Narrative – IOPC Complaints Information Bulletin Q2 2023/24

Each quarter, the Independent Office for Police Conduct (IOPC) collects data from police forces about how they handle complaints. They use this to produce information bulletins that set out performance against a number of measures. They compare each force’s data with their most similar force group average and with the overall results for all forces in England and Wales.

The below narrative accompanies the IOPC Complaints Information Bulletin for Quarter Two 2023/24:

The Office of the Police and Crime Commissioner continues to monitor and scrutinise the complaint management function of the Force. This latest Q2 (2023/24) complaint data relates to the performance of Surrey Police between 01 April to 30 September 2023.

Allegation categories capture the root of the dissatisfaction expressed in a complaint. A complaint case will contain one or more allegations and one category is selected for each allegation logged.  Please refer to the IOPC Statutory guidance on capturing data about police complaints, allegations and complaint category definitions. 

The Office’s Complaints Lead is pleased to report that Surrey Police continue to perform exceptionally well in relation to logging of public complaints and contacting complainants. Once a complaint has been made, it has taken the Force an average of one day to both log the complaint and between 1-2 days to contact the complainant.

Surrey Police logged 1,102 complaints and this is 26 fewer complaints than recorded during the Same Period Last Year (SPLY). It is also similar to MSFs.  The logging and contact performance remains stronger than MSFs and the National Average, that is between 4-5 days (see section A1.1).  This is the same performance as last quarter (Q1 2023/24) and something that both the Force and the PCC are proud of.  However, an area that your PCC continues to be concerned about is the percentage of cases logged under Schedule 3 and recorded as ‘Dissatisfaction after initial handling’.

Following the Q1 (2023/24) data release, the OPCC Complaints Lead secured an agreement of the Force to conduct a review so it could understand why this was the case.  This is an area that has been an issue for a while.  Surrey Police are an outlier, with 31% of cases recorded under Schedule 3 following dissatisfaction after initial handling.  This is nearly double compared MSFs and the National Average who recorded 17% and 14% retrospectively.  We still await the finding of this review and is an area your PCC continues to pursue.  Customer service and high-quality complaint handling is an area the PCC is keen is not compromised.

Although the Force should be praised for making improvements in overall initial complaint handling timescales, a further area worthy of exploration is the number of allegations logged (see section A1.2).  During Q2, the Force recorded 1,930 allegations and 444 allegations per 1,000 employees.  The latter is higher than the SPLY and MSFs (360) and National Average (287).  It could be that the MSFs/National Forces are under-recording allegations or that Surrey Police are generally over-recording.  A review of this has been requested and we look forward to providing an update in due course.

The areas complained about are broadly similar to the areas SPLY (see chart on ‘what has been complained about at section A1.2). In relation to timeliness during Q2, we praise the Force for reducing the time taken by three days in which it finalises cases outside of Schedule 3.  It is better than MSF and National Average. This follows improvements also made during Q1 and is worthy of mention as the unique operating model within the PSD seeks to deal effectively with complaints at initial reporting and where possible outside of Schedule 3.

Moreover, the Force has reduced by 46 days (204/158) the time it takes to finalise local investigation cases recorded under Schedule 3.  During Q1 and as previously referenced during Q4 (2022/23) data, the Force actually took longer than MSFs/National Average to finalise cases recorded under this category (200 days compared to 157 [MSF] and 166 [National]).  Scrutiny by the PCC that revealed resourcing challenges within the PSD department seems to have now been resolved and is having a positive impact on timeliness.  This is an area the Force continue to monitor and is looking to make continual improvements, especially with ensuring investigations are timely and proportionate.

In relation to allegation handling, the Force dealt with 40% of allegations outside of Schedule 3.  This demonstrates the Forces’ desire to deal with complaints as quickly and to the satisfaction of the complainant as possible.  Dealing with complaints in this manner not only provides the complainant with a satisfactory resolution but allows the Force to focus on those cases that actually require investigation in a thorough and timely manner.

When the IOPC receives a referral from the force, it reviews the information they have provided. The IOPC decides whether the matter requires an investigation, and the type of investigation.  Referrals may have been completed in a different period to when they were received.  Where a referral is made by the Force on a mandatory basis but does not meet the mandatory referral criteria, the matter may not fall within the IOPC’s remit to assess and will be determined invalid.  The sum of decisions may not match the number of referrals completed. This is because some matters referred may have come to the attention of the appropriate authority before 1 February 2020 and have investigation type decisions of either managed or supervised.

Section B Referrals (page 8) shows that the Force made 70 referrals to the IOPC.  This is more than the SPLY and MSFs (39/52).  However, what is concerning is the number of Local Investigations being determined by the IOPC.  During Q2, the Force had 51 Local Investigations compared to 23 the SPLY.  This places additional demand on PSDs and is something the OPCC Complaints Lead will explore with the IOPC to determine whether the Mode of Investigation Decisions are appropriate.

The PCC wishes to commend the Force for reducing the number of allegations filed under ‘No Further Action’ (NFA) (Sections D2.1 and D2.2). For cases outside Schedule 3, the Force only recorded 8% compared to 54% for the SPLY. This was 66% during Q1.  Moreover, the Force only recorded 10% under this category for cases inside Schedule 3 compared to 67% SPLY. This is outstanding performance and demonstrates the continued improved data integrity and is much better than MSF and the National Average. The Force has also made greater use of the Reflective Practice Requiring Improvement (RPRP) approach (29% compared to 25% SPLY) and demonstrates the emphasis on learning rather than discipline.

Where a complaint has been recorded under Schedule 3 to the Police Reform Act 2002, the complainant has a right to apply for a review. A person can apply for review if they are unhappy with the way their complaint was handled, or with the outcome. This applies whether the complaint has been investigated by the appropriate authority or handled otherwise than by investigation (non-investigation). The application for a review will be considered either by the local policing body or the IOPC; the relevant review body depends on the circumstances of the complaint. 

During Q2 (2023/24), the OPCC took an average of 34 days to complete complaint reviews.  This was better than SPLY when it took 42 days and is much quicker than MSF and the National Average.  The IOPC took an Average of 162 days to complete reviews (longer than the SPLY when it was 133 days).  The IOPC are aware of the delays and communicate regularly with the PCC and Surrey Police.

Author:  Sailesh Limbachia, Head of Complaints, Compliance & Equality, Diversity & Inclusion

Date:  08 December 2023