MOPAC's Oversight of Police Complaints

MOPAC and the MPS collaborated to conduct an extensive survey of complainants in 2020/21. The MPS then agreed four specific recommendations to improve the quality of their complaint handling. Further information can be found here. 

The MPS subsequently introduced the Complaints Resolution Unit (CRU) in February 2022. The CRU is designed to improve communication with complainants and also streamline handling by delivering swifter and proportionate outcomes.  

Initial contact is now made with complainants far more quickly. The MPS average matched the ‘all-force’ (England & Wales) average of 5 days to contact complainants in 2022/23.  

The CRU function enables specialist MPS officers to discuss the nature of the allegations made in order to gain a full understanding of the complaint and explain the available means of resolution.  

Timely resolution of complaints enhances the scope for any individual or organisational learning to be recognised and implemented by the MPS.  

MOPAC officers meet with CRU counterparts each month to discuss the current caseload, key performance metrics and any emerging issues requiring further examination or research. 

The MPS logged 11,779 complaint cases in 2022/23. This represented circa 14.5% of the 81,142 total complaints logged by all police forces across England & Wales. 

The IOPC calculated that the average number of complaint cases logged per 1,000 employees across all forces in England & Wales in 2022/23 was 329. The MPS logged 247 cases per 1,000 employees so receive less complaints than the national average when the data is analysed on a ‘per capita’ basis for comparison purposes. 

Each complaint case may include one or more allegations. The 11,779 MPS cases comprised a total of 20,202 allegations. Again, when considering the number of allegations per 1,000 employees the IOPC found that with 424 allegations the MPS compared favourably against the national average of 547. 

A complaint can be about any matter which has had an adverse effect on the person making the complaint, that they have witnessed, or which happened to them. As with all police forces, the MPS are required to categorise all complaint allegations logged for monitoring purposes. In this regard the 2022/23 MPS data closely reflected the national picture with the three most populous complaint categories being (in descending order) Delivery of Duties and Service (1), Police Powers, Policies and Procedures (2) & Individual Behaviours (3).  

The IOPC also publish a quarterly Police Complaints Information Bulletin (PCIB) for each force. The latest MPS data can be found here 

Our role as a local policing body is to hold the MPS to account on behalf of the public. MOPAC officers have a monthly performance meeting with MPS counterparts to discuss a suite of data relating to the handling of complaints and conduct matters. MOPAC scrutinises any areas where there has been a deterioration in service standards, and seeks explanation and/or remedial action from the MPS as required. 

The performance meetings enable us to identify and discuss any anomalies in the data and variations in the volume and type of complaints. We ask the MPS to explain any fluctuations observed in the data, and set out the impact of any preventative work in which they are engaged. If the MPS are proposing any changes in governance or administrative arrangements for complaints, we will invite them to explain how and why those changes are being made. 

MOPAC also seek assurances around the type of organisational learning that can be taken from complaints received by the MPS and from any investigations that subsequently ensue. The complaints system is a rich source of such information for police forces. 

MOPAC officers meet with counterparts from the IOPC to discuss governance issues around the management and handling of public complaints. We also use those meetings to discuss the scope and impact of legislative changes. We discuss thematic issues around policing professional standards that have been observed at a national level and participate in surveys and other consultation exercises in related areas. 

The MPS must provide MOPAC with a formal ‘timeliness’ notification in the event of any complaint or misconduct investigation taking 12 months to finalise. This will explain the reason(s) for the delay, and advise what remedial steps are being taken to bring the matter to a conclusion. The MPS took an average of 217 days to finalise the 4,722 complaint cases handled under Schedule 3 to the Police Reform Act 2002 (including suspension) in 2022/23. 

MOPAC uses these timeliness notifications to challenge the MPS around the causes of any unreasonable delays in bringing investigations to a conclusion. Some delays are unfortunately unavoidable due to matters being subject to an active criminal investigation or judicial proceedings. We are working with the MPS to improve the timeliness of complaint investigations and to identify any MPS units where unreasonable delays are regularly occurring. 

Where the MPS are able to log expressions of dissatisfaction and deal with them outside of the formal complaints system the capacity to deliver a swifter outcome is improved. Across 2022/23 the MPS finalised 8,017 cases outside of Schedule 3. The average number of days spent on each case was 16. 

Where either performance data or MOPAC discussions with the MPS identify areas of potential strategic those matters are escalated to the Deputy Mayor for discussion at bi-lateral meetings with the MPS or the IOPC as required. 

Under the 2020 reforms the Government introduced a new right to independent review for complainants dissatisfied at the handling or outcome of their complaint to the police. This was designed to further improve the transparency and integrity of the complaints process. 

Review applications are always considered by an organisation independent of the force concerned, with either the IOPC or the respective local policing body designated as the Relevant Review Body (RRB) depending on the nature of the complaint.  

A review requires the RRB to assess whether the MPS handled the complaint in a reasonable and proportionate manner. It is not, and cannot be under legislation, a re-investigation of the original complaint. If the RRB consider that the complaint has not been handled correctly, a review will be ‘upheld’. Where MOPAC are the RRB we can also then make recommendations to the MPS about how to rectify the situation where appropriate. 

The MOPAC Police Complaint Reviews Team (CRT) is completely independent of the MPS. None of our staff are employees of the MPS. Reviews are carried out independently, impartially, and without bias.  

Over the 12-month period to 30/09/23 there has been a 50/50 split between whether the RRB is either MOPAC or the IOPC for all eligible complaint cases recorded by the MPS under the provisions of Schedule 3 to the Police Reform Act 2002. 

The number of review requests received by MOPAC has fallen quite significantly over the past 12 months. From the period 01/10/21-30/09/22 MOPAC received 659 review requests. In the latest corresponding period from 01/10/22-30/09/23 we received 421 review requests. This represents a decrease of 36%. Over the same period the IOPC received 397 review requests (in relation to MPS complaints). 

Due to the range and volume of information that needs to be considered in the course of conducting a review, it can take a significant amount of time to reach and then set out a determination in clear terms for the complainant. Nevertheless, with additional resources having been recruited into the CRT in 2022 there has been a 17% improvement in the timeliness of MOPAC reviews over the latest 12-month period (to 30/09/23). 

MOPAC ‘upheld’ (determined that the outcome of the complaint was not reasonable and proportionate) 35% of reviews across the 12-month period to 30/09/23. We also made 169 recommendations to the MPS across the same period, an increase of 8% on the previous 12-month period. We are seeking to ensure that our role as an independent review body increases public confidence in the police complaints system by holding the MPS accountable for their complaint handling. We have also been able to work collaboratively with the MPS to inform the training of officers involved in complaint handling and investigation.