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Probation Circular
PC06/2007 – CRITICAL PUBLIC PROTECTION CASES (CPPCs)
IMPLEMENTATION DATE: 1 April 2007 EXPIRY DATE: 31 March 2008

TO: Chairs of Probation Boards, Chief Officers of Probation, Secretaries of Probation Boards CC: Board Treasurers, Regional Managers AUTHORISED BY: John Scott, Head of Public Protection and Licensed Release Unit ATTACHED: Annex A – CPPC referral form
Annex B – Additional funding application form Annex C – Langley House Trust: Services provided for purposes of ‘enhanced supervision’ Annex D – List of abbreviations Annex E – Equality Impact Assessment Form

RELEVANT PREVIOUS PROBATION CIRCULARS
This circular replaces PC19/2004, ‘Notification of Critical Public Protection Cases’ and PC20/2004, ‘National Scheme for Transfer of Public Protection Cases’

CONTACT FOR ENQUIRIES
Charles.Hayward@homeoffice.gsi.gov.uk or 020 7217 0750 Janet.Gregory@homeoffice.gsi.gov.uk or 020 7217 0637

PURPOSE
The purpose of this circular is to set out revised arrangements for critical public protection cases, replacing those set out in PC19/2004 & PC20/2004.

ACTION
Chief Officers are required to ensure this Circular is brought to the attention of MAPPA Area Strategic Management Boards, ‘duty to co-operate’ partners and to all relevant staff (including seconded probation staff, victim liaison staff and staff in Approved Premises).

SUMMARY
This circular contains: • • • • • The criteria for registering a case as a Critical Public Protection Case (CPPC); The process for Areas to refer a case to the NOMS Public Protection Unit (PPU) for consideration as a CPPC; The process by which the PPU will register a case as a CPPC; The roles and responsibilities of the Responsible Authority (RA) in managing CPPCs; Details of the assistance that Multi Agency Public Protection Panels (MAPPPs) and RAs may receive from the PPU; including two enhanced supervision beds (ESBs) at Langley House Trust The arrangements for managing ‘National’ CPPCs.

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Contents
Summary Section 1. Context Multi-agency Public Protection Arrangements (MAPPA) NOMS Public Protection Unit (PPU) Approved Premises Purposes of registration as a Critical Public Protection Case Criteria for a Critical Public Protection Case Referral and Registration Process Offenders subject to licence Offenders released without a licence Appeals against a decision not to register Section 5. Applying for additional funding to manage CPPCs Purposes of the funding Application procedures Section 6. Section 7. Roles and responsibilities following registration National Critical Public Protection Cases Purpose of National CPPCs Principles Criteria for referral for a National CPPC Referral and registration Brokering a transfer Role of the PPU Composition of a National CPPC Panel Role of the National CPPC Panel and the Responsible Authority Section 8. Section 9. Record keeping in high profile cases Langley House Trust; Enhanced Supervision Beds Criteria Process Role of the RA once a CPPC is placed in an ESB Address for correspondence ANNEXES A. CPPC referral form B. Additional funding application form C. Langley House Trust: Services provided for purposes of ‘enhanced supervision’ D. List of abbreviations E. Equality Impact Assessment Form Page 12 Pages 13 - 14 Pages 8 - 9 Pages 9 - 12 Pages 7 - 8 Page 3 Pages 3 – 4

Section 2. Section 3. Section 4.

Page 4 Pages 4 - 5 Pages 6 - 7

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Summary
This Circular clarifies the purposes and criteria for registering cases as CPPCs and sets out the process for referring a case to the PPU for registration. It defines the additional resources that may be available to assist with the management of such cases, including funding for two placements in enhanced supervision beds at Langley House Trust for mentally disordered offenders, and details the application procedures. It describes the roles and responsibilities of RAs and of the PPU following registration, including a new process to de-register CPPCs that no longer warrant registration. This Circular confirms the purpose, criteria and process for national co-ordination in the management of a very small number of violent or sexual offenders (“National CPPCs”) who present extreme resettlement challenges.

1. Context Multi-agency Public Protection Arrangements (MAPPA) The Criminal Justice Act 2003, Sections 325 – 327, requires the Police, Probation and Prison Service to work collectively as the Responsible Authority (RA) in each area of England and Wales to oversee and develop the arrangements for the assessment and management of violent and sexual offenders. The RA is required to establish a Strategic Management Board (SMB) in each Area. The role of the SMB is to ensure that ‘MAPPA’ is effectively delivered and managed in its Area. Once a case has been assigned to an Area, the RA has a duty to ensure that it manages that case under MAPPA. Area MAPP Panels (MAPPPs) are responsible for co-ordinating the management of the level 3 cases. These are offenders, as defined in the Multi-Agency Public Protection Arrangements Guidance (PC54/2004) who: • Are assessed using OASys (or other relevant, appropriate tools) as being a high or very high risk of causing serious harm; and, • Present risks that can be managed only by a plan which requires close co-operation at a senior level (MAPPP) due to the complexity of the case and/or because of the unusual resource commitment required; or, • Attract exceptional media scrutiny and/or public interest in the management of the case. This may be true even if the offender is not necessarily assessed as high or very high risk, and there is a need to manage significantly complex risks to the public, staff, victims and offender from public exposure.

NOMS Public Protection Unit (PPU) One of the core functions of the PPU is to provide central support to local MAPPA through: • Supporting RAs and SMBs to ensure there is robust and consistent management of those cases which present the highest risk of serious harm to the public and staff and are the most difficult to manage; • Reporting to Ministers, the Chief Executive of the National Offender Management Service and the relevant Regional Offender Manager (ROM) on the management of individual MAPPA cases that are assessed as the very highest risk, and/or are notorious with a significant national, or particularly sensitive profile, so that they can be reassured that such cases are being managed effectively in order to protect the public; • Developing expertise centrally with a view to providing advice, support and assistance to RAs and SMBs and all staff working with high risk offenders;

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UNCLASSIFIED • • Developing policy and operational guidance; and Facilitating national coordination, through a National CPPC Panel, of arrangements for resettlement in those very few cases where this is necessary, and ensuring equity between areas.

Approved Premises Approved Premises are central to the management of offenders who pose the most serious risk of harm to the public. PC 37/2005 affirms this function as the core purpose of Approved Premises, and admissions criteria and referral processes should reflect this focus on public protection. In cases where an Area decides that there is good reason why an offender should not be accommodated in an Approved Premises in that Area, it should work with other Areas within the same region to place the offender in an Approved Premises in that region. The Approved Premises estate is a national resource, and Areas and Voluntary Management Committees should recognise that they will need to receive as well as transfer offenders under the National CPPC scheme. 2. Purposes of Registration as a Critical Public Protection Case The purposes of registration as a CPPC are: • To ensure that the PPU is able to inform Ministers, the Chief Executive of the National Offender Management Service and ROMS about the management arrangements for those cases which present the highest risk of serious harm and/or have a significant national or particularly sensitive profile; • To enable the RA to apply to the PPU for additional funding, in cases that are so difficult to manage that they may require extra resources in the form of: o Temporary additional staff cover in Approved Premises o Escort duties o Improvements to security hardware at Approved Premises o An Enhanced Supervision Bed (ESB) at Langley House Trust for an offender with a serious mental disorder o Specific interventions that will contribute to public protection; • To facilitate the co-ordination of arrangements for national CPPCs. 3. Criteria for a Critical Public Protection Case Cases should be referred to the PPU only where the following criteria are met: • The case is being managed at MAPPA level 3; and • In almost all cases, the offender is assessed as presenting a very high risk of serious harm. There is an imminent risk of serious harm (on release from prison). The potential event is more likely than not to happen imminently and the impact would be serious; and/or • Because the case attracts or is likely to attract significant national media interest. While most referrals will be offenders released from prison, others may include: • A known very high risk or high profile offender returning from overseas (whether immediately following their release from custody or not); • An offender who has been managed as medium or even low risk in the community, but becomes high or very high risk as the result of a significant change of circumstances; • An offender on discharge from detention under a hospital order.

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UNCLASSIFIED The PPU CPPC Team is always willing to discuss cases if there is uncertainty about whether or not to refer a case for registration as a CPPC. As a guide, distinction should be made between: • MAPPA level 3 cases These are the very small percentage of cases that satisfy MAPPA level 3 criteria as defined in the MAPPA Guidance and require inter-agency senior management co-ordination and/or additional resources to support the risk management plan. SMBs must be organised to manage the majority of their MAPPA level 3 cases without the additional support of the PPU. CPPCs A small minority of MAPPA level 3 cases will need to be registered as CPPCs where there is demonstrable evidence that: (i) The offender has caused serious harm through violent and/or sexual offending, which has resulted in death or is life-threatening and/or traumatic, and from which recovery, whether physical or psychological, can be expected to be difficult or impossible; and (ii) Serious harm is likely to occur as soon as an opportunity and/or victim is present; the potential event is more likely than not to happen imminently and the impact would be serious; and/or (iii) The case is attracting or is likely to attract significant national media interest. There must be demonstrable evidence of sustained national media interest and the likelihood that this will continue. • National CPPCs A very small subset of registered CPPCs will require some kind of national co-ordination, sponsored by the PPU. These are exceptional cases where the resettlement represents a very high risk both to individuals (public, victims, staff or offender) and there is organisational risk due to exceptional public interest and scrutiny. This subset also includes cases that are categorised as very high risk offenders being returned from abroad who have no particular connections with any specific area within England and Wales, and there is a clear need for a robust risk management plan to enhance public safety. Section 7 below provides further information on National CPPCs.

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UNCLASSIFIED 4. Referral and Registration Process The following process applies to every case referred and registered with the PPU and should be commenced at least 3 months before release. It is essential that referrals to the PPU CPPC Team are made within the specified timeframe. Failure to do so could result in inadequate planning for the management of the case and in late notification to the Minister, Chief Executive of NOMS and ROMs. It is accepted that, due to unavoidable circumstances, there are likely to be some late referrals. In cases where the referral is made less than three months prior to release, the referrer should always indicate the reason for the late referral, so that this can be monitored by the PPU. Offenders subject to licence • • At the point of inclusion at MAPPA level 3 and at all subsequent MAPPP reviews, the panel must consider whether a referral to PPU is required. When the decision to refer has been made, the Offender Manager must complete the ‘Critical Public Protection Case Referral Form’ (Annex A). The referral form should be downloaded from EPIC. A Senior Probation Manager who knows the circumstances of the case, normally the Assistant Chief Officer (ACO) with responsibility for Public Protection, must endorse the referral form. If additional funding is sought, the ACO must complete the ‘Additional Funding Application Form’ (Annex B) in full. The application form should be downloaded from EPIC. The form(s) must be e-mailed to casework.publicprotection@homeoffice.gsi.gov.uk. At the same time, the supporting documentation (as indicated in Annex A, Section 8) must be sent by post, addressed to the Head of the CPPC team. The date of referral will be the date by which all the required documentation has been received. At that point the PPU CPPC Team will acknowledge receipt of the referral. The PPU CPPC Team will assess whether the case meets the criteria for registration, and will write to confirm whether or not the case has been registered as a CPPC. The CPPC team aims to respond within fifteen working days. If the case is registered, the CPPC team will also advise whether any additional resources applied for have been agreed.

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Offenders released without a licence • If the offender is to be released from custody without supervision, but meets the criteria for a CPPC, the prison based probation officer should, with the agreement of the prison’s Head of Public Protection (or equivalent), refer the case to the MAPPA co-ordinator in the Area to which the offender is to be released. If the decision is taken to manage the case at MAPPA level 3, an offender manager should be appointed to manage the case. The offender manager should complete the CPPC referral form (annex A) and, if appropriate, the additional funding application form (annex B). Prison staff will assist by collating risk management information and any other information that is required. The MAPPP will need to decide whether and how they can sustain an active risk management plan. Consideration should be given to accommodating these offenders for a period in Approved Premises where it is decided that this intervention will facilitate resettlement and enhance public protection. This is under the authority of The Criminal Justice and Court Services Act 2000 (Approved Premises) Regulations 2001.

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Appeals against a decision not to register Where the RA does not agree with the PPU CPPC Team’s decision not to register a case, the MAPPP chair, in consultation with the ACO, Public Protection, should write to the PPU CPPC Team, clearly outlining the reasons why further consideration should be given to registering the case as a CPPC. The CPPC Team will respond in writing. Where there is continued disagreement about the decision not to register a case, the final decision will be made by the Deputy Head of the PPU with responsibility for CPPCs. 5. Applying for additional funding to manage CPPCs The PPU CPPC Team has some limited additional funds available for Probation Areas to strengthen risk management arrangements for CPPCs. There is only a small national budget and normal agency resources should be considered in the first instance alongside contributions from strategic partners. Purposes of funding Applications for additional funding will be considered for the following purposes: (i) Temporary additional staff cover in an Approved Premises over and above the required establishment. There must be demonstrable evidence through previous behaviour that there is a physical and/or sexual risk of harm to staff and/or other hostel residents. Areas should note that the PPU will not pay for additional staff simply to bring the Approved Premises into line with the nationally required establishment of double waking night cover. (ii) Escort duties where the MAPPP has decided that this is required for the safe management of the CPPC whilst out of the Approved Premises. In such cases the normal expectation is that the offender gives written consent to being escorted. (iii) Upgrading monitoring equipment within Approved Premises in order to bring them to the required minimum standards. This may include upgrades to security hardware at Approved Premises, for example CCTV, external alarms, dual door systems. (iv) An ‘Enhanced Supervision Bed’ (ESB) provided by Langley House Trust (LHT) for an initial period of up to six months following release from custody or psychiatric unit. Under new arrangements this PPU funding will be limited to two ESBs at a LHT hostel in the North West of England and is restricted to offenders with a serious mental disorder and extensive previous involvement with psychiatric or psychological services. (v) Certain specific interventions where it can be demonstrated that these will help to protect the public, and where the provision cannot be funded through any other source. Funding may be available, for example, as a contribution to the cost of placement with other providers or for specialist risk assessments.

Application Procedures • The ACO must complete the additional funding application form (annex B), in consultation with the AP manager as appropriate. Wherever possible, this should be completed at the same time as the CPPC referral form, no later than three months

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UNCLASSIFIED prior to release. It is, however, recognised that it may not always be possible to give full details of the funding required at that point, in which case this should not delay submission of the CPPC referral form. The application must clearly detail the tasks and duties that the additional staff will be expected to undertake, the proposed times of the day, and the reasons why these cannot be undertaken by the current staff establishment. The application must also include the period for which funding is required and the estimated cost. The PPU CPPC Team will inform the Probation Area in writing whether funding has been agreed. In all agreed cases, PPU will normally fund for a period up to a maximum of 3 months, subject to monthly review. Areas should note that if the assessed risk lessens the PPU CPPC Team will not continue to provide funding and the money cannot be used for alternative purposes. All monies agreed will be paid to the Probation Area’s Finance Department through the monthly NOMS grant. This is subject to receipt of written confirmation from the Area of the actual costs incurred due to be reimbursed by PPU CPPC Team.

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6. Roles and responsibilities following registration The RA is responsible for ensuring, in respect of all CPPCs, that the offender manager: • Sends to the PPU CPPC team a copy of the licence within two working days of release, and an up-to-date OASys risk of harm assessment and risk management plan within 5 working days of release; • Notifies the CPPC team immediately if the offender is recalled to prison; • Sends a copy of all MAPPP minutes to the CPPC team as soon as they are available, so that the CPPC team is kept up to date with developments and made aware of any changes to the assessed risk level; • Advises the CPPC team of all changes that mean that the case no longer meets the criteria for registration, so that the CPPC team can consider de-registering the case. It is important that victim contact arrangements continue to operate in the normal manner in respect of CPPCs. RAs must ensure that victim liaison officers are consulted as appropriate and kept fully informed of developments relating to the offender. This includes notification of transfer of supervision to a different probation area and any changes of offender manager. Taking into account the level of risk, CPPCs should be managed by an offender manager who is a qualified and experienced probation officer. In the event of a decision to recall, CPPCs should normally be dealt with under ‘emergency recall’ arrangements. The PPU CPPC Team will: • Notify Ministers. It is right that Ministers should be assured that systems are in place for protecting the public from offenders who are released into the community, particularly those who are assessed as high and very high risk of serious harm. The PPU is responsible for providing Ministers, the Chief Executive of NOMS and ROMS with timely information and reassurance about the release and risk management plans of the highest risk of serious harm and most notorious offenders; • Consider all applications for additional funding which are submitted at the time of registration. The CPPC Team will also consider applications which, for good reason, are submitted subsequent to a case being registered; • Notify the Home Office Mental Health Unit (MHU) of cases where there are significant mental health concerns. The MHU is able to provide practical assistance only in certain circumstances. This includes recall to hospital in ‘restricted’ cases, and challenging

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UNCLASSIFIED discharge into the community in certain other cases. In addition the MHU may be able to help find a bed where there is medical opinion that a prisoner should be transferred to hospital. The PPU’s role in relation to MHU does not replace the MAPPP’s responsibility to liaise with the prison in such cases; Keep under review all CPPC cases and associated funding agreements; De-register CPPCs once they cease to be managed at MAPPP level 3. CPPCs may also be de-registered where the risk of serious harm to the public is no longer considered to be imminent. It is accepted that in such cases risk is dynamic and cases can and should be re-referred if it is considered that this is warranted. Cases which have been registered because of potential or actual national media interest may be deregistered when the level of media scrutiny subsides.

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7. National Critical Public Protection Cases There are a very small number of CPPCs who are particularly difficult to re-settle and whose successful management requires national co-ordination. This will be provided by the PPU, which will chair a panel of all interested parties until another Area has been identified to assume responsibility for management of the case. The National CPPC arrangements are reserved for genuinely exceptional cases where local and regional arrangements to agree a resettlement plan have been explored and exhausted in the first instance. Purpose of National CPPCs The purpose of designating some cases as “National” CPPCs is to co-ordinate the re-settlement of offenders who cannot be safely located in their home area or within the region. Thus the PPU will broker arrangements that assist and support Areas in managing the transfer of such offenders, the risks they pose to the community, or the serious risks posed to them by their return to the community. The role of the panel chaired by PPU is not to assume control of the management of a case. Rather, it is to advise and support the transfer of cases out of an Area. Responsibility for decisions concerning the supervision of offenders will ultimately rest with the receiving RA and the local MAPPP and will require adherence to policy, procedures and national standards. It is a requirement that an operational senior manager is clearly identified to oversee the case. Principles • • • Offenders come from, and return to, communities and should be managed at the lowest appropriate level within the MAPPA, consistent with defensible management. The Probation, Police and Prison Services, as the RA, are responsible for the management of offenders who live in, or return to, their Areas. Every attempt should be made to facilitate this return (unless victim protection concerns preclude such a return). There is an expectation on the part of Ministers and the general public that in managing the risks posed by dangerous offenders NOMS will act as a genuinely national service. The National Panel will require all MAPPA strategic management boards to recognise their own responsibility in receiving, as well as transferring, such offenders and to cooperate fully with requests made by the panel. The Panel will ensure that the distribution of such offenders around the country is as equitable as possible, subject to the need to manage the risks posed by the offender effectively. Probation Areas should have in place regional arrangements to accommodate and deliver services to high risk offenders who, in the interests of victims concerns, public protection or in exceptionally rare cases the protection of the offender, cannot return to their area of origin. These regional arrangements play a key part in the management of high-risk offenders. Only where the activation of the regional scheme is insufficient, and

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UNCLASSIFIED the criteria outlined below are met, will the National Scheme facilitate placement elsewhere. Criteria for referral for a National CPPC The case has been registered as a CPPC and the offender must present risks that cannot be managed by the local RA and MAPPP alone, or through the regional re-settlement arrangements, and needs to be re-settled in another Area due to: • A high media profile or public interest which could result in public disorder, undermine public confidence in the criminal justice system or agencies managing the case or hinder the successful implementation of the risk management plan and might threaten the life of the offender; or • Very significant issues relating to the offender’s victim(s) that cannot be managed within the offender's home area; or • The need for exceptional resources outside those offered for other CPPCs; or • The need to manage problems associated with dangerous offenders returning from abroad, in conjunction with the police who will be the lead statutory agency unless there is a current licence condition, or from another jurisdiction. Referral and Registration • • • Referrals for a National CPPC should to be made using the CPPC referral form (annex A). the PPU CPPC Team will make initial enquiries with the senior managers within the referring Area, including the MAPPA Coordinator, in order to determine whether the case meets the criteria for transfer/re-settlement through a National CPPC panel; After consideration, the PPU CPPC Team will write to confirm whether the case has been registered as a CPPC and whether it meets the criteria for a National CPPC.

Brokering a Transfer • A specially-convened panel, chaired by the PPU, will seek to broker an agreement with all interested parties as to the permanent resettlement of the offender concerned; • The PPU will consider which RAs may have the capacity to manage the offender and identify those RAs to be involved; • In each case the Head of Public Protection Unit, or his/her delegate, will consult with the Chief Probation Officer and, as necessary, the Chief Constable from the RAs under consideration and agree their engagement in the scheme; • The PPU will seek to identify a ‘contingency Area’, which could accommodate the National CPPC if arrangements in the preferred Area were to break down; • Approved Premises Estate will be considered within any resettlement strategy; additional funding from the PPU to Approved Premises will be considered or a Langley House Trust Enhanced Supervision Bed, if appropriate; • The availability of supports e.g. “Circles of Support and Accountability”, local expertise, or treatment facilities will all help to inform re-settlement decisions; • Central support in brokering the arrangements and putting into place contingency plans will be provided by the PPU, who will ensure the equity of the plan. Responsibility for a case remains with the referring RA until its transfer has been brokered by the PPU and formally accepted by the receiving Area. Responsibility for the case is then transferred to, and rests with, the receiving area. Acceptance of referral to the Scheme does not diminish the responsibility of the Area making the referral until the transfer has been completed. All Areas are expected to participate according to their needs and capacity.

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UNCLASSIFIED Role of the PPU The Head of PPU, supported by PPU staff is responsible for: • Organising and servicing the National CPPC Panel; • Notifying Ministers, the Chief Executive of NOMS, and ROMs, so that they are made aware of relevant details concerning those cases that present a particular risk/threat or have a national or particularly sensitive profile. This will ensure that Ministers can be confident that RAs are rigorous in the performance of their responsibilities under the CJ Act 2003; • Helping to draw up a Home Office media strategy where appropriate. The PPU will be responsible for liaison with the Home Office Press Office; • Liaising at a senior level with other government departments and relevant agencies.

Composition of a National CPPC Panel The panel will consist of: PPU Transferring Area Receiving Area Contingency Area

Head of the PPU or their Senior Operational Manager (normally ACO) delegate Head of the CPPC Team or their representative Senior Police Officer Offender Manager Victim Liaison Officer (from the Area responsible for victim contact) Senior representatives of relevant agencies as appropriate e.g. Prison Service

Senior Operational Manager (normally ACO Senior Police Officer Senior Probation Officer Approved Premises Manager (where applicable) Senior representatives of relevant agencies as appropriate

Senior Operational Manager (normally ACO) Senior Police Officer Senior representatives of relevant agencies as appropriate

Role of the National CPPC Panel and the Responsible Authority • • • • • The National CPPC Panel will aim to agree the timescale for completing the transfer of cases from one Area to another; Where such transfer will require exceptional expenses, the Area may make representation to the PPU for funding assistance; Following the first National CPPC Panel in a given case, the PPU CPPC Team will retain oversight of the case to ensure liaison between the PPU CPPC Team and the RAs/Agencies involved; The National CPPC Panel will, at the earliest opportunity, identify when management of the offender no longer requires national input and can solely be dealt with through Area MAPPA; At this point, any further engagement by the PPU Casework Team will be advisory and the case reverts to being a normal CPPC;

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UNCLASSIFIED • • The effective implementation of the risk management plan will rest with the receiving RA and be discharged through the Area MAPPP; The RA must ensure that the victim liaison officer is consulted as appropriate and kept informed of developments relating to the offender.

8. Record keeping in high profile cases Areas are expected to adhere to national standards, policy and practice guidance on record keeping. However, it is acknowledged that the management of high profile cases can present significant issues for the safeguarding of sensitive information. In a small number of Critical Public Protection Cases the exposure of arrangements for managing offenders would compromise operational effectiveness and might result in threats to offender managers and threats to the life of the offender. In such cases, it may not be suitable to include details on the legacy system and eventually on C-NOMIS. This information would be deemed higher than ‘Restricted’ and must be maintained in a paper based process, by probation areas and the PPU CPPC Team. Other Critical Public Protection Cases will continue on the same business process currently adopted for handling this type of information on IT legacy systems, as they are currently supported by GSI accreditation. The position on record keeping will change as the information systems (C-NOMIS and ViSOR) develop. Further guidance on record keeping in high profile cases will be issued in due course. In the meantime the PPU will be able to provide advice where required.

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UNCLASSIFIED 9. Langley House Trust (LHT) Enhanced Supervision Beds (ESBs) Under new funding arrangements introduced with effect from 1st April 2007, the PPU funds two bed spaces at an LHT hostel for male offenders in the North West of England, for a period of up to six months. Use of these ESBs is restricted to offenders who have a severe mental disorder. This LHT hostel is a registered care home for mentally disordered offenders. The aim of the placement is to stabilise certain dangerous offenders and prepare them for a move on to Approved Premises. The services provided by LHT for purposes of enhanced supervision are set out in annex C. PPU ESB funding is not intended to replace funding from the relevant Primary Care Trust (PCT) in appropriate cases. MAPPPs should seek PCT funding in the first instance, and only if this is unsuccessful should application be made to the PPU. The process below relates to male offenders. Equivalent provision for women offenders will be made on a case by case basis through the female Approved Premises estate. Application should be made to the Head of the CPPC team.

Criteria • The case has been registered as a CPPC; and • There is demonstrable evidence that the offender cannot initially be managed with Approved Premises supervision as he is likely to cause serious harm as soon as any reasonable controls or limits on his behaviour are lifted or breakdown; and • There is demonstrable evidence that the offender requires highly intensive levels of supervision and surveillance on release from prison in order to ensure that he may be subsequently moved to and supervised in an Approved Premises; and • There are significant mental health issues; the offender has a serious mental disorder and extensive previous involvement with psychiatric or psychological services. Process •

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The offender manager must complete the CPPC referral form (annex A) and section 3 of the additional funding application form (annex B) relating to LHT ESB, at least 3 months prior to release, clearly outlining the reasons why the ESB is being sought. Evidence will be required of the offender’s serious mental disorder. The form must be endorsed by a senior manager, normally an Assistant Chief Officer who knows the circumstances of the case. In all cases, proposed arrangements for move on accommodation must be confirmed at the time of referral. This should be in the ‘home’ Area, or elsewhere if there are victim issues or media/community issues and must be managed and arranged by the ‘home’ offender manager. PPU CPPC Team will inform the offender manager and LHT in writing whether funding has been agreed. Once notified that funding has been agreed, the offender manager must copy all information sent to the PPU, including the OASys risk of harm assessment and psychiatric/psychological reports, directly to LHT Director of Offender Management at the address below. The LHT Operations Director will consider the referral and the availability of an ESB, and arrange to visit the offender in prison/hospital. LHT will send a letter to the offender manager notifying the outcome of the assessment (with a copy to the MAPPA co-ordinator in the receiving Area).

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UNCLASSIFIED • • The ACO in the ‘home’ Area must then write to the relevant senior operational manager in the receiving Area to request transfer of the case. A MAPPP will be held to devise a risk management plan, including contingency arrangements in the event of deterioration of the offender’s mental health. The ‘home’ offender manager or, in their absence, the ‘home’ Senior Probation Officer must attend this MAPPP. The receiving Probation Area will assume full responsibility for the management of the case, once transfer has been agreed, except that: The ‘home’ Area will remain responsible for arranging move-on accommodation after the placement ends, whether this is in the ‘home’ Area or elsewhere if there are victim or media issues. At the end of the placement the case will be transferred back to the ‘home’ area (or to a new Area).

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Role of the RA once a CPPC is placed in an ESB • In addition to the responsibilities that pertain to all CPPCs (see Section 6 above), the offender manager in the receiving Area should attend all MAPPP meetings. • The offender manager must ensure that the ‘home’ probation area is kept regularly informed of progress and developments in the case, in preparation for transfer back to the ‘home’ Area or to a new Area when the ESB placement ends. • In the event of a placement coming to an end earlier than expected, it is essential that the Head of the CPPC Team is notified at the earliest possible opportunity, so that the ESB vacancy may be filled by another case.

Address for correspondence Langley House Trust Northern Office PO Box 389 Barnsley S70 2WY Tel no: 01226 203566 Fax no: 01226 203568

PC06/2007 Critical Public Protection Cases (CPPCs)

UNCLASSIFIED

ISSUE DATE – 29 March 2007 14 of 14

RESTRICTED
Annex A

CRITICAL PUBLIC PROTECTION CASE REFERRAL FORM
This form should be used to refer an offender to the Public Protection Unit (PPU) for registration as a Critical Public Protection Case (CPPC). Please refer to PC 06/2007 before completing the form. Please indicate the purpose of this referral by crossing the relevant boxes below: Register the offender as a CPPC Apply for additional funding in Approved Premises
(See PC 06/2007, section 5)

Apply for an Enhanced Supervision Bed (ESB)
(For offenders with serious mental disorder, see PC 06/2007, section 9)

Apply for funding for other specific intervention(s)
(See PC 06/2007, section 5)

Register Offender as a National CPPC
(In exceptional cases only, see PC 06/2007, section 7)

Please indicate whether the offender meets the criteria below:
Note: To be considered for registration as a CPPC, the offender must meet criteria A and one or both of criteria B and C. If in doubt, please telephone the CPPC team before submitting any forms.

Criteria A) The offender is being or is to be managed at MAPPA Level 3 and B) The offender presents an imminent risk of serious harm: the potential event is more likely than not to happen and the impact would be serious and/or The case is attracting or is likely to attract significant national media interest or public interest

Yes/No

C)

Name of Offender: Name of referring Offender Manager: Name of Endorsing ACO: Probation Area:
PC 06/2007. Annex A

i

RESTRICTED 1. Offender Details
Name: Alias:

Date of Birth:

Ethnic Origin:

select from list

Gender:

Any known Disability: Prison/ Mental Health Number: Type of Location: Select from list

P.N.C. Number:

Current Location: Proposed Release Address: Date of Release:

Date Application Submitted:

If the application is submitted less than 3 months before the expected date of release, please give the reason:

2. Area Details
Probation Area: Referred by: Office address: Grade: Tel No: Email address Senior Probation Officer: Telephone No: Email Address: ACO: Telephone No: Email address

PC 06/2007. Annex A

ii

RESTRICTED

3. Offence(s) Details
Index offence(s): Details of Index offence Previous conviction(s): Date of offence:
(dd/mm/yy)

4. Reason(s) for referral
Please provide information that fully explains why you are referring this case:

5. Sentencing and Licence details (relating to index offence)
Sentencing Court: Length of sentence/order: Date of sentence: Type of licence: Select from list

Licence from: Extended Licence Yes

to No Date:

Has the offender been previously recalled?

Yes

No

If yes, please provide details of the dates and circumstances of the recall.

PC 06/2007. Annex A

iii

RESTRICTED 6. Risk Management
Latest OAsys risk assessment (please cross relevant boxes): Children Very High High Medium Low Public Known Adults Staff

Yes
Additional licence conditions proposed
(Describe briefly)

No

N/A

If the offender is not subject to a licence, what risk management plan is proposed (surveillance, voluntary contact, Sex Offender Order etc)?
(Describe briefly here)

Is the offender subject to Sex Offenders Order (SOO)?
(Please give dates)

Is the offender subject to Sex Offence Prevention Order (SOPO)?1
(Please give dates)

Is the offender required to register under the Sex Offenders Act 1997?

Does the offender have significant mental health issues?

7. Victim details
Has the Victim been contacted?
a) If yes, what was the outcome: b) If no or N/A, why has there been no contact?

Have the victim’s concerns/views informed the release/risk management plan?
(If yes, please indicate how)

Name of Victim Liaison Officer (if known):

Telephone Number:

1

SOPOs effective from 1st May 2004. SOPOs replace SOOs as detailed in the Criminal Justice Act 2003) PC 06/2007. Annex A iv

RESTRICTED
8. This referral document must be supported by the following documentation: Item 1. 2. 3. 4. 5. 6.
Pre Sentence Report Previous Convictions Parole Assessment Report A copy of the OASys risk assessment and risk management plan (sections R1 - R11) Psychiatric and other medical reports (if applicable) Copies of the 2 most recent MAPPP meeting minutes

Submitted

The CPPC team will be unable to process this referral until the required documents have been received. If you are unable to include any of the above documents, please indicate why:

8. Referral Endorsement:
This form must be endorsed by an Assistant Chief Officer or manager of equivalent grade who knows the circumstances of the case.

Endorsement I endorse this referral to the CPPC team at NOMS PPU:
If you are not the person named in section 2, please complete your details here

Name: Title: Grade: Tel No.:

Once endorsed, please email this form to casework.publicprotection@homeoffice.gsi.gov.uk and copy to the offender manager who completed the form. The offender manager should then send the additional documents required (see section 8 above) by post to the address below. The documents must be sent double enveloped both addressed to the ‘Head of the CPPC Team’. The outer envelope must show no protective markings. The inner envelope must be marked ‘Confidential’. Head of the CPPC Team, PPU, G22, Abell House, John Islip Street, London SW1P 4LH If you have any queries in relation to this application please telephone the CPPC team 020 7217 0637.

PC 06/2007. Annex A

v

RESTRICTED Annex B

CRITICAL PUBLIC PROTECTION CASE (CPPC) ADDITIONAL FUNDING APPLICATION Please read PC 06/2007 prior to completing This form should be used in conjunction with the CPPC referral form (Annex A) 1. Offender Details Name: Date of Birth: Alias:

2. Application for additional funding in Approved Premises This part of the form should only be completed if you are applying for additional temporary funding in Approved Premises. It should be completed by the ACO (or delegated manager) in consultation with the relevant Approved Premises manager. 2.1. 2.2. What additional funding are you applying for? Select from list. Please explain why this case requires additional funding.

2.3.

Please give details of how this funding will be used in order to manage the risk of the offender. For example, give details of the extra duties to be performed by additional staff.

2.4.

Please provide a detailed breakdown of the funds requested below: • Where funding is for additional staff, please provide details of: o hours to be worked: o hourly rate: • • Addition funding requested from Total amount requested: to
(give dates)

PC 06/2007. Annex B

i

RESTRICTED 3. Application for an Enhanced Supervision Bed (ESB) This part of the form should only be completed if you are applying for an ESB at Langley House Trust. 3.1. Please provide any further information to support your application for an ESB, in addition to section 4 of the referral form. This should include evidence of the offender’s serious mental disorder (e.g. from psychiatric assessments), and the reasons why this offender cannot initially be accommodated in Approved Premises?

3.2.

Please outline briefly what steps have been taken to secure funding from the relevant Primary Care Trust (PCT)

4. Application for funding for other specific interventions This part of the form should only be completed if you are applying for funding other than for Approved Premises or an ESB. It should be completed by the ACO (or delegated manager). 4.1. What intervention are you applying for?

4.2.

Please explain how this intervention will strengthen the risk management plan and contribute to public protection:

4.3.

Total Amount requested:

5. Your details Name: Tel No: Signature:…………………………………… Date:…………………………………. Job title:

PC 06/2007. Annex B

ii

Annex C

Services provided by LHT for purposes of Enhanced Supervision These measures are in addition to the standard Langley House Trust measures for public protection e.g. case recording, monitoring of movements, no internet access 1. Involvement in Multi-Agency Public Protection Meetings 2. Access to psychiatric and psychological services 3. Intensive liaison locally with NOMS and the Police together with other relevant agencies including the development, implementation and monitoring of protocols 4. Co-operation with police intelligence requirements e.g. fabric samples, recording of contacts 5. Monitoring and report of movements and behaviour 6. Support of breach and recall procedures 7. Double cover at all times, including waking night cover 8. Management back-up at all times providing rapid response to difficulties 9. The following measures may be applied to individuals as agreed in MAPPP’s or with NOMS: • 1-to-1 supervision during all periods when resident is not in an alarmed area; • escorted outings with one or two staff; • observations – as frequent as every 15 minutes – this may be visual, video or checking of alarms; • electronic monitoring arrangements; • alarmed doors and windows on individual rooms; • scrutiny of mail; • monitoring of telephone calls 10. Physical security measures, which include: • alarmed doors and windows in bedrooms; • restrictors on all ground floor windows • CCTV – internal and external; • single, central entry point (monitored) and a signing in/out register. Further physical security measures may be added by agreement. 11. Staff self-security systems including walkie-talkie and personal attack alarms.

March 2007

PC 06/2007. Annex C

i

Annex D

List of Abbreviations
ACO CCTV CPPC C-NOMIS ESB LHT MAPPA MAPPP MHU NOMS OASys PCT PPU RA ROM SMB Assistant Chief Officer Closed Circuit Television Critical Public Protection Case C-National Offender Management Information System Enhanced Supervision Bed Langley House Trust Multi Agency Public Protection Arrangements Multi Agency Public Protection Panel (Home Office) Mental Health Unit National Offender Management Service Offender Assessment System Primary Care Trust Public Protection Unit Responsible Authority Regional Offender Manager Strategic Management Board

PC 06/2007. Annex D

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NPS Race Equality Impact Assessment template
Annex E

A. INITIAL SCREENING 1. Title of function, policy or practice (including common practice) Is this a new policy under development or an existing one? Critical Public Protection Cases, (CPPCs), including arrangements for ‘National’ CPPCs and the provision of ‘Enhanced Supervision Beds’ (ESBs) by Langley House Trust (LHT). This is not a new policy. The PC clarifies and in some cases revises existing arrangements

2. Aims, purpose and outcomes of function, policy or practice What is the function, policy or practice addressing? What operational work or employment/HR activities are covered? What outcomes are expected? The PC covers the arrangements for referral, registration, ministerial notification administration and additional funding in respect of CPPC. The aims and purpose of CPPC registration are to: - ensure that Ministers are notified of all CPPCs and reassured that there are robust arrangements in place in Areas (under Area MAPPA) to manage the risks to the public; - direct additional (PPU) funding, in appropriate cases, towards strengthening risk management plans. This includes funding for two enhanced supervision beds at Langley House Trust; - provide for the ‘national’ co-ordination of arrangements in very exceptional cases. The intended outcome is better public protection.

3. Target groups Who is the policy aimed at? Which specific groups are likely to be affected by its implementation? This could be staff, service users, partners, contractors.

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NPS Race Equality Impact Assessment template

The arrangements are aimed specifically at that small number of offenders who meet the CPPC registration criteria. By definition these are MAPPA level 3 cases only. The other pre-requisite criteria relate to high/very high risk of harm and /or public profile. Referral is determined by the MAPPP, and registration by the PPU CPPC team. For each equality target group, think about possible positive or negative impact, benefits or disadvantages, and if negative impact is this at a high medium or low level. Give reasons for your assessment. This could be existing knowledge or monitoring, national research, through talking to the groups concerned, etc. If there is possible negative impact a full impact assessment is needed. The high, medium or low impact will indicate level of priority to give the full assessment. Please use the table below to do this. Equality target group Women Positive impact – could benefit
It is acknowledged that LHT provides ESBs for male offenders only. If ESB type provision is required for women offenders, this will be arranged within the female Approved Premises estate

Negative impact Reason for assessment - could and explanation of disadvantage possible impact
Referral is triggered by the MAPPP. Assuming that the MAPPA are bias free, the CPPC arrangements them selves will not be a source of disadvantage The benefits are for • all potential victims (particularly women and children); also • NOMS staff especially in Approved Premises • offenders, insofar as additional funding is made available to support compliance with licences.

Yes.

Men Asian/Asian British people Black/Black British people Chinese people or other groups People of mixed race

Yes Yes Yes Yes Yes

As above As above As above As above As above

As above As above As above As above As above

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NPS Race Equality Impact Assessment template

White people (including Irish people) Travellers or Gypsies Disabled people Lesbians, gay men and bisexual people Transgender people Older people over 60 Young people (1725) and children Faith groups

Yes

As above

As above

Yes Yes Yes

As above As above As above

As above As above As above

Yes Yes Yes

As above As above As above

As above As above As above

Yes

As above

As above

4.

Further research/questions to answer

As a result of the above, indicate what questions might need to be answered in the full impact assessment and what additional research or evidence might be needed to do this. When a review is conducted of the CPPC process, during 2007/8, attention will be given to ensuring that the registration process is applied equitably.

Initial screening done by: Charles Hayward Name/position. Head of CPPC Team, PPU Date: 29th March 2007

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NPS Race Equality Impact Assessment template

B. PLANNING A FULL IMPACT ASSESSMENT 1. Title of function, policy or practice (including common practice) Is this a new policy under development or an existing one?

2. Aims, purpose and outcomes of function, policy or practice What is the function, policy or practice addressing? What operational work or employment/HR activities are covered? What outcomes are expected?

3. Target groups Who is the policy aimed at? Which specific groups are likely to be affected by its implementation? Use the initial screening to summarise potential adverse impact on each group as identified above and the reasons given. What knowledge and information do you already have, what further research or evidence should be collected in the full impact assessment? □ □ □ □ □ □ Gender Race Disability Sexual orientation/transgender Age Faith

4. Impact assessment process 4

NPS Race Equality Impact Assessment template

Which staff will conduct the IA? (eg Board members, senior managers, policy leads, or a team of staff.) Will you include external advice from community groups or individuals? (cross reference to question 5 below) How will the IA be approved and integrated into senior management processes? What is the role of the diversity manager?

5. Consultation Give details of any planned internal staff and external community consultation and engagement. Who will be consulted, how will it be done, when, what are the aims of the consultation, what will be done with the results? Are a diverse range of staff, service users and stakeholders consulted? How will the impact assessment process be publicised to give as many people as possible an opportunity to take part?

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NPS Race Equality Impact Assessment template

C. CONDUCTING THE IMPACT ASSESSMENT 6. Q & A: Effect of function, policy or practice (use the questions as prompts, not as a list which must be answered in every case) What questions were identified in the initial screening above? What other aspects of the way this policy is, or might be, implemented, should be explored? Are there any points within the policy as it stands where the potential exists for negative impact on staff or service users or stakeholders across all groups? Is there any existing evidence to show that adverse impact on any disadvantaged group has occurred previously in this area, if so what? If not what evidence will you need to collect to assess the impact? (This might be monitoring, evidence from staff networks, evidence from service users, surveys, interviews, focus groups, wider consultation, research at national or area level on impact of similar policies or functions, etc.) How can you be sure you have fully understood potential for adverse impact? Have relevant community members been engaged at all stages in identifying questions to ask, areas of concern? What level of community consultation and engagement has taken place during the impact assessment? What were the results? Overall, how does the policy promote equality, eliminate discrimination and promote good relations?

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NPS Race Equality Impact Assessment template

7. Assessment of evidence and action on results What conclusions can be drawn from the consultation and the evidence collection? Support the conclusions by reference to the outcomes of consultation and evidence collection. Is there is a need to change, amend or withdraw the policy or practice? In what ways will the policy promote good relations, promote equality and eliminate discrimination? Does it need amending to reflect this? If so, what action is needed, by when and who is responsible?

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NPS Race Equality Impact Assessment template

D. FOLLOW UP TO IMPACT ASSESSMENT 8. Monitoring and management How will the policy be monitored to measure the impact of it on the target groups? Are monitoring arrangements adequate to measure the impact of the policy in relation to on all groups? Race Gender Disability Sexual orientation/transgender Faith Age What management structures are in place to ensure effective implementation of the equality aspects of this function, policy or practice?

9. Publishing the results How will you publish the results of the IA and any subsequent monitoring to measure progress? In what formats, aimed at which audiences? If the information accessible to those who need it? How will feedback be given to those involved in consultation?

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NPS Race Equality Impact Assessment template

10. Approval and review Who will give final approval of the impact assessment of the policy or function? How often will it be reviewed in future – by when and by whom?

Final approval by ______________________________________ (name) Date of completed IA and approval _________________________

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NPS Race Equality Impact Assessment template

RACE EQUALITY IMPACT ASSESSMENT Ten key points to ensure a good impact assessment The ten steps below are practical suggestions about how to approach the impact assessment process in general to ensure that it is thorough and fully evidenced. These notes supplement the more detailed guidance in the Home Office Impact Assessment template, to which probation areas should refer for more information if required, as well as the CRE guidance on impact assessment. 1. Establish the local baseline in your area – this will help with all impact assessments Who are your service users? Who are your staff? Who are your partner organisations and those to whom you contract services? What do you know about these groups in relation to racial and cultural background, age, faith, gender, etc? Do you have enough knowledge and information about these diverse groups to be able to assess the impact of your policies and practices on each of them? What sort of information might you need to show that you can give detailed consideration to the possible impact? If you don’t have it, how can you get it? What do you know about your local community and sources of advice and expertise that you could tap into? How can you find out? What could be available in your area or at national level, to strengthen local community sources and their capacity to help with the impact assessment process? Area there any race equality issues in your area which should be taken into account? For example have there been any employment tribunal cases alleging racial discrimination, or complaints from service users or community groups? What well known community concerns are there beyond the probation service – for example any known concerns about policing, or poor community relations – these external factors can affect how the Probation Service delivers its services. 2. Clarify who is responsible for conducting impact assessments Will all impact assessments be done by one person, for example, the diversity manager? Or will relevant policy and operational managers carry them out 10

NPS Race Equality Impact Assessment template

with advice from the diversity manager? How will the assessment be communicated and actioned by senior management? How will the outcome form part of regular performance and management review processes? Are responsibility and deadlines clearly assigned and are there enough resources available for those responsible to do them properly? Will impact assessment training be provided for all those responsible for impact assessments? 3. Set up a process for internal consultation – and use it before you start Given the composition of your staff, who needs to be consulted internally about the impact of policy and practice? Is there already a system in place for consultation? If so how effective is it? And if not can something be put in place before the impact assessment process begins? Can staff associations and support groups help? Use the internal consultation process to help identify potential problems, adverse impact or areas which the impact assessment might need to probe. This framework can be used for all policies and functions. 4. Set up a process for external consultation – and use it before you start What is the best way for you to involve local communities, faith groups etc? What sort of support from you might they need in order to take this on effectively (resources, access, methods of communicating, frequency of consultation and so on)? Are any existing consultation methods working well and do they include the right people? If not, set up a strong and effective system of regular consultation with local communities. Some organisations have set up an independent advisory group specifically to assist with impact assessment, by reviewing priorities for assessment, conduct of the assessment, conclusions, and bringing a challenging and fresh perspective which can be very helpful. Once a good process is in place, consult before you begin the impact assessment to help to identify potential problems, adverse impact or areas which you need to explore.

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NPS Race Equality Impact Assessment template

5.

Decide what questions need to be asked about the policy, function or practice. Remember that policies can be unwritten – custom and practice – as well as formal written policies. What and who does the policy or function affect? How much do you already know about the way it works: has there been any ethnic monitoring in the past, any staff or service users surveys, audit reports or other information? Are there any identified concerns? Use this and the consultation process above to think through any potential adverse impact of each area: what are the danger points where unfair treatment might occur? How much discretion is involved, and how is this discretion supervised and by whom? How is use of discretion recorded? What management oversight and supervision is in place for the policy or function? What are the gaps in your knowledge of the impact of this policy or practice and how can you fill them?

6.

Collect the evidence Evidence can be from a variety of sources: ethnic monitoring where it is in place, of staff and service users, is one source. You can also carry out surveys or interviews and focus groups specifically to gather evidence for the impact assessment, and collect further evidence from the consultation methods set up earlier in the process. There might have been inspectorate reports, or pieces of local research on a topic. Staff associations and networks may have evidence as may partners and service users. In the impact assessment you need to describe what the various sources of evidence were; how it was obtained, from whom and what were the key issues (concerns or successes) which the evidence suggests. It is not enough to state that no adverse impact has been identified: the assessment must make clear the basis for that statement: the how, who, what and when of arriving at that assessment.

7.

Act on the results 12

NPS Race Equality Impact Assessment template

According to what the impact assessment concludes, ensure action is taken to amend the policy or function or even produce a new policy or procedure, and that responsibility and a timetable for action is clearly assigned and implementation is monitored. 8. Set up and use an effective ethnic monitoring system. If the policy or function concerned has not been subject to ethnic monitoring in the past, and has a potential for adverse impact, you need to ensure ethnic monitoring systems are in place. All new policies and functions will also require an ethnic monitoring process to demonstrate year on year that there is no discrimination and that the policy promotes good race relations. Make sure your local ethnic monitoring system can provide the answers to your own local questions (not just provide data for NPD statistics!) and reflects what you know about your service users and your staff. Make sure that everyone involved knows why they are monitoring and how to do it. As well as outcomes in terms of statistics ensure you cover the use of discretion at key decision making points: how is it used, who by, who oversees the outcomes. Can you be sure discretion is always been exercised fairly and can you prove that? Provide training for the staff that will collect and analyse the ethnic monitoring information. 9. Publish the results All race equality impact assessments should be made available to service users and staff, perhaps using the Area web site. Feedback and results should also be given to everyone, internally and externally, who was consulted. Publication promotes openness and accountability and encourages further dialogue and debate. Make sure the published results are in a range of accessible formats to meet the diverse range of access requirements. 10. Keep asking the questions! If the ethnic monitoring and consultation is effective, the review process should become part of the routine performance and management processes

13

NPS Race Equality Impact Assessment template

so that the impact of policy and practice can be continuously reviewed. Think about additional ways to check for impact and gather evidence as time goes by: annual service users and staff surveys, for example. Use local independent external contacts (for example local universities) to conduct small scale research projects to validate the ethnic monitoring results. Impact assessment is an evolving and continuous process. Policy and practice changes and so do people and knowledge and understanding of race and diversity. Setting up a strong system as suggested above will mean the impact assessment process becomes mainstreamed, and can be used as a basis for impact assessment of other diversity strands such as gender, disability, sexual orientation, faith and belief, and age.

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