Our Complaint Handling Functions and Oversight Arrangements

The Elected Local Policing Bodies (Specified Information) (Amendment) Order 2021 requires Police and Crime Commissioners (PCC) to publish the most recent Independent Office for Police Conduct (IOPC) quarterly complaints data for their force and the IOPC annual statistics report, alongside a narrative setting out how the PCC is holding the chief officer to account, and the PCC’s assessment of their own performance in carrying out their other complaints handling functions.

The Order requires that the IOPC data and report are to be published on the PCC’s website within one month of their publication by the IOPC, and the narrative and assessment are to be published annually, within one month of the date of publication of the IOPC’s annual statistics report

View the IOPC’s annual statistics report

The IOPC oversees the police complaints system in England and Wales and regularly publishes data about police complaints handling and recommendations for police forces.

View the latest information about West Yorkshire Police published by the IOPC, including the latest performance reports

Holding the Chief Constable to Account

Details of the arrangements the PCC has put in place to hold the chief constable to account for complaints handling

The Chief Constable reports on a quarterly basis to the Mayor at Quarterly Governance Meetings, a decision-making forum attended by the Mayor, the Chief Constable and members of their senior teams.

The reports to the quarterly governance meetings provide information and statistics about complaint volumes received, proportions handled outside and inside Schedule 3 of the Police Reform Act 2002, most common categories of complaint, average length of time to deal with allegations and comparison with most similar force and national performance. Data on ethnicity and gender of complainants is also provided.

For conduct matters the reports to the quarterly governance meetings provide information on volumes, nature of conduct issues raised and information on handling and outcomes.

The Mayor’s Policing and Crime Casework and Reviews Team team monitors matters raised through complaint reviews and meets regularly with senior members of the Service Review Team in the Professional Standards Directorate to raise any issues of concern in terms of themes or trends.

The Deputy Mayor for Policing and Crime holds regular surgeries with members of the public and is supported by the Casework and Reviews Team to respond to casework matters. Casework also provides information about common themes or trends about issues raised by members of the public.

Progress updates on implementing relevant recommendations made by the IOPC and/or HMICFRS in relation to complaints handling

West Yorkshire Police has a responsibility to respond to all formal IOPC learning recommendations within 56 days unless there are valid reasons not to. The majority of recommendations are accepted by the Force and the response will outline what action has been taken. If the recommendations are not accepted then the Force should inform the IOPC why not and the reasons behind this decision. All responses are then published on the IOPC website unless there are valid reasons not to such as ongoing legal proceedings. This information is also reported to the Mayor’s office.

View learning recommendations made by the IOPC to West Yorkshire Police

Her Majesty’s Inspectorate of Constabulary and Fire and Rescue Services (HMICFRS) undertake inspections of West Yorkshire Police concerning a range of subjects.

View HMICFRS reports 

Mechanisms put in place to identify and act on themes or trends in complaints

The West Yorkshire Police Professional Standards Directorate (PSD) conducts six-monthly health checks with all policing district and Headquarters departmental Heads and their nominated PSD points of contact. These health checks have been in place for over three years and are an effective mechanism for acting on trends and themes.

Issues discussed includes officers of concern who have three or more complaint and conduct cases recorded against them within a twelve-month, together with trends in complaints and details of ongoing investigations. Policing districts are required to report back on each officer of concern to ensure there are no underlying issues which could escalate to more serious incidents.

Systems and Quality Assurance mechanisms in place to monitor and improve performance in the quality and timeliness of complaints handling and responses to complaints

The Chief Constable’s quarterly report to the Mayor includes information about timeliness of complaint handling and measures which are put in place to resolve any backlogs. The Mayor’s Complaints and Casework Team also provide feedback from complainants about timeliness of complaint handling.

Like other police forces, West Yorkshire Police has seen a 203% increase in complaints received since 2019. It is believed that this is due to the new complaints legislation which has made complaint reporting more accessible, but the global COVID pandemic appeared to have also contributed to the increase.

New complaint handling staff joining the PSD Service Review Team (SRT) undertake a structured induction programme which includes close mentoring in the first few months; an early investment which is invaluable to ensure the effectiveness and confidence of that new team member after a relatively short period of time, leading to good quality work produced in a timely manner. SRT also undertakes regular upskilling of Complaints Officers as part of their continual professional development training.

A process of 28-day workload reviews, undertaken by first line managers, ensures complaints are being progressed expeditiously, enquiries remain reasonable and proportionate, and any training or development needs can be identified.

Complaint handling processes have been reviewed and refined to improve efficiency, timeliness and quality. Changes to the handling of complaints where available independent evidence, such as officer body worn video footage, does not support the allegations made and complaints where all reasonable lines of enquiry have been pursued during the attempted informal resolution have been implemented during 2021.

Templates developed for use as the basis of outcome letters have been reviewed to ensure they remain fit for purpose, are written in clear, plain English and improve the understandability for complainants.

The SRT sergeants also undertake an assessment of the public complaints where the complainant is not satisfied with the Outside Schedule 3 resolution and direct that the complaint is formally recorded. This has resulted in a lower upheld review rate from the West Yorkshire Combined Authority.

Regular dip-sampling of work at all stages takes place through internal checking mechanisms. In addition, supervisory workload reviews take place to ensure work is being progressed expeditiously, no training needs are identified, and the staff are rightly supported.

All concluded investigations are reviewed and considered by the SRT manager who then directs the subsequent action that needs to take place. In that work he will quality check the report, ensuring the reasonable and proportionate investigation has been exhausted and the complaint points covered. He will also check content for spelling and grammar. He ensures the outcome letter clearly explains the circumstances, the reason decisions were made / actions were taken and the rationale behind the outcome of the complaint investigation.

The SRT Manager also considers the points raised during upheld reviews, speaks to the West Yorkshire Combined Authority Casework and Reviews Manager where further clarification is required, identifying any trends and learning for either individual complaints officers or across the whole team.

The number of written communications issued by the force under regulation 13 of the Police (Complaints and Misconduct) Regulations 2020 where an investigation has not been completed within a “relevant period”.

Where a complaint or conduct investigation is not completed within 12 months, West Yorkshire Police must provide information to the PCC and the IOPC in writing, which includes a reason for the delay, progress of the investigation and an estimate of when the investigation will be concluded.

Assessment of Our Own Performance in Carrying Out Our Other Complaints Handling Functions

The Policing and Crime Act 2017 introduced a mandatory role for PCCs to become the review body for most complaints handled by their police forces in accordance with Schedule 3 of the Police Reform Act 2002.

The Act also allowed PCCs to choose to take over other parts of the complaint handling process from their police forces, known as Models 2 and 3 within the Act.

In West Yorkshire, the role of PCC is undertaken by the Mayor. West Yorkshire has not adopted either Model 2 or 3.

The timeliness of complaint reviews

The below information supplements the report produced by the IOPC. All data is 1 April to 31 March:

Which review functions the PCC has delegated and what measures they have taken to ensure quality, integrity and impartiality

The Mayor has delegated all review functions to the Policing and Crime Team and reviews are carried out by the Casework Team, which consists of the Casework and Reviews Manager and two Casework Officers.

The Casework and Reviews Manager and one Casework Officer were in post before the responsibility for Reviews commenced on 1 February 2020. Both attended reviews training in 2019 which was delivered by the IOPC and Home Office jointly.

A second Casework Officer joined the Team in May 2021 and attended reviews training in March 2023.

More than one trained reviewer ensures there is resilience within the Team in case of absence or if many review requests are received within a short space of time. This arrangement also ensures impartiality by having an alternative reviewer available if one has had significant involvement in previous casework concerning the matter being complained about.

The responsibility for reviews has necessitated a change to how casework has been handled since 1 February 2020. Any issue raised with the Office which could become the subject matter of a formal police complaint which the Team could later be asked to review is passed, with the sender’s permission, to the West Yorkshire Police Professional Standards Directorate.

Upon receipt, review requests are prioritised over other casework. Validity checks are carried out quickly to be able to accept requests, or otherwise, within 1 or 2 working days.

The Team currently aims to complete reviews within 20 working days and this timescale information is provided to complainants when their request has been accepted.

Quality Assurance mechanisms the PCC has established to ensure that review decisions are sound and in line with the requirements of the complaints legislation and IOPC statutory guidance

Review outcome letters to complainants are based on the questions that reviewers are required to consider, which are set out in paragraphs 18.38 of the IOPC Statutory Guidance. All outcome letters provide the reviewer’s response to those questions.

The IOPC Statutory Guidance incorporates all the requirements of the relevant complaints legislation. View the guidance.

The West Yorkshire Police Internal Audit Team undertook an audit between August and September 2020 of the complaints handling process to ensure its compliance with the IOPC Statutory Guidance. The report, published in December 2020, features commentary on the review process, after the auditor dip sampled 30 completed reviews. The internal auditor concluded that a fair and consistent approach was in place, with efforts made to utilise comprehensive materials to reach conclusions and the outcome was well communicated to the complainant.