We welcome the publication of the draft Police Race Action Plan from the National Police Chiefs’ Council (NPCC) and College of Policing (the College) and their commitment to get feedback, including from the public (via this survey), in order to produce a further iteration in December. We also appreciate that the plan has established an independent body, the Independent Scrutiny and Oversight Board (ISOB), to hold the police to account for becoming an anti-racist service and achieving the outcomes that the draft plan sets out. This transparency is to be applauded.
A whole system approach to tackling entrenched racial inequalities is required urgently, as we know racial disparities are not just found in policing but are experienced and multiply across the criminal justice system (Lammy, 2017) So, there must be a joined-up up strategy with other criminal justice agencies and government departments to achieve the systemic change required. For example, we hope that the Ministry of Justice will follow suit in publishing their race action plan and developing an independently led oversight body.
The CJA were pleased to be consulted on the initial suggestions for the plan and many of our recommendations have been taken on board. However, there are several areas in which we would like to see the plan go further in its next iteration:
Stop and search
We commend the recognition of the harm experiencing stop and search can do to a Black person, drawing on CJA’s research. We approve of the commitments for a national, consistent approach to data collection, officer training and community scrutiny of stop and search. As we argued in our super-complaint, launched one year ago, this lack of consistency was hampering effective practice and contributing to Black people’s mistrust in the use of these powers. However, the plan has stopped short of recommending that an independent national oversight body for stop and search be established, which the CJA and race equality organisations have called for. We would like to see that included in the next iteration, to make sure positive changes made at force level are delivered, maintained and monitored closely.
On suspicion-less Section 60 searches, we endorse the call for extra transparency, especially as the government is still refusing to publish the evaluation of the relaxation of safeguards. However, we would urge the NPCC and the College to go further as Black people are 14 times more likely to be searched than white people under these powers. In our super complaint we called for the repeal of these powers, so we would like to see the plan make clear that there should be significant reductions in the use of s.60, given the commitment to ‘explain or reform’ where significant disparities exist.
Assessing the impact of policies and powers
We would have liked to have seen mention of the Public Sector Equality Duty (PSED) and the use of Equality Impact Assessments in the plan. The PSED is a legal duty which all police officers and staff should be aware of as part of their training. We would like to see more support for police developing policies and procedures to produce robust Equality Impact Assessments, so they are effective in mitigating and reducing direct and indirect discrimination, as well as promoting equality of opportunity and fostering good relations.
Diversity in the police workforce
The greater focus on the recruitment, retention and progression of Black officers is welcome, but the inclusion of targets and a timeframe could help to focus minds on the urgent need to improve outcomes in this area.
Black people detained in police custody
The treatment of Black people in police custody has not specifically been mentioned in the plan, despite Black people being three per cent of the population but eight per cent of deaths in custody (IOPC, 2020). The CJA’s recent report, Just Visiting?, looked at the effectiveness of independent custody visitors at monitoring outcomes for Black and ethnic minority detainees, and set out what more could be done to tackle racial disparities. We hope to see some of our recommendations adopted in the next version of the action plan.
Safeguarding of Black children and young adults
Although the plan mentions safeguarding of children, there is a lack of any specific measures for children or young adults. Despite the recent case of Child Q, there is also a lack of specific actions around the policing of schools, apart from a commitment to review how successful they are as a means of improving community engagement. The plan does not seem to acknowledge that they could be causing more harm than good.
Reparations to Black communities for past harms
We welcome the section on piloting approaches for community reconciliation and reparation for past harms. These must be meaningful, using expert restorative facilitation. They must also ensure Black communities have a direct say in how some of the police’s resources are spent, for example using participatory budgeting, as well as being involved in the recruitment of senior police personnel. One way to start would be to ensure the recruitment process for the new Metropolitan Police Commissioner involves young people and representatives from Black communities that the Commissioner will need to regain trust with.
Improving the experiences of Black victims
We support plans to improve outcomes for Black victims, including young people who have been exploited, women experiencing domestic abuse and those who have experienced hate crime. As the police are often a gateway to victim services, including restorative justice, it is vital this part of the plan is urgently delivered. The CJA were involved in developing the new commissioning guidance for Police and Crime Commissioners (PCCs) launched in April 2021 to improve outcomes for Black, Asian and minority ethnic victims. This guidance, and an evaluation of its outcomes, should be published in order for the public to better understand if and how specialist services for Black victims are being commissioned, and how the police are facilitating and promoting access to these services. The new Victims’ Bill should also ensure this is the case.
Capacity building grassroots organisations is key
We welcome the acknowledgement of the important role that community and voluntary sector partners will play in delivering better outcomes and that the police cannot do this alone. But in the next iteration of the plan there needs to be a commitment to financially invest in capacity building specialist voluntary sector organisations, in particular Black-led, grassroots community organisations, as well as ensuring that Black individuals involved in engagement and scrutiny activities on a voluntary basis receive appropriate training, support, expenses and thanks for their contributions, expertise and time.
Next steps
We will be responding to the plan in full and will publish our response in due course. And we encourage as many people and organisations to feedback using the survey as possible. We look forward to continuing our work with the NPCC, the College and the ISOB and to seeing much needed change for Black people in contact with the police and wider criminal justice system.
