Conclusions and recommendations
1 In the four and a half years since it was
established the IPCC has helped to improve access to, and raise
public confidence in, the police complaints system.
However, the IPCC must tighten up its procedures to protect its
reputation and to provide a strong platform for taking its work
forward. Particular areas for improvement include: quality assurance;
obtaining feedback from complainants, police officers and appellants;
engaging with key stakeholder groups; and demonstrating the impact
of its recommendations.
2 Since it was established in 2004, the IPCC's
workload has increased significantly, which has led to it operating
at above full capacity. The performance
of IPCC regions has been variable, with the London and the South
East region in particular underperforming compared to other regions.
To make better use of resources, the IPCC has recently re-organised
its work to allocate appeals nationally rather than regionally.
Allocating work on a national basis enables demands to be prioritised
more easily. Building on these changes, the IPCC should consider
whether further work or posts can be re-located out of London
and the South East to reduce costs, as well as to improve performance.
3 In May 2008, responsibility for the decision
on how a complaint should be handled by the IPCC was transferred
from Commissioners, who are the guardians of the IPCC's independence,
to Regional Directors, who are part of operational management
within the IPCC. This change increases
the risk that the availability of scarce resources will have an
undue influence over decisions about how a complaint should be
investigated. To ensure proper accountability, Commissioner oversight
of mode of investigation decisions should be restored.
4 The IPCC's quality control arrangements
are not functioning properly and there is therefore only limited
assurance available about the quality of the IPCC's work.
A robust quality assurance framework needs to be introduced that
helps to safeguard and maintain the integrity of the IPCC's work
and the quality of its investigations.
5 There is no specialised external scrutiny
of the IPCC's investigation or appeals work.
The IPCC should introduce arrangements for the external scrutiny
of a sample of its cases to provide independent assurance about
how it handles investigations and appeals. The IPCC should identify
bodies that might appropriately undertake such work, for example,
another police complaints body or one of the practice assurance
organisations that exist in a number of professions such as accountancy
and the law.
6 The IPCC has not routinely sought the views
of complainants or police officers about their experiences of
IPCC investigations, nor has it sought feedback from appellants
about the appeals process. Obtaining feedback
from complainants, police officers and appellants should be automatic
and embedded in the processes for investigations and appeals.
Such feedback could be obtained for little extra cost. It is also
likely to be more cost effective to ask for this information at
the end of each investigation or appeal, than to commission separate
surveys.
7 The IPCC's Advisory Board was established
as a 'critical friend' to the IPCC, providing key stakeholders
with a forum to provide feedback to IPCC Commissioners and senior
managers on how the IPCC and the wider complaints system are performing.
Of the 15 member organisations, however, all but two represent
government, police or staff interests. More needs to be done to
establish better contacts with complainant groups. The IPCC should
re-examine the composition of its Advisory Board with a view to
making it more representative of all relevant interest groups.
8 The IPCC has no mechanism in place for monitoring
whether its recommendations have been implemented by the police.
The IPCC acknowledges that there are inconsistencies in the way
it records a police force's acceptance or rejection of recommendations
and that improvements need to be made. However, it remains unclear
as to who has responsibility for monitoring the implementation
of IPCC recommendations. Clarification on this matter is needed
from the Home Office.
9 The IPCC has a number of performance measures
to identify how well it is handling its workload but does not
have any measures which monitor the wider impacts that its work
is having on the police. The IPCC should
introduce performance measures that would help to establish its
overall impact in improving the performance of the police.
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