28 March 2014

Initial Response to the Crawford Review I would like to thank Catherine Crawford for conducting this extremely important independent review to look at how complaints and conduct issues are handled by the West Yorkshire Police. ' nsuring integrity' in West Yorkshire Police is a vision set out in the Police and Crime Plan !"#$%#& and this independent review fulfils an important commitment made by me to the people of West Yorkshire to ensure integrity and to improve public trust and confidence in policing across the county. It is supported and welcomed by the Chief Constable of West Yorkshire Police 'ark (ilmore. )he review is clearly informed by thorough knowledge* research and consultation* is succinct and provides practical suggestions for improving current processes and practices both within West Yorkshire Police and within the +ffice of the Police and Crime Commissioner ,+PCC-. I will be discussing in .uick time with the Chief Constable how he would like to progress the findings of the review and where it is my responsibility will implement the findings immediately. /s Catherine Crawford points out* this independent report comes at a time of public concern about integrity and openness in the police service and I will make sure that my response is no mere tick box exercise. +f course this will be made more challenging given the further resources being taken from the West Yorkshire policing budget following the 0ome +ffice decisions to top slice the Police 1tandards 2epartment. )his response also has to be set

within the context of the police complaints system itself which the report found to be deeply unhelpful* legalistic and encouraging of confrontation and defensiveness* leading to extended timescales which are unfair and frustrating for officers as well as complainants. I wholeheartedly agree with this analysis of the current system for handling police complaints and I call upon the (overnment to fundamentally look again at the overarching framework. I was very pleased to note from Catherine Crawford3s accompanying letter that* while it has suffered historically from a reputation for responding 4inade.uately5 to complaints* West Yorkshire Police is not significantly different from other comparable forces and the review found nothing of concern that is specific to West Yorkshire. I was also greatly re%assured to receive the report3s une.uivocal finding that my staff and I take our responsibilities in respect of complaints very seriously and that we are clear that the public need confidence in their operation and that there were no matters arising within the course of the review that indicated potential conduct matters involving officers and6or staff of the West Yorkshire Police and6or the +ffice Police and Crime Commissioner for West Yorkshire.

/s the report also says* we should always learn lessons from the past wherever possible and continue to apply this learning going forward. I agree entirely with the view that the single most important success factor for the Professional 1tandards 2epartment is the genuine and unwavering commitment of the Chief Constable and the senior team to its work. I am aware that the Chief Constable has already made significant improvements in the area of standards and conduct and I will support him in making further improvements going forward.

)urning to some of the specific issues* I note the finding that the oversight and .uality assurance role by my office urgently needs more staff resource* with direct access to West Yorkshire Police I) systems and data bases. I will raise this with the Chief Constable as a priority along with the report3s further observations about improving .uality assurance* the way in which communication is handled and providing updates about progress. )hese points will be picked up within the relevant policies and practices of the +PCC immediately. In addition* I have already met with 0er 'a7esty's Inspector of Constabulary ,0'IC- to seek his help in assessing the capability and capacity of the Professional 1tandards functions in West Yorkshire Police and to consider ways in which the structure* monitoring and governance arrangements for complaints might be improved* along with integrity testing and reporting mechanisms. I will agree the full terms of reference of this piece of work with the Chief Constable and 0'IC over the coming weeks. +n the point of communication* there is one part of the report that should resonate with everyone providing public services. It is difficult to argue with the paragraph that says8 4If all those involved took two minutes to read (preferably out loud!) through every letter sent out to check if it would make sense to their own mother or next door neighbour, everyone would benefit. )he report also rightly advocates that we need to get it right in the first place and that many complaints could have been avoided with an apology at the time. I completely agree that regular updates about progress are essential and as the Chief Constable and I are in the process of reviewing our communications the need for feedback and the potential role of the website

and social media in the wider communications around complaints is a helpful and timely reminder for that process. In terms of further opportunities* there are two key areas where the report suggests West Yorkshire is uni.uely placed and recommends further exploration and investment. )he first recognises innovative research looking at the use of mediation in police6community disputes. )he Crawford report concludes 4there is huge scope for this work to be taken further with a view to reshaping both the practice of complaints and conduct handling in forces and the legislative framework.5 )he second uni.ue opportunity for innovation involves the use of a complaints triage system to provide a guide through the complexities of recording and disposal decisions* 4 based on an extension of the highly regarded olice !ational "egal #atabase ( !"#) .5 I will work with the Chief Constable to look at ways to involve people from our communities more to provide independent scrutiny of the integrity of the police service* to review and comment on complaints handling and to potentially act as intermediaries in the early resolution of disputes between the police and complainants. I have already revised the arrangements for sharing information but will continue to work with the Police and Crime Panel to look at ways the Panel and other partners could provide greater support in this regard. )hat the West Yorks +PCC has uni.ue experience and expertise in handling and advising on sensitive and contentious conduct matters locally and nationally* while West Yorkshire Police is a strategic lead force for the region* and nationally* is identified in the review. We are therefore together very well placed to take forward some of the suggestions and learning from this review.

Catherine Crawford however* also made it clear that her report is intended as a means of instigating discussion and exploration and not the end of the process. I will continue to work with colleagues locally* regionally and nationally to explore further opportunities for improvement to ensure a fair* transparent and responsive system for handling complaints* criticisms and allegations and to establish better public trust in the police service. In the wider context of the police complaints framework* I will share this report with the 0ome +ffice and I would urge ministers to take the earliest opportunity to reflect on the findings and 4overhaul5 the current police complaints process. I will also share the report with the College of Policing to support us in making sure that we are learning the lessons of the past and putting things right for the future.

I instigated this review with the support of the Chief Constable with the intention of implementing the findings. )here are suggestions for improved working that can be implemented with immediate effect and others need to be considered over a longer period. I have asked my Chief xecutive to work with the Chief Constable and his team to set out an implementation plan in the coming weeks and report back regularly as both the Chief Constable and I agree that the public and the police themselves need to be reassured that the findings in this review will form part of our work%plan going forward. 921