Commissioner’s response to HMICFRS PEEL Inspection 2021/22

1. Police and Crime Commissioner’s comments

I’m really pleased to see Surrey Police maintain its ‘outstanding’ rating in preventing crime and anti-social behaviour in the latest Police Effectiveness, Efficiency and Legitimacy (PEEL) report – two areas that feature prominently in my Police and Crime Plan for the county. But there remains room for improvement and the report has raised concerns about the management of suspects and offenders, particularly in relation to sex offenders and the safeguarding of children in our communities.

Managing the risk from these individuals is fundamental to keeping our residents safe – particularly women and girls who are disproportionately affected by sexual violence. This needs to be a real area of focus for our policing teams and my office will provide robust scrutiny and support to ensure plans put in place by Surrey Police are both prompt and robust in making the necessary improvements.

I have noted the comments the report makes about how police deal with mental health. As the national lead for Police and Crime Commissioners on this issue I am actively seeking better partnership working arrangements on both a local and national level, to ensure policing is not the first port of call for those in mental health crisis and that they get access to the proper clinical response they need.

The report also highlights the high workload and wellbeing of our officers and staff. I know the Force is working really hard to recruit the extra officers allocated by government so I am hoping to see that situation improving in the coming months. I know the Force share my views on the value of our people so it is important that our officers and staff have the right resources and support they need.

While there are clear improvements to be made, I think overall there is much to be pleased with in this report which reflects the hard work and dedication our officers and staff display daily to keep our county safe.

I have requested the Chief Constable’s view on the report, as he has stated:

I welcome the HMICFRS’s 2021/22 Police Effectiveness, Efficiency and Legitimacy report on Surrey Police and am very pleased that the HMICFRS has acknowledged the significant achievements the Force has made in preventing crime by awarding the Force a grading of Outstanding.

Notwithstanding this recognition of good practice, the Force recognises the challenges highlighted by the HMICFRS in respect of understanding demand and managing offenders and suspects. The Force is focused on addressing these concerns and learning from the feedback within the report in order to develop the force’s working practices and deliver the best possible service to the public.

The areas for improvements will be recorded and monitored through our existing governance structures and strategic leads will oversee their implementation.

Gavin Stephens, Chief Constable of Surrey Police

2. Next steps

The inspection report highlights nine areas of improvement for Surrey and I have set out below how these matters are being taken forward. Progress will be monitored through the Organisational Reassurance Board (ORB), the new KETO risk management system and my office will continue to maintain oversight through our formal scrutiny mechanisms.

3. Area for improvement 1

  • The force should improve how it answers non-emergency calls for service to reduce its call abandonment rate.

  • Surrey Police continue to prioritise emergency call handling with 999 demand continuing to increase (over 16% more emergency calls received rolling year to date), which is a trend being felt nationally. The Force experienced its highest ever recorded 999 call demand in June this year at 14,907 emergency contacts for the month, but performance in answering 999 calls remained above the 90% target of answering within 10 seconds.

  • This increase in 999 call demand, the continued rise in online (Digital 101) contact and existing call handler vacancies (33 staff below establishment at end June 2022) continues to place pressure on the Force’s ability to answer non-emergency calls within target. The Force has however seen an improvement in 101 call handling from an average wait time of 4.57 minutes in December 2021 to 3.54 minutes in June 2022.

  • The current and future actions taken to improve performance are as follows:

    a) All call handling staff have now returned to a single location in the Contact Centre following previous social distancing requirements which saw them displaced into 5 separate locations.

    b) The Integrated Voice Recorder (IVR) message at the front end of the telephony system has been amended to encourage more members of the public to contact the Force online where it is appropriate to do so. This channel shift is being reflected in the initial abandonment rate and an increase in online contacts.

    c) Staff vacancies within call handling (which are also reflected regionally due to the challenging post-covid labour market within the Southeast) are being closely monitored as a Force risk with several recruitment events having been undertaken over recent months. There is a full course of 12 new call handlers being undertaken in August this year with another induction course currently being filled for October and other courses planned for January and March 2023.


    d) As it takes new call handlers approximately 9 months to become independent the staff budget underspend will be used, in the short term, to employ 12 x agency (Red Snapper) staff to undertake crime recording functions within the Contact Centre to free up the capacity of call handlers, in order to improve 101 call performance. Recruitment of these staff is currently in the planning phase with the aspiration that they will be in place for 12 months from mid to late August. If this model of having a separate crime recording function within the Contact Centre is shown to be effective (rather than call handlers performing both functions) then this will be considered for permanent change to the existing model.


    e) A longer-term proposal to consider the pay structure for call handlers to bring their starting salary in line with regional Forces – to improve both the number of applicants and aid retention – will be considered at the Force Organisation Board in August 2022.


    f) The existing upgrading programmes in telephony and command and control (joint project with Sussex Police) are due to be implemented within the next 6 month and should improve efficiency within the Contact Centre and enable interoperability with Sussex Police.


    g) The Force has plans in place for the introduction of Storm and for Salesforce, both of which will in time bring efficiency and public safety benefits to the Contact Centre and allow the Force to more accurately correlate abandonment with its move to online service.

4. Area for improvement 2

  • The Force needs to attend calls for service within its published attendance times and, where delays do occur, victims should be updated.

    This continues to be a challenge for the Force and the attendance times for Grade 2 incidents have increased since the inspection due to a month-on-month increase in the number of Grade 1 (emergency) incidents requiring response (in line with the increase seen in 999 call demand). As of June 2022, rolling year to date data shows an increase of over 8% in Grade 1s (2,813 incidents) meaning that there are fewer resources available to respond to Grade 2 incidents. This alongside vacancies within the Force Control Room (FCR) has increased the challenge of keeping victims updated when they are awaiting a prompt (Grade 2) response.


    The current and future actions taken to improve performance are as follows:

    a) Demand data analysis has shown that non-emergency (Grade 2) response is particularly challenging at the handover period between “earlies” and “lates” and following relevant consultation the NPT shift pattern will be amended from 1 September to bring forward the late shift start by an hour so that there are more resources available at this critical time of the day.


    b) Additionally, there will be a slight change to the shift pattern for those NPT officers within their probation who must complete a mandatory number of Protected Learning Days (PLDs) as part of their degree apprenticeship. The existing way in which these PLDs are scheduled means that there are often several officers off at once thereby reducing available resources on key days/shifts. Following widespread consultation across both Surrey and Sussex their shift pattern will be amended on 1 September 2022 so that the numbers of officers on PLDs is spread more evenly across shifts thereby providing more resilience on teams. This change was agreed by the Surrey and Sussex Joint Chief Officer Team.


    c) On 25th July 2022 additional Grade 2 cars for response to Domestic Abuse will be introduced on each Division to cover the summer peak demand period until the end September 2022. These additional resources (supported from Safer Neighbourhood Teams) on early and late shifts will provide additional response capability and should improve overall non- emergency response performance for the Force.

5. Area for improvement 3

  • The Force should improve how it records victims’ decisions and their reasons for withdrawing support for investigations. It should take every opportunity to pursue offenders when victims disengage or don’t support prosecutions. It should document whether evidence-led prosecutions have been considered.

  • The current and future actions taken to improve performance are as follows:


    a) An operation to continue to develop investigative quality (Op Falcon) across the Force includes senior leaders – Chief Inspectors up to Chief Officer level completing a set number of monthly crime reviews with results collated and circulated. These checks include whether a VPS statement was taken. Current findings show that this varies according to the type of crime reported.


    b) An NCALT Victim’s Code E learning package which includes VPS has been mandated as training for all officers with compliance closely monitored (72% as at end May 2022).


    c) Details of the Victim Code and related victim guidance are available to all investigators on ‘Crewmate’ App on their Mobile Data Terminals and within the ‘victim initial contact contract template’ within each crime report is a record of whether or not a VPS has been completed and reasons.


    d) The force will seek to identify whether there is an automated method of measuring the offering of and completion of VPS within existing IT systems (Niche) in order to produce detailed performance data.


    e) Work is underway to enhance the current Victim Code training provision to all officers to include specific modules on both VPS and victim withdrawal. To date all investigators within Domestic Abuse Teams have received this training with further sessions planned for Child Abuse Teams and Neighbourhood Policing Teams (NPT).


    f) Surrey Police is working as part of the Regional Rape Improvement Group with one of the workstreams being progressed with partners is guidance about when to take VPS’s. Consultation is ongoing with the regional ISVA services to seek direct feedback on this area and the results of the consultation and agreed stance of the group will be incorporated into local best practice.


    g) In respect of when a victim withdraws support for an investigation or asks for it to be dealt with by an out-of-court disposal out of court disposal (OOCD), the revised (May 2022) Domestic Abuse policy now provides guidance on the content of victim withdrawal statements.


    h) Surrey Police will continue to promote the evidence led approach to investigation and prosecution, securing evidence early and exploring the strength of witness, hearsay, circumstantial and res gestae information. Force communications to staff have been made through intranet articles and bespoke investigator training including the use of Body Worn Video, officer observations, images, neighbour evidence/house to house, remote recording devices (home CCTV, video doorbells) and recordings of calls to police.

6. Area for improvement 4

  • The Force should set specific, time-bound tasks to reduce the risk from registered sex offenders. Evidence of completed tasks should be recorded.

  • The current and future actions taken to improve performance are as follows:


    a) Offender managers have been required to ensure that their RISK management plans are better recorded and their updates in actions and enquiries undertaken are ‘SMART’. This has been communicated by team emails from the DCI, line manager briefings and one-to-one meetings, as well as debriefing visits. An example of a well-documented update has been shared with teams as an example of best practice and the risk management action plans set will be specific. The DI team will Dip Check 15 records (5 per area per month) and now provide additional oversight to Very High and High Risk cases.


    b) Records are being dip-checked by line managers following visits and on supervisory reviews. The DS/PS will verbally debrief visits and review, support, and guide action planning as part of their ongoing supervision. There is additional supervision at point of ARMS assessment. DIs will be doing 5 dip checks per month (all risk levels) and updates will be via our DI/DCI meeting cycle and performance regime – themes and issues identified will be raised through weekly team meetings to staff. Oversight of these qualitative audits will be conducted at the Command Performance Meetings (CPM) chaired by the Head of Public Protection.


    c) The Force had an uplift of staff and there are several new and inexperienced officers in the department. Continual professional development sessions have been developed for all staff to ensure continuous improvement. Future new staff will be briefed and mentored in respect of the required standards


    d) Officers are required to conduct intelligence checks including PNC/PND for all their offenders. Where it is assessed one is not necessary (offender house bound, lacks mobility, has 1:1 supervision with carers), the OM is required to record the rationale as to why a PND and PNC has not been completed. PND is completed at the point of ARMS in all cases regardless. Therefore, PNC and PND research is now carried out commensurate with the risk of the individual, and the results are recorded into the VISOR record of offenders. Supervisory officers now provide oversight and cross-force checks will be undertaken when there is information to suggest that offenders travel out of county. Additionally, Offender Managers are booked on available PND and PNC courses to ensure checks can be conducted by the team expeditiously.


    e) All digital examination of devices is now appropriately recorded, and visits verbally debriefed with supervisors. When decisions are made to not act, this is recorded on ViSOR with a full rationale. Additionally, officers are now clearly recording when a visit is pre-planned due to external factors (e.g. court, loading of monitoring software etc). All other visits, which are the vast majority, are unannounced.

    f) A Force-wide supervisors’ planning day is booked to ensure all supervisors are operating consistently for supervision of visits and recording of the visits. An initial consistent policy has been made by the 3 DIs, but this supervisors’ day is focussed on writing a formal policy on this to ensure consistency for dealing with breaches. The event has been delayed by Covid.


    g) In September-October 2022, the ViSOR coordinators will undertake an internal audit via a dip-check of a number of records and feedback both on further work needed and progress against the above standards. The audit will review 15 records per division from a selection of risk levels to check quality of the records, identified lines of enquiry and standards of rationale. Following this in December-March a peer review from a neighbouring force will be conducted to provide independent scrutiny and assessment. Additionally, contact has been made with “outstanding” forces and VKPP to identify best practice in these areas.

7. Area for improvement 5

  • The Force should routinely use proactive monitoring technology to identify indecent images of children and identify breaches of ancillary orders for registered sex offenders.

  • The current and future actions taken to improve performance are as follows:


    a) Where SHPO conditions are in place, the Force uses ESafe technology to monitor digital equipment of offenders. ESafe remotely monitors usage of the devices and notifies offender managers when there is suspected access to illegal material online. OMs take prompt action to seize and secure devices to obtain primary evidence of these breaches. Surrey is currently using 166 Android ESafe licences and 230 PC/Laptop licences across our high and medium risk offenders. These licences are all fully utilised.


    b) Outside of SHPOs the Force also uses Cellebrite technology to monitor other offenders’ digital devices. Although relatively effective, the kit can take over 2 hours to download and triage some devices which limits the effectiveness of its use. Cellebrite initially required updating and staff retraining to use. VKPP has been utilised to identify alternative options in the market but there is currently no fully effective search and triage equipment available.


    c) Consequently, the Force has invested in training 6 HHPU staff in DMI (Digital Media Investigations). These staff support the whole team in the use and understanding of Cellebrite and of other methods to examine digital devices. These staff hold a reduced workload, so they have capacity to support, advise and develop the wider team. They support other members of the team planning interventions and enhanced visits. Their limited workloads contain offenders that have increased requirement for digital supervision. HHPU DMI staff upskill colleagues to make better use of manual triage skills of offenders’ devices to find grounds to seize and conduct DFT examinations to identify breaches. These methods have proven to be more effective than Cellebrite – given its limitations.


    d) The current focus, therefore, has been officer training and CPD in respect of the manual triage process. The Force has also invested in the Digital Investigation Support Unit (DISU) to provide direct assistance to officers in identifying how to effectively gather digital evidence. HHPU staff are aware of the opportunities DISU can provide and are actively using them to advise and support in respect of offenders that are challenging in this area – formulating strategies for visits and proactive targeting of offenders. DISU is creating CPD to further enhance HHPU staff competency.


    e) Offender managers also utilise ‘digital dogs’ and equipment to interrogate wireless routers to identify undisclosed devices.


    f) All these actions will inform a series of metrics that will be scrutinised for the HHPU at the Command Performance Meetings. The identified issue in respect of consistency of dealing with breaches was covered under AFI 1 where the planning day is in place to formalise the agreed policy for dealing with breaches in a consistent manner.

8. Area for improvement 6

  • The Force must prioritise safeguarding when it suspects online offences of indecent images of children. It should carry out repeated intelligence checks to confirm whether suspects have access to children.


    The current and future actions taken to improve performance are as follows:


    a) Following the HMICFRS inspection, changes were made to the way in which referrals were handled once received in force. Firstly, the referrals are sent to our Force Intelligence Bureau where researchers undertake the research before passing back to POLIT for the KIRAT assessment. A service level agreement was ratified between POLIT and the FIB to agree a turnaround time for research and this is being adhered to. The research is a required precursor information about the location, potential suspect, and any relevant information regarding a family setting.


    b) In total, Surrey currently has a backlog of 14 jobs – 7 of these are being researched. From the other 7 outstanding, there are 2 mediums, 4 lows and 1 pending dissemination to another Force. The force has no Very High or High risk cases outstanding at time of writing. The SLA also includes a refresh of research when a referral has not been actioned for a period – aligned to the current level of risk assessment. However, this has not been required since the SLA was written as all warrants have been actioned prior to this set review period. The duty DS reviews the outstanding list each working day to prioritise interventions and this information is currently scrutinised by the Public Protection Superintending ranks to ensure the procedure is functioning effectively.


    c) Recruitment into the department is ongoing to ensure capacity and Uplift bids have been supported to create further investigative and warrant capacity to ensure future resilience. POLIT is also utilising other additional resources (Special Constables) to support the timely completion of referral warrants.


    d) KIRAT 3 training is being delivered and will be in use from next week. Additionally, several POLIT staff now have access to a limited view of the Children’s Services system (EHM) which enables checks to be completed on any children known at the address to establish if there is already any social services involvement and maximise the effectiveness of the risk assessment and future safeguarding.

9. Area for improvement 7

  • The Force should consider staff wellbeing when making decisions about resource allocation. It should provide supervisors with the skills to identify wellbeing problems in their teams and give them the time and space to make early interventions. The force should improve support for those in high-risk roles.

  • The current and future actions taken to improve performance are as follows:


    a) The Force has heavily invested in improving the Wellbeing offering for staff over the last few years with a dedicated Wellbeing Hub that is easily accessible via the intranet home page as a central place to house all things Wellbeing. The Wellbeing Team will engage with the Surrey Wellbeing Board to scope what the barriers are for accessing the wellbeing materials and time available to use these effectively and determine suitable actions to tackle these.


    b) Wellbeing is also a key part of Focus conversations in which line managers should be having quality discussions to provide support and advice to their teams. However, the force recognises that more is required to promote the importance of these conversations and setting dedicated time aside for these take place and further work is planned to better communicate this. New advice and guidance will be produced for line managers to support this activity.


    c) The Force has mandated a number of training packages for line managers to complete once they are promoted, for example the Effective Performance Management course, has a key Wellbeing input to provide awareness of and how to recognise poor mental health. A review will be undertaken of all of the training packages for newly promoted supervisors to ensure there is a consistent approach that provides greater understanding of what is expected as a line manager to deal with wellbeing. The Force will also make use of the National Police Wellbeing Service, Oscar Kilo, who provide a ‘Supervisors Workshop Training’ package in which our officers have access to participate. Since the report publication the Force has won two national awards for Wellbeing – The OscarKilo ‘Creating the Environment for Wellbeing’ Award, and the National Police Federation ‘Inspiration in Policing’ Award for Sean Burridge for his work on Wellbeing.


    d) The Wellbeing Team will also be introducing a force wide roll out of Trauma Impact Prevention Training (TiPT) to raise awareness of how to spot signs of trauma and provide tools to address these.


    e) Currently the Strategic Resource Management Meeting (SRMM), meet to make posting decisions, these will be made based on:

    o Force priorities
    o Available and deployable resources by area
    o Local intelligence and projections
    o Complexity of demand
    o Risk to Force and public
    o Release will also be based on the wellbeing impact of the individual and those remaining in the team


    f) The Tactical Resource Management Meeting (TRMM) meets in between the SRMM, to tactically review the deployable resources, using local intelligence and consider individual requirements. There is also a Complex case meeting which comprises of local HR leads and Head of Occupational Health, the aim of this meeting is to discuss individual wellbeing requirements, to aim to resolve and unblock any issues. The chair of the SRMM will conduct a review to assess whether the current arrangements fully consider the wellbeing of individuals and how else individuals can be supported through this process.


    g) A project has been commissioned for the Wellbeing Team to thoroughly review the current process of psychological assessments and what value these provide in supporting those in high-risk roles. The team will explore what other assessments are available and work with Oscar Kilo to determine what the optimum model of support Surrey Police should provide.

10. Area for improvement 8

  • The Force should expand the work and effectiveness of its ethics panel to ensure staff know how to raise issues.


    The current and future actions taken to improve performance are as follows:


    a) The Surrey Police Ethics Committee has been completely overhauled and is in the process of being significantly improved. It will meet bi-monthly, focussing on two to three ethical dilemmas per meeting, ensuring that all opinions are considered.


    b) The Force are currently recruiting external people to join as Ethics Committee members and have had thirty two applications from people of all different ages, genders and diverse backgrounds. Nineteen applicants have been shortlisted and interviews commence week of 1st August to make a final selection.


    c) The Force has recently recruited it’s Non-Executive Director to be the Ethics Committee Chair. They are a prominent figure leading Black History Month in the south of England and has a vast amount of experience sitting on the Hampshire Police Ethics Committee and also that of a Housing Association. The prominence of external and diverse members with a range of experiences and an external chair is aimed at ensuring that a range or perspectives are considered and to assist Surrey Police in dealing with the many ethical issues our police service and our people face.


    d) The Corporate Communications Department will be promoting the launch of the new committee which is set for its first meeting in October. They will be introducing a new intranet page about the Ethics Committee – detailing how the committee is set up with internal and external members and details of how they can submit their ethical questions for debate. The Force will also be identifying the current internal members to be Ethics Champions, to lead the way for ethics across the force and ensure that officers and staff are aware of how they can submit those ethical dilemmas for other people’s views. The Committee will report into the Force People’s Board chaired by the DCC and as a Force Non-Executive Director, the Chair has regular direct access to chief officer colleagues.

11. Area for improvement 9

  • The Force should improve its understanding of demand to make sure it manages it effectively

  • Over the past year Surrey Police has developed a detailed demand analysis product for Local Policing teams, identifying demand on reactive teams (Neighbourhood Policing Team, CID, Child Abuse Team, Domestic Abuse Team) and proactive teams (specifically Safer Neighbourhood Teams). Reactive demand has been assessed by analysis of numbers of crimes investigated by each team according to crime types, PIP levels and whether DA offences are intimate or non-intimate, compared to the number of staff in each team’s establishment. Proactive demand on Safer Neighbourhood Teams has been assessed by a combination of calls for service allocated to specific teams via the Incident Review Team, and the Index of Multiple Deprivation, which measures relative deprivation by Lower Super Output Areas, and is widely used by government and local authorities to allocate funding for services. The use of the IMD allows Surrey Police to allocate proactive resources in line with hidden and latent demand and build relations with disadvantaged communities. This analysis has been used to review staffing levels in all Local Policing Teams and has so far led to reallocation of CID and NPT resources between divisions.

  • Surrey Police’s focus is now on analysing demand in more complex areas of business, such as Public Protection and Specialist Crime Command, using methods developed for Local Policing, beginning with an assessment of available data, and a gap analysis to identify other datasets that might be useful. Where appropriate and possible, the analysis will use detailed total crime demand while, in more complex or specialist business areas, proxies or indicators of relative demand may be necessary.

Signed: Lisa Townsend, Police and Crime Commissioner for Surrey