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Not Protectively Marked
Equality Impact Assessment
Name of item being assessed
The Equalities impact on a decision to roll out the National Police Promotion
Framework (NPPF)
Owner of item being assessed
Merielle Ghali - Workforce Policy and Strategy Unit
Name of Assessor
George Couch - Workforce Policy and Strategy Unit 020 3113 7398
Name of EDHR advisor
Stuart Budgen 01256 602 438
Date of Assessment
May 2013
Who is responsible for decision making
Professional Committee, College of Policing
Who is responsible for implementing this policy
Workforce Policy & Strategy Unit and all forces in England and Wales under terms of the
overarching (Examinations & Assessment) NPPF quality assurance process.
Executive Summary
The purpose of this EIA is to examine the equalities considerations in the context of a decision
by the Professional Committee to adopt nationally the National Police Promotion Framework
as the sole promotion process to the ranks or sergeant and inspector within England and
Wales. The EIA will allow the College of Policing to show that it has due regard to the
equalities and demonstrate that it has paid due regard to them in making the decision.
Background
In 2004 a review (the Hedger review) was conducted into the how the police service in
England and Wales selects, and promotes officers to the rank of sergeant and inspector.
Arising from the review, work was commissioned to develop a new process of promotion that
addressed the concerns raised. This work culminated in the National Police Promotion
Framework (NPPF) trial.
The trial commenced in 2004 and was reviewed in 2008. As a result, a further trial was
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commenced with ten forces (the original seven plus three new forces) taking part, although
one force withdrew at an early stage. An EIA and full evaluation of the entire trial was
completed and submitted to the Police Promotion Examinations Board on the 4th May 2011
where, by a majority, it accepted the evaluation and the EIA. It formally recommended to the
Minister for Policing and Criminal Justice (then Rt Hon Nick Herbert MP) that the NPPF is a
proportionate means of achieving a legitimate aim, namely the selection and promotion of
officers to the rank of sergeant and inspector, and endorsed full implementation of the NPPF
to all forces in England and Wales.
On 9th August 2012 the Minister referred the decision to the College of Policing stating that
‘the College of Policing will have a mandate to develop the national policing
curriculum and supporting assessment and accreditation frameworks’. The minister
concluded that ‘the College of Policing will need to ensure that any increase in cost (to
the police service) is fully justified and affordable. Furthermore, in making a decision
of this kind there is a legal duty to have regard to equality and any decision will
need to meet the threshold of being a proportionate means of achieving a legitimate
aim’.
The EIA shows that should a decision be taken to implement the NPPF across all forces in
England and Wales it will have no discriminatory impact on any of the protected characteristic
groups. There is some evidence of a potential for discrimination where forces look to
implement NPPF at a local level but measures are in place to remove or minimise this risk.
The NPPF is a proportionate means to achieve the legitimate aim of a promotion policy.
Whilst this EIA is a stand alone document it supports and reflects the detailed analysis
contained within the NPPF trial found here NPPF Trial Documents. This EIA also contains
information regarding candidates and results within the OSPRE® promotion process and whilst
it is not relevant to the impact of this decision, it is included to act as a comparator.
Identify the main aims and purpose of the policy This should identify the legitimate aim of the policy (there may be more than one)
The initial aims of the Police Promotions Trial was to develop a promotion system that
effectively matched the number of qualified sergeants and inspectors to vacancies and to
introduce an element of work based assessment. This EIA is to reflect the impact the NPPF
may have as part of the decision making process.
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Identify the individuals and organisations likely to have an interest in, or be
affected by this policy This should identify the persons / organisations that may need to be consulted about the
policy or procedure and its outcomes. All Police Officers seeking promotion to the rank of Sergeant or Inspector, all officers who
manage such candidates, force policy leads for career development, force examination Units,
force HR departments. The Police Promotion Examinations Board and Police Federation
England and Wales.
Relevance to the Duties
Consider the following to determine to what extent this policy is relevant to the public sector equality duty and the different protected groups.
Can the aims within this policy contribute towards the public sector equality
duty?
• Eliminate unlawful discrimination, harassment and victimisation
• Advance equality of opportunity between people who share a protected
characteristic and those who don’t
• Foster good relations between people who share a protected
characteristic and those who don’t
Yes
Does the policy affect service users, employees or wider community, and
therefore does it potentially have a significant effect in terms of equality?
Yes
Is it major policy, significantly affecting how functions are delivered in terms of
equality?
Yes
Will it have a significant effect on how other organisations operate in terms of
equality?
Yes
Does the policy relate to functions that previous engagement has identified as
being important 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,
promotion processes, access to information for disabled people)
Yes
Does it relate to an area where equality objectives have been set by your
organisation?
Yes
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Consultation Who was consulted and how
In addition to the wide consultation carried out in 2009 – 2011 with the staff associations,
candidate workshops, Trial forces, OSPRE forces etc, additional consultation was undertaken
with the NPPF Strategic User Group through it meeting schedule.
The College of Policing Professional Committee in addition to being an executive body also
provides a forum for staff associations to give their views. At its meeting on 6th March 2013,
the PFEW raised additional issues with regard to disproportionality and gender. These are
addressed below.
Research
Summarise the findings of any research you have considered regarding this policy. This could
include quantitative data and qualitative information.
• Police Federation of England and Wales supplied evidence from a commissioned
survey (Jennifer Brown / Isabel Schuster LSE 2012) that there is a perception that female
officers who work part time or flexible working are not supported as there are few part
time supervisory roles once they are qualified. Additionally there was a belief that some
officers manipulated the system to access local selection boards to the detriment of female
officers or those with caring responsibilities.
• West Midlands Police OSPRE research project – Solihull Command unit. The purpose
of the research was to identify which OSPRE candidates were most likely to be successful
and though intervention and support reduce the costs incurred in supporting candidates
with reduced chances of success. The research identified that there was a correlation
between candidates length of service and a reducing likelihood of passing OSPRE part I at
the 3rd or more attempt. This in part supports the finding that older candidates (which is
linked to length of service) in both OSPRE® and NPPF also have a reducing likelihood of
securing a pass.
• Equality Data supplied to the Exams and Assessment unit, College of Policing
received from NPPF and OSPRE® forces was updated to include the profiles all candidates
up to and including the 2012 promotion process. The data set contained with the original
evaluation and EIA documented were updated to include 2011/ 2012 data for Age, Sex
and Ethnicity. These data sets are shown and commented upon under conclusions below.
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Research indicates (Andreoletti et al 2006, Ashendorf 2006, Schwarz 2006, Finkel et al
2005) that there is an inverse relationship between age and performance on tests of
ability.
Research conducted by West Midlands Police into the cost to forces in the promotion
process for candidates who fail to attend or complete the process was reviewed.
Research from the Police Federation England and Wales on the perceptions of female
officers in undertaking the promotion process and the issues over career opportunities
post promotion through flexible working. (Facing the future - Brown 2012) was reviewed.
Independent Police Commission – Results of a survey public / police attitudes.
(The state of the police service in England and Wales – Bradford, Brown and Schuster
2012) indicates that staff (Constable to Chief Inspector) has less than 50% faith in local
selection processes selecting candidates for promotion on merit.
Greater Manchester Police provided evidence (Disproportionality in Police Professional
Standards - Graham Smith, Harry Hagger Johnson and Chris Roberts 23 July 2012) that
Black and ethnic minority officer were disproportionately more likely to be subject to
formal misconduct proceedings. Interpretation of this evidence suggests that where formal
outcomes were given against officers this would indirectly and disproportionately reduce
the number of eligible officer from a Black or ethnic minority background as they would
not be able to meet the eligibility criteria.
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Monitoring
Summarise the findings of any monitoring data you have considered regarding this policy.
Data on Age
Table 1
Success Rates for OSPRE® Part I / Step 2 NPPF Sergeants Examination 2010 & 2012 - by
Age
OSPRE / NPPF Sgt 2010 and 2012
0
0.1
0.2
0.3
0.4
0.5
0.6
under 21 21 -25 26-30 31-35 36-40 41+
age group
percentage pass
NPPF Sgt
2010
OSPRE Sgt
2010
NPPF Sgt
2012
OSPRE Sgt
2012
Table 2
Success Rates for OSPRE® Part I / Step 2 NPPF Inspectors Examination 2010 & 2012 - by
Age
0
20
40
60
80
100
120
Under 21 21 - 25 26 - 30 31 - 35 36 - 40 41+Age Range
Percentage pass
NPPF Insp
2010
OSPRE Insp
2010
NPPF Insp
2012
OSPRE Insp
2012
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Table 3
Success Rate for NPPF Sergeants
NPPF Steps - By Age 2010 / 2012
020406080
100120
Step 1 2010
Step1 2012
Step 2 2010
Step 2 2012
Step 3 2010
Step 3 2012
Step 4 2010
Step 4 2012
Age Group
Percentage Pass under 21
21-25
26-30
31-35
36-40
41 +
Table 4
Success Rate for NPPF Inspectors.
NPPF Steps by Age 2010 / 2012
020406080
100120
Step 1
2010
Step 2
2010
Step 3
2010
Step 4
2010
Step1
2012
Step 2
2012
Step 3
2012
Step 4
2012
Age Group
Percentage Pass under 21
21-25
26-30
31-35
36-40
41 +
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West Midlands Police OSPRE Data
Table 5
Solihull PC to Sgt OSPRE Candidates. Pass rate / Length
of Service
0
20
40
60
2 to 5 5 to 10 10 to 15 15 to20 20 to 25 25 to 30 30+ yrs
Years in Service
Nos Passing by year
2007
2008
2009
2010
2011
2012
Table 6
Solihull PC to Sgt OSPRE Candidates. Success / Attempts
0%
10%
20%
30%
40%
50%
60%
1st 2nd 3rd 4th 5th 6th 7th
Attempts
Pass Rate
2009
2010
2011
Average
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Table 7
Staff View on Promotion
0 20 40 60 80
Probationer
Const
Sgt
Insp
Ch Insp
Supt
Ch Supt
% beliveing promotion isachieved on merit
See data on Gender
© Independent Police Commission 2012
Table 8
NPPF Steps - Success by Gender 2010 - 2012
0
20
40
60
80
100
Step 1 Step 2 Step 3 Step 4
Female Sgt
Male Sgt
Female Insp
Male Insp
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Table 9
Sergeant Step 1 Step 2 Step 3 Step 4
White Successful 99.7 45.7 44.8 99.9
Black Successful 99.6 27.6 37.3 100
Asian Successful 99.3 31.2 42.7 100
Chinese Successful 100 30.6 20 100
Mixed Successful 98.5 50.3 40 100
Inspector
White Successful 99.9 47.5 40.9 100
Black Successful 98.1 35.4 16.7 100
Asian Successful 100 42.5 38.1 87.5
Chinese Successful 100 25 0 100
Mixed Successful 100 39.1 44 100
NPPF Success by ethnicity 2010 - 2012
Table 10
0
10
20
30
40
50
60
OSPRE Sgt
White
BME
OSPRE Insp
White
BME
NPPF
NPPF Sgt
White
BME
NPPF Insp
White
BME
2009
2010
2012
NPPF / OSPRE success Comparison by ethnicity 2009 - 2012
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Table 11
NPPF / OSPRE® comparison 2012 by Age
Success Rates
Step 2 NPPF (Actual)
(Disparity from Mean Success Rate)
OSPRE® Part I (Actual)
(Disparity from Mean Success Rate)
Trend
(Most Disparity from
Mean Success Rate)
Sergeants
Less than 21 Years
n/a
n/a
21 – 25 Years
53.2% (33) (19.5%)
37.8% (93) (4.1%)
NPPF
26 – 30 Years
48.5% (226) (14.8%)
35.8% (430) (2.1%)
NPPF
31 – 35 Years
43.9% (277) (10.2)
32.3% (349) (-1.4%)
NPPF
36 – 40 Years
34.3% (143) (0.6%)
26.8% (183) (-6.9%)
OSPRE®
41 Years & Over
25.6% (117) (-8.1%)
20.9% (131) (-12.8%)
OSPRE®
Inspectors
Less than 21 Years
n/a
n/a
21 – 25 Years
100.0% (1) (55.8)
0.0% (0) (-44.2%)
NPPF
26 – 30 Years
72.2% (26) (28.0%)
63.8% (37) (19.6%)
NPPF
31 – 35 Years
55.0% (104) (10.8%)
55.9% (114) (11.7%)
OSPRE®
36 – 40 Years
49.8% (113) (5.6%)
40.9% (122) (-3.3%)
NPPF
41 & Over Years
36.5% (159) (-7.7%)
36.3% (160) (-7.9%)
OSPRE®
Success Rates for OSPRE® Part I/Step 2 NPPF by Age (Data taken From OSPRE® Part I Marking File Sergeants’ 2012 and Inspectors’ 2012)
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Table 12
NPPF Steps by Age 2012
Success Rates
Step One
Step Two
Step Three
Step Four
Sergeants
Less than 21 Years
n/a
n/a
n/a
n/a
21 – 25 Years
99.0% (99)
53.0% (32)
100.0% (3)
n/a
26 – 30 Years
100.0% (652)
47.0% (220)
65.8% (25)
100.0% (54)
31 – 35 Years
99.0% (894)
44.3% (283)
59.0% (32)
100.0% (189)
36 – 40 Years
98.9% (553)
34.6% (142)
50.0% (19)
100.0% (133)
41 Years & Over
99.4% (636)
25.4% (119)
45.2% (19)
100.0% (187)
Inspectors
Less than 21 Years
n/a
n/a
100.0% (1)
n/a
21 – 25 Years
100.0% (3)
n/a
n/a
n/a
26 – 30 Years
100.0% (114)
72.0% (36)
69.0% (9)
100.0% (5)
31 – 35 Years
99.8% (457)
41.9% (67)
72.3% (60)
100.0% (26)
36 – 40 Years
99.8% (567)
47.5% (97)
59.7% (83)
100.0% (40)
41 & Over Years
99.7% (1141)
36.7% (165)
65.3% (215)
100.0% (102)
Success Rates for Each Step of NPPF by Age (Data taken from NPPF Data Capture Force Reports 14/04/11 – 10/10/12)
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Table 13
NPPF / OSPRE® success by Gender 2012
Sergeants’ Examination 2012
Inspectors’ Examination 2012
OSPRE®
NPPF
OSPRE®
NPPF
Female Success Rate
36.1%
48.2%
42.2%
49.4%
Male Success Rate
29.1%
36.6%
43.7%
44.7%
% Disparity Gap
7.0%
11.6%
-1.5%
4.7%
Success Rates for OSPRE® Part I/Step 2 NPPF by Sex (Data taken From OSPRE® Part I Marking File Sergeants’ 2012 and Inspectors’ 2012)
Table 14
OSPRE® Part I / NPPF Step 2 Sgt March 2013 by Gender
Male
41.4%
Female
45.8%
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Table 15
NPPF / OSPRE® success by Ethnicity 2012
Sergeants’ Examination 2012
Inspectors’ Examination 2012
OSPRE®
NPPF
OSPRE®
NPPF
Minority Ethnic Success Rate
30.6%
29.0%
37.0%
46.7%
White Success Rate
31.0%
40.3%
43.7%
45.3%
% Disparity Gap
-0.4%
-11.3%
-6.7%
1.4%
Success Rates for OSPRE® Part I/Step 2 NPPF by Ethnicity (Data taken From OSPRE® Part I Marking File Sergeants’ 2012 and Inspectors’ 2012)
Table 16
Table 17
NPPF / OSPRE® success by Disability 2012
Sergeants’ Examination 2012
Inspectors’ Examination 2012
OSPRE®
NPPF
OSPRE®
NPPF
Stated Disability Success Rate
26.2%
43.5%
44.4%
34.6%
Stated No Disability Success Rate 31.3%
39.0%
44.1%
45.6%
% Disparity Gap
-5.1%
4.5%
0.3%
-11.0%
Success Rates for OSPRE® Part I/Step 2 NPPF by Disability (Data taken From OSPRE® Part I Marking File Sergeants’ 2012 and Inspectors’ 2012)
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OSPRE® Part I / NPPF Step 2 Sgt March 2013 by Ethnicity
BME
38.3%*
White
42.9%*
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Table 18
OSPRE® Part I / NPPF Step 2 Sgt March 2013 by Disability
Stated Disability Success
Rate
36.3%*
Stated No Disability
Success Rate
42.8%*
NPPF Forces Only
Stated Disability Success
Rate
41.6%
Stated No Disability
Success Rate
44.8%
NPPF Steps 2009 – 2013 All Sergeant Candidates
Stated
Disability
Success rate
Step 1
97.3%
Step 2
41.6%
Step 3
47.1%
Step 4
100%
Stated No
Disability
Success rate
Step 1
99.6%
Step 2
44.8%
Step 3
44.5%
Step 4
99.9%
NPPF Steps 2009 – 2013 All Inspector Candidates
Stated
Disability
Success rate
Step 1
100%
Step 2
39.3%
Step 3
25.6%
Step 4
100%
Stated No
Disability
Success rate
Step 1
99.9%
Step 2
46.7%
Step 3
41.0%
Step 4
99.9%
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Table 19 Sexual Orientation
Sergeant Data
Step 1
Step 2
Step 3
Step 4
Prefer not to say
10.9% (1371)
11.0% (791)
12.4% (366)
10.8% (195)
Missing Data
0.4% (520
0.4% (28)
1.0% (31)
3.1% (57)
Sexual Orientation
Inspector Data
Step 1
Step 2
Step 3
Step 4
Prefer not to say
10.9% (546)
10.5% (408)
11.6% (180)
12.6% (88)
Missing Data
0.4% (20)
0.3% (13)
0.4% (6)
3.4% (24)
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Conclusions
Taking into account the results of the monitoring, research and consultation, set out
how the policy, positively or negatively impacts or could impact on people from the
following protected groups. This section only outlines the conclusions. The resulting
action is shown under DECISION.
AGE
A review of the data pre and post 2010 shows there remains a tendency for
older candidates to achieve lower success rates for both Sergeants’ and
Inspectors’ processes.
There appears to be a positive relationship between age and number of
previous attempts, with older candidates tending to have more attempts at
the Part I examination. However, there is also a negative relationship
between number of previous attempts and success rate, i.e. candidates who
have a greater number of attempts tend to have a lower success rate. This
finding indicates that the number of attempts, not necessarily age is a
consistent predictor of success in the Part I examination.
This is supported by information from West Midlands Police (Solihull) (see
table 5 and 6). which shows a similar tendency for repeat candidates to be
less successful. Candidates for the Sergeants process in the 5 to 10 years
service bracket are more likely to pass with a marked decline against the
number of attempts thereafter. Of course candidate age profiles change as
the number of attempts increases but age by itself is not a proven factor.
Nationally, candidates are more likely to be successful at passing NPPF Step 2
/ OSPRE® Part I in the early years of their service with a significantly less
success later in their career.
Step Three of NPPF cannot be compared with the local selection process
undertaken by OSPRE® forces (where applied) as such data is not centrally
recorded. However, within NPPF data, for Step Three of the Sergeants’
process there is only a 3% difference in pass rates between the groups over
25. Under 25’s have a lower pass rate but this may be due to a greater
proportion having less experience.
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For Step Three of the Inspectors’ process the pass rate differences are more
pronounced but the differences do not increase linearly with age.
Whilst candidates may achieve lower results by attempt, it is of note that in
the sergeant and inspectors process, NPPF candidates have a higher pass rate
than OSPRE® candidates across all age groups. There is no evidence to show
why this is taking place but it may be the case that NPPF candidates prepare
better than OSPRE® candidates if NPPF is seen (and described) as a
continuing four step process rather than OSPRE® Part I and II which are
(wrongly) seen as separate exercises.
Whilst the link of attempts and age are a concern, there is a body of research
(Andreoletti et al 2006, Ashendorf 2006, Schwarz 2006, Finkel et al 2005)
which indicates that there is an inverse relationship between age and
performance on tests of ability. Whilst the data indicates that attempts/age is
a potentially discriminatory factor, it is consistent across both OSPRE® and
NPPF and in part, replicates adult learning experiences outside of the service.
DISABILITY
Inconsistency in application of Attendance Management Policies at NPPF Step
One (Suitability)
There is evidence that forces are not applying attendance management
policies in a consistent manner, in particular in relation to its impact on
disability. Some forces continue to use the Bradford scoring method which
can have a direct and / or indirect discriminatory impact on those with a
disability who are more likely to require time from the workplace to manage
their disability. Although issued and still promoted as advice by ACPO, we
acknowledge that this has the potential to be discriminatory but is justifiable
as some forces wish to have this level of management to support staff. As
such this is beyond the remit of the PPEB to manage. (See section on Gender
for further comment)
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It should be noted that the data capture analysis to date indicates very high
success rates for all candidates at step 1 but it is not possible to measure
those who may not put themselves forward believing they would not be
supported. This is an issue for forces when implementing an NPPF programme
and this information will be highlighted for their consideration. The data
shows that (see table 17 and 18) within NPPF, only minimal variance is noted.
Across all the NPPF steps the variance between disabled and non disabled
candidates (sergeants) is only 0.6% and 3.9% (inspectors) respectively.
Length and complexity of questions at NPPF Step Two (OSPRE® part 1 Exam).
Issues of examinations and assessments in relation to disability, in particular
dyslexia, are well evidenced. The College of Policing, Examinations and
Assessment unit provide a variety of resources and information to ensure that
officers and forces are aware of the process to request reasonable
adjustments. A recent Employment Tribunal was discontinued at the last
moment by the claimant, and issues on whether multiple choice questions
have the potential to disadvantage candidates who are dyslexic were not
addressed.
There are concerns about WBA methods involving substantial written
evidence.
High quality research in the banking sector found that an over reliance on
written evidence could constitute a barrier for some candidates. Moderate
quality research found that the process of assembling evidence may feel
laborious and discourage less motivated candidates. Quality evidence from
trial forces show that electronic tools; digital voice recorder, visual
recordings, e based management systems etc can be used for organising and
managing the assessment evidence and process. Use of accredited assessors
and occupationally competent assessors in observational or de brief modules
and reference to core documents created as part of the ordinary workload,
further reduce the burden of compiling documentary evidence.
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In the trial forces physical document completion is limited a few pages.
Overall, these research findings indicate that organisations should select
assessment methods that minimise administrative burdens.
A final learning point from the research and case studies is that the credibility
of WBA process and candidate’s likelihood of completing awards may be
maximised by:
• Providing full and clear information about the assessment
process to candidates, managers and assessors;
• Ensuring that assessors are occupationally competent; and that
• Effective assessment methods are used.
Ability to demonstrate operational experience if on restricted duties at NPPF
Step Four (Temporary Promotion and Work Based Assessment).
Historically there is an issue with individuals’ perception of ‘operational’ and
what experience is required for promotion. The Operating Manual for NPPF
has been amended to ensure that the focus is on competence not ‘operational
experience’. The QCF provides a framework for officers to demonstrate
competence that does not require experience in what are perceived to be
typically ‘operational’ roles.
Posting from pool to post
Procedures to identify suitable posts to take proper account of disability /
ability to demonstrate competency if on restricted duties are not applicable
within NPPF as it is a local individual issue. However candidates are supported
in applying through the operating manual and forces have suitable and
effective policies in place to support candidates who identify that they have a
disability. In the workplace, such information may have already been
disclosed at Step Two and should be taken forward for reasonable
adjustments to be made.
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GENDER
Female officers taking time off as sick to look after children, transgender
people taking time off for treatment, understanding of part time
working/flexible working policies. (Attendance management is equally an issue for
gender but is dealt with under disability above.)
There is anecdotal evidence that staff with major home based commitments
regularly have problems in managing the competing demands on their time.
This may impact on the promotion process by preventing participation in the
mistaken belief that specific issues cannot be catered for within the policy.
Likewise a perception exists that officers currently employed on a flexible
work pattern (which disproportionally affects women) are not eligible or will
not be successful as part time vacancies at the higher rank will not be
considered.
Variations in study leave and support to study across forces or teams at
NPPF Step Two (OSPRE® part 1 Exam)
Study leave is set by the force but no data is collected across all forces to
show which force supports study leave, what this consists of and what
impact, if any, this has on a candidate. Where it is in use, anecdotal evidence
suggests it is open to all candidates in that force.
Analysis of current NPPF/ OSPRE® processes show that for all exam types
female candidates are consistently more successful than male candidates (see
table 8). However, due to low numbers of females entering the process,
overall numbers of those who are successful, are also low.
The Operating Manual makes reference to the College of Policing Flexible
working in the police service guide to ensure that forces are aware of it and of
how they can use it with their own policies for promotions.
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Concern over exam timetable clashing with home /family events or which
may disproportionally impact part time or flexible working candidates
The PPEB has considered whether or not a modular approach could be
adopted and whether there is any scope for alternative deliver methods or
timings. The conclusion was that at this time a modular approach was not
feasible due to the current economic climate.
Concerns about subjectivity and ‘jobs for the boys’ culture of posting - NPPF
Step Three
The Metropolitan Police Authority Race and Faith Inquiry – Emerging Issues
[2009] has already indicated that there are clear cases of discrimination in
promotion processes that would suggest the same exists for selection /
posting processes.
This issue remains current (Independent Police Commission report Bradford,
Brown Schuster 2012) in that there is a belief that promotion is not on merit,
but on a basis of nepotism or favouritism. This is particularly evident at the
local selection process. Not unsurprisingly the perception is greatest amongst
Constable and Sergeants with only 26% of constables and 36% of Sergeants
who believed the process to be open and fair. It is only at Superintending
ranks where the level of ‘faith in the local process’ significantly exceeds 50%.
(See table 7)
It is of note that this perception is not confined to either NPPF or post
OSPRE® selection, but extends to a general belief that bias exists across all
locally held selection boards.
Monitoring is undertaken in force in relation to gender and is captured in
quarterly reports. Analysis of the data 2010 – 2012 (see table 8) shows that
at Step 3 females out perform males at the local selection stage. However
numbers are still lower than the proportion of the eligible workforce.
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Concerns remain with posting from pool to post process and the impact that
child care can have on ability to meet responsibilities at a higher rank.
Further a perception exists that successful candidates cannot be promoted to
sergeant or inspector and retain flexible working.
The varying learning styles undertaken within NPPF may disadvantage males
or females dependent on the style used particularly at step 4
There is a perception that the learning styles between men and women can
be affected at both NPPF Step Two and Step Four. There is some literature to
show that women learn through absorption and contemplation of the data,
men through practical application.
This may account for the disparity at Step Two where, as previously referred
to, women consistently outperform men. There is however no evidence to
show a direct cause and effect. It remains the case that due to the overall
numbers of female officers entering the process, the actual number of
successful candidates (proportionate to numbers in service) is also low.
Any implication that one sex or other is likely to be unfairly advantaged by
the Step 4 methodology is unsubstantiated in the statistics. We see a 99.9%
success rate at Step 4 - if there was any meaningful risk that learning style
was negatively affecting the success of one group; we would expect to see
this in the outcomes of Step 4. This has not been evident to date.
Flexible working - Officers working flexibly other than through statutory
entitlement (maternity leave etc.) may be disadvantaged.
Officers have under the flexible working policy the right to request flexible
working. This is in addition to the normal part time working or that supported
by legislation such as maternity, paternity, adoption leave etc. Officers may
work compressed hours (i.e. a full working week over three or four days),
work term time only, permanent night duty etc. The issue raised is whether
within Step 4 these officers can access the full support available to colleagues
who do not work flexibly.
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The Flexible working guidance sets out and gives examples of supervisory
ranks working flexibly and highlights that flexible working is not a barrier to
promotion. The NPPF operating manual has been amended to reflect promote
and support applications from those who work flexibly. Qualified Assessors
(A1 qualified) and occupationally competent line manager assessors, are as
part of their professional responsibilities, required to meet with all candidates
during the working hours of that candidate and to ensure that they are given
appropriate support according to their needs.
Pre grooming of candidates for Step 3 where managers give additional career
opportunities to selected staff in the expectation that they will perform
strongly at the local selection stage. The converse may also be possible in
that unfavoured candidates are denied additional support (The Halo and
Horns effect).
There is no evidence to show that either is practiced but the principle is
supported by of the findings with Metropolitan Police Authority Race and Faith
Inquiry – Emerging Issues [2009].
Such issues if they occur may also be practised across post OSPRE® selection
processes or indeed any other selection process. The NPPF as a promotion
process, does not increase the likelihood for such activity. It is an issue to
highlight with forces as part of any implementation phase and the inclusion of
staff associations in the local design and implementation of what may
minimise such activity although it would be difficult to separate out what is
inclusive management and development and what is biased behaviour.
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Race
Issues with application of misconduct procedures in relation to BME officers
could indirectly affect opportunities for promotion at Step 1.
Greater Manchester Police commissioned a report (Disproportionality in Police
Professional Standards, 2012) to look at how BME officers are treated in
comparison with white officers in relation to disciplinary procedures. This
research showed that BME officers and staff were disproportionally affected
and that this impacted their career. Whilst not addressed in the report, the
wider impact is that BME officers may also be disproportionally affected as
the eligibility criteria specifically states that to access promotion; an officer
must not have any live findings of misconduct.
Data shows that there are general differences in performance within the Step
2 / OSPRE® part I process.
There is conflicting evidence with regard to the success of candidates based
on ethnicity where BME candidates perform less well than white candidates in
the Sergeants process but in 2012, for the first time, BME candidates
outperformed white candidates in the Inspectors Step Two / OSPRE® Part I
examination (see EIA tables10 and 15).
NPPF may have to potential to discriminate against BME officers in force
transfers or act against public duty in that lack of transfer would result in 34
forces having wholly or mainly white promotion candidates.
The Police Federation for England and Wales stated that in their view a lack of
realistic opportunities to move to other forces, whilst there are two different
promotion processes may indirectly discriminate against BME officers due to
under representation. Further, that as the majority of BME officers (around
80%) was located in just nine forces, an ‘in force’ only selection process
would have an adverse impact on BME officers.
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There is no evidence that discrimination has taken place, but this may in part
be due to the overall lack of movement between forces. Where applications
for supervisors have been made, forces in the main have only sought
substantive officers already outside of a probation period. Finally, data is not
collected in this area. Where transfers have taken place they have been
lateral and the trial forces have not reported any issues arising with regard to
NPPF promoted officers.
The limited number of promotions will have a disproportionate adverse
impact on the promotion of BME officers (In 34 forces the promotion pool will
be wholly or mainly white, the view of the PFEW is that it is highly unlikely
that NPPF officers will apply for or be successful for a post outside their home
force).
There is no evidence to support this view, and the same issue would be true
of OSPRE® forces, if this perception was correct. Although OSPRE® Pt II
officers are ‘qualified’ for promotion, there is no proof that this actually makes
a difference to ethnic minority officers looking to transfer. There is no data
capture requirement about how many ‘qualified’ BME officers apply and who
are either are accepted or are rejected by forces. Without such definitive
evidence the proposition cannot be supported or rebutted.
BME staff may be disproportionally affected at Step 3 Local Selection
Within the evaluation report 81.8% (36) of minority ethnic NPPF candidates
who were surveyed in the evaluation, disagreed that the method of
assessment was fair at Step 3, whilst 60.5% (331) of white NPPF candidates
disagreed that the method of assessment at Step 3 was fair.
The following findings are taken from the full data set relating to the
2010,2011, 2012 and 2013(sergeants only)
Sergeants Step 3 - the success rates of white candidates and minority
ethnic candidates are 45.0% (1228 candidates) and 40.7% (81 candidates)
respectively.
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Inspector Step 3 - the success rates of white candidates and minority ethnic
candidates are 41.0% (597 candidates) and 33.3% (31 candidates)
respectively.
Whilst the percentage gap is noted, the analysis consistently shows that such
differentials are not statistically significant primarily due to the low numbers
involved within data subsets where candidates have stated a preferred
ethnicity background, mixed background or not given an answer.
Religion
The potential for discrimination on religion or belief are based around a
perceived lack of opportunity being available that corresponds to the relevant
requirement of the religion or belief. In turn this may prevent candidate
applications at Step 1.
It is accepted that this is an area of potential for discrimination. ACPO
guidance has already been adopted in this area. Through the quality
assurance process key data is captured specifically to identify early trends
and provide feedback to forces. The flexible working guidance is supported
through the Operating manual and this area highlighted to forces when they
consider implementation and equality issues.
SEXUAL ORIENTATION
Concern about confidentiality of monitoring information – specific to sexual
orientation.
There are numerous pieces of advice that are available to support forces to
implement sexual orientation monitoring and individuals to feel confident to
respond. Forces that are Stonewall Champions should make use of their
membership to encourage officers to undertake monitoring and the Operating
Manual for the NPPF also gives a strong message about confidentiality. Force
EIA’s and guidance should refer to the ACPO Guidance on Monitoring Sexual
Orientation the Stonewall guidance document on Monitoring as well as
referring to information provided further on in this EIA on monitoring.
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In direct response to these concerns agreement was reached with forces that
registration information would be collated centrally thereby providing
reassurance that completed sensitive information would not be deliberately or
inadvertently disclosed inappropriately.
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Decision - Updated April 2013
If the policy will have a negative impact on members of one or more of the protected
groups, explain how the policy will change or why it is to continue in the same way. If
no changes are proposed, the policy needs to be objectively justified as being a
proportionate and necessary means of achieving the legitimate aim as set out above.
Age
Justified - The decision to roll out NPPF will not have a discriminatory impact
by way of age and NPPF actually allows equality of access to all eligible
officers. The Step 2 legal knowledge examination is a key part of the selection
process and required to quantify knowledge and secure public confidence that
sergeants and inspectors have a required level of understanding. As such it
remains an integral part of the process and retention is a justifiable and
proportionate means of the legitimate aim of testing knowledge within the
promotion process.
It is recognised that a potential may exist at a local level where older staff
may assume or line managers may assume, that older candidates will have
difficulty in passing because of age.
The potential for discrimination will be minimised through policy, operating
manual, quality assurance process and by forces considering this issue as
part of local implementation. The use of a legal knowledge exam National
data monitoring will continue with results being fed back to forces although
note will be taken of an increasing age profile for new recruits, which may in
time impact on data outcomes.
The use of this stage is proportionate to the needs of the service, the
promotion system and governments agenda on professionalism and
development.
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Disability
Attendance Management
The Bradford method is not of itself unlawful or discriminatory but its use is
not advocated by the NPPF. Taken on balance, forces that do not use the
Bradford method will not generally be at risk of indirect discrimination. Forces
that do use the Bradford method may have a greater chance of discriminatory
behaviour that should be off set by local equalities policies and management
practice.
The NPPF cannot mandate to forces which local policy is used but will as part
of the quality assurance process highlight the issue for consideration in any
local EIA. Forces joining NPPF will have to consider as part of any equality
assessment, what policy amendments may be required to remove or
minimise the potential further.
Learning and complex questions
This EIA has taken into account the position of candidates and the service.
The adjustments offered to candidates who declare a disability are made on
an individual needs basis. They are reasonable and proportionate to permit
equal access and participation within the process.
Whilst this area has the potential for discrimination at a local level, it can be
minimised through adherence to local force policy, data analysis of candidate
information at a national level and bespoke advice to candidates. As such the
policy encourages equality and the changes are justifiable with regard to
permit access and participation within the promotion process.
Disability and Operational outcomes
Amendment to the operating manual have allowed officers with a disability or
on short term restricted duties to access and maintain involvement with the
work based assessment. Whilst adjustments may be required there is equality
of access for all staff.
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Completion of the work based assessment is an integral part of the promotion
process and the changes are a proportionate response to fulfilling the
legitimate need of the promotion process.
Overall Outcome on Disability
Minimised – The decision to roll out NPPF will have no adverse impact as
national and local equality policies within forces and policies within NPPF
itself, already provide equality of access and participation.
The data shows that within NPPF only minimal variance is noted. Across all
the NPPF steps, the variance between stated disabled and stated non disabled
candidates is only 0.6% for sergeants and 3.9% for inspectors.
Any potential for discrimination can be minimised through adherence to
policy, the operating manual, quality assurance mechanisms, data analysis
and advice to line managers and candidates. It directly affords disabled
officers access to the same process as other groups with additional support
being made available on application by the candidate. This continues through
the process where needs can be met within the work based assessment
process in terms of time or tailored support by the assessors. As such the
NPPF remains a proportionate process to select suitable candidates for
promotion.
Gender
Access to Promotion – Females, transgender staff
There is no discriminatory impact on staff within a protected characteristic
group or groups by implementation of the NPPF. There is a potential for
discrimination in how staff access it at a local level.
Under NPPF Forces are required to monitor the application of flexible working
staff and are all required to demonstrate due regard to equality in their
policies in relation to posting and flexible working. Forces can also utilise
Gender Agenda 2 [2006] which identifies barriers to promotion for women
and good practice in relation to removing those barriers. Forces should also
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refer to their own policy on Flexible Working and or make use of the College
of Policing Flexible working in the police service.
The flexible working guidance gives examples of part time or flexible working
through supervisory ranks.
All forces involved in the trial have been provided with a link to PAB Guidance
covering the fair use of Attendance Management policies.
The Operating Manual has been updated to ensure that disability related and
maternity/paternity related absences do not affect an individual’s opportunity
to be promoted. (Operating Manual)
The TUC / Unison advice and guidance can be found here (TUC Sickness
Absence and Disability Discrimination) and will along with all other
contributions, form part of the advice pack to forces.
The Licensing requirements for the NPPF have been amended and now
specifically require forces to provide evidence in relation to:
• The use of Reasonable Adjustments
• How due regard has been given to the equality duty to promote
equality of opportunity
• Demonstrate how Step 3 has been implemented in accordance with the
Operating Manual
Study Leave
This is a potential area for discrimination but at a corporate level rather than
between any protected groups. The issue of study leave was reviewed both
within the terms of the trial and the Strategic User Group (SUG) who
determined that in the current economic climate paid study leave was not
viable. However as an outcome of this EIA, it will be raised with forces as part
of their implementation planning to ensure this issue is addressed at a local
level. Whilst support may vary between forces, where given, it should be
equal support to all within a force. The SUG will continue to monitor and
review its decision.
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Impact on family life
Fixed date exams were a potential area for discrimination but the policy was
changed to reduce the impact on those who may work term time only or have
specific child care arrangements which disproportionally affect women. The
scheduling of Inspector’s NPPF Step Two is reviewed annually so as to
minimise clashes with school holidays, religious festivals etc and recently the
Inspectors process schedule was moved back in the year to minimise any
clash across the summer period. This will continue with the scheduling of
NPPF step 2 exams (currently March and October) to avoid key periods of
family activity.
Jobs for the Boys culture
The decision on the NPPF will not impact on this area as we can only
recognise the perception that women are disadvantaged as a group but which
is not borne out by the data. The issue is one of information to staff not
change to policy. That said if the perception continues it could lead to
potential area of discrimination if it prevents access before candidates even
apply for Step 1.
To minimise this potential for discrimination NPPF policy will be to encourage
access by female officers. Quality assurance and national data analysis will
continue to track candidates, with information being returned to senior
managers within each force. The operating manual has been amended to
reflect that staff association input in the design or implementation of the local
process may provide openness and confidence in the process. Forces will be
encouraged as part of their EIA and implementation to assess how they may
encourage participation or understand what barriers may be encountered by
female staff before they consider applying.
Learning Style
NPPF uses a range of approaches to test and support candidates. They
undergo development through distance learning (preparation) and on-the-job
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experience (workplace development).
Therefore the process uses a range of different methodologies to assess the
candidate's overall performance.
Step 4 and WBA provides all candidates a range of activity and reflection
rather than a confined learning style of study and implementation or learning
by completion of a task (i.e. both genders undertake activity that may not be
their natural 'learning style'.
During the trial and throughout the evaluation no potential discrimination or
adverse impact has been identified at step four and the success rates would
indicate that there is no issue. The pass rates at step four indicate that there
is no adverse impact occurring between genders.
The legal exam and work based assessment are integral parts of the process
and no evidence has been found to show that learning styles lead to
discrimination. The process is applicable to all protected characteristic groups
and does not discriminate between them. It is both proportionate and
legitimate.
Flexible Working within NPPF
There is no evidence to show that this is or has been a problem within forces
although it is recognised that a perception that working flexibly may stop
applications from being submitted or careers developed in the misguided
belief that flexible working is not available at higher ranks.
The Strategic User Group who oversee assessment at step 4 highlight that
assessors, qualified and line managers are required to be flexible in meeting
the needs of the individual. Forces joining NPPF will be required to have
equality policies in place including flexible working. The decision will have a
positive affect on staff as flexible working is seen as being open to and
working within supervisory ranks.
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Pre Grooming
There is no direct evidence to show this is happening but it is a potential area
for discrimination. It is an issue for forces to address but data can be
monitored to identify any trends. The operating manual advocates’ staff
association involvement and this issue will be raised with forces as part of an
implementation plan and local EIA to influence local policy amendment or to
clarify the bounds of ethical support for line managers.
Overall Outcome Gender
Justified – The service has concluded that there is a requirement for
candidates to undertake a selection process. The support given by line
managers is specific to local forces but should be corporate in its approach
(through the QA process and Operating manual) and will afford equal access
and opportunities being given to candidates. As previously discussed the
Strategic User Group has not supported a policy of ‘learning support’ across
forces (although it will be re-visited once financial restrictions are relaxed)
but this will be highlighted as an issue as part of any implementation
planning.
A decision to implement NPPF will allow differing groups the same access and
support at force level and will have only minimal effect in terms of Gender. As
such, where a potential for discrimination exists it is objectively justified to
support an effective promotion process.
Race
Misconduct and BME officers
The decision to roll out NPPF does not directly discriminate in this particular
area although misconduct proceedings may potentially prevent access. The
implementation of misconduct and who is supported to go forward for
promotion is for the Chief Officer to determine.
The operating manual and information to forces will reflect that in
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determining whether support can be given to a candidate, care must be taken
to ensure that the decision is made on the facts of the particular incident, the
end date for a misconduct finding and its relevance to participation in the
promotion process. It remains an issue for forces, but will be highlighted as
part of any implementation plan. We cannot remove the potential but its
continued acceptance is justified to provide a corporate approach to access
the examination process and allowing Chief Officers to determine who they
would support.
Difference in pass rate at Step 2
It cannot be necessarily concluded that these differences are directly
attributable to the examination format and (because of the low numbers
involved) the differential noted have been reported to the PPEB as not being
statistically significant.
All candidates are examined in the same way with the only adjustment being
made is in respect of disability.
A decision to implement NPPF will positively impact this area as the quality
assurance process and data analysis specifically aims to provide equality of
opportunity by providing feedback to senior managers.
BME Transfer Opportunities
As data is not collected in this area we cannot show whether the decision to
implement NPPF would have a direct impact in terms of discrimination. The
reduced number of promotion opportunities across all forces has arisen not
because of a promotion process but external financial restrictions and force
restructure.
The premise that BME officers are disproportionality affected as a result of
having two systems is recognised, but this EIA is to look at the impact that
implementation NPPF may have if NPPF is rolled out nationally.
Implementation of the NPPF will not have a direct discriminatory impact on
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BME officers as the process all allows all officers to seek transfer at the same
point. Within NPPF, this could be after being successful at Step 2 or after
being substantively promoted on completion of NPPF. The key difference is
not the process but rather the eligibility criteria set by forces seeking external
candidates.
A force can if they wish, advertise for candidates who meet the selection
stage. This means that a candidate who has attained Step 2 can apply for a
place at Step 3 and equally a candidate with an OSPRE® Part I and II pass
can apply at the same position.
However, forces generally do not seek a PC from another force directly into
the rank of Sergeant (ditto for Sgt to Insp) and instead opt for level
transfer’s.
NPPF may have the potential to discriminate against BME officers in that lack
of transfer would result in 34 forces having wholly or mainly white promotion
candidates and in doing so act against public sector equality duty
There is no evidence that discrimination has taken place or evidence to
support this view and the same issue would be true of OSPRE forces, if this
perception was correct.
There is no proof that this actually makes a difference to ethnic minority
officers looking to transfer. There is no data capture requirement about how
many BME officers apply and who are either are accepted or are rejected by
forces. Without such definitive evidence the proposition cannot be supported
or rebutted.
If NPPF is adopted then the impact would be that all officers are eligible to
transfer once they have passed Step 2 or are substantively promoted. The
opportunity for promotion is not limited to just OSPRE® ‘qualified candidates
with NPPF being excluded until such time as they too have completed the
entire promotion process.
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Candidates are not directly or indirectly disadvantaged as any officers seeking
to transfer at this point would be in open competition with others Step 2
candidates or OSPRE® I and II qualified candidates who have not yet been
selected for promotion. Both NPPF and OSPRE® candidates will undertake a
local selection process.
If NPPF is the nationally adopted promotion process and a force wishes to
recruit external candidates, then as for its internal pool, they must select
from those who are eligible. They would indirectly discriminate if they chose
to select from just part of the pool. This would not however prevent a force
from seeking sergeants or inspectors on lateral transfer. This issue will be
made very clear to forces as part of an implementation plan.
With regard to the position of forces being wholly or mainly white, the NPPF
as a process cannot affect this as an outcome. Officers are selected on merit
and race cannot be a criterion for selection. Forces can and do encourage
applications from BME officers and nothing in the NPPF process prevent
candidates from applying, if they wish.
Rather than reducing opportunity, NPPF actually increases the diversity of the
selection pool that forces can draw upon. This applies whether the force seeks
to select from an internal pool or whether it opens its process nationally.
Under OSPRE® a candidate must pass Part I /NPPF Step 2 and then go on to
pass Part II before being eligible. The diversity of candidate’s decreases as
they withdraw from or are unsuccessful at OSPRE® Part II.
Under NPPF candidates are selected from the larger pool of those who pass
who pass Step 2 / OSPRE® Part I.
Step 3 Local selection Process
A decision to implement NPPF and in particular the Step 3 local selection
process does not directly discriminate against any of the protected groups.
How it is locally implemented may be a potential area for discrimination.
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Whilst it cannot be proven that dissatisfaction at failing a step 3 processes
had a direct cause and effect on the survey outcome it is likely, but it cannot
apply to all candidates who responded to the survey. As such remains a
potential area for discrimination but as the data indicates, this is not specific
to BME officers
The operating manual, quality assurance and data capture for step three
provide for a structure to be in place around the selection process which is
not the case in all OSPRE® selection processes. The operating manual also
advocates involvement of staff association specifically to ensure openness
and transparency in the selection process.
Whilst there remains a possibility of indirect discrimination, the selection
stage is a key part of the process. It allows Chief Officers to select candidate
under general guidelines whilst meeting the government’s agenda for localism
wherever possible. It is a legitimate and proportionate process to support the
promotion policy.
Overall Outcome Race
Minimised – Whilst accepting its Public Sector Equality duty, the NPPF is not
designed to balance protected characteristics across forces. However it does
provide for equality of access and opportunity. It also widens and therefore
includes a broader diverse range of candidates who can access the local
selection process. The policy, processes and operating manual all support
this. There is no evidence to show that BME officers are discriminated against
in terms of transfer as those attaining Step 2 are in equal competition with
their peer group within NPPF or OSPRE®.
The potential for discrimination on race is minimised through the quality
assurance process, operating manual, data analysis and feedback, and a
requirement for forces to have in place corresponding equality policies.
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The requirement to have a selection process is integral to the promotion
process, required as part of workforce planning and meets the localism
agenda in that Chief Officers set the criteria, within a national structure, to
select the best candidate.
Religion
Adoption of NPPF does not result in direct or indirect discrimination on
religious grounds but there remains the potential for discrimination at a local
level. To minimise this forces are required to have suitable policies in place
around equalities and flexible working which is closely linked. It is subject to
data capture requirements with any trends (if identified) being reported back
to senior management within forces. Amendments to the Operating manual
reflecting flexible working guidance and local EIA will minimise or remove this
issue. At Step 4 work based assessor will engage with candidates to provide
support at time suitable to the candidate. As such NPPF remains a legitimate
and proportionate response.
Sexual Orientation
A decision to roll out NPPF will have not result in direct or indirect
discrimination but there is a potential for discrimination.
There is no evidence to suggest that this has, or is taking place but the
perception or fear that information may be released cannot be discounted.
The issue cannot be removed because an unwarranted fear may be enough to
stop initial applications and the unknown cannot be measured. However, the
central collation requirement to respect confidentiality is promoted as a key
EIA issue for local implementation. Candidates are also told that confidential
data requested will be dealt with sensitively and data sent back to forces, is
in a statistical format only. Individuals cannot be identified. The data shows
(see table 19) confidence in the system with percentage preferring not to say
at 10.9% and for missing data about 0.6% of candidates.
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The requirement to collect data is a key function of NPPF the quality
assurance process and required to influence strategic decisions as part of the
Public Sector Equality Duty. The requirement to collect data is proportionate
to the aims of the promotion process.
Overall Conclusion
The overall decision is that the National Police Promotion Framework does not
directly or indirectly discriminate although it is recognised that there is a
potential for discrimination. Where such potential exists, it is not beyond that
already found within OSPRE® and policies and processes are in place to
minimise these risks.
NPPF is a proportionate means of achieving a legitimate aim. The rationale for
this is;
1. It is accepted that there is the potential for discriminatory practice in
NPPF, but data analysis does not show an increase over OSPRE®. Any
discriminatory practice, whilst minimised is justifiable in terms of
meeting the Government’s localism agenda, the need for effective
workforce planning and the need for an effective promotion process.
The PPEB will continue to monitor at a national level the data on key
protected characteristics and other areas (such as educational
attainment background) and provide analysis for national and local use.
The Quality Assurance programme will monitor the equality
requirements particularly as forces Step 3 introduce the process.
Overall, whilst it has been found that the NPPF does not have a
detrimental impact on the requirements of the equality duty, its
implementation and supervision at a national level is limited in the
positive impact it can have.
This limitation is due primarily to allow local implementation where
interaction between groups actually takes place. Chief Officers must
have the ability to manage their staff in accordance with the needs of
the force, particularly at Step 3 and implementation of NPPF, together
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with its Operating Manual and Quality Assurance processes into local
policy will remove or reduce any potential for discrimination.
2. The main risk that lies with forces is in relation to Step 3 of the NPPF
promotion, selection and posting processes, including external
candidates. The risk and onus is on forces to ensure that the
mechanisms they use within a locally designed Step 3, and other steps
of the NPPF, are compliant with the public sector equality duty and
national quality assurance requirements set by the PPEB.
That said the PPEB, as the legislative body for the supervision of
promotion to the ranks of sergeant and inspector, recognise and retain
their own public sector duty requirements and legal ownership of the
policy. The key issues will feature prominently within implement
planning and forces will be expected to address them.
3. The board agreed at its meeting on 9th April 2013, it held the legal
responsibility for the Public Sector Equality Duty, that data collection
across the agreed areas and protected characteristics would continue if
NPPF is rolled out nationally. In addition the Quality Assurance Sub
Committee would remain as the initial body to supervise and advise
forces in the implementation of any local EIA, monitor through the
quality assurance programme the collection and analysis of data and
hold initial discussions with forces to highlight and remedy identified
issues.
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