“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 the 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 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.
Those OPCCs judged as reaching a satisfactory standard are awarded the CoPaCC “Open & Transparent Quality Mark” each year.
Over the years, the process, criteria and rigour of the assessment has been refined and improved to support OPCCs to improve standards of transparency.
This year’s assessment used 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.
This year, CoPaCC added a further criteria for assessment – ‘ease of use’ ie how easy is it for a member of the public to find the information disclosure. This means that it is no longer sufficient to just make the information available; it should be easy to identify where the information can be found and simple to navigate with the minimum number of steps. It is 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 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 during November and December 2019 with our researcher acting as a ‘mystery shopper’ looking for the required information on the website of each OPCC.
Thirty-two OPCCs were assessed this year including the 28 who received the Quality Mark in 2019 plus four additional OPCCs who responded to the invitation to take part.
CoPaCC are pleased to announce that despite the new ‘ease of use’ criteria and a higher pass threshold, 28 OPCCs are recognised to have reached the required standard for the 2020 ‘Open & Transparent’ Quality Mark including three of the four OPCCs new to the process.
Which OPCCs are awarded this year’s Transparency Quality Marks? The 2020 recipients…
We are very pleased to announce the recipients of the CoPaCC “Open and Transparent Quality Mark 2020” are as follows:
- Avon & Somerset
- Devon & Cornwall
- Essex (New recipient)
- Hampshire (New recipient)
- North Wales
- North Yorkshire
- Northumbria (New recipient)
- South Wales
- Thames Valley
- West Midlands
- West Yorkshire
We will be holding a formal presentation to OPCCs of the CoPaCC “Open and Transparent Quality Mark” at the forthcoming Police Governance Summit in the Autumn.
Finally, I would like to thank my CoPaCC colleagues, Sandra Andrews and Ian Barrett, for their work on this latest CoPaCC analysis and the forthcoming CoPaCC Thematic Report on OPCC Transparency, which will be published after the PCC elections.
Publisher, Policing Insight
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 to facilitate an ongoing process to raise standards.
All the OPCCs participating in the process either reached or exceeded the required standard.
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 2021 CoPaCC “Open and Transparent Quality Mark”
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, 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 3 points; 1 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 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 28 recipient OPCCs actually scored above the 90% threshold.
During the audit, 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 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 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.
This year, we only referenced the 2013 specific Home Office guidance for PCCs with the scoring sheet directly transposed from the published table of required disclosures.
Following the ‘mystery shopper’ assessment, each OPCC was then contacted with the results of the assessment. Those OPCCs not reaching the required standard for the award are given detailed feedback on the areas where they fell short. Where there are minor infringements which are easily resolved there is an opportunity for the OPCC to be reassessed.
All the OPCC recipients currently announced have met the required standard without further assessment.
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.