mutilation.

Home Secretary commissions

In March 2021, Her Majesty’s Chief Inspector of Constabulary received a commission from the Home Secretary, under section 54(2B) of the Police Act 1996, to conduct an inspection of the quality and effectiveness of interactions between the police and women and girls, as victims, offenders or witnesses. Our first inspection dealt with women and girls as victims of crime and our work will continue as part of this programme.

We will complete an inspection into the vetting of police officers and measures to prevent police corruption, following the sentencing of Sarah Everard’s murderer, at the time a serving police officer.

We anticipate further inspections to be commissioned by the Home Secretary, the Mayor of London, other mayors and police and crime commissioners over the period covered by this programme. We will undertake all Home Secretary commissions and consider all other commissions through the usual process.

Inspection of national agencies and other non-Home Office forces

Subject to further discussion with the organisations concerned, we intend to carry out inspections of the following:

• HM Revenue & Customs;
• the police forces concerned with the armed services;
• the National Crime Agency;
• the British Transport Police;
• the Gangmasters and Labour Abuse Authority;
• the Police Service of Northern Ireland; and
• police forces in British Crown Dependencies (Isle of Man Constabulary) and British Overseas Territories (Sovereign Base Areas Police (Cyprus) and one further territory yet to be determined).

Super-complaints

The Policing and Crime Act 2017 established a new system of police super‑complaints.

A super-complaint is a complaint made to HM Chief Inspector of Constabulary that a feature, or combination of features, of policing in England and Wales by one or more police forces is, or appears to be, significantly harming the interests of the public. Super-complaints can be made in respect of any one or more of the 43 police forces in England and Wales, the National Crime Agency, the Ministry of Defence Police, the Civil Nuclear Constabulary and the British Transport Police.

Only a body designated by the Home Secretary may make a super-complaint. Sixteen such bodies were designated by the Home Secretary in June 2018.

Although each super-complaint must be made first to HM Chief Inspector of Constabulary, HMICFRS will decide with the College of Policing and the Independent Office for Police Conduct (IOPC) whether it is eligible for investigation. If it is, we will jointly investigate the super-complaint and representatives from HMICFRS, the College of Policing and the IOPC will then consider what action, if any, should be recommended. The outcomes could include:

• an inspection by HMICFRS;
• an investigation by IOPC;
• changes to existing policing standards or support materials from the College of Policing;
• a recommendation that another public body is better placed to deal with the concern;
• a recommendation to one or more police forces to change practices or local policies;
• a recommendation to another public body or government department to take action to respond to the super-complaint or a related matter;
• finding the super-complaint needs no action; or
• finding the super-complaint is unfounded.

We expect to receive further super-complaints during the period covered by this framework. Based on the experience of the first five super-complaints, these may each be on very different topics, and (if established to be eligible) will require very different investigations.

The Home Office has provided funding for the team that considers the eligibility of complaints and runs the secretariat for the programme. However, the timing of investigating eligible complaints is dependent on funding being made available. The topics for investigation are not within the scope of this consultation.

Inspectorate capacity

This inspection programme and framework is predicated on there being a full complement of inspectors of constabulary, working full-time on the affairs of the inspectorate during the inspection year in question. To the extent that this is not the case, and subject to the requirement for consultation, this inspection programme and framework will have effect for such period and with such modifications as the chief inspector of constabulary shall specify and publish.

Before the chief inspector of constabulary makes any such modifications, he must first have consulted the Home Secretary and those local policing bodies and chief officers, and such other law enforcement bodies and policing institutions, as he considers likely to be affected by the modifications he proposes to make. And he must have taken into consideration their observations and representations if they have been made in good time.

HMICFRS’s inspection framework

PEEL programme

In 2014, we introduced our police efficiency, effectiveness and legitimacy (PEEL) inspections, which assess the performance of all 43 police forces in England and Wales. Since then, we have continuously adapted our approach and last year saw the most significant changes yet.

A more intelligence-led, continual assessment has replaced our annual PEEL inspections. We also improved how we report findings to make them as clear as possible for the public.

We introduced an accelerated reporting process where we find a serious or critical shortcoming in a force’s practice, policy or performance, known as a cause of concern. This means forces can act rapidly when they need to improve, rather than waiting for our full report.

We changed our approach to graded judgments and we now assess forces against the characteristics of good performance. We more clearly link our judgments to causes of concern[1] and areas for improvement,[2] where policy or performance falls short of the expected standard.

We expanded our previous four-tier grading to five – outstanding, good, adequate, requires improvement and inadequate. This means we can state more precisely where we consider improvement is needed and how to achieve it. These changes mean it isn’t possible to make direct comparisons between the grades given with those in previous PEEL inspections.

The intelligence-led, continuous assessment model allows us to make greater use of the breadth of evidence we already collect on each force throughout the year, to come to an assessment of performance. This determines the need to collect evidence through on-site fieldwork. Evidence sources include:

• the relevant force management statement;
• findings from thematic and joint inspections;
• progress against established causes of concern and areas for improvement;
• routine data collections; and
• evidence collected through regular engagement with the force.

We continue to use a range of evidence collection methods, including:

• analysis of documents and data;
• reviews of case files;
• surveys of the public and interested parties;
• interviews;
• focus groups; and
• observations of police practice.

Last year we also introduced a new PEEL Assessment Framework (PAF). We make graded judgments in several areas of policing (against our ‘core questions’ within the PAF).

We recently updated this framework, to ensure our inspection programme evolves and improves in response to evaluation and changes in policing.

For example, we are taking a regional approach to the inspection and reporting of how organised crime is tackled, to better reflect the way police forces respond. We will introduce grades for regional organised crime units, but forces will still receive graded judgments in their PEEL reports.

We will inspect areas that need a more specialist focus as thematic inspections. This thematic approach includes how we inspect police corruption, professional standards and vetting, which we will report on nationally. However, we will continue to grade forces in these respects in our PEEL reports.

Another change will be our assessment of the service provided to victims. We will remove the graded judgment to enable a stronger narrative assessment that provides more context.

All but the first eight forces in the current round of PEEL inspections will be inspected in line with the new methodology. We will continue to evaluate and seek feedback on our approach to PEEL to identify any further improvements needed.

Local policing bodies’ priorities

In the design of each inspection, and before carrying out fieldwork in each force, we examine and review in detail the local policing body’s police and crime plan for the force, to be clear on its established local priorities. The police and crime plan is also used as a source of information about the local circumstances and characteristics of the force, the police area in question, and the factors that affect considerations of public protection, crime and disorder, including demand – latent and patent – for police services.

Each force management statement must be sensitive to, and reflective of, local conditions and circumstances. It must show clearly how the chief constable discharges his or her statutory duty to have regard to the local policing body’s police and crime plan.

College of Policing standards

College of Policing standards are of great importance to the improvement of policing and the achievement of consistency in practice. We always consider the College’s current standards in the design of inspections and our assessments of forces.

Methodology, monitoring, assurance and insight

HMICFRS’s monitoring process

HM Inspectors of Constabulary (HMIs) routinely and continuously monitor all police forces to promote improvements in police practice. If an HMI identifies a cause of concern about police practice, it is raised with the chief constable and the local policing body so that they can take action.

Follow-up from previous inspections

In relation to each inspection, each year we do follow-up work. This work ranges from formal revisits (for instance, as part of the child protection inspection programme, and aspects of our PEEL programme) to offering support to forces in responding to our findings (for instance, in the custody inspection programme). We also track the progress that forces have made against the recommendations made in our reports.

HMICFRS’s assurance obligations

In addition to our statutory obligations to inspect and report on the efficiency and effectiveness of police forces and certain other bodies, we monitor and provide assurance about other aspects of policing. These include matters such as compliance by chief officers with the requirements of the Police National Database’s statutory code of practice. We continue to conduct monthly reviews at force level to monitor statistics relating to the usage of the Police National Computer.

Advisory and reference groups

We regularly convene advisory and reference groups, involving experts who have specific skills and experience in the areas that are inspected. We use their knowledge and advice to establish a sound methodology for inspections.

We draw members from a wide range of relevant organisations, including several universities, the National Police Chiefs’ Council, the Association of Police and Crime Commissioners and the College of Policing.

Our Technical Advisory Group (TAG) helps to design inspection programmes, so they are as effective and efficient as possible. TAG members include representatives of the National Police Chiefs’ Council, the Association of Police and Crime Commissioners, the offices of police and crime commissioners, the College of Policing, the Home Office, the Office for National Statistics, staff associations, police forces and other specialist agencies.

Our Academic Reference Group (ARG) provides expert advice and discussion on the design and ethical considerations of new research projects that support inspections, the development of methodologies, and the evaluation of inspection methodologies and outcomes. The ARG members include academics from several universities with specialities in policing, research leads from other inspectorates (including the CQC, Ofsted and HM Inspectorate of Probation), the Home Office, and other policing bodies, including the College of Policing and the Police Foundation.

We also have other programme-specific reference groups covering, for example, our overall approach to PEEL inspections and specific aspects such as child protection and crime data integrity.

We received feedback asking us to consider using more public input when establishing our inspection methodology. As far as practicable, we will do so.

How to respond to this consultation

Please submit your answers to these questions, together with any other comments, by email to: 2022-23HMICFRSPolicingInspectionProgrammeandFramework@hmicfrs.gov.uk no later than 1700 on Friday 18 March 2022.

If you prefer, you can post responses to the Chief Operating Officer, HMICFRS, CONSULTATION RESPONSE, 8th Floor, 23 Stephenson Street, Birmingham B2 4BH.

If you have a complaint or comment about HMICFRS’s approach to consultation, you can email this to: 2022-23HMICFRSPolicingInspectionProgrammeandFramework@hmicfrs.gov.uk

How consultation responses will be reviewed

HM Chief Inspector of Constabulary will consider respondents’ views and, if he determines it appropriate to do so, change the proposed inspection programme and framework before putting it to the Home Secretary for approval. In accordance with the Police Act 1996, Schedule 4A, paragraph 2, HM Chief Inspector of Constabulary must obtain the approval of the Secretary of State before publishing the inspection programme.

The final document, which will be appropriately revised to reflect the results of consultation, will be made available on HMICFRS’s website.

You should note that HMICFRS may publish consultation responses, or summaries of them, except where they have been provided in confidence. Please indicate in your response if you do not wish it to be published.

References

[1] Causes of concern – If HMICFRS’s inspection identifies a serious or critical shortcoming in a force’s practice, policy or performance, it will be reported as a cause of concern.

[2] If HMICFRS’s inspection identifies an aspect of a force’s practice, policy or performance that falls short of the expected standard, it will be reported as one or more area(s) for improvement.

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Policing inspection programme and framework commencing April 2022: For consultation