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Transforming Professional Standards

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A note on the following document - Transforming Professional Standards in

Cleveland Police

This cover note was attached by Will Green, Head of Corporate

Communications, on Monday January 23rd 2017.

At the beginning of January 2017 the Chief Constable of Cleveland Police and the

Police and Crime Commissioner for Cleveland made clear their intention to transform

the way in which Cleveland Police handles and investigates complaints made

against its officers and staff and how it polices its workforce.

So what exactly will the future look like? And how long will this transformation take?

John Armstrong has been commissioned to lead Cleveland Police through this

transformational change and has set out his proposal of how he sees this work

taking shape. Transparency and accountability will be at the core of this approach,

and so John’s proposal is set out here. John is taking a hands-on approach and has

already started to work closely with all those involved in professional standards and

with those who have an interest in helping shape its future.

John’s proposal starts by setting out the role of a professional standards department

in a wider policing context before moving on to outline the case for reform. He sets

out the fundamental principles that will underpin this transformational work: building

organisational effectiveness, increasing transparency in assessments and decision

making, and engaging with internal and external stakeholders. John will be advising

on how Cleveland Police can widen the scope of its professional standards, to

include taking a leading role in all matters of policing standards and organisational

learning rather than at present, a department focused on complaint management

and dealing with misconduct.

These initial phases of this work have already commenced and will continue in the

coming months as John helps the force to be clear on exactly wants it professional

standards to look like in the future, and how it wants it to operate.

Please note that although John’s initial document sets out a provisional timetable,

this was put together as an initial concept and no set timescale is currently in place.


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in Cleveland Police

Scope, methodology and terms of

reference

Author:

John Armstrong

January 2017


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Transforming Professional Standards in Cleveland Police

A proposed approach to reform

Context

1. In common with every police force, Cleveland Police has a Professional Standards

Department (PSD) that also includes a counter corruption function. The present form

and function of PSDs are largely the product of a series of reforms going back over the

past decade. Chief influences and drivers for change at that time - and since - include:

The police service’s response to HMIC report Raising the standard: a thematic

inspection of professional standards (2006) 1 which focused on the structures,

activities and resourcing of PSDs, highlighting disparities in police complaint and

misconduct recording practices across England and Wales, from which came

standardised recording practices; the inclusion of counter corruption units with

intelligence, preventative and enforcement functions; and police community vetting

units as an integral part of PSDs.

The increasing influence and coordination of the (then) ACPO Professional

Standards Portfolio 2 with its national working groups on Complaints and

Misconduct, Counter Corruption (ACCAG)3 and more latterly, the Vetting Working

Group. In 2014, following the transition of ACPO to the National Police Chief’s

Council (NPCC), this Portfolio became enjoined to form the present National

Policing Professional Standards and Ethics Portfolio.

Reforms brought about by the Taylor review (2005)4 which modernised the police

disciplinary system, bringing it more into line with employment law principles and

which led to the regulatory framework of the Police (Conduct) Regulations 2008

and more latterly the 2012 Regulations, and the parallel implementation of Police

(Performance Regulations).

1 Raising the standard: a thematic inspection of professional standards, HMIC, London, 2006

2 Now the National Policing Ethics and Professional Standards Portfolio

3 ACPO Counter Corruption Advisory Group, which itself was borne from the ACPO presidential task force on

police corruption in 1999 4 Taylor, W. Report into disciplinary arrangements for the Police Service in England and Wales (2005) Home

Office


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The establishment of the Independent Police Complaints Commission (IPCC) in

2004.5 The primary statutory purpose of the IPCC is to secure and maintain public

confidence in the police complaints system in England and Wales. The IPCC has

become an increasingly important stakeholder in the PSB landscape across all

matters of public complaint, police misconduct and cases of death or serious injury

during or following police contact.

The work of individual and collective forces in becoming more proficient and adept

at improving their own professionalism and standards of integrity. Such initiatives

have continued - and are continuing - to evolve as increasing accountability,

transparency and professionalism remain high on force agendas.

2. In many forces throughout England and Wales, PSDs have progressed from being

departments solely or predominantly focussing on complaint management and

enforcing discipline to taking a more holistic approach to professional standards. At the

same time, the remit of Heads of PSD in all forces has invariably broadened to include

responsibility for matters such as information security, legal services, grievances,

unsatisfactory performance cases, employment tribunals, civil claims, complaints

about how the force is operated, led and managed,6 operational review and critical

incident management and in some forces, wider human resource functions. In some

instances, such expansion of scope has been identified as good practice and has

enhanced PSD legitimacy; in other cases, such diversification of role has tended to

lead to a diminution of effectiveness of core PSD responsibilities.

3. This landscape is constantly evolving. A recent survey7 of forces in England and

Wales reveals that 24% of PSDs have formed formal collaborations or strategic

alliances across one or more forces, either in full or in part. The same survey showed

a further 10 forces report they plan to actively consider such collaboration or alliances

during the coming year.

4. However broad or narrow the focus of its responsibilities, a primary function of any

PSD should be to safeguard the force’s reputation, not only by enforcing and

maintaining the standards of professional behaviour of individual members of the wider

5 As set out in the Police Reform Act 2002

6 Previously known as ‘direction and control’ matters

7 Complaints and Misconduct Working Group Stocktake Survey (unpublished), December 2016


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workforce, but also by fearlessly and actively exposing organisational or operational

shortfalls or wrongdoing whenever and wherever it occurs and thereby promote

learning and adherence to the highest possible standards of service. A successful and

effective PSD ought to be as familiar and adept at catching people ‘doing the right

thing’ as well as identifying and intervening where individual or force standards and

behaviours fall short of expectation.

5. Fair, consistent decision-making and respectful treatment of the public by the police

are essential components of police legitimacy, which, in turn, encourages people to

cooperate with the police and uphold the law. The twin concepts of fairness and

respect apply equally within police organisations and have a similar effect on the

attitudes and behaviour of the workforce.8

6. Fairness at a supervisory and senior leadership level is associated with officers and

staff adhering to high ethical standards, promoting integrity in policing, valuing the

public and feeling empowered to go the extra mile without personal gain. Fair and

respectful treatment encourages officers and staff to identify with the organisation and

its values, rather than a police subculture. Any real or perceived lack of fairness and

respect within a PSD will undermine both its effectiveness and its legitimacy.

7. The promotion and maintenance of high ethical standards across any force is not, nor

should it be, the sole responsibility of a PSD. Notwithstanding that less serious

breaches of the standards of professional behaviour of officers and staff as set out by

the Code of Ethics9 and relatively minor examples of misconduct are dealt with by

locally based supervisors and managers, PSDs generally assess and investigate the

more serious allegations of misconduct, gross misconduct and criminality of the wider

workforce, including corruption in all its manifestations. There ought therefore to be

clarity and consistency across the organisation as to thresholds of referral to a PSD.

Transparency and openness in referrals and assessments of conduct, and the

provision of updates and feedback to those who report known or suspected instances

of corrupt or improper practices are all hallmarks of a PSD in which a force has

confidence, which in turn contributes to creating and maintaining high standards of

professional behaviour.

8 Quinton, P., Myhill, A., Bradford, B., Fildes, A. and Porter (2015) Fair cop 2: Organisational justice, behaviour

and ethical policing. Ryton-on-Dunsmore: College of Police 9 Code of Ethics: - A Code of Practice for the Principles and Standards of Professional Behaviour for the Policing

Profession of England and Wales, College of Policing, London, 2014.


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8. Any unwarranted level of internal unfairness, whether real or perceived, will pose a

significant reputational risk to the force because of its detrimental effect on staff

attitudes and behaviours. The positive impact of both fairness and respect on

workforce attitudes and behaviour will far exceed that of the more traditional incentive-

based or sanction-based approach, which run the risk of fostering unthinking

compliance with the rules even when officers thought it might be the ‘wrong thing’ to

do. Promoting and improving internal organisational justice will improve public

confidence in the police service and improve levels of satisfaction with service delivery

to victims and all who receive a service from Cleveland Police.

9. The naturally complex nature of policing with ever increasing emphasis on public

accountability and transparency means that the issue of ethics is always central to

corruption and misconduct control. The social and political environment in which any

force operates with its challenges of policing diverse communities with a

commensurate degree and complexity of organised criminality means ever-present

challenges to the professionalism of its workforce. The economic landscape forces

continual focus on increasingly scarce resource allocation and innovative ways of

working.

The case for reform

10. Both the Chief Constable and the Police and Crime Commissioner (PCC) for

Cleveland Police have a long-standing commitment to reform of PSD. In his Police and

Crime Plan 2016-2020, PCC Mr Barry Coppinger set out his “aim for Cleveland Police

to be a national lead in terms of professional standards and the way in which we

handle complaints. I will hold the Chief Constable accountable for embedding the code

of ethics and shaping an innovative programme of development across the whole

organisation.”10 Barry Coppinger’s commitment extends to working in collaboration to

establish a new approach to the way complaints and professional standards are

handled including expanding the role of the PCC’s office in police complaints handling,

and working with the Chief Constable to review and develop the PSD to ensure

Cleveland has the best model possible.

10

http://www.cleveland.pcc.police.uk/Document-Library/Police-and-Crime-Plan/2016-17/Police-and-Crime-Plan-DOUBLE-SPREAD.pdf




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11. Chief Constable Iain Spittal had planned a formal review of Cleveland PSD to

commence in January 2017 as part of the force Towards 2020 programme. On 22

December 2016, CC Spittal set out his strategic intention for transforming professional

standards in Cleveland Police.11 The ending of a high public profile misconduct hearing

in mid-December highlighted what CC Spittal believed to significant weaknesses in the

ability of the current PSD to undertake and deliver consistent high quality

investigations and gave rise to a pressing need for Cleveland Police to undertake a

fundamental shift in how it responds to complaints from the public, how it deals with

allegations of misconduct, how it proactively tests the integrity of its workforce, and

how it undertakes activity to prevent wrong-doing by its officers and staff.

12. CC Spittal raised his concern that under existing PSD structures, Cleveland Police was

unlikely to promote confidence in its workforce and in the community it serves that it is

a learning organisation and one capable of effectively investigating complaints,

misconduct allegations and preventing wrong doing by those who work as part of the

organisation. In setting out his broad vision, CC Spittal commissioned an independent

review to put into place a transformed PSD that would operate as follows:

directly support the principles established under the Everyone Matters 12

programme

be the organisational lead for officer, staff and volunteer conduct and behaviour

have appropriate ethical separation from the force so as to build confidence both in

the communities served and in those who work for Cleveland Police

operate in a manner that stimulates individual behaviours that are seen to reflect

the recognised ‘duty of candour’ that already exists within Health Service

organisations in the UK

support the development and embedding of a culture that seeks to learn from

mistakes

seek to prevent the likelihood of criminal or misconduct action or activities

occurring within the organisation, and should undertake misconduct proceedings

only where proportionate and necessary

expeditiously respond to complaints from members of the public in a manner that

starts from a position of service recovery where the needs of the complainant are

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Professional Standards: Time for a new approach, Chief Constable Iain Spittal internal force document, December 2016 12

Everyone Matters is Cleveland Police’s approach to equality, diversity and human rights set out in earlier 2016 across 3 strategic themes; serving our communities, supporting our people, and organisational processes


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recognised. Where possible, complaints should be resolved in this service

recovery approach. The review should take into account the forthcoming

anticipated legislative changes13 to propose an interim complaints handling model

which could seamlessly progress to delivery which is facilitated through the shortly

to be enacted change in legislation. i.e. one where the PCC undertakes a more

significant role in complaint handling

operate and be seen to operate in a way which demonstrates the value of quality

of service

be constructed in a manner that enables effective, proactive seeking out of corrupt

practices within the organisation

be resourced by officers and staff who are professionally competent and

demonstrate sound ethical practice

13. CC Spittal made clear the structure and model of delivery is to be shaped through

review activity, and that the review will benefit from support independent of the police

service. The review will be supported significantly by PCC Barry Coppinger, and will be

jointly co-directed by Deputy Chief Constable Simon Nickless and Mr Simon Dennis,

Chief Executive of Cleveland OPCC.

14. In short, and whilst not directly referenced in CC Spittal’s Time for a new approach

document, the case for PSD reform in Cleveland Police is further driven by the

adverse impact of a number of PSD related concerns driven from both internal and

external sources which, when taken collectively, present a high level of risk to force

reputation and which, in the absence of transformational change, will likely lead to a

significant loss of confidence in Cleveland Police’s ability to police its communities.

15. The force has suffered recent reputational damage in cases attracting high levels of

local, regional and national media commentary. These include the findings of an

employment tribunal (Saddique –v- Chief Constable of Cleveland Police) in which an

officer was awarded a significant sum of money in compensation for claims brought for

victimisation and discrimination. The 2015 Employment Tribunal upheld 16 separate

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The Policing and Crime Bill 2016 received Royal assent earlier in December 2016. Part 2 of the Bill will give PCCS increased involvement in complaint handling. PCCs will become the relevant appeal body for those appeals against the outcome of complaints or local resolution based appeals that since 2012 have been handled by chief officers. PCCS will have further options under the Bill to take enhanced responsibility for recording and resolving complaints, as well as options for responsibility for communicating with complainants.


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allegations of discrimination, concluding that Mr Saddique had been victimised

because of his previous complaints and discriminated against because of his race. The

IPCC is currently independently investigating conduct matters against Cleveland PSD

officers associated with the handling of this case.

16. Earlier in December 2016, the Investigatory Powers Tribunal indicated it would find

Cleveland Police to have acted unlawfully in securing telecommunications data of

former officers and journalists in its attempts to investigate alleged leaks of police held

information.

17. On 12 December 2016, the appropriate authority withdrew allegations of breaches of

standards of professional behaviour against one of its officers Sergeant Waseem Khan

during the course of a misconduct hearing held in public.

18. Cleveland PSD’s investigation and handling of this particular case over the course of a

three-year period received censure, most notably failings in investigative record

keeping, review and disclosure as well as concerns over the manner in which a former

member of PSD had allegedly conducted himself during the course of the

investigation. The Khan investigation is to be subject of a separate organisational

learning review.

19. CC Spittal’s assessment summarises a number of key questions repeatedly asked of

PSD, all of which demand scrutiny and further insight to determine the extent to which

supporting evidence and experiences exists to suggest these are causes or symptoms

of the prevailing culture within PSD. Put simply and starkly, these questions include:

Lack of regulatory compliance

Investigative disproportionality

Wittingly or unwittingly incognizant of discrimination issues

A lack of desire to respond or evolve

20. The report of HMIC’s most recent thematic inspection 14 of police integrity and

corruption in November 2014 highlighted, inter alia, that Cleveland Police’s PSD had

effective processes and governance, and found there to be no bias evident in its

investigation of complaints and allegations. HMIC made two recommendations; that

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Police Integrity and Corruption: Cleveland Police (November 2014)


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the force should ensure it has an effective process to communicate to all staff both

locally and nationally identified lessons to be learned on integrity and corruption; and

that the force should ensure that it has the proactive capability to effectively gather,

respond and act on information which identifies patterns of unprofessional behaviour

and corruption.

21. There is some resonance on these recommendations in a subsequent HMIC

inspection on police legitimacy in December 2016, when HMIC found that Cleveland

Police requires improvement in respect of how legitimate it is in keeping people safe

and reducing crime.15 Specifically, in respect of PSD related issues, HMIC found that

Cleveland Police needs to improve the steps it takes to ensure its workforce behaves

ethically and lawfully. Notwithstanding the workforce was found to be aware of the

standards of behaviour expected of them, and that all staff had received some briefing

or training on the Code of Ethics, HMIC found the counter-corruption unit to have

limited resources to conduct any proactive intelligence gathering, and the recording

and the force’s assessment of intelligence was not comprehensive.

22. Areas for improvement identified by HMIC included: (i) The force should ensure it

complies with all aspects of the current national guidelines for vetting; (ii) The force

should review the capacity and capability of its counter-corruption unit to ensure it can

manage its work effectively; and (iii) The force should improve the way corruption

intelligence is assessed, graded and stored.

23. The case for more fundamental and wide-ranging PSB reform is further strengthened

by the external drivers in police complaints and disciplinary reform. PSBs have had to

manage and adapt to a series of reforms in recent years brought about by:

the increased transparency and public accountability of misconduct procedures

the strengthening of the capacity of the IPCC to undertake more independent

investigations

increased police service, public, media, and governmental focus on improving

police integrity and ethical behaviour (some of which has been undertaken

proactively, and other aspects more reactive in nature to events)

15

PEEL: Police legitimacy 2016 – an inspection of Cleveland Police http://www.justiceinspectorates.gov.uk/hmic/wp-content/uploads/peel-police-legitimacy-2016-cleveland.pdf

http://www.justiceinspectorates.gov.uk/hmic/wp-content/uploads/peel-police-legitimacy-2016-cleveland.pdf


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changes to the landscape and framework of complaint management and

appeals arising from the Police Reform and Social Responsibility Act 2011

further reforms to the police disciplinary system, including the introduction of a

voluntary based Disapproved Register for officer dismissed or who leave the

service during the course of an investigation into gross misconduct (December

2013), misconduct hearing held in public (May 2015) and the introduction of

independent, legally qualified chairs for misconduct hearings (January 2016)

24. The latest legislative and regulatory reforms which will impact significantly upon PSB

capacity and capability is brought about by Part 2 of the Policing and Crime Bill 2016.

Secondary legislation to implement these reforms is due to commence in the early part

of 2017. These statutory reforms are rooted in HM Government’s response to

widespread consultation in 2014 and 2015 on reforming the complaints and discipline

systems. Whilst some finer detail is yet to be determined, the main headlines for

conduct matters will be:

amending police regulations to allow gross misconduct investigations to

continue after an officer has resigned or retired (together with an early repeal of

the Regulation 10A) and extending the conduct regulations to include former

police officers so that misconduct cases can be taken to a conclusion,

notwithstanding an officer’s departure from the force

the placing of the Disapproved Register on a statutory basis which will make it

mandatory to refer to the College of Policing the names of officers dismissed

and allow publication of names of barred officers (the Police Barred List) and a

second non-public facing list of those officers who were not dismissed but who

resigned during the course of an investigation (the Police Advisory List).

further protections for those in the service reporting concerns of corrupt or

improper practice

the increased involvement of PCCs in complaint recording and resolution and

communications, and the handing over of appeals against investigation

outcome and local resolution from chief officers to PCCs

the IPCC is having a fundamental re-structuring and will become the

Independent Office of Police Conduct under a Director General. Further powers

for the IPCC will follow, including a requirement for the IPCC to independently

investigate all cases involving chief officers, and the granting of powers to the

IPCC to present its own cases to disciplinary hearing panels


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25. Perhaps the most impactive of these latest reforms will be those involving complaint

management procedures to include a stronger and more involved role for PCCs, as

this may have more profound resourcing and financial impact on PSD role and

responsibilities. Considerable work and negotiation will be required to determine the

extent to which Cleveland’s PCC will wish to become involved in and take

responsibility for the administration, handling, and resolution of mainstream complaints

about conduct and service.

26. What is also apparent is there will be a re-definition of the relationship between:

local force Appropriate Authorities

PCCs

the College of Policing

National Policing Professional Standards and Ethics

the IPCC

27. It is worth concluding this contextual overview by focusing on the more general nature

of policing and the means by which it is successfully governed. Whilst such issues

raise necessary questions about institutional structures and powers, the reality is that

much of this also boils down to not only the values and ethics set out by CC Spittal in

his Time for a new approach strategic intention, but also what the wider internal and

external stakeholders of Cleveland Police wants its internal policing function to look

like, and how it wants to operate in order to promote confidence in its legitimacy.

Proposed Reform Methodology

28. Placing ethical scrutiny at the heart of all PSD operational and case management

decision making and the recruitment, selection, training and continuous professional

development of all within the PSD environment is vitally important to the development

of a culture that is not only intolerant of corruption, but is able to operate with internal

and external legitimacy. Such intolerance requires clear, consistent and robust

management which can operate with independence but under a framework of external

oversight and governance. Evidence and experience points to corruption and


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unsatisfactory performance flourishing where management, scrutiny and governance

is lax or insufficient.

29. Two simple questions: “What do we want the PSD to do?” and “How do we want

them to do it?” form the basis of this Proposal for Reform, to be considered over four

distinct phases. Answering the question “What do we want the PSD to do?” will

establish the scope for PSD, enabling it to establish clear expectations of what it will

and will not provide to each of its key stakeholders. Answering “How do we want them

to do it?” will provide PSD with the processes and controls to ensure and assure

stakeholders that services are being delivered effectively and to established standards.

30. The methodology includes three fundamental design principles for a transformed PSD:

(1) Organisational effectiveness – to assure consistent and appropriate outcomes

As evidenced by:

Robust processes and procedures to resolve complaints, conduct and DSI

matters, including critical control points and documented procedures

Clear accountability, responsibility and authority for decision-making within a

defined Scheme of Delegation and Governance

Robust performance scrutiny and internal challenge that ensures high quality

investigations and casework

An ability to operate in a timely and consistent fashion across all aspects of

assessments and casework

(2) A culture of integrity, fairness and impartiality – to assure reputation

As evidenced by:

Strict adherence to the regulatory and legislative framework

Demonstrable, auditable transparency in decision making and procedures

Appropriate internal and external mechanisms to provide challenge and

accountability

Clear and consistent reporting structures

(3) Constructive and positive stakeholder engagement – to maintain and enhance

relationships


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As evidenced by:

A clear and current understanding of internal and external stakeholder

perspectives

Regular engagement with stakeholders, especially those who have least

confidence in the police complaints and misconduct system

A willingness to respond to constructive commentary and to influence

improvements in policing standards

31. Each of the four project phases will be overseen by the co-directors in a governance

structure that will both approve work and provide guidance and direction for future

activity. The phases and timescales are purely indicative at this stage.

Phase 1: Current Service analysis and assessment

Timescale: early to late January 2017

Analyse and assess PSD current operating model, practices and outcomes

Identify recognised good regulatory and complaint management practice from

both within and without the police service

Key stakeholder engagement and PSD engagement

Phase 2: Best Practice Proposal and Outline Design

Timescale: late January 2017 to mid-February 2017

Define principles to be applied in the design of future PSD

Develop proposed Governance framework

Develop high level organisational design for PSD

Phase 3: Operational Service Design

Timescale: mid-February 2017 to mid-March 2017

Define each operating model component, applying approved design principles

Define Governance arrangements and controls


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Phase 4: Implementation Planning

Timescale: mid to end March 2017

Develop and deliver implementation plans

32. Project management will be tailored to dovetail with existing Cleveland Police

methodologies for transformational change as directed by DCC Nickless and Mr Simon

Dennis.

33. It is anticipated the review will benefit from input from the Joint Independent External

Ethics Committee of Cleveland Police and Durham Constabulary, and also from further

external and independent input from those with expertise in professional conduct or

complaint management in other public or private sector organisations.

34. As it is beyond doubt that stakeholder confidence will be a critical success factor for

any reformed PSD, consideration ought to be given to establishing a Reference Group

that will comprise individuals selected as subject matter experts and to represent

members of the community, and to include representation from Cleveland Police

officers and staff who are most directly impacted by Professional Standards and the

services it provides.

35. The buy-in and involvement of the present PSD senior management throughout the life

of the reform project and beyond will be a further critical success factor. The role of

any such Reference Group will be to provide oversight of all proposals for Professional

Standards reform and to provide assurance that proposed reforms will enable

Professional Standards to meet the needs of the community, and Cleveland Police

officers and staff.

36. It is anticipated the involvement of the author (as subject matter expert) is likely to be

on a 2-4 day per week basis on average throughout the life of the project. Particular

phases and workloads may lead to a short-term reduction, or conversely, an increase

of involvement or capacity. CC Spittal has aligned Cleveland Superintendent John

Lyons to the review on a full time basis, who will ensure named officers or staff at

suitable levels of seniority are appointed as points of contact in those departments that

are integral to the scope of this project.


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Concluding remarks

37. It is beyond the scope of this outline approach document to suggest exactly what a

reformed Cleveland PSD will look like, or what it ought to look like, and what its core

roles will be other than it will of course include the elements set out in CC Spittal’s

Time for a new approach strategic intention. The whole point of this structured

approach is to ensure stakeholder consultation and engagement as a theme

throughout, and that stakeholder views are taken into account.

38. A measure of success of cultural and structural reform will be the increased internal

and external confidence in the PSD and, in particular, reassure those working within

PSD they are able to discharge their responsibilities in a fair and consistent manner

which will engender the respect of the wider force and the communities it serves, and

will leave Cleveland Police’s PSD better placed to:

Protect the public and the workforce from any lack of professionalism

Ensure public confidence in the reputation of the force by more transparent

policing of high professional standards

Demonstrate to colleagues and to the public that misconduct or corrupt or

improper practices in any of their many manifestations will be identified and

dealt with expeditiously, fairly, robustly and above all, professionally

John Armstrong

January 2017

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