Response to HMICFRS report: An inspection of the West Midlands regional response to serious and organised crime

Dear Inspector / Minister,

On 14 May 2024, His Majesty’s Inspectorate of Constabulary and Fire and Rescue Services (HMICFRS) published its report: ‘An inspection of the West Midlands regional response to serious and organised crime’.[1] As the Police and Crime Commissioner for Warwickshire (Local Policing Body), I provide the following response to HMICFRS and the Secretary of State for the Home Office. This action is pursuant to my obligations under Section 55(1) of the Police Act 1996.

1.  Local Policing Body’s Comments.

I welcome the report and its findings and thank HMICFRS for its inspection of how well the West Midlands region tackles serious and organised crime (SOC). The West Midlands region consists of four forces (Staffordshire Police, Warwickshire Police, West Mercia Police and West Midlands Police) and their Regional Organised Crime Unit for the West Midlands (ROCUWM).

I note that the report includes sections on two associated areas: –

1. Regional findings: A summary of inspection evidence that identifies good or poor performance within the region. The performance of the region is not given a graded judgement. Instead, areas for improvement, causes of concern and innovative and promising practice have been highlighted, where applicable.
2. The West Midlands Regional Organised Crime Unit (ROCUWM) and individual police forces within the region: The ROCUWM and each individual force in the region are given a graded judgment.

The regional findings have added relevance to Warwickshire Police as at the time of the inspection the force’s chief constable had taken the additional responsibility to oversee the region’s response to SOC, with support from an assistant chief constable responsible for managing how it tackles SOC and counterterrorism.

The foreword of the report is useful in framing the context and findings of the inspection. The report also identifies areas for improvement and recognises where innovative practice has been accomplished. The following is my perception of the main conclusions of the report:

1.1. Regional Findings

• Most SOC demand comes from West Midlands Police in terms of high threat and high volume.
• The SOC lead for the West Midlands region should make sure regional change is managed effectively.
• The ROCUWM has a new set of strategic groups to manage SOC.
• Not all forces request ROCUWM support at the regional tasking meeting.
• There is a regional communication strategy to promote work done to tackle SOC.

Area for improvement

1. The Regional Organised Crime Unit for the West Midlands and its constituent forces should improve how they work together to tackle serious and organised crime.

The ROCUWM and its constituent forces should:

• Improve the effectiveness of the lead responsible officer (LRO) role.
• Improve the quality and consistency of 4P (Protect / Prepare / Prevent / Pursue) plans.
• Develop a regional approach to the management of 4P plans.
• Improve how serious and organised crime disruptions are recorded to accurately reflect regional performance; and
• Identify and promote promising and innovative practice.

HMICFRS has identified these themes from its inspection of the regional forces. They are explained further throughout the report.

LROs should prepare 4P plans to manage SOC threats. These plans are important and should support joint working with relevant SOC partner organisations. The operational 4P plans HMICFRS reviewed across the region were inconsistent in their content and quality.

HMICFRS found there was no formal process for ROCUWM senior investigating officers and local LROs to work with each other. This means there are differences between the activity taking place in the ROCUWM and the local management of threats. Some LROs weren’t sure what was expected of them if an organised crime group they were responsible for was also being investigated by the ROCUWM.

The ROCUWM and its constituent forces record SOC disruption activity in different ways. This makes it difficult to understand how effectively SOC is being tackled regionally. The regional rollout of the agency and partner management information system may improve the accuracy of disruption recording.

The ROCUWM has a SOC community co-ordinator. Part of their role is to improve the local response to SOC throughout the region by, for example, supporting Clear, Hold, Build initiatives in forces. At the time of the inspection, regional forces were in the early stages of implementing the Clear, Hold, Build model.

1.2. ROCUWM

The ROCUWM has been graded as ‘Adequate’ at tackling serious and organised crime: –

• It has effective structures and processes to gather and assess intelligence.
• It should make sure it collects intelligence for all types of SOC.
• The ROCUWM works with local forces to respond to emerging threats. For example, they target those responsible for the organised theft of vehicles, which has been identified as a regional problem.
• It makes effective use of its specialist capabilities.
• It focuses on tackling vulnerability.
• It is dealing with an increase in demand.
• It doesn’t consistently record organisational learning.
• It should improve how it records disruption activity.

Innovative Practice

• The ROCUWM has a team dedicated to exploiting technical intelligence.
• The ROCUWM has an undercover online team targeting potential offenders.

Area for improvement

1. The Regional Organised Crime Unit for the West Midlands should improve the quality of its 4P plans.

At the time of the inspection, the ROCUWM had generic 4P plans for its operations. HMICFRS found that supervisors weren’t routinely reviewing or updating these plans and therefore concluded that these plans weren’t driving investigative activity. The ROCUWM should make sure personnel are trained to complete and maintain 4P plans. Supervisors should regularly quality assure these plans.

2. The Regional Organised Crime Unit for the West Midlands should improve its management of serious and organised crime offenders.

The West Midlands region contains 12 prisons that house over 2,000 serious and organised crime offenders. The regional prison intelligence unit isn’t resourced well enough to manage this demand. The unit works with HM Prison Service staff to gather intelligence about corruption in prisons. They have jointly developed a system to assess offenders in prison and help with information sharing. But in one focus group, HMICFRS heard that some prisons had generated little intelligence on corruption.

At the time of the inspection, there were only two offenders on the multi-agency response to serious and organised crime (MARSOC) programme. Interviewees described referrals to MARSOC as “scant”. When HMICFRS interviewed personnel in regional forces, it found that there was a lack of awareness about MARSOC. HMICFRS reviewed disruption data from November 2021 to October 2023 and found that the ROCUWM had the lowest number of MARSOC disruptions across England and Wales.

1.3. Warwickshire Police

Warwickshire Police has been graded as ‘Requires Improvement’ at tackling serious and organised crime: –

• The force has a structure to manage its response to SOC.
• The force should improve how it gathers intelligence in some geographical areas.
• Tackling the threat from SOC may be affected by the ongoing force restructure.
• SOC analysts aren’t always supporting SOC investigations.
• The force doesn’t have enough resources or expertise to use covert tactics.
• The force works with partner agencies to protect vulnerable victims and prevent people from becoming involved in SOC.
• The force has partnership arrangements to tackle SOC – partners that were spoken with were generally supportive of the SOCJAG meetings. They recognise the importance of tackling SOC and the links to serious youth violence. At the time of the inspection, the force was preparing to introduce the Clear, Hold, Build model. Although this was in the first stages of preparation, the force had briefed its strategic and tactical partners.

HMICFRS last inspected Warwickshire Police’s response to SOC in the 2018 integrated PEEL inspection. HMICFRS graded the force’s response at that time as ‘Good’ but identified three areas for improvement: –

1. The quality of 4P plans.
2. Organisational learning and the force’s understanding of how its work affects SOC; and
3. The management of SOC offenders.

During this inspection, HMICFRS found that problems remain in all three areas.

Areas for improvement

1. Warwickshire Police should develop an up-to-date serious and organised crime local profile.

At the time of the inspection, the force didn’t have a serious and organised crime (SOC) local profile. This document should be used to help prepare a multi-agency action plan to tackle SOC.

The force does produce an intelligence document called a local profile, which is used by the SOC joint action group partnership meeting. But the local profile only considers known SOC threats and doesn’t explore place-based harm or community vulnerabilities. It doesn’t meet the requirements for an effective SOC local profile.

2. Warwickshire Police should improve the quality of its 4P plans.

During the inspection, HMICFRS reviewed some of the force’s 4P plans, they were found to be inconsistent in content and quality. Most of the plans that were reviewed contained a list of 4P actions, but the outcomes of these actions weren’t recorded. Some 4P plans focused on pursue activity and lacked actions on prevention and protection against serious and organised crime. HMICFRS found one example where a 4P plan had only recently been completed for an investigation that had been running for some time. Consultation with serious and organised crime partners on 4P plans was inconsistent and varied between individual lead responsible officers.

The force’s processes for managing SOC threats aren’t efficient. We found that, alongside 4P plans, the force was using problem-solving plans to respond to local SOC threats and record activity. In most cases, these problem-solving plans were being stored on a different IT system. This means that personnel, including some lead responsible officers, sometimes can’t access plans on both systems.

Although interviewees told HMICFRS that there is ongoing training for lead responsible officers, some said they need further training and support to write and manage their 4P plans.

3. Warwickshire Police should improve how it learns from concluded operations.

During this inspection, some interviewees said that good practice is discussed at force meetings, such as the serious and organised crime and exploitation and tasking meetings. There is also a forum for senior detectives to meet and share learning. But some interviewees couldn’t identify where organisational learning is stored or how it can be retrieved.

Disruption recording is largely the responsibility of the force’s organised crime group co-ordinator, but there is a lack of information about disruptions from others. Lead responsible officers and other personnel rarely provide updates on what they have done. Many of the personnel we interviewed didn’t know why or how disruptions should be recorded. The force should address this through training.

4. Warwickshire Police should improve how it manages serious and organised crime offenders.

During this inspection, the force said that four serious crime prevention orders were in place and another five were being applied for. Local teams proactively look for opportunities to identify appropriate orders to prevent youth offending. But some lead responsible officers don’t consult with these teams when seeking support to prevent reoffending. The force said that it is introducing a civil orders team to encourage the use of ancillary orders and to support personnel through the application process. This should lead to improvements.

2.  Comments from the Chief Constable

“I am grateful to HMICFRS for visiting the force in June 2023 and completing a thorough inspection of our capabilities in response to Serious and Organised Crime. I thank the inspection team for the report and accept the findings – it is this scrutiny which helps us not only to drive improvements but also to ensure we provide the best possible service for people across Warwickshire. The ROCU remains an important regional collaboration for Warwickshire and therefore I also acknowledge the recommendations attributed to them.

I am pleased that the report has recognised much of the excellent work already going on in Warwickshire Police and that it acknowledges our commitment to improvement. There are several areas identified where we can continue to improve as a force. We have already developed a coherent action plan to address them which we have also shared with ROCUWM ensuring there is no duplication of effort and to support the ongoing coordination and identification of areas where their responsibilities can assist forces in delivering more effectively.

Each of the four Areas for Improvement (AFI’s) for Warwickshire Police have been allocated to the Head of Protective Services (Chief Superintendent). Addressing specifically our current progress against each AFI: –

1. Warwickshire Police should develop an up-to-date serious and organised crime local profile.

Our Analysis & Performance Department has already commenced work on developing comprehensive SOC Local Profile documents, which are tailored to the individual features of each particular locality and the SOC challenges faced. These will be used to drive our intelligence collection plans and assist our tactical tasking process to best align resources.

2. Warwickshire Police should improve the quality of its 4P plans.

4Ps Plans are now embedded into all SOC operations in Warwickshire Police and are monitored and scrutinised at the monthly SOCEX meeting (SOC and Exploitation), chaired by the D/Superintendent Head of Prevention. This has been embedded for over 12-months now. Our documents are seen as good practice within the region and we will be collaborating with ROCUWM to ensure that there is a consistent approach to 4Ps plans across all forces.

3. Warwickshire Police should improve how it learns from concluded operations.

As the report highlights, our Senior Detectives Forum enables shared learning between practitioners, also supported by ROCUWM colleagues. The recently launched internal learning platform ‘What Works Warwickshire’ hosts all learning from internal and external sources, including serious crime reviews and a forthcoming dedicated section for other force debriefs. Entries are encouraged across the workforce and the submission of good practice to the College of Policing’s Practice Bank is also promoted through the site. Learning is tagged according to subject areas, enabling users to search specifically on good practice around themes. Organisational learning is an agenda item within all our strategic boards and our leads encourage the sharing of learning wherever possible, as we move ever closer to a culture of shared learning and reflection.

We are now undertaking reviews of finalised operations as a matter of standard practice and learning will be disseminated back to relevant managers by a dedicated SOC Detective Chief Inspector. A similar process will ensure that learning is also discussed within SOCEX, SOC Partnership Delivery Group, SOC Joint Action Group and Evidence-Based Policing meetings as required. Further work is ongoing to formalise the learning process through a standardised procedure, beyond submission to What Works Warwickshire – this is over seen by the Head of Prevention.

4. Warwickshire Police should improve how it manages serious and organised crime offenders.

The force now has a dedicated Civil Interventions Team within our Prevention function. The team provides expert support and advice to officers in the application and enforcement of orders such as Serious Crime Prevention Orders. Further work is ongoing with our partners in MARSOC and His Majesty’s Prisons and Probation Service SOC Team to understand opportunities to collaborate and better manage SOC offenders. Improved information sharing through our SOC Partnership Delivery Meeting has also been prioritised, identifying opportunities for collaborative working and disruption of offenders where another agency has more appropriate powers.

Proactive and robust action against high-risk suspects and offenders is driven through a tactical Management of Offenders Board, allowing resources to be focussed on those who pose the greatest threat of harm or risk against our communities. Recently, Operation Swept demonstrated our commitment to relentlessly pursuing offenders who try and evade the criminal justice system, reducing outstanding failure to attend warrants by 40%.

Scrutiny of HMICFRS recommendations and AFI’s in Warwickshire is robust. Oversight is provided at Chief Officer level in this instance through the force’s Proactive and Preventative Steering Group (chaired by an Assistant Chief Constable) and the Performance & Assurance Board (chaired by the Deputy Chief Constable). Local administration is driven by the SOC Delivery Board, chaired by the Chief Superintendent Head of Protective Services.

The Force Liaison Officer will work closely with HMICFRS to provide assurance around progress and compliance of the above AFI’s, through to final sign-off. I will of course keep the Police & Crime Commissioner up to date with our progress too.”

3.  Comments from the local policing body on the CC’s comments

3.1. Regional

In respect of the Regional findings from the inspection and the two AFI’s identified, a Regional SOC Board is responsible for progressing the operational improvements in ROCUWM activity and providing oversight of the arrangements to address the AFIs.

Together with my other Police and Crime Commissioners (PCC) colleagues in the West Midlands region, we provide strategic governance of the ROCUWM through a formal collaboration agreement (s22a of Policing Act 1996) and a quarterly Regional Governance Group (RGG), currently chaired by Staffordshire PFCC Ben Adams. This RGG will therefore be performing the holding to account function for the ROCUWM to ensure that the AFI’s are addressed. In addition, the PCC’s also fund Regional Policy Officers with responsibility for coordinating our collective responsibilities towards the ROCUWM, which will assist in this process.

3.2. Warwickshire Police

I note Chief Constable Tedds comments that she is supportive of the findings of this HMICFRS inspection and her commitment to addressing the AFIs’ identified in the report. I also welcome her ambition to further improve the force’s response to SOC, ensuring that it provides the best possible service for people across Warwickshire.

Progress will be scrutinised through the existing governance arrangements of the OPCC and Warwickshire Police. it is my expectation that all the recommendations from the inspection will be fully completed in the specified timeframe. I will continue to ‘hold to account’ the Chief Constable in affecting these changes and I look forward to seeing Warwickshire Police achieve and demonstrate the required improvements.

This response will be published on the website of the Warwickshire Office of the Police and Crime Commissioner.

Yours faithfully,

Philip Seccombe TD

Police and Crime Commissioner

2 July 2024

[1] An inspection of the West Midlands regional response to serious and organised crime – His Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (justiceinspectorates.gov.uk)