This year’s CoPaCC PCCs and Statutory Transparency Report is the latest in an annual series examining conformance with statutory transparency obligations by Offices for Police and Crime Commissioners (OPCCs).
CoPaCC first examined OPCC transparency in Autumn 2013. Early the following year, CoPaCC Chief Executive Bernard Rix gave oral evidence to the House of Commons’ Home Affairs Select Committee during which the Committee suggested that CoPaCC, as a public service, should review OPCC transparency annually.
Participation by OPCCs in the process is voluntary, with 28 taking part this year
As well as establishing an annual assessment of and report on OPCC websites, CoPaCC has established the “Open and Transparent” Quality Mark awarded annually to OPCCs taking part in the assessment and reaching the required standard. The OPCCs are able to display the Quality Mark on their website to signal to the public their commitment to transparency.
Participation by OPCCs in the process is voluntary, with 28 taking part this year. Development and improvement of the process of assessment is ongoing to provide a constructive but rigorous approach to improving standards of OPCC transparency.
A new process
This year, rather than inviting OPCCs to submit evidence of adherence to their statutory responsibilities, CoPaCC instead implemented a ‘Mystery Shopper’ process with a researcher visiting each website as a member of the public to try to locate the information required by The Elected Local Policing Bodies (Specified Information) Order 2011 and the simplified and specific guidance for PCCs “Guidelines for PCCs on publishing information” based on the 2011 Elected Local Policing Bodies (Specified Information) Order and published by the Home Office in 2013. The researcher marked each OPCC website against the list of Statutory Disclosures noting both the presence of the information and its timeliness. OPCCs were then provided with the opportunity to clarify any shortcomings before the final grading.
Areas for improvement
Despite the review finding a high level of achievement and a strong appetite for improvement among the OPCCs taking part, the report does highlight some key areas for improvement including information around grants, records of public meetings and easy access to contracts and tenders.
However, the most important area for improvement was not necessarily a statutory requirement, but is critical for optimal transparency: user experience and the ease of use of the OPCC websites. There is no point fulfilling all the legal requirements for the presence and timeliness of information if the user has an opaque maze to navigate when trying to find information. This will be a key area of focus for next years’ assessment.
In addition to the detailed analysis of OPCCs’ approach to transparency, the report contains a number of thoughtful and thought-provoking articles from relevant leaders in policing governance. Julia Mulligan, the Conservative Police, Fire and Crime Commissioner for North Yorkshire and the Transparency Lead for the Association of Police and Crime Commissioners (APCC) reflects on the learning from this latest Thematic for all PCCs and their staff. Barry Coppinger, the Labour Police and Crime Commissioner for Cleveland, explains why high levels of openness and transparency are so important to him and to his team. Christopher Jackson, the Chief Executive of the Office of the Police and Crime Commissioner for Suffolk, provides a view from one of the OPCCs that successfully met the threshold for award of the Transparency Quality Mark.
Recognising a commitment to transparency
Please join us in congratulating the 28 OPCCs who achieved the 2019 CoPaCC “Open and Transparent” Quality Mark. There is more work to do but they have demonstrated a high standard of transparency as well as commitment and enthusiasm for ongoing improvement:
- Avon & Somerset
- Bedfordshire
- Cambridgeshire
- Cleveland
- Derbyshire
- Devon & Cornwall
- Dorset
- Durham
- Dyfed-Powys
- Gwent
- Hertfordshire
- Humberside
- Kent
- Leicestershire
- Lincolnshire
- Norfolk
- North Wales
- North Yorkshire
- Northamptonshire
- Nottinghamshire
- South Wales
- Staffordshire
- Suffolk [see note]
- Surrey
- Thames Valley
- Warwickshire
- West Midlands
- West Yorkshire
To read about CoPaCC’s review of OPCC transparency and the “Open and Transparent” Quality Mark awards, please download the report – it is FREE to view; just register a free account or sign in to your existing account.
PCCs and Statutory Transparency
A CoPaCC Thematic Report
Registered users click here to download
The CoPaCC “Open and Transparent Quality Mark” scheme
The CoPaCC “Open and Transparent Quality Mark” scheme is open to all OPCCs. Each year CoPaCC contacts every OPCC office and invites them to participate. The aim of the process is not to highlight failure but to engage in a process that ensures statutory transparency requirements are fulfilled and facilitate an ongoing process to raise standards.
All the OPCCs participating in the process either reached the required standard or elevated themselves to that standard during the process.
CoPaCC would urge the remaining OPCCs to engage with the scheme to demonstrate their standards of transparency to their peers and the public they serve.
Please contact us at [email protected] if you would like your OPCC to take part in the assessment for the 2020 CoPaCC “Open and Transparent Quality Mark”
Improving our approach to our research
For the 2019 assessment, we have made a number of significant improvements to our process, moving from asking simply OPCCs to provide details on how they meet their statutory transparency requirements to something more like a ‘mystery shopper’ approach. This, we judge, better reflects the public experience of how easy (or difficult) it is to find information on OPCC websites.
For this approach, our researcher navigated the participating OPCC websites, starting at the respective home page, looking for the specific information required by the current statutory transparency requirements. This approach is, we judge, much more typical of the approach that a member of the public would adopt. Our researcher then reviewed each required disclosure, assigning a score according to whether the information was present, and for whether it met timeliness requirements.
CoPaCC uses the transparency factors set out in statute as the basis for its assessment of OPCC transparency. These statutory transparency factors are contained in The Elected Local Policing Bodies (Specified Information) Order 2011 and the simplified and specific guidance for PCCs “Guidelines for PCCs on publishing information” based on the 2011 Elected Local Policing Bodies (Specified Information) Order and published by the Home Office in 2013.
The 2013 Home Office publication presented the specific requirements for PCCs in a more simplified form and drew attention to some amendments made to the 2011. To quote the 2013 guidance:
“In this guidance the information to be published has been put under headings taken from the Information Commissioner’s Office’s definition documents under their model publication scheme. The Order ensures that PCCs will make available to the public information on:
- Who they are and what they do
- What they spend and how they spend it
- What their priorities are and how they are doing
- How they make decisions
- What policies and procedures govern the operation of the office of the PCC
- Lists & registers”
In the 2013 guidance, the government encourages PCCs to go beyond the minimum requirements of the Act and make available any additional information they wish to.
We used both the 2011 Elected Local Policing Bodies (Specified Information) Order and the simplified 2013 Home Office guidance as a reference in our assessment.
Following the ‘mystery shopper’ assessment, each OPCC was then contacted with the results of the assessment and asked to either justify or fix where they appeared not to fulfill the statutory requirements. This constructive approach has helped to ensure an accurate and fair assessment as well facilitating the participating OPCCs drive for continuous improvement in the transparency of their activities.
Presumably where things are published is to be monitored and assessed? Publishing on a website which has no public awareness is the 21st century equivalent of a Council posting on a noticeboard in an obscure location, so surely website usage needs to be included?