Transparency data

Updated NPCC Response to TVIP super-complaint

Updated 25 March 2024

Applies to England and Wales

1. Introduction and background

1.1. The NPCC Honour-Based Abuse, Forced Marriage and Female Genital Mutilation (FGM) portfolio has requested updates on force progress against the three key recommendations from the report on the TVIP super-complaint relating to how the police respond to victims of sexual abuse when the victim is from an ethnic minority background and may be at risk of honour-based abuse (HBA).

Recommendation 1: The Risk of honour-based abuse

We found forces generally only include the risk of honour-based abuse in their domestic abuse policies, so we recommend that chief constables update their forces’ sexual abuse policies to include the risk of honour-based abuse.

Recommendation 2: Cultural awareness

During our investigation, we found forces generally lack awareness and understanding of different cultures and religions. This means some officers are unlikely to recognise the wider risks of honour-based abuse after some victims report sexual abuse. Chief constables should make sure that:

• officers and staff are aware of the demographics of the communities they police so they can understand the nuances of different cultures and have time to learn about those communities
• independent advisory groups or equivalent groups reflect these demographics
• forces work with the local communities they police to prepare up-to-date information on culture and religion and ensure officers have access to it
• investigations consider any extra factors that might be relevant because of the culture and background of the victim or suspect

The information in the third point must include:

• the potential risks of honour-based abuse that some victims of sexual abuse face
• any additional challenges and pressures relating to re-traumatisation that victims of sexual abuse from different ethnic minority backgrounds may experience

Recommendation 3: Consideration of findings

The NPCC and the College of Policing consider the findings from this investigation so they can be satisfied that the proposed changes and standards they are working on address the lack of recorded ethnicity data, including:

• data on voluntary attendance
• data on the use of interpreters
• data on offering and providing special measures

We recommend this work includes how officers and staff collect data, and their confidence and capability to ask the right questions.

1.2. 40 out of the 43 forces from across England & Wales responded to this request and on the following pages is a consolidated overview of the information received.

2. Snapshot

2.1. Recommendation 1: Chief constables update their forces’ sexual abuse policies to include the risk of honour-based abuse

Amongst the forces that responded a significant amount noted that HBA was referenced within a variety of their force policies, strategies and standard operating procedures (SOP) including: harmful practices, domestic abuse, RASSO, sexual abuse, child abuse, culturally harmful practices, forced marriage and/or female genital mutilation. There was a clear commitment to ensuring the risk of HBA was well understood by officers, considered in instances of sexual abuse, appropriate action is taken to ensure victim safety and support and an effective investigation is conducted to prosecute the offender. Many forces also noted bespoke training packages that are available to their officers around HBA and close working with specialist HBA charity Karma Nirvana.

Five forces had implemented or were developing a specific HBA policy or SOP to ensure the risk of HBA is fully understood and tackled.

For a small number of the forces HBA is not currently referenced directly within their policies however there is work underway to ensure it is added.

There were no forces who said HBA was not and will not be referenced.

2.2. Recommendation 2a: Chief constables should make sure that officers and staff are aware of the demographics of the communities they police so they can understand the nuances of different cultures and have time to learn about those communities

Forces recognised that they work in multi-cultural and diverse areas and noted the importance of properly understanding them. Across the responses received it was clear that there is a significant amount of activity taking place to improve police officer and staff awareness of the diversity and complexity of the communities they serve.

Across many forces Neighbourhood Policing Teams are broken down to local borough (or similar) level to enable the officers within those teams to engage more actively with their community, thus supporting their ability to understand them. Furthermore, local neighbourhood profiles have been developed by a large number of forces to capture the demographics of communities, utilising a variety of datasets including census and local authority and, in some forces, insight from their ‘Alert’ systems (Example: Derbyshire Alert). These profiles are available to all staff and are used to inform community engagement strategies which also tend to tailor activity by boroughs (or similar) based on understanding of demographics, community tensions and vulnerable individuals and groups.

Some forces reflected that data is not available at the necessary level (borough/ward) or is outdated but in these instances local knowledge and insights of local officers is relied upon. One force has developed Community Engagement Guides which provide advice and guidance to staff about potential cultural barriers and etiquette. Another force utilises single points of contact (SPOCs) who have detailed knowledge on local cultures to provide up to date information to officers.

Another force noted they have a Community Engagement Unit which identifies community tensions by gaining a thorough understanding of communities and the vulnerabilities contained therein. The unit monitors local, national and international issues as well as intelligence and crime statistics to assess potential impacts on local communities. Another force utilises their Community Cohesion Team to build a rapport with the community to better understand community tensions.

Initial police training and specialist investigative training are two routes forces use to ensure awareness. The former provides a more general overview, and the latter a valuable opportunity to deep dive into more specific communities depending on an officer’s specialism. For example:

• one force trains all of its new officers and existing staff in HBA and forced marriage, and trains detectives using examples involving different communities, such as white gypsy traveller, Iraqi Kurdish as well as South Asian case/s

• another force uses the ilearn tool to educate and support its work to ensure that its workforce is Diversity, Equality and Inclusion (DEI) informed, as well as supporting the delivery of its current DEI Strategy and DEI Action Plan

• another force has implemented Inspector and Sergeant training days utilising information from staff networks, community partners and local data to ensure leaders are knowledgeable on HBA to build confidence in their teams to address HBA

• another force highlighted that the policing education qualifications framework (PEQF) and Detective Training Program include sessions on FGM and HBA

There is a large range of work underway to improve relationships with different communities. For example, one force holds regular equality, diversity and inclusion days to enable staff to meet community members.

2.3. Recommendation 2b: Chief constables should make sure that independent advisory groups (IAG) or equivalent groups reflect these demographics (different cultures and religions)

Force responses to this recommendation show a range of progress. Overall the majority of forces that responded have a IAG, or equivalent, model established in their area and acknowledge the value of having these diverse groups of individuals representing key community groups and providing a mechanism for 2-way communication. A handful of forces did not directly comment on IAGs, or equivalent, within their responses, and in a couple of areas there is work ongoing to establish IAGS, to recruit for IAG members or to improve the representation of all communities within IAGs.

There are a variety of IAGs in existence across forces including SIAGs (Strategic Independent Advisory Groups), YIAGs (Youth Independent Advisory Groups), JEGs (Joint Engagement Groups) and/or CAGs (Community Action Groups). A number of forces also cite specific VAWG IAGs with a women-focused membership providing insight on Violence Against Women and Girls (VAWG) via personal lived experience or representing those with lived experience. In many instances the IAGs within force provide high levels of challenge to support the Police Race Action Plan.

In some instances forces utilise their wider networks, for instance Key Individual Networks (KIN) to invite additional members to IAGs on a bespoke basis. A couple of forces have gone further with their IAGS; one has a Racial Advisory Group and the other has an African and Caribbean Reference Group, and forums for faith including a Black Faith Leaders Forum and a Muslim Faith Leaders Forum.

In one force they have established a different advisory group: in partnership with the University of Leicester this force has established VOICES (Valuing Our Individual Communities, Experiences and Skills) which is an advisory group made up of survivors of sexual violence from a diverse range of communities. The group advises the multi-agency Response to Sexual Violence group which is a strategic partnership of police and statutory and non-statutory partners. The VOICES group will ensure the policies and practices of the force and its partners are scrutinised, shaped, and informed by the voices of survivors and specifically by representatives from under-represented communities.

A different force has introduced an initiative called ‘People’s Voice’, which gives officers and staff the opportunity to learn from members of the public about nuances of diverse cultures based on their religions, ethnic backgrounds, sexual orientations, and gender identities.

In many instances IAGs feed into Independent Scrutiny Oversight Boards or other types of scrutiny panel. Forces focus on ensuring the right representation is seen within IAGs to then, in turn, ensure representation within their governance structures. For example, in one force some IAG members are thematic leads, and, as such, attend and contribute to governance groups such as the force’s Inclusion Board, Public Encounters Group and VAWG Board. Some members also chair and assist in the development of public scrutiny boards, in relation to Stop & Search, Use of Force, and most recently, public complaints against police. Feedback from public scrutiny is evaluated and actioned appropriately. This has led to the development of Stop & Search cards, changes to force training and also changes as to how force is presented.

2.4. Recommendation 2c: Chief constables should make sure that forces work with the local communities they police to prepare up-to-date information on culture and religion and ensure officers have access to it

The Neighbourhood Policing Guidelines support the use of community engagement to gather information and intelligence to address local, force and national priorities. These priorities link together and influence the delivery of policing. Many forces noted the value they place on community and/or partnership engagement to inform force activity, signpost demographic changes and monitor communities identified as vulnerable, at risk of crime or hard to reach.

As noted in the response to recommendation 2a, forces utilise a variety of datasets to gain an understanding of the areas they police and the insight, typically a ‘profile’ or similar, are readily accessible to officers and staff.

Community engagement spans both that with individuals/small groups representing specific communities, and targeted engagement with other bodies for instance Mosques and community networks. Many forces have focused Community Engagement Officers, or similar, who provide specialist support to community groups, work with police and partner agencies to bridge gaps and increase communication and confidence. Similalrly, one force has implemented Community Innovations Hubs to develop strong relationships with BAME communities.

Forces place value on the insight they can gain from relevant agencies including HALO and have established a variety of forums to enable conversations between HBA leads and key partners including the Crown Prosecution Service. One force also cited that it is utilising the research expertise of a local university, working with them to better understand and provide an improved response to HBA. Another force noted that the Sexual Assault Referral Centre which they co-commission with the NHS, is available to provide specialist advice and guidance to operational officers and staff. This includes signposting to specialist cultural and religious support agencies such as Zinthiya and the Shama Centre. They also acknowledge the value of working with colleagues from the Office of the Police and Crime Commissioner who are highly focussed on community engagement and have a Deputy Police and Crime Commissioner who leads on VAWG.

One force has introduced ‘Neighbourhood Matters’ which is driven by Local Policing and focuses on issues within the community. Neighbourhood Matters provides a central depository, that allows officers to record their community engagement. This will then allow a subsequent review and analysis of current trends and landscape of a particular area.

Similarly, another force has implemented a ‘Cultural Intelligence App’ which acts as a centralised system to provide officers with updated and accurate information.

Across many forces the information gathered and/or relationships developed via community engagement is utilised to provide officers with training or continuous professional development. For example, in one force a recent multi-agency Continuous Professional Development (CPD) day saw inputs from a range of third sector support groups, affected communities themselves, the Forced Marriage Unit and the National FGM Centre. These inputs included the fact that those at risk of HBA may also be at risk of sexual violence and the particular issues that some communities face.

2.5. Recommendation 2d: Chief constables should make sure that investigations consider any extra factors that might be relevant because of the culture and background of the victim or suspect

The THRIVE (Threat, harm, risk, investigation, vulnerability and engagement) assessment was developed to support officers in assessing the right initial police response to a call for service, allowing judgement to be made based on the relative risk and places the victim’s needs at the centre of the decision. Many forces noted that in instances where HBA is identified via THRIVE there is a clear process which is followed thereafter with these incidents treated as high risk. Force approaches differ slightly but one example which appears in a number of force responses is that a Dash risk assessment would also be completed with the victim and if HBA is identified upon assessment, this initiates an automatic referral into the Multi-Agency Risk Assessment Conference process.

Other processes include: in one force their custody staff complete a risk assessment which includes to highlight any cultural needs, and in a different force sexual violence offences are investigated by specialist officers who work with the SARC team and the force are considering creating a team of specialist sexual offence responders to increase the knowledge and specialism of officers who engage with victims of sexual violence at first point of contact with police.

Subject Matter Experts exist in a number of forces to provide advice and guidance to investigating officers and teams and, in some instances, provide information to Command teams. For example, one force has 54 dedicated HBA Champions to provide best practice and insights on HBA.

Furthermore, as noted in response to recommendation 1, many forces utilise the HBA charity Karma Nirvana to provide training to their officers and staff, to improve knowledge and support across the organisation for all victims and to support and guide investigators. Many also make use of the Karma Nirvana risk assessment tool, which allows them to learn and ask more about the community, in some cases alongside the Domestic Abuse Risk Assessment (DARA). Forces are clear of the importance of understanding the results of these assessments to provide insight into the background of the victim.

In addition, a number of forces indicated other training course or CPD events to provide officers and staff with greater understanding and improve investigations on HBA. One force hosted a HBA conference with policing partners and subject matter experts to better understand culturally harmful practices.

There are less examples of assessing a suspect’s culture or background however forces are addressing this as part of the Operation Soteria Bluestone improvement plan relating to rape and serious sexual offences (RASSO).

One force has implemented Operation Palais, which is the force’s commitment to reducing domestic homicides through safeguarding domestic abuse victims, increasing domestic abuse prosecutions and making homes a safe place for victims of domestic abuse. This operation is designed to support the force in achieving the objective of Supporting Victims and Vulnerable People, as outlined in the Force Strategy and has been developed to support the force’s approach to the three pillars of the NPCC VAWG Framework, a national initiative that all forces are required to implement to ensure there is a consistent response to violence against women and girls.

Another force has introduced a revised RASSO Investigation Booklet which ensures that ethnicity is specifically recorded along with the victim’s first language and interpreter requirements. It also includes an in-depth witness assessment which the attending officer is to complete prior to obtaining any initial fast-track account. This assessment steers officers to ask the victim about any specific cultural or religious needs. This information is subsequently captured in the Investigative Assessment Framework section of the associated crime record. The Investigative Assessment Framework assesses risk relating to the victim and their environment. It is a mandatory requirement for the attending officer to complete this prior to a crime record being screened for investigation. Correct completion ensures that cultural factors impacting on the investigation are documented in cases where honour-based abuse (or the risk of) is identified.

2.6. Recommendation 3: The NPCC and the College of Policing consider the findings from this investigation so they can be satisfied that the proposed changes and standards they are working on address the lack of recorded ethnicity data, including: data on voluntary attendance; data on the use of interpreters; and data on offering and providing special measures. We recommend this work includes how officers and staff collect data, and their confidence and capability to ask the right questions

Not all forces responded to this recommendation and as such the NPCC cannot confidently state the extent to which we are satisfied that progress have been made against it. From the 15 forces that did respond we saw varying levels of delivery but a reassuring acknowledgement of the importance of recording ethnicity information. Below is a summary of comments from the 15 forces and as such should not be viewed as representative of all forces, or even as a consolidated response from the NPCC.

One force commented that quality of recording against all eight protected characteristics varies, they reflected that they record gender and age well, ethnicity is recorded to some extent but improvements are still needed and the other characteristics are not recorded well, if at all. We expect this is likely to ring true for other forces too and there were some more general comments about data quality in this area.

Data on protected characteristics is a national issue which has been flagged in numerous thematic HMIC reports as well as a number of force’s PEEL inspections. Forces have taken action to encourage and enhance recording practices. One force received an Area for Improvement specifically entitled “The force needs to improve the recording of equality data”. An NPCC Working Group governed by the Diversity, Equality and Inclusion Coordination Committee was set up to discuss the issue as no clear and current national position was available to forces and there was a risk of duplication and inconsistency. This group’s report and recommendations were due in January 2023, but have not yet been published. Another force stated that their Custody department has created an auditing system following a previous HMIC Inspection in 2019, which dip samples records against nineteen AFIs set by that Inspection. Includes within those AFIs are ethnic and cultural factors which are monitored and reviewed monthly by the Custody Senior Management Team and are absorbed into the force’s Performance Management Framework (PMF) process which ensures that all records are subject to scrutiny and learning shared to provide a consistent standard.

It is well understood that flags are included on a range of command, control and record management systems within forces and these flags include HBA. One force made an interesting reflection that this only provides insight on reports, incidents, and crimes where the flag has been selected. It is not possible to check all reports, incidents, and crimes where flags may not have been selected, therefore it is likely there are data quality gaps in relation to the true picture of honour-based abuse. In this force these gaps would be addressed via appropriate training in HBA, and wider traditional harmful practices. Another force noted that their HBA officers are required to flag additional markers to any Athena/Crime reference when identified alongside the primary classification. This allows for easy access to review the amount of cases and the content of those cases and compare investigations. VAWG can be flagged in a similar way. This allows for sharing of data and also analysis and audit of the data to ensure that the necessary information is being asked.

A number of forces noted the existence of data dashboards for these data type however there was limited information provided on how these are used to address the lack of recorded ethnicity data. One force cited their ‘data quality’ management information dashboard, that every member of the organisation has access to, where specific staff/officer’s mistakes are highlighted for them to individually correct any errors they have made; victim ethnicity recording features within this. Those individuals who record the most amount of errors each month are referred to their supervision for feedback and to enable improvements.

More generally, forces commented on the continuation of activity to raise awareness around the importance of data quality and understanding the needs of victims to ensure appropriate support mechanisms are put in place. One force shared that they issued a message to all officers and staff reminding them of the need to record self-defined ethnicity and that any victim of sexual abuse when the victim is from an ethnic minority background may be at risk of HBA. The message stressed the importance of understanding the ethnicity and background of victims and their abusers and highlighted that accurate and timely recording of this information ensures the early identification of HBA cases so that the appropriate safeguarding and support services are offered and that more informed risk assessments can be undertaken. Another Force highlighted raising awareness of data quality in command and control centres has resulted in significant improvement in coding of HBA within 12 months.

A few forces indicated that there remains work to do to address the lack of recorded ethnicity data, particularly with regard to data on the use of interpreters and data on offering and providing special measures. One force indicated that the inability to report on interpreter data was due to the limitations within the system.

Annex A - The forces that responded

• Avon & Somerset
• Bedfordshire
• Cambridgeshire
• Cheshire
• City of London
• Cleveland
• Cumbria
• Derbyshire
• Devon & Cornwall
• Dorset
• Durham
• Gloucestershire
• Greater Manchester
• Gwent
• Hampshire
• Hertfordshire
• Humberside
• Lancashire
• Leicestershire
• Lincolnshire
• Merseyside
• Metropolitan
• Norfolk
• North Wales
• North Yorkshire
• Northamptonshire
• Northumbria
• Nottinghamshire
• South Wales
• South Yorkshire
• Staffordshire
• Suffolk
• Surrey
• Sussex
• Thames Valley
• Warwickshire
• West Merica
• West Midlands
• West Yorkshire
• Wiltshire