Recommendation - Greater Manchester Police, July 2024

The IOPC recommends that Greater Manchester Police (GMP) review their custody policies and processes on managing the risk of suicide and self-harm to ensure they are clear and in line with the College of Policing’s Authorised Professional Practice.

This follows an IOPC review of a local death or serious injury (DSI) investigation where an individual took their own life less than a week after being arrested on suspicion of possessing indecent images of children. The individual who was known to have mental health issues and a history of self-harm was not seen by a health care professional (HCP) or the Liaison & Diversion Service (L&D) during their time in custody.

The force’s written operating procedure at the time stated that a referral to L&D should have been made. However, a change to the policy had been communicated to custody staff, whereby they were told that there were no longer any mandatory reasons to refer detainees to L&D.

The written operating procedure was updated in December 2023 (after this incident) and said anyone suspected of committing offences relating to indecent images of children should be referred to L&D. However, GMP has confirmed that this was an error and that their position remains:

• Detainees should only be referred to a HCP or L&D on the basis of an identified risk by an officer or upon request by the detainee.
• Welfare interviews will be carried out by the officer in charge of the criminal investigation.

The College of Policing’s (COP) APP says detainees who are deemed to be high risk must be seen by a HCP before going on to say that being arrested for sexual offences against children is a factor which may indicate an increased risk. In our view, there is a risk that GMP’s guidance is not sufficiently clear in respect to when a detainee should be referred to a HCP or L&D. We also feel that GMP’s guidance may not follow the COP APP, and specifically its Operational note on managing the risk of suicide for persons under investigation for online child sexual abuse and exploitation. For example:

• GMP’s position does not appear to adequately highlight that all child sexual exploitation and abuse offenders are potentially vulnerable and at risk of suicide.
• GMP’s position does not appear to reflect the operation note which more robustly states “Where an individual is identified as a possible suicide risk, ensure referral to medical support agencies as soon as possible.”
• GMP’s position does not appear to clearly distinguish between the responsibilities of the officer carrying out the welfare interview and those of the custody officer. There may be an over reliance on welfare interviews, conducted by investigating officers, to inform custody risk assessments and care plans.

We know that a high proportion of suicides following police contact involve those who have been arrested on suspicion of possessing indecent images of children. It is, therefore, really important that in such cases officers have clear guidance on how to manage the risk of suicide and self-harm.

Accepted:

In December 2023 GMP adopted the College of Policing Authorised Professional Practice (APP) as their principal operating framework. The GMP Custody Operating Procedure (COP) is a supporting document which should be read in conjunction with the APP. The COP provides procedural guidance for custody practitioners where the APP directs that Force local procedures should be followed or where GMP believes that additional emphasis needs to be afforded to a particular subject.

The GMP COP is currently under review with several amendments being implemented and it is anticipated that the latest version (8.1) will become effective from August 2024. Careful consideration has been given to the IOPC recommendations following which amendments have been made to section 5.6 of the COP which deals with the subject relating to “release and safeguarding”. The following textual amendments have been inserted which includes a hyperlink to the APP operational note on managing the risk of suicide for persons under investigation for on line child sexual abuse and exploitation:

Offences involving child sexual exploitation (CSE) and indecent images of children (IIOC):

• there is strong evidence that persons under investigation for CSE and IIOC are at an increased risk of suicide or self-harm.
• give additional consideration to risk factors associated with these offences.
• ensure that a Notarise interview has been conducted with the detainee in custody and feedback has been provided. This will inform the ongoing care plan and exit risk assessment.
• use the National Decision Model to inform decision making, including consideration of referral to a Health Care Professional (HCP) before release.
• for further information, refer to operational guidance on suicide prevention and risk management.

During the summer of 2023 a series of Continuous Professional Development workshops were held with all custody officers which addressed exit risk assessments. Detainees at heightened risk of suicide whilst under investigation for CSE/IIOC offences were specifically addressed. All staff were informed to de-brief with the investigating officer to identify relevant triggers which would prompt a referral to a HCP for assessment and relevant intervention where necessary.

The training course delivered to newly appointed custody officers is a national package which has been developed by the College of Policing and GMP does not deviate from any of the course content. The topic relating to conducting a Notarise interview with a suspect is covered and attendees are taught to engage with the interviewing officer to elicit information thereby informing their own on-going risk assessment/care plan. GMP will now review that lesson plan with a view to having a more in-depth exploration of each topic identified in Appendix A of the operational guidance document.

GMP remains committed to affording the highest level of care and treatment to all those who enter its care and continue to retain the position that any referral to a HCP is based upon the needs of the individual as identified by subjective and ongoing assessment from point of entry, duration of and point of egress from our care. We do not hold the view that we will make a mandatory HCP referral based on purely upon the type of offending category.

GMP are currently exploring the possibility of making an amendment to the IOPS computer system to provide an automatic prompt during the exit risk assessment process. The prompt will be designed to ensure that where a Notarise interview has taken place, the custody officer acknowledges the fact and has considered the outcome when considering their referral options at point of exit.

In relation to the point identified by the IOPC relating to what guidance is provided to officers on how to conduct welfare interviews, trainers at GMP’s Sedgley Park training school have confirmed that this topic is not part of the curriculum as stipulated in the College of Policing PIP 1 and 2 programme. However, GMP does include it on the trainee detective programme. This includes a guest speaker from the Online Child Abuse Investigation Team (OCAIT) where the importance of conducting welfare interviews is emphasised when dealing with suspects who are accused of offences relating to indecent images of children. The GMP guidance document Understanding and Preventing Suicide is sent out to delegates as a reminder of their obligations and following this case this document is now subject to review in order to ensure that it is in line with the APP.