Organisational learning issued after investigation into staff in the Directorate of Professional Standards – Metropolitan Police Service, November 2017
Our investigation (Operation Embley) into allegations that nine individuals within the Metropolitan Police Service’s (MPS) Directorate of Professional Standards (DPS) allegedly abused their position to affect ongoing investigations, found no case to answer against any individual and has reinforced ongoing changes to working practices. The matter was referred to us in November 2017 and our investigation concluded in July 2020.
The evidence we obtained during our investigation included written responses from the individuals who had been subjects of the investigation, interviews under caution, and witness statements from 27 MPS officers and staff. We searched more than 2.8 million items of data in MPS emails and user accounts and reviewed case management system records. Our investigation received more than 1000 documents from the MPS, and we collected 67 exhibits.
Our investigation highlighted confusion and opposing processes for decision maker and management roles combined with a breakdown of communication, which had led to apparent mistrust within the DPS.
We found occasions when there was an appearance that senior officers were interfering in cases, when they were in fact managing the quality or timeliness of the investigation, and in some instances they had been legitimately tasked to conduct a review of an investigation. We further highlighted that officers or staff acting in the Appropriate Authority (AA) role had the right to disagree with the investigator’s view on whether there was a case to answer and that this was not corruption but a matter of professional disagreement.
There was clear evidence of a number of ‘broken systems’ which led to the appearance of some officers acting in multiple roles, contrary to the regulations. Different processes were followed in different teams and some processes could potentially have unintended consequences; one of those being the undermining of the AA decision maker.
Our investigation found there was often confusion regarding which regulatory framework investigations should be conducted under. Those regulatory frameworks direct different approaches as to who should make investigative decisions, particularly regarding severity assessments. We found that the correct regulations were not always applied, leading to decisions being made by the wrong person.
We did not find evidence to suggest that any officer or member of staff had inappropriately interfered in the decision making processes, or that decisions were made based on personal relationships.
The MPS had already begun to implement the following changes:
• Creation of a dedicated ‘Appropriate Authority (AA) Cell’ to assist with addressing issues highlighted in this investigation. The AA Cell has a smaller pool of individuals who complete the role of the AA and the individuals are supported by training and experienced AAs who provide peer support.
• Introduction of a regular programme of ‘benchmarking’ training. This is to safeguard decisions to ensure they are appropriately discussed and challenged, and to ensure AAs are provided with continuous professional development to support their decision making role.
The MPS has already improved some processes in its Department of Professional Standards but there is still work to do as part of their commitment to continuous improvement.
We have made three learning recommendations under Paragraph 28A of Schedule 3 of the Police Reform Act 2002 in order to: embed the changes made by the MPS; ensure that systems are implemented to monitor compliance; ensure the development of culture change within the DPS continues and is fully embedded successfully.