12.  The IPCC's statutory responsibility is to increase public confidence in the police complaints system.[21] However, the IPCC does not have a formal quality control framework in place.[22] This omission exposes the IPCC to criticism and makes it more vulnerable to allegations of incompetence or bias. Quality control arrangements should fall into two categories: those that involve internal processes and procedures to ensure the quality of investigations and appeals; and those where the IPCC seeks external validation of its performance.

13.  Internal quality control procedures have not been applied consistently across the IPCC. Only 55 of the 100 independent investigations begun in 2007-08 had the required self assessment of the progress of the investigation, and only 19 of these were subject to review by the IPCC's senior investigator assigned to review cases.[23] The IPCC also has no formal procedures in place for post-investigations reviews to be held which would enable best practice to be disseminated and potential improvements to the investigation process to be identified.[24] The IPCC accepted that its quality control procedures had not been operating properly. In future, every investigation would have an initial review by the investigator and would then be peer-reviewed by other investigators, who are currently being trained for this role.[25]

14.  Commissioners are required to approve completed investigation reports formally, but in 25% of the cases reviewed by the National Audit Office there was no documentary evidence of approval. The IPCC stressed that all these reports had been approved by the relevant Commissioner but accepted that such approval should have been formally recorded.[26]

15.  The IPCC has no arrangements for investigations to be externally reviewed, although the IPCC considers that Commissioners have a key role to play in overseeing and scrutinising its work.[27] There are no external bodies that scrutinise the IPCC other than the National Audit Office and this Committee. There is also no right of appeal against the outcome of an IPCC investigation. Complainants can challenge an IPCC decision through the courts via Judicial Review.[28]

16.  The IPCC had not sought the views of complainants, police officers or appellants about their experiences of the IPCC's processes.[29] The IPCC told us that in November 2008 it had started an appellant feedback survey, which was being piloted in its Northern region. It planned to roll out the appellant survey across England and Wales, starting in January 2009. It also proposed to pilot a survey of complainants and police officers involved in independent investigations. From April 2009, the results of this work, which would be publicly available, would be used to improve the IPCC's processes.[30]

17.  The IPCC obtains feedback about its performance and other issues through an Advisory Board, which has been in place since the IPCC became operational in 2004. The Advisory Board, which meets quarterly, was set up with the intention of representing the views of the police, complainants and the public. In November 2007, the Police Action Lawyers' Group resigned from the Board because it did not find this forum a productive way of liaising with the IPCC and because it was unhappy with aspects of the way the IPCC operates. The IPCC has taken steps to initiate bi lateral discussions with the Police Lawyers' Action Group but it has not sought to replace the Group on the Advisory Board. As a result, of the 15 current members of the Board all but two represent government, police or staff interests (Figure 3).[31]Figure 3: Members of the IPCC's Advisory Board

IPCC	Home Office
HM Revenue & Customs	Crown Prosecution Service
HM Inspectorate of Constabulary	Metropolitan Police
Association of Police Authorities	Association of Chief Police Officers
Police Federation (representing police officers below Superintendent rank)	Superintendents' Association
Unison (representing non-officer police staff)	National Black Police Association
PCS HMRC Group (representing HM Revenue & Customs staff)	Citizens Advice Bureaux
INQUEST (a charity representing bereaved families following deaths involving contact with the police)

Source: C&AG's Report, Figure 24

18.  The IPCC told us that the role of the Advisory Board is to be a 'critical friend' made up of people who have a direct interest in the complaints system, and who are able to provide feedback to the IPCC about how it is organising and running itself.[32] There is a risk, however, that the current balance of representation on the Board could result in insufficient weight being given to the views of complainants and appellants.

22   C&AG's Report, para 2.7 Back

23   C&AG's Report, paras 2.9-2.10 Back

24   C&AG's Report, para 2.12 Back

25   Q 10 Back

26   Qq 31-32 Back

27   C&AG's Report, para 2.13 Back

28   Qq 48-49 Back

29   Qq 14-15, 46 Back

30   Qq 16, 47 Back

31   Qq 51-55; C&AG's Report, paras 3.19-3.21; Ev 11 Back

32   Q 50 Back