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Not Protectively MarkedAppendix Y

Equality Impact Assessment

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Name ofPolicy/Function

National Police Promotions Framework Trial

Name ofAssessor/Author

Alex Protts ([email protected])

Name ofPolicy/FunctionLead

Merielle Ghali ([email protected])Project Executive

What are the keyaims of the policy?

The main aim of the NPPF trial is to address a finding of the HedgerReview that identified a number of police forces and police officers whohad expressed concerns that the national promotion system (OSPRE®)which controls the flow of officers qualified for promotion was notproviding the right number of officers of sufficient calibre for promotion inforces in England and Wales. There was also concern that local policeforces should feel a greater ownership of the promotion process. ThePolice Promotion Examinations Board (PPEB) was asked to trial an optionthat would incorporate significant elements of work based assessment(WBA) against National Occupational Standards (NOS) to replace some orall of the tests of potential administered through OSPRE®.

Who is responsiblefor decision-making in relationto this policy?

Police Promotion Examinations Board

Who is responsiblefor implementingthis policy?

National Policing Improvement Agency

Relevance to the DutiesConsider the following to determine to what extent this policy is relevant to the public sectorequality duties and the different protected groups (the protected groups being age, disability,gender (incl Transgender), race, religion or belief, and sexual orientation)?

Can the aims within this policy contribute towards the public sector equality duty?a) eliminate unlawful discrimination, harassment and victimisationb) advance equality of opportunity between people who share a protected

characteristic and those who don’tc) foster good relations between people who share a protected characteristic

and those who don’t.

Yes

Does the policy affect service users, employees or the wider community, andtherefore does it potentially have a significant effect in terms of equality?

Yes

Is it a major policy, significantly affecting how functions are delivered in terms of Yes

Not Protectively Marked


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equality?

Will it have a significant effect on how other organisations operate in terms ofequality?

Yes

Does the policy relate to functions that previous engagement has identified as beingimportant to particular protected groups?

Yes

Does or could the policy affect different protected groups differently? Yes

Does it relate to an area with known inequalities (e.g. racist incidents, promotionprocesses, access to information for disabled people)

Yes

Does it relate to an area where equality objectives have been set by yourorganisation?

Yes

DEVELOPING THE POLICYConsider the following questions to determine how the policy relates to equality and how it canbe developed to support the equality duties.

How do the aims of the policyrelate to equality?

What is the purpose ofthe policy?

In what context will itoperate?

Who is it intended tobenefit?

What results areintended?

Why is it needed?

Main aims of the proposed policy/policy change

The main aim of the NPPF trial is to address a finding of theHedger Review that identified a number of police forces andpolice officers who had expressed concerns that the nationalpromotion system (OSPRE®) which controls the flow of officersqualified for promotion was not providing the right number ofofficers of sufficient calibre for promotion in forces aroundEngland and Wales. There was also concern that local policeforces should feel a greater ownership of the promotionprocess. The Police Promotion Examinations Board (PPEB)was asked to trial an option that would incorporate significantelements of work based assessment (WBA) against NationalOccupational Standards (NOS) to replace some or all of thetests of potential administered through OSPRE®.

The context in which the policy will operate

In 1991 OSPRE® (Objective Structured Performance RelatedExaminations) was introduced. OSPRE® comprises two parts.Part I is a 150 multiple choice question examination testingcandidates’ knowledge of law, evidence and procedurerelevant to the rank of sergeant and inspector. Part II is aseries of seven 5 minute role acted work sample exercisesdesigned to assess officer performance across a range ofbehavioural competencies. OSPRE® is effectively a singlepromotion framework for the police service.

Once qualified through OSPRE® officers are then able to applyfor selection for promotion. PPEB has no role in the finalselection of officers to be promoted and this is not monitoredby NPIA.



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During 2004 seven forces were invited to take part in a trial ofa new promotion process that would incorporate WBA. Afterconsultation in 2007 a phased roll out was approved tocommence in 2009, however, concerns were raised in relationto the NPPF. The concerns raised were:

The PPEB and NPIA not being able to guaranteecompliance with NPPF,

No effective governance procedure in place to ensureforces comply with NPPF,

No effective underpinning PDR and assessmentstructure process,

Uncertainty and lack of clarity in respect of actual costfor implementation and operation of NPPF,

Failure to comply with statutory duty to promotediversity under the race, disability and gender duties topromote equality – an adequate EIA had not beenundertaken which identified whether replacing theOSPRE Part II with the NPPF process would have adisproportionate impact on people from minority groupsin the service or whether in those circumstances theNPPF can be justified as being a proportionate means ofachieving a legitimate aim as required by the legislation

As a result a new trial was devised to take into considerationthese concerns and test the new measures to address themwhich began in April 2009. The EIA covers the whole trial interms of considering evidence and information in relation tothe actual or potential impact.

The NPPF covers the whole process from the initial applicationfor promotion from police constable to sergeant and sergeantto inspector to substantive promotion. The four steps of theNPPF are:

Step One - Suitability.Candidates must have completed probation and becompetent in their current rank as assessed through thePerformance Development Review.

Step Two - Legal examination (OSPRE® Part I exam).Candidates must demonstrate the appropriate legalknowledge relevant to the rank applied to.

Step Three - Assessment against rank specific competenciesand vacancy requirements.



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Candidates must demonstrate potential against the fullrange of required competencies. Additional competenciesmay also be required for specific roles.

Step Four - Temporary promotion and work-basedassessment.

Candidates are provided with an opportunity todemonstrate competence in the relevant rank aspired toover a period of at least 12 months, and if successful theyare expected to achieve a substantive promotion.

Ten police forces in England and Wales are involved in thisfurther two year NPPF trial; these include the original sevenforces from the first trial and three others (listed below). Thisshould enable a test of the full licensing process. The forcesinvolved are; Avon and Somerset, Bedfordshire, Hertfordshire,Leicestershire (for Inspectors only), Merseyside, Metropolitan,North Wales, Sussex, Thames Valley and West Midlands. Theadditional forces were Avon and Somerset, North Wales andthe West Midlands. Part of the selection process to identifyfurther trial forces included looking at their representationcompared to their local area to ensure that there was as muchopportunity as possible to ensure that further informationcould be gathered as part of the assessment of potential andactual impact.

Who is supposed to benefit

The NPPF trial will benefit officers, the wider police service andcitizens if found to be a successful way to improve standardsand numbers of officers eligible for promotion.

What results are intended?

To establish if there is a better way of promoting officers intothe ranks of sergeant and inspector in England and Wales.The success criterion being used are:

1. Forces are able to match candidate numbers to vacancynumbers (fully involves local management input anddecision making)

2. Forces are clear about the requirements needed forpromotion and national standards are being used (clearand reasonable licensing regime and fair and robustPDR)

3. Forces and candidates can operate the NPPF easily(minimal bureaucracy)

4. Forces report that the quality of newly promotedsergeants and inspectors is improving (national



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minimum standards to assist with consistency andequality of application)

5. The NPPF helps forces achieve their obligations under thestatutory Equality Duties (progress on equality)

Why is it needed?

The Hedger Review found that OSPRE® was not bringingenough officers into the promotion process. The findings ofthe review group recommended that the police service trialalternative approaches to promotion to establish if there is abetter way of promoting officers into the ranks of sergeantand inspector in England and Wales, and that an alternativewas sought and commissioned through the National PolicingImprovement Agency.

What aspects of the policy aremost relevant to equality?

Based on responses to focus groups and concerns raised bystakeholders:Assessment against Competencies (Step 3)Work Based Assessment (Step 4)

What equality information isavailable?

At the time of the trial starting there was limited data captureand a number of other areas where information is available inrelation to equality issues in police promotion.Policing Green Paper ‘From the Neighbourhood to the National[2008]Career Progression of Ethnic Minority Police Officers [1999]The Report of the Morris Inquiry – An Independent Inquiryinto Professional Standards and Employment Matters in theMetropolitan Police Service [2004]Commission for Racial Equality Formal Investigation of thePolice Service [2004]HMIC Leading from the Frontline [2008]Policing Minister’s Assessment of Minority Ethnic Recruitment,Retention and Progression in the Police Service [2008]Hedger Review and associated documents [2003]National DNA Database stage 2 EIA (incl. EHRC audit) [2009]Metropolitan Police Authority Race and Faith Inquiry –Emerging Issues [2009]Gender Agenda 2 [2006]NPIA - A Strategy for the 21st Century Leading Policing [2008]NPIA - A People Strategy framework for the Policing inEngland and Wales [2008-2013]Strategy for a Healthy Police Service [2006-2010]Disability in the Police Service [2006]EHRC Beyond Tolerance: sexual orientation project [2009]Home Office Flexible Working in the Police Service [2007]Home Office In Sickness and in Health: Reducing SicknessAbsence in the Police Service [2001]



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NPIA National Police Promotions Framework documentsEquality Diversity and Human Rights Strategy for the PoliceService [2009]NPPF Operating ManualHome Office Positive Action ToolkitACPO Guidance on Expressions of Religion and Belief in theWorkplaceNoteworthy Practice DocumentOfficer Promotion to Sergeant and Inspector: Supply andDemand (Eikonika) [2003]The Evaluation of the Trial of Work Based Assessment forPromotion (Symbia) [2005]Centrex Evaluation of the Police Promotion Trials to the rankof Sergeant and Inspector incorporating Work BasedAssessment [2007]

What are your informationgaps and what can you do tofill them

We have worked throughout the trial to ensure we have a fulldata set to analyse as part of the evaluative review at thecompletion of the trial. This will be one of the reports thatinform decision making in relation to the future of NPPF.We also undertook focus groups with officers who have beenthrough both processes to identify any concerns or issues inrelation to the processes and these findings have been fedinto the EIA to also support decision making at the end of thetrial.We have also undertaken surveys of candidates of OSPRE®

and NPPF to identify any issues in relation to the processesbeing run and equality, this information was also fed into theEIA.We have also undertaken some work to review the availablepool and attempt to look at trends on those in the rank ofconstable, sergeant and inspector - available in the HomeOffice Statistical Bulletin ‘Police Service Strength England andWales’ over the last 10 years, this has also been used in theEIA.All of these activities were undertaken as part ofrecommendations of initial impact assessment work on thetrial.

Which groups do you thinkyou should engage with tobetter understand the actualor potential effects of yourpolicy on equality?

Staff Associations (Police Federation of England and Walesand Superintendents Association of England and Wales)Diversity Staff Support GroupsGroups of officers from protected characteristics who havebeen through the promotion process or who are seeking to gothrough the promotion process.

ANALYSING THE EFFECT OF YOUR POLICY



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Using the information you have gathered, answer the following questions to understand theeffect on equality your policy might have.

Could the policy outcomes differbetween protected groups?

There is a concern that there is an adverse impact onequality for forces using NPPF when compared to forcesthat are using OSPRE®. However, due to the fact thatNPPF data capture does not provide data in a linearformat and that NPIA does not capture data past Part II ofOSPRE® it has not been possible to compare aspects ofthe two difference processes.There was also a concern that those in forces using NPPFwould be disadvantaged in relation to progression as theywould not be able to transfer to forces who were notusing NPPF and vice versa.

What are the key findings of yourengagement?

The notes from our focus groups have been included atAppendix B.Key findings however are that:Negative effect:

Inconsistency in relation to assessment in force Step 4 can be an overly bureaucratic process and

can impact on those with additional responsibilitiesoutside of work

Five year rule could cause issues for those who aretaking longer to get through the process throughno fault of their own

Assessment period of 12 months is too long Pass marks are too low Issues around postings and disabled officers in

force Acting opportunities in force are not offered fairly Issues of assessment in Specialist roles Lack of positive action in forces to support officers

Positive effect: Transparent process Structured process More practical and realistic than OSPRE®

Level playing field Assessment in the workplace Compliance with processes Improved people skills and engagement Access to support Has opened up promotion to those who would

never have taken OSPRE®

The initial EIA that was completed as part of the trial to



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identify action that could be taken to enable us to informa full EIA at completion of the trial found 15recommendations based on previous engagement andconcern. These have been captured in a work packageand progress and outcomes of those actions are alsoprovided and can be found at Appendix C.

Is there different take-up ofservices by different groups?

People from protected characteristics are generally underrepresented in the promotion processes.Overall female police officer representation has increasedsince 2002 from 17.9% to 25.7% in 2010, also a clearalthough less notable increase in female officerrepresentation at Sgt and Insp ranks during same periodfor NPPF and non NPPF forces, and similar findings reethnicity representation, but this is not proportionate tothe increase in representation in the service particularlyat senior levels.

Could the policy affect differentgroups disproportionately?

See appendix D.

If there is a greater effect on onegroup, is that consistent with thepolicy aims?

The greater effect in this area is not part of the policyaims. The policy aims are to enable forces to meet theirequality duties but to also provide a promotion processthat is fair and does not cause adverse effect.

Has the policy delivered practicalbenefits for protected groups?

Some have found that the work based assessmentprocess offers more flexibility and ability to perform indifferent roles than the OSPRE® Part II process.The focus group attendees (people who have beenthrough NPPF and are from a protected characteristicgroup) indicated that there is greater confidence inrelation to the transparency of the process in most steps,and also the fact that NPPF has a defined structure, testsyou in the role and makes forces have to follow certainstandards. Some of the activity for the evaluation reporthas identified a different response in relation to this issue:

Key stakeholders, whilst small numbers, show nodisparity in perceptions of transparency of OSPRE® orNPPF, with OSPRE® having slightly greater strength ofagreement.

Candidates were asked for perceptions of transparency ateach step but not to compare with OSPRE®

Step 1 – 56.7%

Step 2 – 84.6%

Step 3 – 28.7%



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Step 4 – 57.2%

OSPRE® Part I – 83.4%

OSPRE® Part II – 56.1%

However, these findings were not analysed by respondent(i.e. protected characteristic) so it is not possible toidentify any trends in relation to equality. The focusgroups, on the other hand, indicated a perception thatNPPF was more transparent than OSPRE®.

Does the policy miss opportunitiesto advance equality and fostergood relations, including forexample, participation in publiclife?

The gaps in the NPPF process that could contribute toadvancing equality and fostering good relations are inrelation to the ability, or not, of NPIA to mandaterequirements such as the use of positive action and therequirement of forces to undertake and publish an EIA ontheir own process. During the initial EIA work, as part ofthe trial, a number of recommendations and findings werereliant on forces taking them on or taking action and NPIAcurrently has no power to mandate forces to do certainthings – particularly in relation to step 3. The work planfor these actions is included as an appendix to this EIAand it is clear to see where progress has stalled due tothe fact that the NPIA can only raise awareness withforces about good practice, or legal requirements underthe equality duties but can’t enforce these requirements.

Could the policy disadvantagepeople from a particular group?

The requirements of the NPPF itself, as set out bystandards and processes in the Operating Manual andLicensing System do not disadvantage anybody from aparticular group. However, the way it is applied in forcecould, as evidenced through engagement processes. Soforces must be mandated to fulfil certain requirements orprovide certain information to demonstrate that nodisadvantage is experienced – as required by the EqualityAct 2010 and reiterated in the Operating Manual (use ofPositive Action for example).

Could any part of the policydiscriminate unlawfully?

No

Are there any other policies thatneed to change to support theeffectiveness of the policy underconsideration?

Consideration needs to be given to the issue of mandationof certain parts of the Operating Manual – i.e. publicationof equality data (already required in law) and use ofpositive action, particularly following a recent issue inrelation to fitness testing which is yet to be resolved. The



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work plan clearly shows where there are limitations to theinfluence NPIA has over forces compliance withrequirements in relation to equality, and stakeholders (inparticular the Police Federation of England and Wales) feelthat more should be done to ensure forces are complyingwith these requirements.

Having considered all of the information and analysed the impact on equality, you should be ina position to make an informed judgement about what should be done with your policy.

There are four options:No major change – your analysis is robust and the evidence shows no potential fordiscrimination.Adjust the policy – your analysis has identified steps that you can take to remove barriers orbetter advance equality.Continue the policy – this means implementing the policy despite any adverse effect ormissed opportunities, provided that you have satisfied yourself that it does not unlawfullydiscriminate. If it is not unlawful because it is objectively justified this must be recorded.Stop and remove the policy – if the effects are not justified and can’t be mitigated, youmight want to stop the policy altogether. If a policy shows unlawful discrimination is MUST beremoved or changed.

Record here how you are going to proceed and record any actions on the action planat appendix A.

The EIA has demonstrated that there are some steps that can be taken to remove barriers andbetter advance equality – namely improved monitoring of progress to identify where barriersexist and demonstrate trends within the service as well as considering the position of theNPIA/Government to mandate certain aspects of the activity identified within the EIA processto further ensure that NPPF supports forces ability to meet their equality duties and to ensurethat they are not creating negative effect in their application of the process.

Progress on this EIA will be reviewed (in agreement with EDHR) on:This EIA is the final EIA that will be submitted to inform the final decision in relation to thetrial. Depending on the decision that is made moving forward, further work will be completedin relation to additional monitoring requirements and action that can be taken with forces.

This EIA and action plan (if relevant) has been approved by the policy/function leadand by EDHR.

Policy/Function Lead: Merielle GhaliDate: 12.04.11

EDHR Lead: Alexandra ProttsDate: 18.03.11



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Appendix A

Action Plan for your Policy

ACTION OWNER DUE BY OUTCOME COMPLETEDY/N

Consider whether theNPIA/Governmentwould be able tomandate certainrequirements of theNPPF to forces i.e.Operating Manualrequirementsidentified through EIA

PPEB Decision Date Removal of negative effectidentified in relation tolocal application of NPPF

Following the decisionabout the future ofthe trial, ensure thatmonitoring processesare reviewed andamended to captureeffective equalitydata for futureanalysis

NPIA Beforeimplementationof furtherprocesses(work alreadycommenced)

Effective capturing of datato enable analysis ofimpact and identify issuesduring implementation.



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Appendix B

Focus Groups June 2010

Participants:24 Male Officers, 17 Female9 BME officers

Debrief ReportFour questions were asked of persons present and responses have been scanned and collatedto seek areas of consensus about the NPPF and equality issues. These will be provided to theInitiator and will be included in the next Stage 2 Equality Impact Assessment.

Question 1From your own perspective, please identify three things that you like about the National PolicePromotion Framework?Main Issues Identified

Transparent process Structured Process Increases team management More practical/realistic than OSPRE New centralised selection panel (MPS) Management qualification (Herts) Fair/level playing field Assessed over time Assessed in workplace No Part II OSPRE Encourages engagement with team Ensure proper procedures followed Makes candidates do things ‘properly’ Improves people skills in candidates WBA better as a selection tool then OSPRE II Set Standards Removes the uncertainty of OSPRE II Has opened up promotion to those who would never have taken OSPRE

Question 2From your own perspective, please identify three things that you don’t like about the NationalPolice Promotion Framework?Main Issues Identified

Inconsistent Assessors Bureaucracy at Step Four Exam pass marks too low Assessment methodology – too paper based (MPS) Too much of own time involved at Step Four Five year rule/ promotion opportunities



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Variations in standards around Step 3 (MPS) Changes to MPS Step 3 process Difficulties in being assessed in specialist roles Too much paperwork WBA too long Lack of consistency at Step 3 Variances in assessors at Step 4 More difficult in some roles to do Step 4 Lack of Knowledge in force about NPPF Percentage of vacancies compared to candidate pool Having to do a legal exam at each rank APEL? Duplication of assessment

Question 3If you were responsible for improving the way that your force uses the National PolicePromotion Framework what improvements would you make. (3 suggestions)Main Issues Identified

Assessor based assessment Reduce assessment period to 8 months At Step 3 look more for potential rather than acting experience Raise Pass marks Add additional criteria at Step 1 Happy with how force is using NPPF ( Sussex) Less repetition of assessment Assessors based on BCUs More Assessors Networking of officers on WBA ( Step 4) Improved Induction needed (MPS) Consider job swaps for those in specialised posts Reduced bureaucracy/paperwork Honest evaluation of promotion prospects Consider candidates aspirations Raise exam pass marks Link work experiences of assessors to candidates (specialised roles) Modular approach to OSPRE I Close link between PDR and NPPF Reduce numbers of candidates taking exam Application to take OSPRE I – competency/aspiration based Step Three looking at roles Increase time in ranks before taking next one Better ties between L/Manager and Assessor Manage numbers entering the process better Talent Spot Pre NPPF force assessment

Question 4



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Please advise of any equality or diversity issues that you are aware of in your force area withthe National Police Promotion Framework, with any suggestions as to how to overcome suchissues?Main Elements Identified

Concerns re disability and Postings after Step 3 Timing of Inspector Pt I OSPRE Acting opportunities to be offered fairly Concerns re fairness of positive action Requirement for more positive action/ wider catchment Equality of evidence gathering opportunity based on posting Concern re LGBT monitoring Concern re focus on race in Diversity monitoring Consider fairness not EDHR issues Wider availability of positive action Concern re recording biographical data Fairness to candidates compared to colleagues not on WBA Fear in forces of saying no to BME candidates Disability SPOC on BCUs to assist re officers with disability No real EDHR issues identified Consideration of festivals in timing of OSPRE exams. Publish list of posts for restricted officers Guaranteed interview for disabled officers meeting criteria More Positive Action More encouragement of underrepresented groups to apply0 NPPF not discriminatory Better management of all candidates expectations

DSSA Focus GroupGay Police AssociationBritish Association of Women in PolicingSikh Police AssociationNational Trans Police Association

Each DSSA was asked to comment on the EIA work package and EIA itself and to identify anyfurther actions or activity that can be undertaken to promote equality through the NPPFprocess.

Updates were also provided to the DSSA in relation to progress that has been made since theirinvolvement in 2009.

Summary of Issues Raised:MonitoringTrans monitoring is not included but should be.Monitoring should be inclusive and used to inform decisions.

Assessors



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Concern around capacity of assessors and assessment style differencesPerceptions still exist that the process is subjective and there should be more awareness abouthow to challenge.Are all WBA assessors qualified?What is the diversity make up of the assessors?

Step 1 FilterIf a filter is introduced is must set out expectations and provide options to officers.Forces need to ensure that any process they adopt is transparent and impact assessed locally.Messages should be shared at the very start of the process.

Method of ExaminationWelcome the change in dates.Consideration should be given to modular style exams to take into account different workingpatterns.

Workforce NumbersConcerns about number of posts and number of applicants and lack of opportunity within timescalesConcern around posting policies and experiences of luck of the draw for some individuals

Positive ActionMore should be done to support officers from different cultures to enable people to progress –such as tutoring on how to write applications etc.There should be mentors for individuals going through the process to support them.Guidance should be issued to individuals interested in the process with clear and positivemessages to encourage applications.Concerns around the amount of time people have for preparation and the differences betweengroups.Concerns around those on restricted duties and the opportunities available for promotion

Focus Groups January 2011

Group 1Specialist roles – accepting evidence depends who the assessor is

Need more training for assessors – up to 45 per assessor in the Met- So many people the assessors can’t do operational observations- Thames Valley has 1:6 and use staff assessors for management competencies- Met constables all have training to be tutors now

Need to link it to PDR process

Disability information – some forces have disability passport to take through career to newjobs



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5 year limit and bottle neck – need to suspend process for new entrants until more vacancies

Legal examination should stay but question over why do it twice (could have extra tier for Ins)

Thames Valley:- Positive action drives / talent management promotion in force- Stopped study leave for positive action schemes and promotion exams (OSPRE I)- Restrict acting roles to people with Part I pass (? this idea or exists)

Met:- Positive action is a tick box for other promotion opportunities (just done to look good)- Study leave depends on boroughs – organised at an individual level- Officers on temp promotion (WBA) move to different boroughs and teams – the good

people get moved on so no continuity- 2000 people go for promotion each year

Need more performance evaluation post-Inspectors – no other tests

Can transfer police qualifications to NVQ – for new degree requirement

Need training in project management and budgets etc.- WBA / TOWBAR – need to demonstrate people management skills- Supervisors (Sgts and Insp) have to do more people management now HR moving more

centrally

Police forces need to manage expectations better – give more info about too many peopleapplying and not enough jobs. – No communication from forces in current climate and norumour control – monitoring information is published somewhere but not made obviousFreezes – people are going to stagnate, have to be a Special to get into the Met – concernsthat this could discriminate (e.g. PCSOs can’t become Specials)

Exam – raise minimum level to be able to retake (higher than 20%)

Group 2General Comments

The tacit nature of assessor knowledge means there may be unfairness when they areassessing candidates from specialist roles where they may not have solid understandingof the role.

There are large, potentially unmanageable, volumes of candidates per assessor. Thiswas a Met opinion. Thames Valley felt that this was better managed on their force withPolice Staff assessors working with Police supervisors. It was felt that this set up limitedsubjectivity and had positive feedback

It was noted that Thames Valley deal with much lower volumes (4-5 per assessorcompared to up 60 for the Met).



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It was noted that the PDR system did not link directly to Step 3 of the NPPF. This wasmainly due to the need to assess performance against current role in the PDR andperformance towards a more senior role in the NPPF.

It was felt that there was less promotion opportunity on boroughs due to cuts. An issue was raised where candidates had passed Step 2 but did not complete the

process due to a lack of posts available. It was concluded that suspending the process now, while there is little promotion

opportunity would eliminate the potential issues around the 5 years cut off issue.

1. Are you aware of any changes to the process in your force or what the current situationis with the trial?

A Met specific issue was raised whereby there had been a change in policy from 6months work based assessment to 4 months. This wasn’t advertised and there wasconcern as to how this information should be made available in future.

2. Has your force undertaken any positive action initiatives in relation to promotion?

Reasonable adjustments are made but there are often cost implications which aresometimes difficult to justify.

There was a feeling that PALP was not an effective way of helping under representedgroups to progress.

It was also noted that there seem to be fairness and equality issues with HPDSopportunities.

3. Have you progressed any further since the last focus group?

There are much fewer opportunities now which impacts impact on opportunity. There are fewer “acting up” opportunities making it very difficult to ascertain evidence

for Step 3. It was felt that everyone should get feedback irrespective of pass or fail. There was a feeling that the text boxes used in the assessment process were not

adequate to fully detail work.

4. Has your force put out any communication about the potential lack of opportunity forpromotion?

See number 1 and 3. It was felt that the 30+ and 30+plus schemes limited the amount of promotion

opportunities. This combined with lower pass marks means that there are more peoplein the pool for fewer jobs.

5. Does your force share monitoring information about its promotion process or would youknow where to find it if you wanted to?

The group were not sure who had responsibility for this or where details could be found.



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6. Has there been any other representations made to you about inequality within theprocess - either anecdotal/rumour mill/or experience?

None specifically but point was made that line managers should be assessed as to theirsuitability to be assessors.

7. Should the service suspend the NPPF process while there are fewer promotionopportunities?

Whilst the general consensus was that of suspending NPPF, a point was raise by a Metofficer. He had concerns that there may be unfairness issues for those officers with 3-4years service left before retirement.



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Appendix C

National Police PromotionFramework - Equality ImpactAssessment

Review

This work package has been reviewed one year on from publication of the EIA to update onprogress against the recommendations identified within the EIA.

Feedback from the focus groups conducted during 2010 has been attached at appendix Babove.

The limitations of the recommendations from the EIA are around the relationship betweenNPIA and forces, some actions are limited as to how much the NPIA can affect or influenceforces to take further action as it is for forces and chief officers to use their own EIA processesto identify areas for improvement.

Overall, it would appear that whilst there are some elements of the NPPF that could have anadverse impact on underrepresented groups, these forces implementing the trial need toaddress these through their own promotion processes.

A substantial amount of amendments have been made to the Operating Manual, theNoteworthy Practice Guide, the Licensing System and the NPPF website to raise awareness toforces about the different elements identified within this EIA.

The overall EIA and findings from focus groups and sounding boards as well as additional workon analysis that has been carried out as a result of the EIA will be incorporated into the finalreview of the trial prior to a decision being made on whether or not to fully implement the newprocess in order that the decision making body can take full account of the potential impact.

WP NameNational Police Promotion Framework – Equality Impact Assessment –December 2009

WP ID Equality Impact Assessment

WP Owner NPIA



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Description

The National Police Promotion Framework is being trialled as new systemthrough which police officers are promoted from the ranks of constable tosergeant and sergeant to inspector.One component feature of the trial is the equality impact assessment andNational Policing Improvement Agency’s Corporate Equality Diversity andHuman Rights Team Leader, Alex Protts, has completed an equality impactassessment in November 2009 which contains a number ofrecommendations.

This work package identifies each recommendation, assigns it to an ownerand identifies the action required and the timescale in which it is to becompleted.

Techniques,processes,procedures tobe used

StandardEach submitted document to be ‘signed off’ by the project executive.

InterfacesProject ExecutivePolice Promotion And Examination BoardPolice Promotion Implementation Project Board

Constraints

[Identify any constraints imposed upon the team or person carrying out thework.]Where the recommendations require implementation by forces, the taskowner may be constrained by the extent to which forces are prepared toaccede.

Quality processAction to be discharged by the target date to the standard of the projectexecutive.

Resources,costs andtimescales

ResourcesThose named in the document. Tasks can be delegated to appropriatelyskilled individuals with their manager’s consent.

TolerancesThe only restriction is time, as stipulated by the Project Executive, thereforeany time tolerances required should be requested of the project manager atthe time, and agreed with the project executive.

Configurationmanagementrequirements

The actions and a brief summary of the outcomes arising from them shouldbe recorded in this work package document.Reference copies of each component document should be retained byworkforce strategy unit in the Churchill drive file path N:\03-WIP\Workforce_Strategy along with the November 2009 equality impactassessment and annexes.



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Comments

[The team manager/person responsible for undertaking the work mayrequest to make adjustments to the work package description after itspreparation by the project/stage manager. This section is included to allowfor exclusions, risks, dependencies, revised timescales or resources, and anyother such agreed amendments to be recorded.]

Work package reporting requirements

Regularreportingprocess

Activity owners to report progress to the project manager as part of thehighlight reporting process.

Exceptionreportingprocess

[Exception reporting will normally follow the procedure outlined in the PID orproject/stage plan, as appropriate. If the team manager/person responsiblefor the work package forecasts that ‘tolerances’ are going to be/have beenexceeded, then the project/stage manager should be informed using thisprocess.]

Recommendation (1): [CLOSED]

Data that is currently provided as part of results and analysis reports should, whereappropriate, be evaluated by national policing improvement agency equality diversity andhuman rights unit to ascertain any differences in success rates based on age.

This recommendation is closed as the issues are covered at recommendation five in relation toage and the National Police Promotion Framework process.

Recommendation (2):

National Policing Improvement Agency Workforce Strategy Unit co-ordinate work to determinewhether or not:

a) Association Of Chief Police Officers/National Policing Improvement Agency/Home OfficeGuidance On The Use Of Bradford Scores – has any new advice been issued since thepublication of the Home Office In Sickness And In Health: Reducing Sickness Absence InThe Police Service [2001] guidance;

b) If the Bradford scores are still being used, work should be undertaken to determine howforces are using it and what their monitoring shows in terms of disability;

If no guidance is available to forces, in relation to attendance management and national policepromotion framework, advice should be given through the operating manual that for thepurposes of National Police Promotion Framework any absence that is related to disability,communicable diseases, work related injury or illness or one off epidemics, should bediscounted from an individuals absence record. If this is not possible, justification should be



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provided.

Owner: Ian Barry

Activity required: Share Police Advisory Board guidance from 2008 with forces Publish guidance on website Use the Association of Chief Police Officers Attendance

Management Forum to establish the use of policies in force andhow these are monitored.

Issue guidance through Association of Chief Police Officers forumin relation to monitoring disability and sickness (as required inlaw).

Share information with forces in relation to the up comingEquality and Human Rights Commission investigation of the policeservice in relation to disability.

Date required: September 2010

Update: Discussed at Strategic User Group – March 2010.

The outcome of the Association of Chief Police Officers AttendanceManagement Forum meetings/conversations will be provided to theStrategic User Group in May 2010 and further evidenced in this workpackage.Update July 2010 - this took place and further updates to be provided asmeetings take place.The EHRC Inquiry into Disability Hate Crime in the Police Service hasbeen considered in this area but the terms of reference cover hatecrime, and do not consider employment issues.

Outcome: All forces are now supplied with Police Advisory Board guidance. PoliceAdvisory Board guidance is also on National Police Promotion Frameworkweb pages and all forces advised to ensure they are compliant withDisability Discrimination Act legislation surrounding sickness absenceand discounting from attendance management policies.

December 2010Work has been completed since the last update to try and identifywhether there is any information available centrally in relation todisability related absence and promotion. The only data that exists is inrelation to absence and whether it is injury on duty or not. It has alsonot been possible to provide guidance on disability monitoring asrestrictions have been placed on the NPIA and ACPO in relation to thecreation of guidance, and the information provided to date alreadyprovides this information:

Disability in the Police Service Guidance PAB Guidance on Bradford Scores



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Monitoring Advice links within the EIA document

There is also existing guidance available from the Equality and HumanRights Commission in relation to monitoring disability in line with thedisability equality duty.

It is recommended that this action is closed.

Recommendation (3):

During the trial of the National Police Promotion Framework, if the National PolicingImprovement Agency Workforce Strategy Unit identifies noteworthy practice in relation topostings and disabled officers this will be incorporated into the noteworthy guidancedocumentation for other forces to use.

Owner: Ian Barry

Activity required: Monitor number of reasonable adjustments being offered. Identify experiences of candidates through focus groups and

suggestions for addressing these.


Update: Disability specific focus groups have been arranged for June 2010 tofurther explore this issue.

After discussion at the noteworthy practice event in January the sharedpractice document is to be updated for March 2010.

The Step Two is subject to the OSPRE® reasonable adjustment policy,through which candidates have the opportunity to seek reasonableadjustments to test conditions. Since 2004, 240 individually tailoredreasonable adjustments have been offered to OSPRE® Part I candidates.

Review July 2010.The focus groups held in June 2010 have identified that the main areawhere individuals feel there is an issue is around Step 3 and postings toroles.

Ask forces about whether or not they monitor postings andinclude disability?

Identify any good practice around roles and disability to ensurepeople are doing what they can rather than focusing on what theycan’t.

Number of reasonable adjustments at Step Two and within OSPREhas been provided to forces.

To be included on agenda of next Strategic User group meeting inJuly 2010



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December 2010 Disability Passport Scheme from Cambridgeshire examined and

documents sent to all forces. Scheme for categorising roles and individuals in TVP has been

discussed. The scheme has been prepared but has not beenimplemented at present. Further information was sought in March2011, and the scheme has still not been implemented.

Forces have been reminded about their duty to EIA their postingprocesses.

Further work with focus groups in June also identified that this isstill an area of concern for forces.

Licensing system now requires this information also.

Outcome: Work has been done to identify good practice and this has been shared.Monitoring data is collected centrally in relation to step two, but forceshold data on other steps and postings and should be using this.Shared practice document to be updated following discussion for March2010.

This was one of the areas covered in meeting with all trial forces inJanuary 2011 to feed noteworthy practice into the evaluation of the trialPractises identified through the licensing system and hints and tips forany new forces will be prepared in time for any potential roll out of theNPPF.

Licensing system now requires this information also.

It is recommended that this action is closed.

Recommendation (4): [CLOSED]

The National Policing Improvement Agency should give consideration to whether or not adviceshould be provided to forces on providing study time/leave to ensure the issues of inequalityare addressed.

Owner: Ian Barry

Activity required: As per recommendation.

Date required: July 2010

Update: This action is completed and closed.

Outcome: This has been considered and forces have been asked about their studyleave policies. In the current economic climate the National PolicingImprovement Agency would not wish to advise forces or set a precedent– but forces must complete an equality impact assessment in relation tostudy support to officers before any decision is taken to remove (or add)a policy to ensure that no person suffers a detrimental impact.



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Recommendation (5):

Further work should be co-ordinated by National Policing Improvement Agency WorkforceStrategy and Examinations and Assessment Units to justify the five year limit on OSPRE® PartI and identify any exclusion terms that could be incorporated into the operating manual.

Owner: Ian Barry & Charlie Eyre

Activity required: Evaluation of data captured through the national police promotionframework and OSPRE® will be ongoing.

Evaluation around success at Step Three relates to similar issuesof older candidates being less successful.

Stats included in five year rules paper to be examined further toidentify any trends.

Data to be collated and evaluated from March 2010 andSeptember 2010 exams.


Update: A test of knowledge is currently required to determine competence inlegal and procedural issues in relation to the aspired rank. A number ofpapers have been written that justify the argument in relation topotential disproportionality and this was discussed at police promotionimplementation project board in February 2010 and will be furtherdiscussed in March 2010.

Subject of further consideration and change of process underway. ThePPIPB also asked the PPEB to consider the issue in relation to OSPREforces to address fairness in the application of the rule.

Forces to consider timing of any processes to match OSPRE® time table.

Paper on five year rule to be included on the Promotion web page.

July 2010 Update - Additional paper on PPIPB agenda for discussion postchange to 5 year rule in July 2010 to potentially include officers witheligibility running out in 2010

December 2010 Item discussed at PPEB April and October 2010 with no changes

to present rule Minor change made in respect of Leicestershire and their intention

to return to OSPRE – allowing registration of candidates withinthe 5 year period.

Outcome: ACPO letter to forces seeking views on proposal to extend 5 year ruleand extend period that candidates can remain in Step Three pools, apaper is to be submitted to PPEB for May 2011.



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Recommendation (6):

That the National Policing Improvement Agency Workforce Strategy Unit use thecommunication strategy for the National Police Promotion Framework to highlight issuesaround posting and monitoring and seek areas of noteworthy practice for inclusion in existingguidance.

Owner: Ian Barry

Activity required: Ask forces about how they implement positive action aroundposting and what their posting criteria is.

Provide guidance to forces in relation to the above.


Update: Discussed at the noteworthy practice event in January 2010.Forces seem to be unsure in relation to positive action and posting.

Develop some specific guidance around positive action in relationto posting that can be shared with forces.

Use the NPPF update to provide specific information in relation toposting and good practice as a dedicated article.

December 2010This action is similar to recommendation 3, and all of the activity is thesame.

Propose that this recommendation is closed as it is a repeat ofrecommendation 3.

Outcome:

Recommendation (7):

The Police Promotion and Examination Board and National Policing Improvement Agency utilisethe communication strategy to further publicise these initiatives to forces.

Owner: Ian Barry

Activity required: Ian Barry to follow up earlier contact with Greater ManchesterPolice and identify any learning from this work.

Ask forces about positive action that is in place internally. Research discipline issues contained in the Policing Minister’s

Assessment Of Minority Ethnic Recruitment, Retention AndProgression In The Police Service [2008]

Use article in summer 2010 newsletter to publicise issue andmake forces aware.


Update: Greater Manchester Police work has not been completed due to lack of



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funding although it is being progressed with Independent PoliceComplaints Commission, Home Office, British Transport Police and WestMidlands Police. Other forces have also been invited to take part in aresearch project. However, there is no outcome to date that can beused to inform the National Police Promotion Framework equality impactassessment.

Forces have been asked to provide information on positive actioninitiatives that are taking place. As a result of the initiatives identifiedthe shared practice document will be updated.

Review July 2010 The research is now being progressed in Greater Manchester

Police to look at disproportionality in disciplinary processes.Initial meetings have been held involving NPIA and once workcommences it is anticipated that the results will be publishedwithin 6 months.

December 2010The GMP work around disproportionality appears not to have goneahead, and as such there is no further information available for inclusionin this recommendation. Forces will be aware, however, of existinginformation relating to fairness in discipline procedures that washighlighted during the Taylor Review.

The general response from forces in relation to positive action is thatsome have specific programmes that do address promotion processesand others aren’t undertaking positive action. Feedback from focusgroups with under represented officers who have been through theprocess is that they are unaware of any positive action initiatives in theirforces (apart from MPS).Positive Action remains a tool that forces can opt to use, and remains avoluntary provision of the Equality Act 2010, despite having anadditional clause to allow for the selection of candidates with protectedcharacteristics as a means of addressing inequality, where thatcandidate is equally qualified at the end of an assessment process. Thiswill be for Chief Officers to decide whether they wish to implement thisprovision within their force.

Outcome: Publication of noteworthy practice document in March 2010.This was superseded by a document providing information to forcesinterested in early adoption of NPPF which included information onWorking with Greater Manchester Police to inform their research projectfrom a National Police Promotion Framework angle.

I would recommend at this point that this recommendation is



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exhausted in so far as how much the NPIA is able to do, and assuch suggest that it is closed. Any available information orability to prompt for the use of positive action has beenincorporated. NPIA is unable to mandate that forces usepositive action. In addition NPIA supplies a quarterly newsletteron the NPPF to all forces and interested parties to ensure that allrelevant information is supplied to forces in a timely way.

Recommendation (8):

National Policing Improvement Agency project team and Police Promotion and ExaminationBoard to monitor information from forces to identify whether or not any disparity does existbetween Black and minority ethnic and White officers in relation to transfers to other forcesprior to step four. Comparison should also be made, where possible, to previous data fromOSPRE®. Forces will also be able to monitor this information as they will receive quarterlyupdates from their returns; this will further support forces in house equality impactassessment processes. However, comparison will be difficult as the current OSPRE® does notmonitor nationally what happens in forces after officers become qualified.

Owner: Ian Barry

Activity required: Ask forces whether or not they have a transfer’s policy. Establish if National Policing Improvement Agency data capture

identifies transferees National Policing Improvement Agency to research transfers in

forces through evaluative research reporting in March 2011

Date required: March 2011

Update: Review: July 2010 Further issues have been identified through consultation in

relation to the transfer of officers on restricted duties and theimpact on promotion opportunities due to the limited number ofroles that may be suitable.

December 2010 The recent evaluation of NPPF has asked questions in the areas

outlined in Recommendation 10 and results are currently beinganalysed to be fed into the PPEB in May 2011.

The opportunity for transfers between forces on promotion or atexisting ranks has been monitored between September 2010 andDecember 2010. Opportunities for transfers at existing rank oron promotion have been severely limited, and mostly relate tospecialist skills.

Outcome: March 2010 – Proforma sent to all forces with regard to transfers



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including transfers to and from Police Service of Northern Ireland andScottish forces to coincide with work by Police Advisory Board aroundthis issue. Association of Chief Police Officers to collect informationfrom OSPRE® forces. This report came to the conclusion that this is amatter that involves a very small number of officers and that wheresuch transfer does occur, forces have been able to adapt their ownprocesses for ensuring officers in such a position receive adequatetraining and induction to integrate them into their new force.

Recommendation for this action to be closed due to evidenceshowing that no negative impact exists and to also reduce thebureaucracy of surveying forces.

Recommendation (9):

The Operating Manual and licensing agreement for the National Police Promotion Frameworkshould make reference to the APA Equality Monitoring Duty guidance, the ACAS Guidance OnMonitoring and the Stonewall Guide ‘What’s It Got To Do With You?’ so that forces can ensureofficers are aware of how the information get’s used and the levels of confidentiality as well aschecking their own monitoring provisions.

Owner: Ian Barry

Activity required: Advice to forces re Stonewall Champions Provide stonewall monitoring document on web page Discuss on line completion of monitoring forms with Examinations

and Assessment Monitor ongoing completion rates of monitoring forms. Discuss data capture with forces.


Update: The issue of online completion of monitoring forms has been discussedwith examinations and assessment and will consider as part of anoverall piece of evaluative research into National Police PromotionFramework. This will report back to the Police Promotion andExamination Board in February 2011.

Work to monitor completion rates will be incorporated into existing datacapture processes and the completion rates should be available for thenext equality impact assessment review in September 2010.

Outcome: Discussed at noteworthy practice event in January 2010 with trialforces.

All trial forces bar Avon and Somerset are members of Stonewall andHertfordshire, Metropolitan Police, North Wales Police, Thames ValleyPolice, Sussex Police and West Midlands Police all took part in the



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Workplace Equality Index in 2009/2010.

Operating manual has been amended to ensure advice is incorporated.

July 2010 - The GPA and ACPO document ‘Stand Up and Be Counted’will also be placed on the NPPF website.

Full monitoring data sets are now completed and will beincorporated in to the evaluative research as part of the finalreview of the NPPF trial. I recommend that this action is closed.

Recommendation (10):

National Policing Improvement Agency Equality Diversity And Human Rights Unit undertakeanalysis of the results of the survey to identify response trends in relation to biographicalmonitoring

National Policing Improvement Agency Workforce Strategy Unit to establish the feasibility ofworking with National Policing Improvement Agency Research Analysis And Information toimplement a regular survey tool for officers undertaking NPPF and those who have undertakenOSPRE® in non trial forces to provide accurate comparative information.

Owner: Ian Barry

Activity required: Link to National Police Promotion Framework evaluative researchproject to incorporate and remove duplication.

Candidate survey to be repeated mid 2010 as part of overallresearch piece.


Update: The proposal for this piece of research has been formulated inconjunction with Equality Diversity And Human Rights Analyst and isawaiting approval prior to work commencing.

December 2010The evaluation of NPPF has asked questions in the following areas andresults are currently being analysed to be fed into the PPEB in May2011:

NPPF Candidates Survey Quantitative Questions

For Step 1 of the NPPF, The method of assessment is fair, i.e. itallows an impartial assessment of candidates





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The NPPF process does not discriminate unfairly betweencandidates

The NPPF process recognises diversity by being flexible tocandidates requirements

OSPRE Candidates Survey Quantitative Questions

For OSPRE® Part I, The method of assessment is fair, i.e. it allowsan impartial assessment of candidates

For OSPRE® Part II, The method of assessment is fair, i.e. itallows an impartial assessment of candidates

My force operates a fair method of selection for promotionfollowing OSPRE® Part II, i.e. it allows an impartial assessment ofcandidates’ ability

The OSPRE® process does not discriminate unfairly betweencandidates

Outcome: The candidate survey piece has been incorporated into the evaluativeresearch.The analysis of biographical information has been completed and will beincluded as part of the evaluative review of the NPPF.

I recommend that this action is closed.


Work should be undertaken by National Policing Improvement Agency Workforce Strategy Unitto identify whether or not all forces have completed equality impact assessments on internalpromotion processes (initial responses indicate that only a small number have) and raise anyconcerns with the Police Promotion And Examination Board

Owner: Alex Protts

Activity required: Letter from Police Promotion and Examination Board to ask forequality impact assessment from forces.

National Policing Improvement Agency to collate responses. National Policing Improvement Agency to provide template to

forces through national equality impact assessment.


Update: Letters have been sent and feedback requested before the end of March2010.

Once list is complete action will be taken to focus on equality impactassessments in trial forces to ensure they are appropriate.



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December 2010 Forces have been advised as to the need for an EIA across their

processes and NPIA will provide support and assistance to forcesin their completion.

NPIA is not in a position to monitor or evaluate the standard orcontent of EIAs provided by forces but can offer bespokeguidance as required.

The onus would be on the force to demonstrate an effective EIAof their processes if challenged. The NPIA can offer support andguidance, as stated, but cannot mandate a format or ‘assess’ theeffectiveness of force EIAs.

Outcome: Work already completed with MPS (Step One-Three equality impactassessment) and possibly Sussex in the near future.

Forces are now focused on equality impact assessment and are alsorequired to submit as part of licensing procedures. However, NPIAcannot enforce the requirement for EIAs, apart from the role thelicensing process has.

I recommend that the NPIA can not do anything further withregard to this recommendation and as such I suggest that it isclosed.


National Policing Improvement Agency Workforce Strategy Unit co-ordinates work with trialforces to identify informal grievances in relation to National Police Promotion Framework toidentify further issues that may affect the implementation of National Police PromotionFramework.

Owner: Ian Barry

Activity required: Write to forces to ask about recent tribunals/grievances Responses to be collated and shared in March 2010 Data on post OSPRE® process to be evaluated alongside step

three processes.


Update: Strategic user group asked for updates to be passed through by March2010.July 2010 – For agenda at next Strategic User group in July 2010

December 2010

An area where not much progress has been made to date. Some forceshave been slow to respond to this area, and will be asked again at



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meeting of all trial forces in January 2011. Forces have no duty toprovide this information to the NPIA, but it should be available onthrough their publication schemes or as evidence within their EIAs oftheir own processes.

Outcome: I recommend that if nil returns are offered by forces, that thisrecommendation is exhausted and should be closed.


The National Police Promotion Framework provides guidance or links to positive actioninitiatives/toolkits to trial forces and the National Policing Improvement Agency WorkforceStrategy Unit co-ordinates work to establish what, if any, positive action initiatives are beingused to encourage applications to the national police promotion framework from underrepresented groups and to support those groups through the process.

Owner: Ian Barry

Activity required: Consider the development of national guidance/process forapplication and monitoring.

Provide better support for managers to be able to assessindividuals.

Provide guidelines on positive action (in addition to existingguidance)

Utilise technology to assist with information capture. Include links to qualifications and curriculum authority codes of

practice on promotion web pages. Use communications strategy to focus on message of reduced

bureaucracy and acceptable assessment methodology.


Update: Further work around monitoring is captured at recommendation 15.

National Policing Improvement Agency is involved in a review ofMetropolitan Police Work Based Assessment processes and willincorporate learning outcomes into guidance for forces.

There is an established positive action network amongst forces whereinformation can be shared.

Initiatives have been identified and will be shared in a noteworthypractice document update in March 2010.

Strategic and standardisation groups will share noteworthy practice.

Review July 2010:



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Through focus groups it has been identified that a specific pieceof work in relation to positive action and the NPPF should becompleted. This is captured at recommendation 6.

December 2010The NPIA has been restricted from developing further guidancedocuments for forces. The EHRC will be producing new guidance onpositive action in line with the new Equality Act 2010, and NPIA hasrecently provided an ACAS seminar to forces that covered positiveaction as a specific area.

Outcome: Operating manual was further updated in October 2009 to reflect theseissues and recommendations.

National Police Promotion Framework to take account of changes of useof qualifications and credit framework as and when guidance is issued inrelation to assessment and training.

I recommend that the NPIA’s ability to influence this work areais exhausted, and that with the restriction on issuing guidance,and the fact that positive action is a choice for forces to make,that this action is closed.


National Policing Improvement Agency to use the National Police Promotion FrameworkCommunications Strategy and a diversity group sounding board to ensure that groups continueto be involved in the development and review of the national police promotion framework.

Owner: Ian Barry

Activity required: Reconvene sounding board re proposed work and consultations


Update: Further dates set for May 2010.

Outcome: Outcome of 2010 focus groups attached at appendix 1 to this workpackage.Activity is captured within the work package.

December 2010 A group of those who attended EIA focus groups in 2010 will be

meeting to discuss issues and consider mitigations for anyconcerns in January 2011.

The Sounding board group has been asked to provide writtenfeedback on proposed changes to the NPPF licensing system.Closing date for feedback was the end of December 2010.



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The focus groups mainly identified issues within force processesthat have been fed back to force leads through the strategic usergroup. These include:

o Lack of assessorso Lack of opportunitieso Isolation of being moved as part of step 4 and losing

networks of supporto Lack of communication about what is happening with the

trialo Lack of realistic information available about opportunities –

i.e. advertising for people to join process but not indicatinghow many positions are available

However, some forces will be promoting officers to the rank of Sergeantin 2011/12 and subsequently. Forces would need to consider whether itis fair to increase the chances of promotion for those already throughstep 2 by denying others their attempt at step 2. This needs to be fullyassessed before any decision is taken.

The key issue identified by the focus group was that they believethat entry onto the promotion process should be stopped for aperiod of time to allow the force to properly develop andpromote the people already in the pool. The group alsosuggested that if this was put in place then an overalljustification of extending the 5 year rule by one year (orhowever long the process was stopped for) as it would beapplicable across the board.

The overall feedback from these groups will be fed into the finalreview of the NPPF as a result of the EIA.


National Policing Improvement Agency Workforce Strategy Unit co-ordinates a full equality anddiversity analysis of the first year data of the new trial for summer 2010 (in support ofrecommendations made in the National Police Promotion Framework data capture report[September 2009])

National Policing Improvement Agency Equality Diversity And Human Rights Unit to provideinformation to the National Policing Improvement Agency Workforces Strategy Unit on thebiographical make up of forces so that comparison of the potential pool against those applyingfor promotion under the National Police Promotion Framework can be undertaken

National Policing Improvement Agency Equality Diversity And Human Rights Unit should



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establish the feasibility of completing a comparative analysis of biographical data for success atprevious OSPRE® processes and new processes under the national police promotionframework.

National Policing Improvement Agency Workforce Strategy Unit should undertake to establishwhether or not information is available to show drop out/failure rate at each stage of thenational police promotion framework with biographical data.

Owner: Ian Barry

Activity required: Long term analysis work with Equality Diversity and HumanRights team.

Reliant on data provided by trial and forces Linked to Examinations and Assessment evaluative research Focus groups and sounding board activity will also feed in.

December 2010This analysis has been undertaken, taking account of the limitationsplaced by candidate numbers and reporting protocols. It will form a partof the evaluation of the trial to go before PPEB in May 2011.


Update: There are limitations on how the data can be used, this has beendiscussed between EDHR and E&A and will be fed into the evaluativereview of the NPPF. It is also not possible to identify candidates throughthe steps of the process, only how many at each stage, so drop outrates are not available.Information on a possible change to the computer based system isbeing fed into current discussions on any update

Outcome: I recommend that this action is closed as it has beenincorporated into the evaluative review of the trial.

Work return arrangements (and advising completion)

Work package allocation

Authorised(name & role)

Merielle GhaliProject Lead

Date 27.01.11

Qualitychecked(name &role)

Ian Barry – Police Promotions Manager – WorkforceStrategy UnitAlex Protts – Corporate Equality Diversity and HumanRights Team Leader – Equality Diversity and HumanRights Unit

Date 27.01.11

Received(name &role)

Charles Eyre – principal psychologist – Examinationsand Assessment

Date



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Work return arrangements (and advising completion)

Work updates are to be provided by the owners to inform the highlight report, and completedwork is to be submitted to the project executive (Merielle Ghali), cc’d to the police promotionsmanager (Ian Barry). The project executive will ‘sign off’ each completed document.

Qualityreview(name &role)

Merielle Ghali

The quality review for each product in the workpackage is performed as described in each product’sProject Documentation, and a quality review signatureprovided when all products in the work package havebeen reviewed.

Date



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OSPRE NNPF OSPRE NPPF

Female Pass Rate 46.1% 56.8% 43.8% 56.9%Male Pass Rate 38.9% 48.5% 40.3% 49.0%% Disparity Gap 7.2% 8.3% 3.5% 7.9%

20102009Sergeants exam

Appendix D

Could the policy affect different groups disproportionately?

The different nature of the NPPF and OSPRE promotional processes means that it is notpossible to compare an overall success rate for those entering and leaving the process. This isbecause the final steps of each process have different outcomes.

This analytical support considers three areas in the Sergeant and Inspector processes.

Success – Comparing the success rates for OSPRE Part I and NPPF Step 2examinations.

Perceptions – Comparing the perceptions of fairness for both processes. Impact – Comparing how NPPF and OSPRE forces have changed since operating each

process.

It should be noted that comparable national data is available for ethnicity and genderprotected characteristics.

Success

The examinations in NPPF Step 2 and OPSRE Part I are directly comparable, allowing us todirectly ascertain any disparity in pass/success rates by protected characteristics.

Across both processes, female candidates generally have higher success rates when comparedto their male colleagues, a trait that is also consistent in OSPRE Part II. However the gap seenin NPPF forces is consistently greater than that which is seen in OSPRE forces. This is true forboth the Sergeants and Inspector examinations.

It should be noted that the Metropolitan Police Service makes up a notably large proportion ofNPPF force data and thus will have a disproportionate impact on overall NPPF statistics.

As with gender there is an overall disparity in the success rates of candidates based onethnicity. White candidates have consistently higher success rates when compared to minority


Female Pass Rate 39.5% 55.6% 43.6% 50.6%Male Pass Rate 40.3% 50.8% 38.5% 44.6%% Disparity Gap -0.8% 4.7% 5.1% 5.9%

Inspectors exam2009 2010



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ethnic candidates. However there is no evidence to suggest that one process consistently hasa higher level of disparity. This is show in the tables below.

Perceptions

In 2010 a survey was produced in order to obtain NPPF and OSPRE candidate views andopinions. Candidates were asked how fair they felt the methods of assessment were withineach process.

NPPF Step 1 – Around two thirds of respondents felt the method of assessment at Step1 is fair. Minority ethnic respondents were less likely to agree when compared to whiterespondents. There was also some disparity between age groups with youngerrespondents answering more likely to agree that the method is fair.

NPPF Step 2 – 79% of total respondents agreed, to some extent, that the method ofassessment at Step 2 is fair. Over a quarter of respondents strongly agreed that thestep is fair.

NPPF Step 3 – Over half of the respondents disagreed, to some extent, that themethod of assessment for Step 3 is fair. Minority ethnic respondents felt strongly aboutthis step with 76% of these respondents disagreeing that the step is fair.

NPPF Step 4 – A large proportion of respondents (44%) agreed that Step 4 is fair.Around a third of respondents neither agreed nor disagreed with the statement. Therewas a high level of disparity between the two aggregated ethnic groups with minorityethnic respondents much less like to agree that the step is fair compared to whiterespondents.

Candidates were also asked two general questions for both the NPPF and OSPRE process, theresults of which were directly comparable.

Unfair discrimination between candidates – A larger proportion of respondents fromthe OSPRE survey (62%) agreed that the promotion process does not discriminateunfairly between candidates compared to NPPF survey respondents (41%).

Recognising diversity by being flexible – Large proportions of both respondentsgroups neither agreed nor disagreed that the promotion processes recognised diversityby being flexible to candidate’s requirements. However, a larger proportion of theOSPRE respondents agreed that the process recognised diversity by being flexible whencompared to NPPF respondents.


White Pass Rate 41.2% 51.0% 41.3% 51.4%Minority Ethnic Pass Rate 32.3% 45.8% 39.9% 42.6%% Disparity Gap 8.9% 5.2% 1.4% 8.8%

Sergeants exam2009 2010


White Pass Rate 40.1% 52.1% 40.3% 46.0%Minority Ethnic Pass Rate 37.3% 42.3% 28.3% 38.4%% Disparity Gap 2.8% 9.8% 11.9% 7.6%

Inspectors exam2009 2010



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Impact

Research has been carried out to identify how female and minority ethnic officer distributionwithin ranks has changed between 2002 and 2010. The findings suggested that choice ofpromotion process (NPPF or OSPRE) had little or no impact on the distribution of underrepresented officers within the rank structure.

Between 2002 and 2010, the increase in the level of female officers distributed inSergeant and Inspector ranks was greater for OSPRE forces than it was for NPPF forces,irrespective of Metropolitan Police figures being included or excluded.

Between 2002 and 2010, increase in the level of minority ethnic officers distributed inSergeant and Inspector ranks was greater for NPPF forces (excluding MPS) than it wasfor OSPRE forces. Excluding Metropolitan Police data however shows a level of increasethat is less than OSPRE forces.

NPPF Forces 2.9%NPPF (excl MPS) 2.4%OSPRE Forces 3.3%

Force Group% Point change

2002 - 2010

Female Officers distributed in

Sergeant and Inspector ranks

NPPF Forces 0.9%NPPF (excl MPS) 3.9%OSPRE Forces 2.4%

Improvement% Point change

2002 - 2010

Minority Ethnic Officers distributed in

Sergeant and Inspector ranks

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