“The public need independent, consistent and clear information on the performance and activities of their PCC. Transparency is essential to promote confidence in the elected PCC. A consistent minimum amount of evidence will also allow the public to compare the performance of their PCC with PCCs elsewhere.” Home Office
Every year since 2013, CoPaCC has assessed how offices of police and crime commissioners (OPCCs) fulfil their statutory obligations for transparency as required by the statutory transparency factors contained in The Elected Local Policing Bodies (Specified Information) Order 2011, based on the information delivered through the OPCC websites.
Each year those OPCCs judged as reaching a satisfactory standard are awarded the CoPaCC Open and Transparent Quality Mark. Over the years the process, criteria and rigour of the assessment have been refined and strengthened, to support OPCCs to improve standards of transparency.
The assessment uses the Home Office’s 2013 publication Guidelines for PCCs on publishing information, based on the 2011 Elected Local Policing Bodies (Specified Information) Order, as the basis for scoring each disclosure requirement – ie that the information both exists and is timely.
CoPaCC adds a further criteria for assessment, ‘ease of use’, which considers how easy is it for a member of the public to find the information disclosure. This means it’s not sufficient to just make the information available; it should be easy to identify where the information can be found and simple to navigate.
It’s no longer acceptable to ‘tick the box’ of technical and legal compliance but then hide the required disclosures through unclear jargon and complex navigation; clear, non-technical language and simple navigation should be the aim to ensure true public transparency.
All OPCCs taking part in the process were sent a copy of the new assessment form in advance of the audit period to facilitate comment and engagement on the criteria. The OPCCs were then assessed between November 2020 and January 2021, with our researcher acting as a ‘mystery shopper’ looking for the required information on their individual websites.
CoPaCC are pleased to announce that 39 OPCCs have reached the required standard for the 2021 Open and Transparent Quality Mark, including all eight OPCCs new to the process.
For the first time all 40 OPCCs were assessed, regardless of whether they responded to the invitation to take part. Previously we have only assessed those offices that responded to the invitation; last year 32 OPCCs were assessed, with 28 receiving the Quality Mark.
CoPaCC are pleased to announce that 39 OPCCs have reached the required standard for the 2021 Open and Transparent Quality Mark, including all eight OPCCs new to the process.
Eighteen OPCCs scored performed very well and are highly commended – three of which were new to the process and audited for the first time.
Congratulations to the 39 recipients, and many thanks to the OPCC staff who have worked tirelessly since the Quality Mark was launched in 2013 to improve publication of statutory disclosures and in some cases exceed the requirements
Gloucestershire OPCC scored very highly but were not awarded the Open and Transparent Quality Mark, primarily because they do not have a Freedom of Information log on their website. This is a key requirement for transparency, and was drawn to Gloucestershire OPCC’s attention last year, although at the time of the assessments it had yet to be addressed.
The OPCC recipients of the CoPaCC Open and Transparent Quality Mark 2021
We are very pleased to announce that the recipients of the CoPaCC Open and Transparent Quality Mark 2021 are as follows:
- Avon & Somerset*
- Bedfordshire
- Cambridgeshire
- Cheshire (New award)
- Cleveland*
- Cumbria (New award)
- Derbyshire*
- Devon & Cornwall*
- Dorset*
- Durham*
- Dyfed-Powys
- Essex*
- Gwent*
- Hampshire
- Hertfordshire
- Humberside
- Kent*
- Lancashire (New award)
- Leicestershire
- Lincolnshire
- Merseyside (New award)*
- Norfolk*
- North Wales*
- North Yorkshire
- Northamptonshire*
- Nottinghamshire
- Northumbria*
- South Wales*
- South Yorkshire (New award)
- Staffordshire
- Suffolk
- Surrey
- Sussex (New Award)
- Thames Valley
- Warwickshire*
- West Mercia (New award)*
- West Midlands
- West Yorkshire
- Wiltshire (New award)*
*Highly commended
Grant Thornton, the leading police assurance provider, sponsors CoPaCC’s Open and Transparent Quality Mark analysis and the associated awards. Paul Grady, Head of Police for Grant Thornton, commented that: “Transparency is an essential part of the democratic process. For the public to be able to gauge how successful their PCC is in delivering their electoral mandate, they need access to information that is accessible, easy to understand and fit for purpose. Grant Thornton is proud to once again be supporting these Transparency Awards and we congratulate all those who have been successful in meeting the standards required.”
For my part, these OPCCs have all demonstrated that they are transparent in what they do, meeting relevant legal requirements. They present key information in an accessible format on their websites. I was particularly gratified to see, after seven years of assessments and awards, such high standards delivered by almost all OPCCs.
There is still much work to be done, even for those OPCCs highly commended, to go beyond fulfilling the guidance and truly make their information easy to find
There is still much work to be done, even for those OPCCs highly commended, to go beyond fulfilling the guidance and truly make their information easy to find. This means using language the public understands and making key information highly visible and navigable with minimal clicks. We will be further reviewing our scoring methodology to put emphasis on this aspect.
I congratulate all the responsible OPCC staff on their award-winning work, and I look forward to what I trust will be continued excellent work by each and every one of them in this area.
We would normally hold a formal presentation to OPCCs of our Open and Transparent Quality Mark at the CoPaCC Police Governance Summit, but plans for this year’s event are currently under review due to the COVID-19 restrictions.
In the meantime digital certificates have been awarded to the recipient OPCCs in addition to 2021 Quality Mark images and banners for display on the websites – please do look out for this mark of excellence.
Finally, I would like to thank my CoPaCC colleagues, Sandra Andrews and Ian Barrett, for their work on this latest CoPaCC analysis.
Bernard Rix
CEO, CoPaCC
Publisher, Policing Insight
The CoPaCC Open and Transparent Quality Mark scheme
The 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 to facilitate an ongoing process to raise standards.
We now audit all OPCCs regardless of co-operation.
Improving our approach to our research
In 2019, CoPaCC made a number of significant improvements to the process, moving from simply asking OPCCs to provide details on how they meet their statutory transparency requirements to something more akin to a ‘mystery shopper’ approach. This, we judged, better reflects the public experience of how easy (or difficult) it is to find information on OPCC websites.
Building on this approach for the 2020 assessment and continued for the 2021 award, we implemented a new ‘ease of use’ score in addition to the points awarded for the statutory disclosures being published in a timely manner.
Each required disclosure can score a maximum of three points – one point each for information being present, posted within the timeframe/frequency required, and being easy to find.
To qualify as easy to find, the information being searched for should be posted in a logical section of the website with the navigation clearly labelled in plain English and avoiding technical jargon. The path to the information should take no more than three clicks by the user.
The threshold for receiving the award was to score a minimum of 80% of the 141-point total. We are please to report that this year, 18 of the 39 recipient OPCCs actually scored above 90%.
During the audit, our researcher navigated the 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 a member of the public would adopt. Our researcher then reviewed each required disclosure, assigning a score according to whether the information was present, whether it met timeliness requirements, and how easy it was to find.
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 Guidelines for PCCs on publishing information published by the Home Office in 2013.
The 2013 Home Office guidance presented the specific requirements for PCCs in a more simplified form and drew attention to some amendments made to the 2011 Order. The guidance stated:
“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 encouraged PCCs to go beyond the minimum requirements of the Act and make available any additional information they wish to.
Since last year year, we only reference the 2013 specific Home Office guidance for PCCs with the scoring sheet directly transposed from the published table of required disclosures.
