Recommendations - Metropolitan Police Service, June 2024

The IOPC recommends that, where information or intelligence is obtained by the MPS about a potential declarable association, or an actual or perceived inappropriate relationship which does not amount to potential conduct, that an intervention with the officer or staff member in the form of a reminder of the declarable association policy and invitation to consider their current relationships in conjunction with the policy, be considered in order to mitigate any future risk to themselves and/or others.

This follows an investigation where, the MPS DPS on two occasions were informed of the relationship between Male A and the subject by another police force. Despite there being a mechanism in place for the DPS to alert officers when they are in a potentially declarable relationship, this route was not taken. Furthermore, in both cases, the investigation was initially closed with no further action. The rationale centred largely around the fact that Male A was above the age of consent, and the sex was described by Male A as consensual. It was only when information came to light about Male A’s additional vulnerabilities, that the case was re-opened and referred to the IOPC.

Accepted

The recommendation has been accepted by the DPS (Directorate of Professional Standards) Intelligence Bureau and is predominantly managed by the DPS Integrity Assurance Unit.

Below is a general response with further detail extracted from the MPS Declarable Associations Policy added at the end of this response.

The current and published MPS policy on Declarable Associations provides for circumstances whereby an association has been identified that may present risk but the officer or member of staff has not disclosed the association and/or maybe be unaware of the need to disclose. The published process allows for the association to be risk assessed and managed by the Directorate of Professional Standards whilst ensuring compliance with GDPR and Data Protection Legislation.

The policy is readily available on the MPS Intranet. New recruits are given training input regarding Declarable Associations and local awareness and reinforcement is provided by BCU/OCU-specific Professional Standards Units. We are consistently finding information regarding potential Declarable Associations through the ongoing integrity screening measures we have adopted. This includes regular checks as to maintain high standards and as part of the aftercare of our officers and staff, and information we find through legacy operations such as our PNC and PND data washes. We are using these as opportunities to remind our officers and staff of the Declarable Opportunities policy and to consider their current relationships relative to this.

The case in question was, on both occasions, dealt with as potential misconduct and referred for assessment and recording and was not initially treated as a Declarable Association.”

Extracted from the MPS Declarable Associations Policy on the MPS intranet:

‘MPS officer or staff member becomes aware of a relationship held by another MPS officer or staff member that it considers might be declarable. All MPS police officers and staff are required to report and challenge conduct that has fallen, or appears to have fallen, below the required standards. Where an officer or staff member becomes aware of an individual who has an association that should be declared in line with this policy, they have a responsibility to report them to their line manager, or Appropriate Authority. Further options are available via the Raising concerns Policy.’

The IOPC recommends that the MPS should increase awareness amongst officers regarding the Resource Management Policy, particularly concerning the booking on and off of colleagues other than themselves through the CARMS system. Training should be put in place to ensure officers and staff understand how to reflect officers’ actual working hours in CARMS, and the importance of ensuring that information is accurate.

This follows an investigation where, the data held on CARMS concerning the times between which the subject officer was on duty is inaccurate. This investigation highlighted that officers are routinely booking on and off other officers citing ‘CARMS compliance’, without confirming if the officer in question was working.  The MPS should consider the value of an accurate record of the hours worked by officers.

Having an accurate record is particularly important where officers and staff are working from home or working a flexible shift pattern, or as in this case, where concerns are raised about an officer’s behaviour.

Accepted

The recommendation has been accepted by MO6. Below is a list of what is already in place and has been augmented to increase awareness with regards to individual responsibilities in terms of booking on and off duty. This not only applies to booking on and off but also wider CARMS compliance in general to increase accuracy in duties management.

• Training package created by MO6 and delivered on the front line leaders training course regarding CARMS usage and CARMS compliance, emphasising personal responsibilities for effective duties management and supervision.
• Training package created by MO6 and delivered on the middle line leaders training course regarding CARMS usage and CARMS compliance emphasising personal responsibilities for effective duties management and supervision.
• Weekly meeting with Operational Support Event which includes CARMS usage and CARMS compliance review.
• Briefing to HQ Superintendents regarding CARMS standards and usage.
• Duties offices pilot being trialled to support a more accurate picture of resourcing and CARMS compliance, with the intention to expand further.
• Automated ‘not booked on’ message to individuals which also notifies line management – compliance monitored via Strategic Resource Board.
• CARM 4.7 upgrade which provides a change to the booking on and off page
• An Operational Notice on the internal Intranet will be published providing guidance to officers and staff about booking one another on and off and having an accurate record of working hours on CARMS will be issued

The IOPC recommends that MPS takes steps to ensure that all police officers who regularly come into contact with members of the public, whether face-to-face or by some other means, receive training created by NPCC in 2021 on APSP. They should also ensure that an auditable record is made for each person, detailing that the training has been received and understood. Training should be repeated on a regular basis, and a record kept of any refresher training.

This follows an IOPC investigation where an officer was reported to have had an inappropriate relationship with a looked after child. The officer stated he had not received any training on APSP, this was supported by his training record. Although the MPS does provide an input to new joiners, there doesn't appear to have been any auditable training for officers who started before the new joiner APSP input was introduced. Although an article covering APSP and sharing a video on the topic created by the NPCC was posted to the MPS intranet, there is no easy means of tracking who has seen this. The MPS should consider the value in having an auditable training to ensure all officers are well informed about APSP and accountable for their behaviour.

Accepted

The APSP video content is currently being converted to a format that is suitable for the MPS Learning Management System (LMS) in order to track progress and completions.

The APSP video will then be assigned to every officer in the MPS in their ‘to do’ lists in LMS.