dumfries and galloway constabularyegenda.dumgal.gov.uk/aksdumgal/images/att6271.pdf · sop now...

Report Police, Fire and Rescue Committee 26 November 2009 5 -

DUMFRIES AND GALLOWAY CONSTABULARY

I s r ~ L i i s h r d 1 ‘ h f l

Police Headquarters, Cornwall Mount, Dumfries DG1 1PZ Tel : 0845 600 5701

PATRICK J SHEARER QPM., M.A., LL.B. Chief Constable

HMlC INSPECTION REPORT - POLICE NATIONAL COMPUTER (PNC) RE-INSPECTION REPORT JULY 2009

1. Reason for Report To provide members with an update in relation to observations and recommendations made by Her Majesty’s Inspectorate of Constabulary (HMIC) as a result of their recent inspection on the Force’s use and management of the Police National Computer (PNC).

2. Report Summary 2.1 HMlC carried out an inspection of Dumfries and Galloway Constabulary’s use and management of the Police National Computer (PNC) in 2006. This inspection resulted in a number of formal recommendations being made. In July 2009 HMlC carried out a follow up inspection with a view to identifying what progress had been made in respect of the recommendations made in 2006 and make any fresh recommendations deemed appropriate.

2.2 The purpose of this report is to provide members with an update on the force’s current position in respect of the outstanding recommendations and outline the proposed management and resolution of the issues identified.

3. Glossary of Terms HMlC - Her Majesty’s Inspectorate of Constabulary PNC - Police National Computer ICT- Information, Communication & Technology QUEST - Query using enhanced search techniques VODS - Vehicle on-line descriptive search SOP - Standard Operating Procedure CHS - Criminal History System

4. Recommendations Members are asked to: 4.1 and the recommendations therein, and 4.2

scrutinise the content of the HMlC Follow Up Inspection Report (Appendix 2)

scrutinise the proposed management and resolution of the issues identified.

5. Plan Links and Contribution The use of PNC plays a key role in the force’s efforts to deliver on the community promise and obligations under the Single Outcome Agreement.

Report Police, Fire and Rescue Committee 26 November 2009

6. ResourcesNalue for Money Assessment There are no resource implications in relation to implementing the recommendations that have been put forward by HMIC.

7. Risk Assessment There are risks associated with non compliance of the recommendations made by HMIC. These risks have been recognised and has resulted in the formation of a strategic oversight group being formed.

8. Authorities & Legal Implications Each Force throughout the UK has a responsibility to ensure that their use and management of PNC complies with national standards.

9. Consultations Dumfries and Galloway Constabulary will continue to consult with HMIC’s inspection team to progress the outstanding recommendations and will also seek to consult with other forces to identify and share good practice.

10. Background 10.1 Constabulary’s use and management of PNC. This inspection resulted in 9 recommendations being made. These recommendations, in the main, concerned internal management arrangements for PNC.

In 2006 HMlC carried out an inspection of Dumfries and Galloway

10.2 In January 2009 an internal review of the recommendations made in relation to PNC, as a result of the 2006 inspection, was carried out. This review identified that a number of the 2006 recommendations had not been fully complied with.

10.3 In an effort to progress work on the outstanding recommendations, a PNC Liaison Group was formed. This group maintained communication with HMIC’s PNC Inspection Team and were able to advance some of the work arising from the 2006 recommendations. In support of this group, strategic and tactical groups were also formed to assist in delivery of the recommendations.

10.4 In July 2009 HMlC carried out a follow up inspection of Dumfries and Galloway’s use and management of PNC. As a result of this follow up inspection HMlC produced a report commenting on progress made in respect of the 2006 recommendations and making an additional five new recommendations.

10.5 Some of the observations made in the 2009 follow up Inspection Report levelled some criticism at the force, but the report also highlights areas of good practice within Dumfries and Galloway Constabulary concerning the use and management of PNC. In particular, positive comment was made in relation to

1) Creation of the PNC Tactical Team and link to PNC Strategic Team 2) Full Time PNC / ICT Trainer 3) Quality Control procedures

10.6 The PNC Inspection also revealed that Dumfries and Galloway Constabulary’s use of PNC is the highest (pro rata) of all Scottish Forces, see Figure 1.

2


Figure 1

Fife L Grampian Lothian & P Borders Northern

Strathclyde Tayside Scottish Average

6788 125408 156203 26732

12099 328544 331275 76053 2867 66862 91151 12596

12070 422586 784661 149253 4649 103069 149207 21974

Average Usage

Total

11 779548

630 181173 266 143504

10.7 The Force has fully considered HMIC’s report arising from the 2009 follow up Inspection and is fully committed to addressing the outstanding recommendations and the issues which have attracted some criticism. The recently formed Strategic Oversight Group and Tactical Group will ensure the force fulfils its obligations in respect of management of PNC.

10.8 An Action Plan is now in place to ensure compliance with all outstanding recommendations (Appendix 1).

10.9 A copy of HMIC’s follow up Inspection Report is also attached (Appendix 1).

11. Key Issues In summary, the follow up inspection report does include some observations that are critical in nature, in particular regarding a lack of progression in respect of the 2006 recommendations. The report also acknowledges and identifies a significant amount of good practice. The new structure and format adopted within Force will ensure proper management of the PNC system and compliance and progression of the recommend at ions made .

lrvine Watson Inspector No 344 Dumfries and Galloway Constabulary Date of Report: 9 November 2009 File Ref:

Chief Constable Patrick J Shearer Dumfries and Galloway Constabulary Police Headquarters Cornwall Mount Dumfries DGI 1PZ

Appendix 1 UP DATE POSITION ON RECOMMENDATIONS

Appendix 2 - HMlC Re-Inspection Report July 2009 Dumfries and Gallowav Final Report 09.pdf


Appendix 1 Update Position on Recommendations

In total 9 recommendations from 2006 and now a further 5 as a result of 2009 inspection

Achieved - 5 Achieved In Part - 2 Not Achieved - 2 New - 5 Recommendation

1. Her Majesty’s Inspector of Constabulary recommends that the force develops a PNC Strategy which expands upon the current PNC action plan to include future changes to the PNC to enable it to prepare a strategic position to forthcoming developments and to respond effectively at an operational level when these changes are introduced.

2 . Her Majesty’s Inspector of Constabulary recommends that the force develops a comprehensive PNC policy document to cover all aspects of PNC.

3. Her Majesty’s Inspector of Constabulary recommends that Dumfries and Galloway introduces an independent audit, at least annually, of all user access administration.

4. Her Majesty’s Inspector of Constabulary recommends that the Force adopts a structured approach to marketing by way of a formal marketing strategy to promote the effective use of the PNC.

Status

Not Achieved

Achieved In Part Now Achieved

Achieved In Part

Not Achieved

Action

PNC Tactical Team to progress and submit to PNC Strategic Group for adoption

PNC Tactical Team to progress - PNC Strategic Group for adoption

PNC Tactical Team to progress with users

PNC Tactical Team to progress

Completion Timeframe 3-6 months

3-6 months

SOP now produced

6-12 months

3-6 months

4


5. Her Majesty’s Inspector of Constabulary recommends that the force cease all PNC update training that is being delivered by non- accredited staff. In order to comply with national standards and provide consistent training for the staff the force should consider the benefits of gaining the accreditation to provide the training ‘in house’.

6. Her Majesty’s Inspector of Constabulary recommends that the force explores options to ensure that the essential functions carried out by the PNC Liaison Officer can be maintained in the organisation as part of the Business Continuity Plan.

7. Her Majesty’s Inspector of Constabulary recommends that the Force introduce tighter controls regarding the submission of data for input to CHS and subsequently to the PNC.

The force should develop a returns policy to return substandard forms to the arresting officer and introduce a process to record details of officers who submit poor or late data with a provision to produce management information on behalf of divisional commanders

Achieved

Achieved

Achieved In Part

No Action Required In Respect Of Recommendation


PNC Tactical Team to progress in conjunction with Custody Lead

6-12 months


8. Her Majesty’s Inspector of Constabulary recommends that the force reviews its policy for recording location details on the PNC originator line to bring it in line with the PNC National Manual.

9. Her Majesty’s Inspector of Constabulary recommends that the force considers the introduction of formal quality control procedures within the FCC and warrants unit, with performance of staff monitored through Personal Develop men t Reviews.

10. Her Majesty’s Inspector of Constabulary recommends the USB ports on networked computers be disabled as a matter of urgency

11. Her Majesty’s Inspector of Constabulary recommends that the force review out of hours access to Visor as a matter of urgency

12. Her Majesty’s Inspector of Constabulary recommends that the Force review its user access system with a view to moving towards an up to date role based system of authorisation

Not Achieved (Now Achieved)

Achieved

New - July 2009

New -Ju ly 2009

New -Ju ly 2009

PNC Tactical Team to progress with suitable advice and guidance


SPSA identified product and getting quotes for same to resolve issue

Visor access to be considered for FCC Duty Officers

PNC Tactical Team to progress in conjunction with SCOPE management team

3 months Process changed

3 months

3-6 months

6-1 2months

5 - Report Police, Fire and Rescue Committee 26 November 2009

13. Her Majesty’s Inspector of Constabulary recommends that based upon the PNC Manual Of Guidance the force develop a policy identifying which items of ad-hoc intelligence be entered onto PNC

14 Her Majesty’s Inspector of Constabulary recommends that the PNClCHS Steering Group review the data quality from partner agencies and organisations and establish protocols for the completeness and timeliness of such data

New - July 2009

New -July 2009

PNCTactical Team to progress and link to appropriate national groups to progress

PNC Tactical Team to progress through discussion with partner agencies

6-1 2months

~~

6-1 2months

(this will be an ongoing action that we will never fully achieve)

APPENDIX 2

Dumfries and Galloway Constabulary PNC Re-Inspection Report

6 - 8'h July 2009

Dumfries and Galloway PNC Re-Inspection July 2009 Page 1 of 51

Report Structure

This report is structured differently to the other Scotland PNC report primarily because the inspection has been in two parts.

A document review, which included the force response to the 2006 inspection, was carried out in January 2009. At this time it was apparent that the force needed to undertake further work prior to the formal inspection in July 2009.

Background 3

Conclusion Good Practice Areas for Development

4 4 4

Inspection Based on 2006 Recommendations 6

Other Issues 15

Annex. A. 2006 PNC Inspection Report 20

Annex. B Force response to 2006 Inspection report with HMlC comments 32


Background

1.

2.

3.

4.

5.

6.

Dumfries and Galloway ConsfaMary covers 2,649 square miles in the south- west of Scotland. The population is approximately 148,5801, just under 3% of the population of Scotland. The largest towns are Dumfries (31,600), Stranraer (10,800) and Annan (8,300). Whilst there have been many changes over the years, traditional agricultural and forestry industries are still substantial employers in the area. The outstanding landscape and many recreational facilities continue to attract large numbers of visitors, while the 21 8 miles of coastline offer both work and leisure opportunities.

The close proximity to Northern Ireland also places demands upon force resources. The ferry port at Stranraer has frequent passenger and freight services to Northern Ireland resulting in a considerable amount of foreign traffic passing through the force area. As the border is within the UK common travel area the police are primarily responsible for security issues. There are no commercial airfields within the force area, there are however 16 private airstrips the largest of which, Castle Kennedy, has a metalled surface. Also included within the force area are 107 small ports.

The force is divided into two operational policing divisions; Galloway which covers the Stewartry and Wigtownshire region, and Dumfries which covers the Annandale/Eskdale and Nithsdale areas.

The force is managed through a structure, which maintains clearly defined links between the executive and policy group. The force executive comprises Chief Constable, Deputy Chief Constable and Chief Superintendent. The force policy group comprises the aforementioned executive members plus the heads of each area of service delivery.

The transfer of data between the force and the PNC is through the Criminal History System (CHS) which the force updates with pending cases and associated information including disposals. The CHS is also electronically updated with case details and trial dates by the Procurator Fiscal's computer system and court disposals from the Scottish Court Service. All information on CHS that is relevant for PNC is transferred electronically using an interface that is managed by the Scottish Police Services Authority (SPSA). Two key areas which do not electronically transfer to PNC are MO information and warnings signals.

In order to create a record on the CHS, the reporting officer enters sufficient details onto IMAGE2. The IMAGE application emails sufficient details to the Records Office for the staff to create a skeleton record3 on CHS. The officer is also responsible for completing a descriptive form, known within the force as the DF. This manual form is sent directly to the Records Office in order for the staff to populate the skeleton record on CHS with complete details of the offender. Warning signals are entered onto PNC from the descriptive form.

' (2008) source: Scottish Neighbourhood Statistics Incident Management and General Enquiry computer system. A record of basic, identifying details only.


5

7.

8.

9.

PNC nominal records are created on PNC following a download from CHS. All cases in Scotland are updated locally by forces onto CHS and, in almost real time, data is transferred to PNC. The force owning the data on CHS is responsible for ensuring that associated data on PNC is accurate and up to date.

The force was subject to a PNC inspection in May 2006 after which nine recommendations were made. An extract of the subsequent inspection report is attached at Annex A.

In January 2009, at the request of HMlC Scotland a re-inspection was scheduled and the force was asked to detail the progress made to address the recommendations. The submitted copy of the action plan showed that only limited progress had been made by the force. Between January and the inspection in July 2009 the force has made some progress towards addressing the recommendations and the action plan has been updated accordingly. The current action plan is attached at Annex B.

Conclusion

10. The force has undertaken a limited amount of work to address the recommendations of the 2006 report. The majority of the work, which was commenced when the force was notified of the inspection in January this year, is a quick attempt to produce something for the inspectors.

11. The force has fully complied with three of the nine original recommendations.

Good Practice

12. The creation of the PNC Tactical Group, effectively the PNC User Group with a pooling of departmental heads is a good model for a small force. This would be further enhanced by the attendance of the data protection and information security officers. The output from this group feeds into the Strategic Group. There does however need to be more input from divisional operational personnel into whichever group the force considers most appropriate.

13. The appointment of a full time trainer gives the force a focus of expertise.

14. The creation of a quality control document off the Image system which accompanies a print out of a PNC update for the originator to check is good practice.

Areas for Development

15. The chief officer is responsible for data quality and timeliness on PNC.

16. HM Inspectors are concerned that the force has no risk assessment mechanism or audit plan in place and as such is seriously exposed to the risk of incorrect data on PNC. There is a possibility that this is exacerbated by working practices within the District Court. The management of these issues would normally be defined within a comprehensive PNC Strategy which the force does not have. The delivery of the strategy would normally be overseen by the strategic group.


17. The Code of Practice recognise that the police can not be held responsible for the acts or ommissions of other organisations, it does however go on to state:

‘The Steering Group will manage the force’s relationship with stakeholders outside the police service to resolve local issues relating to conflict in business processes and ensure that inter-organisation systems are in place to maximise co-operation to achieve compliance with statutory requirements.

Where a force is unable to achieve the required performance criteria due to an act or omission by another force or organization within the wider criminal justice community, it will be the duty of that force to establish the extent and possible cause of such omission. The force will be in a position to evidence any remedy sought by the use of existing local procedures ’.

18. There is evidence that, at an operational level, police officers and support staff work hard to ensure that the data entered onto PNC from the courts and the Fiscal is timely and accurate, often doing extra work to make up for weaknesses in the other organisations. The message that timely and accurate data is the only acceptable standard needs to be reinforced at the strategic level.

19. The Leeds Magisrates Court enquiry clearly illustrated what can go wrong when a criminal justice partner fails5 Had it not been for the procedures in place within West Yorkshire Police the missing records may not have been identified.

20. The use of PNC within the force needs to be driven at a senior level by a group that can deliver a well developed, comprehensive strategy.

The Police National Computer Code of Practice - January 2005 httD://w.iustice.aov.uk/newslannouncementsl10308a.htrn

4


5

Response to 2006 Report

Recommendation 7

Her Majesty’s Inspector of Constabulary recommends that the force develops a PNC Strategy which expands upon the current PNC action plan to include future changes to the PNC to enable i t to prepare a strategic position to forthcoming developments and to respond effectively at an operational level when these changes are introduced.

1. A PNC Strategy was produced in February 2009 shortly after the force was notified of the impending inspection. This strategy addresses issues relating to Governance, Training and Performance. It is unfit for purpose and does not address the management of data originating in sources other than the police force.

2. It is not within the remit of HM Inspectors to tell a force how to devise a strategy; however at the very least a strategy could usefully detail how the force is to interact with external organisations, particularly the courts.

3. The purpose of a strategy is yet to be appreciated by the force.

Status: Not Achieved


Recommendation 2

Her Majesty’s Inspector of Constabulary recommends that the force develops a comprehensive PNC policy document to cover all aspects of PNC.

1. A copy of the force’s Standard Operating Procedures has been supplied but this is woefully inadequate as it just covers PNC procedures. The original text and recommendation detailed how the document should cover the roles and responsibilities of all personnel with regard to PNC.

2. To avoid wasteful duplication of effort it is suggested that (subject to the chief officers consent) the SOP currently in use in the Fife Constabulary be evaluated and, if considered suitable, used as a basis for the development of a more complete SOP.

Status: Achieved In Part


5

Recommendation 3

Her Majesty’s Inspector of Constabulary recommends that Dumfries and Galloway introduces an independent audit, at least annually, of all user access administration.

1.

2.

3.

4.

5.

6.

7.

8.

Although the recommendation refers to user audits, this section will cover all auditing.

The force has not had a full time Data Protection Officer for some time and until recently the role has been undertaken by a member of staff with other responsibilities. The DPO is now full time and an additional member of staff has been recruited but is not yet in post.

There is a great deal of work to be done to bring the force up to the required standard. It is imperative that the DPO receives full accredited training for this role and achieves the required level of competence.

An independent user audit has recently been completed although it would appear to be the first one since the original report some years ago. The IT trainer maintains a spreadsheet of all users.

There is evidence that transaction auditing is regularly carried out and end users confirm that they have been asked to justify the purpose of transactions. The response is checked by the line manager. This is, in the main, good practice. However the transactions are selected by FCC personnel for officers identified by the Data Protection Officer. This is not particularly effective, even though the task in undertaken by an FCC ‘back office’ member of staff. If current procedures are adhered to the DPO should check access by the FCC staff. This has not been done since February 2009. Current procedures must be strictly adhered to and there needs to be a more independent element.

There are a number of products available to automate this process thereby reducing personnel costs. The Hendon PNC Help Desk will be able to advise further.

System audits, e.g. reconciliation of stolen vehicles on PNC against validated records, are virtually none existent. Although some working practices in relation to data entry onto PNC are well considered and thorough, the force has not in recent times completed an ACPOS compliant systematic audit of any system. The purpose of such an audit is to identify records or updates that have slipped through real-time quality control procedures. In view of this there is a risk that a number of data items on PNC for which the force is responsible are incorrect.

The force should refer to the ACPO Audit Manual of Guidance [MOG] which provides details of how forces should be auditing their data, along with recommended frequencies of audits and how to set up a risk assessed audit plan. Additionally the MOG includes “toolkits” of how to carry out specific data quality audits.


9. PNC password re-sets can be undertaken by the duty officer. This is appropriate and does not frustrate business objectives. The fact that a password has been re-set and the reasons for the action must be logged and the log audited.

10. An audit plan of sorts has been produced but there is no evidence of a risk assessment to support the plan. It is suggested by the force that a stolen vehicle audit is the first priority and yet from information obtained during the brief inspection the District Court is clearly is some disarray and may be supplying warrant data, the timeliness and accuracy of which is, at best, suspect. It is suggested from the limited research undertaken that the force may benefit from a timely Wanted/Missing audit.

11. A full risk assessment is long overdue.

Status: Achieved in Part


5

Recommendation 4

Her Majesty’s Inspector of Constabulary recommends that the force adopts a structured approach to marketing by way of a formal marketing strategy to promote the effective use of the PNC.

1

2.

3,

4.

5.

6.

7.

8.

9.

A PNC Marketing Action Plan has been produced but not a strategy

The marketing of PNC must be focused on the potential business benefits and should be viewed as a continuous process not just a one off initiative. For example South Yorkshire Police recently published a double page ‘Did you Know’ PNC spread in their force newspaper and monitored transaction use to gauge effectiveness.

It is not suggested that the relatively small sample of operational personnel interviewed is representative of the whole force. However it is suggested that the areas detailed below would benefit from some marketting:

Roads policing officers interviewed did not realise that it is possible to create a vehicle record on PNC even though the vehicle is not UK registered. This facility can produce real benefits in an area used extensively by foreign ve h icles.

Officers were unaware that additional markers can be added to PNC even though the marker may already be present. For example where a person has been violent, a ‘Violent’ marker can be added to the record even when one already exists. This reinforces the message for the protection of the public and police.

Most of the operational officers interviewed did not understand the implications of an AcVReact marker. Although this function has not been widely adopted in Scotland and the force has a working group to address this, it is widely used in England and Wales and operational personnel should be aware of the implications of such a marker.

There was no understanding of the Caeser‘ marking system for stolen construction plant and the help that is now availble to identify high value stolen property. This will be of benefit to the ports unit.

Most operational officers interviewed had no knowledge of the ACPO UK Central Authority for the Exchange of Criminal Records (UKCA)’. The authority carries out conviction checks on european nationals ensuring that any court before which a foreing national appears has the most up to date antecedents. Whilst it may be appropriate for the single point of contact to be within the FIB, it is important that all operational officers have an understanding of the system.

In the interim it may be of use, prior to the development of any marketing strategy to discover exactly what service delivery personnel know and don’t

httD://w.cesarscheme.ora/

’ httD://www.acDo.Dolice.uWacro/UKCAECR.asD


know about the PNC. This is not suggesting the use of a questionnaire but face to face discussions during the course of normal business.

10. Force policy on the layout of e-mail messages should be clear and rigidly enforced. HM Inspectors will assist with this further if required.

Status: Not Achieved


Recommendation 5

Her Majesty’s Inspector of Constabulary recommends that the force cease all PNC update training that is being delivered by non-accredited staff. In order to comply with national standards and provide consistent training for the staff the force should consider the benefits of gaining the accreditation to provide the training ‘in house’.

1. The force has actioned this recommendation and an accredited trainer is now in post. Whilst there is no specific IT training classroom HM Inspectors were assured that, subject to operational commitments, there are rooms available at the main stations in the force suitable for the purpose.

2. There was no evidence of Data Protection input to the training course. All attendees should not only receive the input but also sign a document to acknowledge that they have understood what has been taught. The signed document will then be retained in the officers personal file and be available should the officers conduct be challenged in respect of any data protection matters.

3. Although a ‘Happy Sheet’ is sent to course attendees six weeks after the completion of the course there was no evidence of a sheet being given at the end of the course in accordance with NPlA best practice and the Kirkpatrick model of evaluation. To do so will bring the force in line with national standards.

4. The system for assessing the training requirements for PNC authorised operators who have been absent for a prolonged period of time is too casual. Each person upon return should be assessed by the trainer to ensure up to date knowledge and competence. This need not be over-bureaucratic; a short discussion followed by a test based upon the individual’s authorisation levels will suffice.

5. Whilst, due to the size of the force, one trainer may be adequate for current IT training requirements, that person will lose the mutual support culture found in larger force training departments. To ensure that the trainer develops her full potential she should be allowed to work with, and be assessed and guided by, a larger force training department.

6. The force must not use distance learning packages which were never intended to be used unsupported by expert trainer input.

Status: Achieved


Recommendation 6

Her Majesty’s Inspector of Constabulary recommends that the force explores options to ensure that the essential functions carried out by the PNC Liaison Officer can be maintained in the organisation as part of the Business Con tin uity Plan.

1. The original text leading to this recommendation highlighted the lack of resilience should the PNC Liaison Officer be no longer available to the force. The danger of this lack of resilience has been clearly demonstrated by the unforeseeable extended absence of a full time Date Protection Officer.

2. The development of the PNC/CHS Tactical Liaison Group by the force, although recent, is seen as sharing the expertise amongst other personnel and thereby reducing the reliance upon an individual. This is good practice and could usefully be replicated by other small forces.

Status: Achieved.


5

Recommendation 7

Her Majesty's Inspector of Constabulary recommends that the force introduce tighter controls regarding the submission of data for input to CHS and subsequently to the PNC.

The force should develop a returns policy to return substandard forms to the arresting officer and introduce a process to record details of officers who submit poor or late data with a provision to produce management information on behalf of divisional commanders

1. This recommendation has been actioned. There is evidence of a clear quality culture in relation to the submission of descriptive forms for entry onto CHS with the involvement of line management for 'repeat offenders' .This is, in part, good practice.

2. Evidence suggests that the checking of the descriptive documents is completed away from the custody area. Such checking can only at best relate to omissions on the input document, it can not relate to incorrect descriptive information in the absence on the accused.

3. The only satisfactory method for quality checking a descriptive document is in the presence of the subject.

Status: Achieved in Part.


Recommendation 8

Her Majesty’s Inspector of Constabulary recommends that the force reviews its policy for recording location details on the PNC originator line to bring it in line with the PNC National Manual.

1. The force is still using a codified location system. This is contrary to national best practice and, whilst facilitating speedy data entry, is not understood by organisations outside the force. The originator line should identify the originating officer, the terminal user and the actual location of the check.

2. FCC personnel defend this method as quick and ‘understood by all’ but this is only within the force.

3. There is absolutely no latitude for this type of local practice on a national computer system. The practice should cease forthwith and the force should adhere to national standards.

Status: Not Achieved.


Recommendation 9

Her Majesty’s Inspector of Constabulary recommends that the force considers the introduction of formal quality control procedures within the FCC and warrants unit, with performance of staff monitored through Personal Development Reviews.

1. The issues raised by this recommendation have been addressed.

2. Initially FCC supervisors checked the PNC entry however, as no errors were detected this practice was discontinued. The system now in place is that a copy of the entry is attached to a quality control form printed from the IMAGE system which is returned to the originator.

3. It is the originators responsibility to check the accuracy of the PNC entry and act accordingly. This system applies to all PNC updates including output from the FIB. If correctly adhered to the system appears to add the desired quality element to record updating.

4. It is particulalry commendable that the OMU updates PNC with changes in relation to sex offenders.

5. As an additional fall back, the warrants officer checks PNC when a warrant has been executed.

Status: Achieved


Other Issues

A number of issues, not part of the previous report, came to light during the inspection and are forwarded for consideration.

Security

1. The Universal Service Bus (USB) ports on networked computers are not disabled. This allows the use of any device connected to the port including memory and disk storage devices. Data can be transferred from and to other devices. The risk of this occurring with a resultant loss of data can not be overstated.

2. Further enquiries on behalf of HM Inspectors from the SPSA reveal that a request in December 2008 for the USB’s to be disabled has not yet been action.

Recommendation 10

Her Majesty’s Inspector of Constabulary recommends the USB ports on networked computers be disabled as a matter of urgency.

Visor Access

1.

2.

3.

4.

5.

Access to the Violent and Sex Offenders Register (Visor) is limited to Offender Management Unit personnel only. As illustrated by the circumstances surrounding the IPCC report into the Sweeney case*, Visor access must be available at short notice to operational personnel at all times.

The force should not place reliance upon local databases (CHSISID) in this area.

As the system carries the Security Policy Framework classification of ‘Confidential’ a higher level of security, which is not conducive to control room access, is required.

Although information contained with Visor can be critical to an ongoing occurrence it is anticipated that this will only occur occasionally. There is the possibility that the force train the duty officer with view only access to Visor and permit access to an otherwise secured room within the OMU for the purpose.

As a ‘Visor’ marker appears against a PNC nominal record with an indication of the category of risk, the marketing of Visor should be considered as part of the PNC strategy. It should also be noted that forces are now entering violent offenders into the system which could have implications both the officer and public safety.

httD://www.ipcc.aov,uk/childareDort.Ddf


Recommendation 11

Her Majesty’s Inspector of Constabulary recommends that the force review out of hours access to Visor as a matter of urgency.

PNC User Access

1.

2.

3.

4.

5.

Access to PNC is currently dependant upon the individual’s job description. Any additional requests for access are reviewed by the PNC Tactical Liaison Group.

It is suggested that each post within the force has a skills profile and access to PNC is dependant upon that profile. With regard to post changes, the force has explored the possibility of using the SCOPE personnel system to track this but the output was not what was required. If the SCOPE output can not be refined the force will have to continue the present system of taking the information from the weekly bulletin.

When an individual moves to a role without PNC, or without a particular part of PNC access in the skills profile, access will automatically cease.

This will allow the current system of removing users who have not accessed PNC to be refined. If a role requires PNC access, barring exceptional circumstances leading to prolonged absence from the post, there should be no lapsed users.

An accurate skills profile supported by an up to date system to accommodate changes will ensure that the ad-hoc requests will be rare and can be easily managed by the CI Operational Support Services.

Recommendation 12

Her Majesty’s Inspector of Constabulary recommends that the force review its user access system with a view to moving towards an up to date role based system of authorisation.

Ad-Hoc Intelligence

1, The force was unable to supply a force policy in relation to the entry of ad-hoc intelligence onto PNC.

2. Ad-hoc intelligence could originate from any none formal process and will normally be assessed and where appropriate entered onto Scottish Intelligence Database [SID]. This ensures that only the Scottish forces have access to the information. This has obvious limitations when a force borders onto England and may have many criminals travelling to and through the force area.

Recommendation 13

Her Majesty’s Inspector of Constabulary recommends that based upon the PNC Manual of Guidance the force develop a policy identifying which items of ad-hoc intelligence be entered onto PNC.


Data from Non-Police Sources

1, During the course of the inspection it became apparent that the local District Court is in some state of disarray. The force received approximately 750 Means Warrants over a three week period having received none for two years. There is evidence that the Sherriff and High Courts regularly send a list of outstanding warrants but the District Court does not. There have been occasions where warrants are duplicated because the defendant has returned to court and failed to comply with an undertaking.

2. Personnel working for the force have had to visit the Procurator Fiscals office to discover how cases have been resolved.

3. The adoption of court employed enforcement officers has been delayed.

4. These examples show how the police have to undertake tasks to minimise the impact of poor business practice within the courts. In the absence of a courts inspectorate in Scotland it is difficult to see how this risk can be minimised.

5. As the chief officer is liable for all the force data on PNC it is of some concern that, particularly as there has been no audit for some time, the force is at risk from incorrect or outdated data which may have originated from an external organ isat ion.

6. The local Criminal Justice Board may be the correct forum to resolve many issues, however it has been found elsewhere that the PNC Steering Group is more sighted on data quality and timeliness issues, a good example being the lack of Means warrants for two years.

Recommend at ion 14

Her Majesty’s Inspector of Constabulary recommends that the PNClCHS Steering Group review the data quality from partner agencies and organisations and establish protocols for the completeness and timeliness of such data.


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Annex A

Extract from PNC Inspection Report Mav 2006

2. Detailed Findings and Recommendations

2.1 Leadership

2.1.1 The responsibility for the PNC in Dumfries and Galloway Constabulary falls within the remit of the Head of Operations, currently a Chief Superintendent, who reports to the Deputy Chief Constable. Despite overall responsibility not resting with an officer of chief officer rank, as has proved to be good practice in England and Wales, the force does have a suitable structure to ensure that all issues that are identified as corporate issues are brought to the attention of appropriate senior managers. The force has a tiered meeting structure for making strategic and operational decisions.

2.1.2 The force has set up a PNC User Group, which meets every quarter and has been doing so for a year. Whilst this meeting structure has still to be fully embed into the culture, HMlC Auditors were provided with the documented terms of reference, which clearly outlined the objectives of the group and identified the key stakeholders invited to attend. A review of the minutes revealed that the meetings were well attended by staff from relevant areas to the PNC. In addition, the PNC Liaison Officer attends the force morning strategic meetings, so would be able to raise any priority PNC issues should the need arise.

2.1.3 The force uses the Image system to ensure that skeleton data is supplied to CHS and consequently to PNC in a timely manner. HMlC Auditors were provided with a flow chart outlining this process, including the completion of the Descriptive Form (DF), which is required to provide the data to update the full record details on CHS. The flow chart stated that the duty sergeant checked the DF, anecdotal evidence indicated that this was not the case. The reality checks performed by the HMlC Auditors did not raise any data quality concerns; if therefore this step in the process is now redundant the flow chart should reflect the current operational process.


2.2

2.2.1

2.2.2

2.2.2.1

2.2.2.2

2.2.2.3

2.2.3

2.2.3.1

Policy and Strategy

With regard to policy and strategy, the inspection focused on three areas; PNC Policy & Strategy, Security, and Data Protection. Each of these themes is discussed in further detail below.

PNC Policy and Strategy

Whilst the force has a PNC action plan which is reviewed at each PNC User Group meeting, this is not considered by HMlC Auditors to be a strategic document. The current document could be expanded to include longer term PNC issues such as PNC via Airwave and the introduction of the new custody system. This strategic document would help to ensure that the force is getting a maximum return on its investment in the system and that officers gain most benefit from the information which is stored on it. The document should be regarded as a living document and be updated accordingly.

Recommendation I

HMlC Auditors are of the opinion that the policy documents provided were fragmented and in need of review. The force should produce a formal policy outlining the responsibilities on individual staff in all aspects of the PNC. The policy should also direct staff on what processes should be followed, the reasons why and the consequences of failing to adhere to the policy.

If a comprehensive policy document is not available or is not communicated to all relevant police officers and staff, the risk of inadequate or inappropriate conduct is increased. Furthermore, the task of monitoring and ensuring adherence to procedures will be more onerous and time-consuming.

recommends that the licy document to cover

all aspects of PNC.

PNC Security

PNC security is considered to be an area of strength within the force. The force employs a full time Information Security Officer who works closely with the Data Protection Unit at force headquarters. Information Security policy documentation is comprehensive.


2.2.3.2 Approximately five years ago the force employed the CETIS computer based training package to update staff on their responsibilities concerning freedom of information, information security and data protection. HMlC Auditors were informed that the upgrade to this package had already been purchased, the force is therefore encouraged to utilise this method to reinforce awareness of these areas.

2.2.3.3 This section of the report also considers the controls in place to manage access to the PNC. HMlC Auditors were informed that the ability to create, amend or delete users from the system is limited to the force control centre (FCC) manager. Whilst restricting the number of staff with this ability reduces the risk of unauthorised updates being made to the system with regards to user access, the force is at risk of not being able to make those changes during periods of absence of the sole updater. HMlC Auditors were informed that the force was in the process of authorising the proposed PNC trainer to make those changes in the absence of the FCC manager. HMlC Auditors encourage the force to move towards establishing this resilience.

2.2.3.4 With regards to the creation of new users and defining the appropriate level of access, the force training school provide an e-mail to the manager of the force control centre, who on receipt makes the necessary changes to the PNC user groups. An email is also sent from the human resources unit detailing staff leaving the organisation and those changing their job role to allow the force control centre manager to make the necessary changes to the PNC.

2.2.3.5 Every three months the FCC manager also reviews PNC usage against all the PNC User IDs. If a user has not made an enquiry on PNC in that three month period their access is removed. This is considered to be good practice by HMlC Auditors.

2.2.3.6 In addition, whilst HMlC Auditors do not question the integrity of the work of the FCC manager, there is some risk to the organisation in having a individual able to make such changes to system access with no independent auditing of the activity being carried out.

Recommendation 3


2.2.3.7 In addition to the controls on user access groups, HMlC Auditors also considered the process that the force employs to carry out transaction monitoring. The FCC operators and the Data Protection Unit are responsible for carrying out transaction monitoring. The FCC operators send out five standard forms per day to the enquirer or PNC operator requesting an explanation for the transaction being performed. The form must be endorsed by the person’s line manager prior to being returned to the Data Protection Unit. Responses are reviewed by the Data Protection Unit who either files the check or may conduct further investigation.


2.2.3.8

2.2.4

2.2.4.1

2.3

2.3.1

2.3.1.1

2.3.1.2

2.3.1.3

2.3.1.4

The Data Protection Unit carries out the same validation process on the FCC operators, by sending out two requests per day Monday to Friday. This is seen as by the HMlC Auditors as good practice.

Data Protection

The force produces a three year risk assessed Audit Programme. During the inspection, the PNC Auditors were provided with a copy of the previous two reports. The most recent of these dated January 2006 included a ‘Schedule of Audit Findings’ which is seen as good practice, as the force is able to formally document and track the management response to the recommendations. It was also encouraging to note that the PNC User Group has ownership of these reports to ensure that any actions resulting from the report are carried through to completion.

People

PNC Awareness

During meetings and focus groups, HMlC Auditors were pleased to note a good all round awareness of the PNC functionality. Often staff were not aware of the technical details in requesting the various types of checks, but they had sufficient knowledge to make the enquiry and the FCC operator was able to act on the request.

During the inspection HMlC Auditors were made aware of the various techniques that Dumfries and Galloway had employed to market the PNC investigative tools such as PNC screen savers and requesting PITO Customer Services to deliver awareness presentations.

There was only one area of concern under this heading. There was limited knowledge and understanding of the implications of the ViSOR (Violent and Sexual Offenders) marker on PNC. The force is therefore exposed to the risk that valuable intelligence and or investigative opportunities could be lost in this area.

HMlC Auditors are of the opinion that the force would benefit from a formal marketing strategy. The marketing of the PNC needs to be viewed as an ongoing process where a variety of strategies are employed to encourage interest and awareness in the PNC on a rolling programme basis.

Recommendation 4 Her Majesty’s Inspector that the force adopts a structure formal marketing strategy to promote the effective use of the PNC.

ay of a


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2.3.2

2.3.2.1

2.3.2.2

2.3.2.3

2.3.2.4

2.3.2.5

2.3.2.6

Training

With regards to PNC Training, HMlC Auditors viewed this as an area of concern.

Currently the force has no capability to deliver PNC training. This was known throughout the force, so staff had stopped requesting PNC enquiry courses on the belief that were not available. Dumfries and Galloway are potentially unaware of the backlog they could face once PNC training is commenced again within force.

However, HMlC Auditors were informed that Dumfries and Galloway had outsourced the PNC training for enquiry courses during this time to Tayside and Cumbria, and they had also used the training facilities at PlCTTS (Police Information and Communication Technology Training Service) based in Leicestershire.

The force is undergoing the process of accrediting the IT Trainer for PNC. HMlC Auditors encourage the force to continue with this course of action.

There is no facility in the force to deliver PNC update training. However, in the FCC once new staff have received enquiry level training, supervisory staff in the FCC provide the update training. A similar situation occurs in the Records Department where staff occasionally have to modify an offence on the PNC. The training is delivered by the Records Supervisor who although has received training from a recognised source, is not an accredited PNC trainer. The FCC and the Records Department do not provide training against structured lesson plans with specified aims and objectives to ensure that a consistent approach to the delivery of training is achieved. In addition, this ‘training’ in not assessed. This practice has implications for the force and is contrary to the principles of the Code of Connection and also the guideline provided by the PNC Manual. In a previous HMlC thematic inspection it was noted that;

“It is a requirement of the code under which forces are connected to PNC that all persons having access to PNC must have received the correct training. It has also been agreed, by the PNC Director, NPT and user groups, that training will only be delivered by trainers who have successfully attended the nationally accredited PNC Trainers Course. ’’’

Whilst the thematic inspection report that this extract is taken from was conducted in England and Wales, the point raised is relevant to any force using and updating the PNC.

HMlC Auditors are of the opinion that all PNC update training being provided by the FCC and the Records Department should cease immediately to ensure compliance with national standards. The force should investigate the benefits of accrediting the IT Trainer as an update trainer. Another option open to the force is a reciprocal arrangement with another force in Scotland or in England.

’On The Record -Thematic Inspection Report on Police Crime Recording, the Police National Computer and 9

Phoenix Intelligence System Data Quality‘ P.115, Paragraph 7.5.2 Dumfries and Galloway PNC Re-Inspection July 2009

Page 24 of 51

I Her Majesty’s Inspector of Constabulary recommends that the force cease all PNC update training that is being accredited staff. In order to comply with national provide consistent training for the staff the for the benefits of gaining the accreditation to pro house’.

2.4

2.4.1

2.4.2

Partnerships and Resources

Partnerships is another area of strength for the force. The force has developed good relationships within the criminal justice system and other agencies. These relationships mirror the ethos of the whole of the Dumfries and Galloway area in which public services are delivered using a community based approach. All agencies work together to improve services and the Dumfries and Galloway Constabulary have embraced this protocol.

In addition to the information sharing protocols, Dumfries and Galloway Constabulary has forged good working relationships with the Procurators Fiscal’s (PF) office and the Sheriff and District Courts. The Records Office Manager is based in the PF office and is able to progress any concerns regarding outstanding cases.

2.4.3 Dumfries and Galloway Constabulary has established a position of PNC Liaison Officer for the force. The post holder is based in the force Communications Centre, and reports to the Chief Inspector, Operational Services. The PNC Liaison Officer is the central point of contact for any PNC related matter and represents the force at regionallnational level to ensure that the force participates in national PNC development and adopts identified best practice. The post holder also undertakes the role of system administrator.

2.4.4 Throughout the week of the inspection, it was clear that the PNC Liaison officer is held in high regard throughout the force in terms of his work and knowledge of the PNC. Although this is seen as a strength in the short term, it was felt that this could be a potential weakness for the force as there was no similar role anywhere in the force. The PNC Liaison Officer carries out a number of administrative functions, prepares the key performance figures, offers advice and guidance concerning PNC, all of which would need to continue if the current post holder was no longer available.


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2.5

2.5.1

2.5.2

2.5.3

icer can be maintained in the

Processes

This section of the report examines the detailed processes that exist in the management of PNC data. For the purposes of the report, only aspects that are within the direct control of Dumfries and Galloway Constabulary have been reported upon. For example, information pertaining to DNA samples does not transfer to PNC, however, this is a national problem throughout Scotland, therefore, it has not been included in this report.

HMlC Auditors reviewed the process for submitting the DF form. Whereas the data entered by the officer onto the Image system is used to create a skeleton record, the data on the DF form is used to complete the record with descriptive information and further details of the offence. During the inspection it was discovered that there are limited controls in place to ensure that all the forms are submitted on time and to a suitable standard.

The quality of information is important for the success of QUEST searches on the PNC. This will require the introduction of performance monitoring of individual officers regarding the submission of the forms. Any substandard forms that reach the Records Office must be recorded and returned to the officer in the case. Management information should also be made available to Divisional Commanders in order that any necessary action can be taken against officers who persistently submit late forms or poor quality data. The force is in a situation where the culture amongst officers is to be addressed with the introduction of a new custody application, this opportunity should be used to enable the force to move towards recording high quality information on CHS and PNC in a timely way

Recommendation 7

Her Majesty’s Inspector of Constabulary recommends that the force introduce for inp

r controls regarding the submission of data

0 develop a returns policy to return substandard forms to the arresting officer and

introduce a process to record details of officers who submit poor or late data with a provision to produce management information on behalf of divisional commanders.

2.5.4 HMlC Auditors also considered the quality of information being entered on the originator line of PNC. The originator line is a free text field to record the reason why a transaction is taking place. It can be used as a tool for supervisors who are managing PNC users to ensure that all transactions are for a legitimate policing purpose. The information on the originator line can also be used during investigations, when a history of transactions is being reviewed.


2.5.5 In view of this, it is important that all reasons and locations of checks are recorded accurately and with the correct reason codes. During the inspection, a sample of 100 transactions was examined for the quality of the information contained on the originator line. The Dumfries and Galloway Constabulary area is divided into a grid system with each area being allocated a two-digit code. It is code that is recorded on the originator line rather than free text location details as per the national standard as described in the PNC Manual. This is an area of concern for HMlC Auditors.

I Recommendation 8

2.5.6 The final process that is worthy of note is the management of operational updates in the force control centre and the warrants office. Operational updates include such items as Wanted/Missing reports including warrants, Disqualified Driver Reports, ASBOs (Anti Social Behaviour Orders), sex offender registration orders, vehicle and property reports. The force control centre and the warrants office in Dumfries are the only places in the force where operational updates are carried out. In order to ensure that updates are subject to quality assurance, supervisors within the units have responsibility for quality checking the updates to the PNC.

2.5.7 HMlC PNC Compliance Auditors were encouraged by this approach as it gave staff ownership of the work and it was clear during focus groups that the staff pride themselves in making sure that PNC updates are accurate and up to date.

2.5.8 Whilst this provides the force with additional controls surrounding the quality and accuracy of the data, HMlC Auditors identified two points that should be considered to improve the process further. Firstly, as the force does not have a formal procedural document for PNC updates supervisors on the different shifts may quality assure the work to different standards (see recommendation 2 ) . Secondly, any errors that are identified are dealt with on ad hoc basis and there is no recording of the types or frequency of errors that are made. HMlC Auditors are of the opinion that formal recording of errors for use in personal development reviews would add value to the quality assurance work being carried out.

Recommendation 9

Her Majesty’s Inspector of Constabulary recommends that the

2.5.9 Administratively, warrants are dealt with in the Warrants Units in Dumfries and Stranraer. The staff member based in Stranraer is not trained in the warrants update so has to send all the requests for PNC update to the force control centre whilst the Dumfries unit is able to take full ownership of the process and update PNC when necessary. The training for the administrator at Stranraer would only involve a half day. HMlC Auditors encourage the force to invest in the training so that Stranraer warrants administrator could become fully accountable for the Stranraer warrants and relieve some of the pressure from an operational


5

unit (the force control room) carrying out administrative updates to the PNC.

2.6 Resu Its

2.6.1 In terms of the timeliness of the creation of ArrestlSummons reports, Scottish forces have been set a new target of 90% of skeleton cases being input onto CHS within 5 days of the caution or charge. Data provided by the force established that they had achieved that target since October 2005 through to March 2006. Using the monthly statistical data provided by PITO where comparison is also made against other forces in Scotland and notably in which no allowance is made for the variation in the judicial process between England and Wales and Scotland, it shows that for the past 6 months (November 2005 - April 2006), Dumfries and Galloway has been consistently above or within 1% of the Scottish average for entering 90% of arrest summons reports onto the PNC within 24 hours. Also during that period in all but November, Dumfries and Galloway has either been the best or second best performing Scottish force.

2.6.2

2.6.3

2.6.4

Performance with regard to the input of Court Results is similar. For the months of May and June 2005 when the target was 50% of disposals to be entered within 10 days the force was achieving the target. However, the target was increased to 75% in July 2005, since then the force has not achieved the target. Although its performance is always above the Scottish national average. HMlC Auditors do acknowledge the differing processes in Scotland which can impact on the overall performance data that is provided by PITO.

In terms of Impending Prosecutions (IPs), the force has seen the overall figure increase by 625 for the twelve month period March 2005 to April 2006. Whilst there has been a corresponding increase of IPs outstanding on the CHS, HMlC Auditors are of the opinion that IPs should be proactively managed so that the increase does not continue indefinitely. A robust process in which a monthly list of cases is supplied by PITO for the force to review now supports this reduction. However, as a result of discussions during the inspection and the good relationship Dumfries and Galloway have developed with the PF office, as mentioned in paragraph 2.4.2, it has been agreed with the Area PF that a more effective mechanism will be put in place to resolve the backlog of pending cases on the PNC.

The recommendations outlined in this report aim to improve the quality of the data being input and to assist Dumfries and Galloway Constabulary in obtaining maximum benefit from the PNC.

Her Majesty’s Inspector has no further recommendations to make in this area.


A Summary of Good Practice within Dumfries and Galloway Constabulary

0 The review and deletion of unused PNC user ids performed every three months.

The process employed by the force for transaction monitoring.

0 The PNC User Group’s ownership of the Audit Reports and the use of the ‘Schedule of Audit Findings’ to track and monitor the report recommendations.

The good working relationship the Dumfries and Galloway has developed the Procurator Fiscals office.


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Summary of Recommendations for Dumfries and Galloway Constabulary

Recommendation 1

Her Majesty’s Inspector of Constabulary recommends that the force develops a PNC Strategy which expands upon the current PNC action plan to include future changes to the PNC to enable it to prepare a strategic position to forthcoming developments and to respond effectively at an operational level when these changes are introduced

Recommendation 2

Her Majesty’s Inspector of Constabulary recommends that the force Her Majesty’s Inspector of Constabulary recommends that the force develops a comprehensive PNC policy document to cover all aspects of PNC.

Recommendation 3


Recommendation 4

Her Majesty’s Inspector of Constabulary recommends that the force adopts a structured approach to marketing by way of a formal marketing strategy to promote the effective use of the PNC.

Recommendation 5

Her Majesty’s Inspector of Constabulary recommends that the force cease all PNC update training that is being delivered by non-accredited staff. In order to comply with national standards and provide consistent training for the staff the force should consider the benefits of gaining the accreditation to provide the training ‘in house’.

Recommendation 6

Her Majesty’s Inspector of Constabulary recommends that the force explores options to ensure that the essential functions carried out by the PNC Liaison Officer can be maintained in the organisation as part of the Business Continuity Plan


Recommendation 7

Her Majesty’s Inspector of Constabulary recommends that the force introduce tighter controls regarding the submission of data for input to CHS and subsequently to the PNC. The force should:

develop a returns policy to return substandard forms to the arresting officer and

0 introduce a process to record details of officers who submit poor or late data with a provision to produce management information on behalf of divisional commanders.

Recommendation 8

Her Majesty’s Inspector of Constabulary recommends that the force reviews its policy for recording location details on the PNC originator line to bring it in line with the PNC National Manual.

Recommendation 9

Her Majesty’s Inspector of Constabulary recommends that the force considers the introduction of formal quality control procedures within the FCC and warrants unit, with performance of staff monitored through Personal Development Reviews.


Annex B

Dumfries and Galloway PNC Audit 2009

This document comprises the original recommendations, the force response and HM Inspectors comments on progress to date (January 2009).


Recommendation 1

Her Majesty's Inspector of Constabulary recommends that the Force develops a PNC Strategy which expands upon the current PNC action plan to include future changes to the PNC to enable it to prepare a strategic position to forthcoming developments and to respond effectively at an operational level when these changes are introduced

Report Content Leading to Comment

Whilst the Force has a PNC action plan which is reviewed at each PNC User Group meeting, this is not considered by HMlC Auditors to be a strategic document. The current document could be expanded to include longer term PNC issues such as PNC via Airwave and the introduction of the new custody system. This strategic document would help to ensure that the Force is getting a maximum return on its investment in the system and that officers gain most benefit from the information which is stored on it. The document should be regarded as a living document and be updated accordingly.

Force Position

The existing PNC Action Plan was developed to highlight and manage the issues identified in force with a view to tightening up force practices and procedures in line with the PNC manual.

It has been accepted that this has been a useful way to identify issues and specifying a lead person for addressing the issue.

Action

The Force PNC User Group chaired by Chief Superintendent, Head of Operations to progress the expansion of the PNC Action Plan to form a PNC Strategy.

Action Manager - Ch. Supt, Head of Operations.

Supt Marshall to obtain copies from other forces and adopt best practice.

Supt Marshallll Dawson to develop a broad strategy linked with a Policy before Jan 08 PNC User Group Meeting

Action: I Dawson to distribute Policy to members for comment with timescale of 4 weeks from date of circulation.

Update

Update of 07/02/08

Draft Policy will be circulated to members of the group, with sections relevant to departments highlighted as appropriate. A timescale of four weeks from receipt of draft document is given for the return of comments to Ms Dawson.

UPDATE OF 2/12/08 ACTION NOW COMPLETE.


HM Inspectors Comments

Recommendation 1

It is not entirely clear by the comments in response to this recommendation whether there is an understanding within the force as to what a strategy is and what it is intended to deliver.

Sitting alongside the main strategic objectives of the force, for example the crime strategy, the PNC strategy brings together the strands which are subject to further recommendations later in the report. For example the PNC strategy will detail how the force is to manage training and marketing requirements. It will detail how PNC is to be used to support the organisations main strategic principles, it may include indicative (but not exact) costings and it will be up to date.

Simply if it is not in the PNC Strategy (or one of the work-trains feeding the strategy) then it will not happen in relation to PNC.

As the action is shown complete I assume a current strategy is now in place. Please forward the most recent version.

Update 3rd July 2009

The force strategy in respect of PNC has been completed and is included in the folder.


Recommendation 2

Her Majesty’s Inspector of Constabulary recommends that the Force develops a comprehensive PNC policy document to cover all aspects of PNC.


HMlC Auditors are of the opinion that the policy documents provided were fragmented and in need of review. The Force should produce a formal policy outlining the responsibilities on individual staff in all aspects of the PNC. The policy should also direct staff on what processes should be followed, the reasons why and the consequences of failing to adhere to the policy.

Force Position

Due to the manner in which PNC is woven through various aspects of Force business the management of PNC has been delivered through a mixed regime approach. This has led to the creation of a number of area specific policy documents owned by the respective devolved management teams but overseen by the Force PNC User Group. It is accepted that a singular consolidated policy document is preferable.

Action

The Force PNC User Group chaired by Chief Superintendent, Head of Operations to progress the consolidation of existing PNC policy documents into a comprehensive policy document to cover all aspects of PNC.


Update

Update of 07/02/08

Has more or less rolled into Rec 1 above -noting the need to ensure a hierarchy of documents that fits the emerging structure being designed for the force Strategies / policies / SOPS



Recommendation 2

PNC policy is subservient to the strategy and can not be rolled into one document. The policy is heavily influenced by the Code of Connectivity and the PNC Manual. The role of PNC within the force should not be subject to departmental practices but should consistently reflect agreed national working practices.

Please forward the most recent version.


Update 3rd July 2009

The force has developed a policy document and standard operating procedures in respect of PNC with usage. These documents are included in this folder.


Recommendation 3



HMIC Auditors do not question the integrity of the work of the FCC manager; there is some risk to the organisation in having an individual able to make such changes to system access with no independent auditing of the activity being carried out.

Force Position

This recommendation is accepted fully.

Action

Information Directorate to risk assess and develop an auditing policy on the work of the PNC Liaison Officer/ Manager. To be incorporated into the overall PNC policy document outlined in recommendation 2.

Action Manager - Mr Russell, Information Directorate.

D Russell & L Tennant to create user authority audit, refining as PNC Policy is refined and include this in the Audit Policy

Action - D Russell to find out from S Sloan what progress was made.

Action - Margaret Jardine to pick up Audit and progress.

Action. I Dawson to include a section in the Policy to cover managing access and training

Update

User Access audit due Aug 07 by S Sloan

Update of 03.10.07

Audit has been started however due to sick leave it is still a work in progress.

The Audit should be reflected in PNC plan.

Update of 07/02/08

No further progress on audit due to other pressures. Should be ongoing in approx 3 - 4 weeks. Some interim tidying being carried out by PNC trainer.

Following discussion it was agreed to include section in Policy about managing access and training, noting issues of withdrawal of access that is automatic after 6 months of non-use and the need to avoid the risks of infrequent use leading to mis- reading of the system..


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UPDATE OF 211 2/08 ACTION NOW COMPLETE.


Recommendation 3

Progress would appear to be fairly slow on this issue. If the finalised version is included in the document requested in (2) above I will examine it there, if not please forward the most recent version.

Update 2"d July 2009

The only update of PNC is done within the FCC, FCC Back Office Warrants and Records Office.

The Records Office only updates disposals when some human intervention is required - it was discovered however that there is no double checking on these updates, or indeed for that matter on updates onto CHS -this is at odds with the process in relation to the updates carried out by FCC and BOF Warrants staff which eliminates errors and is seen as good practice.

The newly formed PNC/CHS Tactical Liaison Group is to produce recommendations to reduce the risk of error in this area.

PNC Audit framework attached to show processes in place/being put into place to ensure management of audit.

User access processes and procedures have been formalised for both the PNC and CHS systems (documents in folder).

Dumfries and Galloway PNC Re-inspection July 2009 Page 38 of 51

Recommendation 4

Her Majesty’s Inspector of Constabulary recommends that the Force adopts a structured approach to marketing by way of a formal marketing strategy to promote the effective use of the PNC.


HMlC Auditors are of the opinion that the Force would benefit from a formal marketing strategy. The marketing of the PNC needs to be viewed as an ongoing process where a variety of strategies are employed to encourage interest and awareness in the PNC on a rolling programme basis.

There was only one area of concern under this heading. There was limited knowledge and understanding of the implications of the ViSOR (Violent and Sexual Offenders) marker on PNC. The Force is therefore exposed to the risk that valuable intelligence and or investigative opportunities could be lost in this area.

Force Position

The force has been marketing aspects of PNC through specially designed screen savers to highlight VODS and QUEST and through distribution of posters through the force, awareness training to probationer classes and divisional LlO’s. In addition a small PNC handbook has been obtained from PITO and distributed force wide to all officers.

Action

The Force PNC User Group chaired by Chief Superintendent, Head of Operations to progress the development of a marketing strategy as a component of the overarching PNC Strategy outlined in Recommendation 1.


Action: I Dawson to check PNC Bulletin Board for items of interest which can go on lntranet for staff info.

PNC reminder piggy-backed onto national campaigns

Action: inspector Watson to issue reminders about what PNC can offer to FCC staff.

Action. I Dawson to speak to Andy Naylor re national awareness programme..

Update

Recent Vods & Quest training carrying out. PNC use raised at recent T&C meetings.

User Group to tackle any issues at quarterly meetings.

Update of 3.1 0.07


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D&G usage of PNC is still higher than other Scottish forces however, marketing will need to be a feature in the Strategy / Policy. I Dawson advised this would move forward in first quarter of 2008.

New ICT trainer will also play a role in keeping FCC up to date and proactive.

Update of 07/02/08

Various ideas suggested, several of which were directed to trainer, including attending briefings, a road show, inclusion in visit to FCC, use of Opportunity Days. Also suggestion to resurrect screen saver.



Recommendation 4

The effectiveness of marketing can be tested during interview. A copy of any documented marketing strategy or evidence of recent initiatives would be appreciated.


It is acknowledged that there have in the past been various actions taken to promote the use of PNC. These would appear to have been relatively successful given that the force's PNC usage is the highest of all Scottish forces.

It must however be accepted that there lacked a consistent drip feed action to ensure that PNC was being fully utilised so a market strategy action plan has been developed. This will be seen as a living document primarily driven by the PNC/CHS Tactical Liaison Group. The force wide use of this marketing strategy will be a standing item with the PNC/CHS Tactical Liaison Group and owners of actions will be held to account for progress or lack thereof.

The marketing strategy action plan is included in this folder.


Recommendation 5

Her Majesty’s Inspector of Constabulary recommends that the Force cease all PNC update training that is being delivered by non-accredited staff. In order to comply with national standards and provide consistent training for the staff the Force should consider the benefits of gaining the accreditation to provide the training ‘in house’.


There is no facility in the Force to deliver PNC update training. However, in the FCC once new staff have received enquiry level training, supervisory staff in the FCC provide the update training. A similar situation occurs in the Records Department where staff occasionally have to modify an offence on the PNC. The training is delivered by the Records Supervisor who although has received training from a recognised source, is not an accredited PNC trainer. The FCC and the Records Department do not provide training against structured lesson plans with specified aims and objectives to ensure that a consistent approach to the delivery of training is achieved. In addition, this ‘training’ in not assessed. This practice has implications for the Force and is contrary to the principles of the Code of Connection and also the guideline provided by the PNC Manual.

Force Position

The Force employed a full time PNCAT trainer until relatively recently when the staff member concerned was successful in joining the police. A replacement PNC/IT trainer was appointed however this coincided with the Force migration to AIRWAVE which was deemed to be a high priority project for the Force. The PNCAT Trainer was heavily committed to the AIRWAVE project so alternatives for PNC training were utilised including outsourcing and piloting of modular packages from other Forces.

The Force PNC/IT trainer has now returned to her primary function and is currently working towards delivery of fully accredited courses for staff requiring training.

Until the capability in force is fully achieved through the PNCAT Trainer, the Force will continue to outsource accredited training. Centrex have all been used in this regard and should continue to be used until training needs can be met in force.

Cumbria Constabulary, Tayside and

Action

Progress the full accreditation of the PNCAT trainer for the delivery of PNC update training.

As required, outsourcing of such training to be arranged.

Action Manager; Head of Personnel and Training.

Actions: C/lnsp Glendinning to obtain requirements via NIPAKentrex. C/Supt to check where PNC sits re SPSA role. I Dawson to obtain next national PNC meet date.

Actions: Dumfries and Galloway PNC Re-Inspection July 2009

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Ch Inspector to contact NPlA to verify if trainer can carry out training for other forces to enable them to get accreditation.

Ch Supt to contact Andy Naylor for name of contact to clarify how 8 forces are structured re representing Scotland in use of PNC.

Ch Supt to contact J Gates to check if any plans for PNC training to be done central I y .

Update

NlPA & Centrex contacted Jul 07 to obtain exact requirements /training needs for new PNC trainer.

National PNC quarterly meeting should support / discuss issues e.g. training.

Update of 3.10.07 Job description and person spec has been prepared and a business case is ready for presentation. The role could fulfil quality control, marketing and centralised training. This change to in house provision would avoid costs someone to come in and carry out training there - as experience by Ports Unit. Training for trainers now being offered by Centrex / NPlA but there will be a cost for this and a cost to have a trainer accredited through the conducting of training sessions observed by an accreditor. Accessing this type of training via SPC would be ideal and more cost effective - Ch Supt to write to SPC to check if they have any plans in this regard.

07/02/08 Update Ch Supt had written to SPC re training. In interim NPlA have decided to resume training as in the past. L Holland had been in contact with NPlA to find out what qualifications are required to attend the trainers course and there are none. She has emailed requesting a list of dates and associated costs.

UPDATE - 2/12/08 Matter still outstanding, efforts ongoing to resolve issues.


Recommendation 5

The issue is still obviously under review but there does not appear to have been much progress since February 2008. Please update on the current situation.


The ICT trainer has gained accredited trainer status.


Recommendation 6

Her Majesty’s Inspector of Constabulary recommends that the Force explores options to ensure that the essential functions carried out by the PNC Liaison Officer can be maintained in the organisation as part of the Business Continuity Plan


The force has established a position of PNC Liaison Officer for the force. The post holder is based in the Force Communications Centre, and reports to the Chief Inspector, Operational Services.

This Officer is the central point of contact for any PNC related matter and represents the Force at regionaVnational level to ensure that the Force participates in national PNC development and adopts identified best practice. The post holder also undertakes the role of system administrator.

Throughout the inspection, it was clear that this officer is held in high regard throughout the Force in terms of his work and knowledge of the PNC. Although this is seen as strength in the short term, it was felt that this could be a potential weakness for the Force as there was no similar role anywhere in the Force.

The Officer carries out administrative functions, prepares key performance figures, offers advice and guidance concerning PNC, all of which would need to continue if the current post holder was no longer available.

Force Position

The force recognises the issues and the risks inherent in having this role focused within one individual.

The force has reviewed all HQ functions and are progressing a restructuring implementation plan with a view to building organisational resilience. The issue of PNC management features in the process.

Action

The Force PNC User Group chaired by Chief Superintendent, Head of Operations to address the issue of resilience of the PNC Liaison Officer role and system administration.

Action Manager - Ch. Supt, Head of Operations

Action: DC/lnsp Carr to identify Personnel within Stranraer to support above.

Action: I Dawson to speak to DC/lnsp Carr to enquire if PU would be willing to train a trainer to give resilience.

Update

I Dawson to act as PNC Liaison Officer.


This role linked with L Tennant and FCC BOF Sgt to provide resilience.

A joint email request has been submitted to CIS for above staff to access all correspondence.

Update of 3.10.07 The joint email box is now in place.

Action now complete.

07/02/08 Update

The PNC Manager training course will enhance force capacity and be of benefit to - - the IT Trainer.

UPDATE OF 211 2/08 ACTION NOW COMPLETE.


Recommendation 6

The matter is marked as compl


te but the final r sult is not clear, please advise.

It was acknowledged that being dependant on one individual in respect of management of PNC was not appropriate, so to ensure business continuity in this regard a PNC/CHS Tactical Liaison Group has been formed.

This team will push forward the business of the PNC/CHS Strategic Group. Members of the PNClCHS Tactical Liaison Group included the PNC Manager, PNC Liaison Officer, ICT Trainer, FCC BOF Sergeant, Records Officer, Supervision, Information Security Officer, Data Protection Officer. The FCC Inspector although not part of this team will act as critical friend and assist with progression of business when appropriate.


Recommendation 7

Her Majesty’s Inspector of Constabulary recommends that the Force introduce tighter controls regarding the submission of data for input to CHS and subsequently to the PNC. The Force should: develop a returns policy to return substandard forms to the arresting officer and introduce a process to record details of officers who submit poor or late data with a provision to produce management information on behalf of divisional commanders


HMlC Auditors reviewed the process for submitting the SCRO Descriptive Form (DF). Whereas the data entered by the officer onto the IMAGE system is used to create a skeleton record, the data on the DF form is used to complete the record with descriptive information and further details of the offence. During the inspection it was discovered that there are limited controls in place to ensure that all the forms are submitted on time and to a suitable standard.

The quality of information is important for the success of QUEST searches on the PNC. This will require the introduction of performance monitoring of individual officers regarding the submission of the forms. Any substandard forms that reach the Records Office must be recorded and returned to the officer in the case. Management information should also be made available to Divisional Commanders in order that any necessary action can be taken against officers who persistently submit late forms or poor quality data.

Force Position

The Force has been instrumental in the development and introduction of a new national Custody Application. Testing is ongoing and training of staff will commence late summer 2006. This provides the force with an opportunity to reinforce the requirements for quality and timeliness in the submission of information onto CHS and PNC. It is anticipated that performance monitoring and quality checks will be made easier with the new IT application. A management system to identify and return sub standard data will be developed in tandem with the Custody application with reports being generated for relevant line managers.

Action

Chief Superintendent, Head of Operations to review the training programme regarding Custody Application to ensure input on quality and timeliness and ensure adequate performance monitoring is in place along with a management system to address sub standard data submissions.


Action: C/Supt to contact Sgt Hendrie for specifics of quality checks.

Update

Sgt J Hendrie submitted email outline of quality control.

Update of 3.10.07 Dumfries and Galloway PNC Re-Inspection July 2009

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Controls have been introduced. Sgt Hendrie and Sgt Alcorn will dip sample, reviewing a high percentage of reports. Officers will be sent a memo highlighting errors and omissions.

This action can now be considered complete.



Recommendation 7

Whilst efforts have been made to address this matter the original recommendation does not envisage dip sampling as a satisfactory method of quality control. The methodical recording of latelinferior documentation to identify persistent offenders will ensure that divisional supervision can effectively manage errant members of staff.

There may have been computerised developments since the earlier inspection so I will discuss this during the inspection.


It is acknowledged that the constabulary did not progress this matter as requested, and the resolution has been identified as being inappropriate in respect of dealing with errant members of staff.

The PNC/CHS Tactical Liaison Group will address this issue and work with the two divisional operational support sergeants (who have responsibility for these forms). It was also identified that focusing in on a process that looks to address problems is fine in its own right, however more importantly addressing the causal issues was deemed to be equally if not more important.

With this in mind, and working within the criteria of the marketing policy, direction will be issued to all staff regarding the importance of accurate and timely forms being submitted. The onus of responsibility will rest with the enquiry officer, however there will also be responsibility on the first line manager to address these issues prior to the release of any person from custody as part of the custody handling process.

Consultation will take place with the officer who has direct responsibility for custody management within the force so that a multi-tiered approach can be formulated and progressed through the PNC/CHS Tactical Liaison Group.

The Records Office has developed a process to record errors and identify 'persistent offenders'. This process has already identified problem users and forms have been returned via line managers.


Recommendation 8

Her Majesty’s Inspector of Constabulary recommends that the Force reviews its policy for recording location details on the PNC originator line to bring it in line with the PNC National Manual.


HMlC Auditors also considered the quality of information being entered on the originator line of PNC. The originator line is a free text field to record the reason why a transaction is taking place. It can be used as a tool for supervisors who are managing PNC users to ensure that all transactions are for a legitimate policing purpose. The information on the originator line can also be used during investigations, when a history of transactions is being reviewed.

In view of this, it is important that all reasons and locations of checks are recorded accurately and with the correct reason codes. During the inspection, a sample of 100 transactions was examined for the quality of the information contained on the originator line.

Force Position

The Force operates a consistent approach to this originator line with a geographical location code based on a grid system, a reason code and the officers shoulder number. Supplementing these codes is the force policy which requires officers to maintain a detailed record of the check in the personal notebook. This process is audited to ensure compliance.

The national standard as described in the PNC Manual is silent and does not preclude the use of codes for this purpose.

CENTREX have in the past commended the forces approach as one that offers additional security in the event of being targeted by ‘cold callers’ attempting to gain access to police data. Work is ongoing in Force regarding mobile data and options are being explored of utilising GPS technology and unique identifier lSSl numbers from AIRWAVE to populate location fields

Action

Consideration to be given to the feasibility of utilising free text style input on the originator line. Evaluation of the retraining implications for operational staff and PNC operators to be carried out set against the perceived business benefits for all PNC users.


Update

Item to remain as current practice whilst awaiting technological solutions via Airwave vehicles and person location systems or Storm. We will monitor for any problems arising from our use of location codes rather than full locations. Update of 3.1 0.07


No concerns highlighted. STORM MA will assist with this as if offers Resource Location System.

Update of 07/02/08

Location codes will be sufficient to show who is using the system and Aitwave will give exact information.



Recommendation 8

No query.


Recommendation 9

Her Majesty’s Inspector of Constabulary recommends that the Force considers the introduction of formal quality control procedures within the FCC and warrants unit, with performance of staff monitored through Personal Development Reviews.


Operational updates include such items as WantedlMissing reports including warrants, Disqualified Driver Reports, ASBOs (Anti Social Behaviour Orders), sex offender registration orders, vehicle and property reports. The force control centre and the warrants office in Dumfries are the only places in the force where operational updates are carried out. In order to ensure that updates are subject to quality assurance, supervisors within the units have responsibility for quality checking the updates to the PNC.

Whilst this provides the force with additional controls surrounding the quality and accuracy of the data, HMlC Auditors identified two points that should be considered to improve the process further. Firstly, as the Force does not have a formal procedural document for PNC updates supervisors on the different shifts may quality assure the work to different standards (see recommendation 2).

Secondly, any errors that are identified are dealt with on ad hoc basis and there is no recording of the types or frequency of errors that are made. HMlC Auditors are of the opinion that formal recording of errors for use in personal development reviews would add value to the quality assurance work being carried out.

Force Position

As at Recommendation 2.

Action

The Force PNC User Group chaired by Chief Superintendent, Head of Operations to progress the consolidation of existing PNC policy documents into a comprehensive policy document to cover all aspects of PNC including issues of quality assurance, standards and recording of errors ensuring that feedback on individual’s accuracy and performance can be included in their appraisals.


Action: S Sloan - Logging of specific errors to be carried out at times of Audit.

Action: D Russell to look at format of audit and subsequent memos to target each role in FCC.

Update

Specific errors should be investigated to ensure that no underlying issues exist.

The audit facility will cover this issue. The policy document will show audit outcomes fed back to system owner, manager and staff who are not carrying out procedures correctly.


A memo to recognise good performance to be fed into process which will go to person and their supervisor and referred to in appraisal would be a good idea and would be proof of practice.

This action now complete.



Recommendation 9

The audit facility is identified as the solution to this issue. If details of this facility are not included in the policy document please forward the latest copy.


A process of checking (by the duty officer) the quality of PNC input in a monthly bases was implemented. However, due to the double checking/quality management of inputs - outlined in the strategy - it was found that there were no significant errors and this was thought not to be the best use of the duty officer time. On that basis the process was stopped.

This aspect had been reconsidered and as opposed to totally disregarding the concept, but to minimise the impact of the checking process when no significant errors result, this process will be built into the quarterly training needs analysis and employee development checks that were introduced into the FCC. These checks concentrate on performance, training needs and welfare issues.

The process that is in place in relation to the management of PNC will inform supervisors of any issues highlighted during this audit.


LIST OF GOOD PRACTICE

In addition to the specific recommendations HMlC highlighted 4 areas of good practice:

1. The review and deletion of unused PNC user ids performed every three months.

2. The process employed by the Force for transaction monitoring.

3. The PNC User Group’s ownership of the Audit Reports and the use of the ‘Schedule of Audit Findings’ to track and monitor the report recommendations.

4. The good working relationship the Dumfries and Galloway has developed the Procurator Fiscals office.


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