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An act of parliament that provides the core framework of police powers to combat crime and provide codes of practice for the exercise of these powers.
Leads and manages the development of the police service in England, Wales and Northern Ireland.
The body that represents the interests of all police constables, sergeants, and inspectors.
Deals with someone’s inability or failure to perform to a satisfactory level, but without breaching the Standards of Professional Behaviour.
Focuses on putting an issue right and preventing it from happening again by encouraging those involved to reflect on their actions and learn. It is not a disciplinary process or a disciplinary outcome.
Department within a police force that deals with complaints and conduct matters.
Refers to lower-level misconduct or performance-related issues, which are dealt with in a proportionate and constructive manner.
This means doing what is appropriate in the circumstances, taking into account the facts and the context in which the complaint has been raised, within the framework of legislation and guidance.
The average is calculated using the individual results of the forces in that most similar force group.
An investigation carried out by IOPC staff.
Carried out by the police under their own direction and control. The IOPC sets the terms of reference and receives the investigation report when it is complete. Complainants have a right of appeal following a supervised investigation (unless it is an investigation into a direction and control matter).
This act sets out how the police complaints system operates.
How a police force is run, for example policing standards or policing policy.
An investigation carried out by the police under the direction and control of the IOPC.
The organisation that is responsible for assessing how to deal with a complaint. For example – whether it can be handled locally or reaches the criteria for referral to the IOPC. The appropriate authority may be the chief officer of the police force or the PCC for the force. If a complaint investigation finds that someone has a case to answer for misconduct, the appropriate authority is responsible for arranging any misconduct proceedings. If you make a complaint, the appropriate authority for your case will contact you.
An intelligence-led agency with law enforcement powers, it is also responsible for reducing the harm that is caused to people and communities by serious organised crime.
Policing bodies include police and crime commissioners, the Common Council for the City of London, or the Mayor's Office for Policing and Crime.
Investigations carried out entirely by the police. Complainants have a right of appeal following a local investigation (unless it is an investigation into a direction and control matter).
IOPC guidance to the police service and police authorities on the handling of complaints.
A complaint or recordable conduct matter that doesn’t need to be referred to the IOPC, but where the seriousness or circumstances justifies referral.
Parameters within which an investigation is conducted.
A person is adversely affected if he or she suffers any form of loss or damage, distress or inconvenience, if he or she is put in danger or is otherwise unduly put at risk of being adversely affected.
This is where a manager deals with the way someone has behaved. It can include: showing the police officer or member of staff how their behaviour fell short of expectations set out in the Standards of Professional Behaviour; identifying expectations for future conduct; or addressing any underlying causes of misconduct.
This could be the Police and Crime Commissioner, the Common Council for the City of London, or the Mayor's Office for Policing and Crime.
A flexible process for dealing with complaints that can be adapted to the needs of the complainant. It may involve, for example, providing information and an explanation, an apology, or a meeting between the complainant and the officer involved.
A flexible process for dealing with complaints that can be adapted to the needs of the complainant. It may involve, for example, providing information and an explanation, an apology, or a meeting between the complainant and the officer involved.
A breach of standards of professional behaviour by police officers or staff so serious it could justify their dismissal.
A matter where no complaint has been received, but where there is an indication that a person serving with the police may have committed a criminal offence or behaved in a manner that would justify disciplinary proceedings.
Disapplication means that a police force may handle a complaint in whatever way it thinks fit, including not dealing with it under complaints legislation. This may only happen in certain circumstances where the complaint fits one or more of the grounds for disapplication set out in law.
The ending of an ongoing investigation into a complaint, conduct matter or DSI matter. An investigation may only be discontinued if it meets one or more of the grounds for discontinuance set out in law.
Quarter 1 covers 1 April - 30 June Quarter 2 covers 1 April - 30 September Quarter 3 covers 1 April - 31 December Quarter 4 covers the full financial year (1 April - 31 March).
You can request a review/appeal if you’re not satisfied with how your complaint has been handled.
Used to house anyone who has been detained.
Complainants have the right to appeal to the IOPC if a police force did not record their complaint or notify the correct police force if it was made originally to the wrong force.
The purpose of an investigation is to establish the facts behind a complaint, conduct matter, or DSI matter and reach conclusions. An investigator looks into matters and produces a report that sets out and analyses the evidence. There are three types of investigations: local, directed and independent.
The ending of an ongoing investigation into a complaint, conduct matter or DSI matter. An investigation may only be discontinued if it meets one or more of the grounds for discontinuance set out in law.
The type of behaviour being complained about. A single complaint case can have one or many allegations attached.
A person who makes a complaint about the conduct of someone serving with the police.
The ending of an ongoing investigation into a complaint, conduct matter or DSI matter. An investigation may only be discontinued if it meets one or more of the grounds for discontinuance set out in law.
List of officers and staff who have been dismissed from policing, or would have been if they had not retired or resigned.
The type of behaviour being complained about. A single complaint case can have one or many allegations attached.
Disapplication means that a police force may handle a complaint in whatever way it thinks fit, including not dealing with it under complaints legislation. This may only happen in certain circumstances where the complaint fits one or more of the grounds for disapplication set out in law.
An independent judicial officer, the coroner enquires into deaths reported to him/her.
A breach of the Standards of Professional Behaviour that would justify at least a written warning.
No further action may be taken with regard to a complaint if the complainant decides to retract their allegation(s).
A record is made of a complaint, giving it formal status as a complaint under the Police Reform Act 2002.
This is a format where information is written in plain English and short sentences.
The IOPC must be notified about specific types of complaint or incidents to be able to decide how they should be dealt with.
No further action may be taken with regard to a complaint if the complainant decides to retract their allegation(s).
Casework involves assessing appeals. Casework staff also have a role in overseeing the police complaints system to help ensure police forces handle complaints in the best possible way.
Disapplication means that a police force may handle a complaint in whatever way it thinks fit, including not dealing with it under complaints legislation. This may only happen in certain circumstances where the complaint fits one or more of the grounds for disapplication set out in law.
Conduct includes acts, omissions, statements and decisions (whether actual, alleged or inferred). For example: language used and the manner or tone of communications.
You can request a review/appeal if you’re not satisfied with how your complaint has been handled.
You can request a review/appeal if you’re not satisfied with how your complaint has been handled.

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An act of parliament that provides the core framework of police powers to combat crime and provide codes of practice for the exercise of these powers.
Leads and manages the development of the police service in England, Wales and Northern Ireland.
The body that represents the interests of all police constables, sergeants, and inspectors.
Deals with someone’s inability or failure to perform to a satisfactory level, but without breaching the Standards of Professional Behaviour.
Focuses on putting an issue right and preventing it from happening again by encouraging those involved to reflect on their actions and learn. It is not a disciplinary process or a disciplinary outcome.
Department within a police force that deals with complaints and conduct matters.
Refers to lower-level misconduct or performance-related issues, which are dealt with in a proportionate and constructive manner.
This means doing what is appropriate in the circumstances, taking into account the facts and the context in which the complaint has been raised, within the framework of legislation and guidance.
The average is calculated using the individual results of the forces in that most similar force group.
An investigation carried out by IOPC staff.
Carried out by the police under their own direction and control. The IOPC sets the terms of reference and receives the investigation report when it is complete. Complainants have a right of appeal following a supervised investigation (unless it is an investigation into a direction and control matter).
This act sets out how the police complaints system operates.
How a police force is run, for example policing standards or policing policy.
An investigation carried out by the police under the direction and control of the IOPC.
The organisation that is responsible for assessing how to deal with a complaint. For example – whether it can be handled locally or reaches the criteria for referral to the IOPC. The appropriate authority may be the chief officer of the police force or the PCC for the force. If a complaint investigation finds that someone has a case to answer for misconduct, the appropriate authority is responsible for arranging any misconduct proceedings. If you make a complaint, the appropriate authority for your case will contact you.
An intelligence-led agency with law enforcement powers, it is also responsible for reducing the harm that is caused to people and communities by serious organised crime.
Policing bodies include police and crime commissioners, the Common Council for the City of London, or the Mayor's Office for Policing and Crime.
Investigations carried out entirely by the police. Complainants have a right of appeal following a local investigation (unless it is an investigation into a direction and control matter).
IOPC guidance to the police service and police authorities on the handling of complaints.
A complaint or recordable conduct matter that doesn’t need to be referred to the IOPC, but where the seriousness or circumstances justifies referral.
Parameters within which an investigation is conducted.
A person is adversely affected if he or she suffers any form of loss or damage, distress or inconvenience, if he or she is put in danger or is otherwise unduly put at risk of being adversely affected.
This is where a manager deals with the way someone has behaved. It can include: showing the police officer or member of staff how their behaviour fell short of expectations set out in the Standards of Professional Behaviour; identifying expectations for future conduct; or addressing any underlying causes of misconduct.
This could be the Police and Crime Commissioner, the Common Council for the City of London, or the Mayor's Office for Policing and Crime.
A flexible process for dealing with complaints that can be adapted to the needs of the complainant. It may involve, for example, providing information and an explanation, an apology, or a meeting between the complainant and the officer involved.
A flexible process for dealing with complaints that can be adapted to the needs of the complainant. It may involve, for example, providing information and an explanation, an apology, or a meeting between the complainant and the officer involved.
A breach of standards of professional behaviour by police officers or staff so serious it could justify their dismissal.
A matter where no complaint has been received, but where there is an indication that a person serving with the police may have committed a criminal offence or behaved in a manner that would justify disciplinary proceedings.
Disapplication means that a police force may handle a complaint in whatever way it thinks fit, including not dealing with it under complaints legislation. This may only happen in certain circumstances where the complaint fits one or more of the grounds for disapplication set out in law.
The ending of an ongoing investigation into a complaint, conduct matter or DSI matter. An investigation may only be discontinued if it meets one or more of the grounds for discontinuance set out in law.
Quarter 1 covers 1 April - 30 June Quarter 2 covers 1 April - 30 September Quarter 3 covers 1 April - 31 December Quarter 4 covers the full financial year (1 April - 31 March).
You can request a review/appeal if you’re not satisfied with how your complaint has been handled.
Used to house anyone who has been detained.
Complainants have the right to appeal to the IOPC if a police force did not record their complaint or notify the correct police force if it was made originally to the wrong force.
The purpose of an investigation is to establish the facts behind a complaint, conduct matter, or DSI matter and reach conclusions. An investigator looks into matters and produces a report that sets out and analyses the evidence. There are three types of investigations: local, directed and independent.
The ending of an ongoing investigation into a complaint, conduct matter or DSI matter. An investigation may only be discontinued if it meets one or more of the grounds for discontinuance set out in law.
The type of behaviour being complained about. A single complaint case can have one or many allegations attached.
A person who makes a complaint about the conduct of someone serving with the police.
The ending of an ongoing investigation into a complaint, conduct matter or DSI matter. An investigation may only be discontinued if it meets one or more of the grounds for discontinuance set out in law.
List of officers and staff who have been dismissed from policing, or would have been if they had not retired or resigned.
The type of behaviour being complained about. A single complaint case can have one or many allegations attached.
Disapplication means that a police force may handle a complaint in whatever way it thinks fit, including not dealing with it under complaints legislation. This may only happen in certain circumstances where the complaint fits one or more of the grounds for disapplication set out in law.
An independent judicial officer, the coroner enquires into deaths reported to him/her.
A breach of the Standards of Professional Behaviour that would justify at least a written warning.
No further action may be taken with regard to a complaint if the complainant decides to retract their allegation(s).
A record is made of a complaint, giving it formal status as a complaint under the Police Reform Act 2002.
This is a format where information is written in plain English and short sentences.
The IOPC must be notified about specific types of complaint or incidents to be able to decide how they should be dealt with.
No further action may be taken with regard to a complaint if the complainant decides to retract their allegation(s).
Casework involves assessing appeals. Casework staff also have a role in overseeing the police complaints system to help ensure police forces handle complaints in the best possible way.
Disapplication means that a police force may handle a complaint in whatever way it thinks fit, including not dealing with it under complaints legislation. This may only happen in certain circumstances where the complaint fits one or more of the grounds for disapplication set out in law.
Conduct includes acts, omissions, statements and decisions (whether actual, alleged or inferred). For example: language used and the manner or tone of communications.
You can request a review/appeal if you’re not satisfied with how your complaint has been handled.
You can request a review/appeal if you’re not satisfied with how your complaint has been handled.

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Preface First

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Content

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Operation Linden Learning Report

Update (June 2022): Please read the Operation Linden 13 recommendations and responses here.

Operation Linden was the name given to the IOPC investigation of a significant number of complaints and allegations relating to the police response to non-recent child sexual exploitation in the Rotherham area.

Our work began in 2014 and continued to grow until 2018, when five new complaints were received. Operation Linden resulted in 91 separate independent investigations started between 2014 and 2018, the last of which concluded in 2020.

The operation investigated 265 separate allegations, covering the period from 1997 to 2013. There were 51 complainants, 44 of whom were survivors of abuse. We are grateful to those complainants and survivors whose bravery in coming forward has enabled us to shine a light on the failings of the past.

Operation Linden investigated the conduct of 47 officers: eight were found to have a case to answer for misconduct and six had a case to answer for gross misconduct. Five have faced sanctions from management action up to a final written warning, while one hearing is still outstanding. A full report on the findings of the investigations and the outcomes will be published following the conclusion of the final misconduct hearing in 2022.

Police understanding of this type of offending has evolved significantly in recent years and we must acknowledge the efforts made to improve the way these cases are dealt with.  However, there is still work to do and we have issued these recommendations to South Yorkshire Police, national policing bodies and others so that the bravery of those who came forward and supported our investigations can result in lasting change and that mistakes of the past are not repeated.

Learning and recommendations 

Learning identified during our investigations helps improve policing practice, and prevent similar incidents happening again.  

We have two legal powers to make recommendations under the Police Reform Act and have outlined these in this learning report, along with other learning we considered but did not make recommendations on.  

Our learning looked across the 91 investigations we have completed so far under the umbrella of Operation Linden to identify any recurring themes or issues. We listened to feedback from survivors, and discussed learning with South Yorkshire Police, interested stakeholders and our own staff who worked on these investigations. 

Given the lengthy time period over which the events we investigated occurred, we considered whether the learning we identified was still an issue now or whether policing policy and practice had changed since the events under investigation.  

A number of inspections and reviews have taken place specifically in relation to child sexual exploitation in Rotherham, numerous recommendations made to South Yorkshire Police and the broader focus on child sexual exploitation across policing and social care, such as the Independent Inquiry into Child Sexual Abuse.  

We also recognise that understanding and awareness of child sexual exploitation has developed and improved over time.  

While the learning we identified relates to investigations of child sexual exploitation, it may have wider relevance to other types of crime. In particular, there is a great deal of crossover between child sexual exploitation and child criminal exploitation or ‘county lines’. Child criminal exploitation was a subject most frontline officers we spoke to raised as an area of concern and they expressed a clear desire to get things right. 

Formal learning recommendations 

The following recommendations are made under paragraph 28A, Schedule 3 of the Police Reform Act. The police force or organisation we make a recommendation to must provide their response to us within 56 days. 

Ensuring police officers and staff are equipped to deal with child sexual exploitation 

Our investigations found officers and staff without the right skills were often expected to lead on child sexual exploitation investigations, and individuals were given tasks they were not trained to carry out.  

There have been many improvements in child sexual exploitation training nationally. South Yorkshire Police advised us they have implemented their own new measures to help ensure officers and staff receive appropriate training to deal with child sexual exploitation. This was acknowledged by HMICFRS in its 2018/19 PEEL report which said South Yorkshire Police  “develops its workforce and leaders well and understands the skills and capabilities that it needs now and for the future. The force has good professional and leadership development programmes in place…”. 

However, there is more work to be done to build on and maintain the knowledge and skills of South Yorkshire Police officers and staff. Police officers we spoke to said they would welcome more refresher training that also includes more recent, and challenging exploitation cases, to help them consider new issues that they will need to be prepared for.  

Recommendation 1  The IOPC recommends South Yorkshire Police ensures knowledge and skills of those involved in child sexual exploitation work are kept up to date as part of their continuous improvement cycle. This should include: 

  • regular training to take into account staff turnover 

  • continuing professional development needs 

  • any emerging issues and new developments in best practice 

 

Listening to and understanding survivor experiences can be a powerful way to raise awareness of child sexual exploitation-related issues in training sessions and develop empathy. We are aware that South Yorkshire Police considered an offer from a survivor to participate in its training sessions but did not take this up because it was concerned it would distress the survivor. 

While reliving their experience during a number of training sessions could be traumatising, there are other approaches which could incorporate the voices of survivors without causing trauma, allowing survivor experiences to be heard and showing officers the impact of police handling of an investigation. For example, South Yorkshire Police has used contributions from a survivor’s parents and have shown a video describing one victim’s experience. 

Recommendation 2  The IOPC recommends the College of Policing looks for further opportunities to incorporate the ‘voice of survivors’ in national training about child sexual exploitation and provide guidance on how the ‘voice of survivors’ can be incorporated into local training by forces. 

 

While the issues we examined happened between 1992 and 2013, and there has been a great deal of work in this area by the police service since, we are concerned that some issues still exist today, and there are still lessons to be learnt from this across policing.  

Real examples, or case studies based on actual examples, can help bring some of these issues to life and help officers and staff consider what they would have done in that situation. 

Recommendation 3 The IOPC recommends the College of Policing looks for opportunities to use any elements of Operation Linden in future training (for example case studies).  

 

Crime recording 

We found many instances where crimes were not recorded when they should have been, including reports of sexual assault or sexual activity with a child. South Yorkshire Police has provided us with detailed information on action to improve crime recording practice. In its 2018 crime data integrity inspection in South Yorkshire Police HMICFRS found that South Yorkshire Police had improved crime-recording processes since the previous report in 2014 and that there was ‘a commitment to crime recording that is victim-focused’. 

A significant improvement in the recording of sexual offence crimes since 2014 was noted and some good practice in scrutiny and auditing by the force crime bureau and force crime registrar was highlighted. The report also said that vulnerable victims were supported through the force’s safeguarding arrangements, even in those cases that had not been recorded. 

However, the 2014 inspection highlighted a cause for concern about crimes involving vulnerable adults and children reported directly to South Yorkshire Police’s public protection department (mostly through professional third-party reports) were not all being recorded. We are concerned that HMICFRS’ re-inspection of crime data integrity in South Yorkshire Police (2020) found there had been no discernible improvement to this. In particular, inspectors found significant under-recording of crimes committed against vulnerable children. 

Recommendation 4 – The IOPC recommends South Yorkshire Police takes steps to ensure that crime recording practice in its public protection departments is compliant with the Home Office Counting Rules for Recorded Crime.  

 

Working with victims and survivors 

Our investigations highlighted many issues with how police officers and staff dealt with child sexual exploitation victims and survivors. South Yorkshire Police has told us about the changes made to improve practice in this area.  

The Victims’ Code is an important tool to help criminal justice agencies, including the police, ensure they are providing an appropriate level of service. We note that the Victims’ Commissioner’s national review in 2018/19 found that monitoring of compliance with the Victims’ Code had been almost non-existent across all forces. 

Recommendation 5 – The IOPC recommends that South Yorkshire Police ensure it has a way of effectively monitoring compliance with the Victims’ Code. This should include the quality of interactions between itself and others and not just a ‘tick box exercise’ of the various entitlements being made available.  

 

South Yorkshire Police told us that IT system changes mean that once a crime is recorded using Connect (the police records management system) the investigating officer is now prompted to keep victims updated regularly, and at least once every 28 days. However, when we spoke to the local independent sexual violence advisor (ISVA) service manager10, they told us that the updates do not always happen in practice. They said ISVAs regularly receive calls from victims complaining that they have not been updated. 

Recommendation 6 – The IOPC recommends South Yorkshire Police take steps to ensure that victims are regularly updated, and at least once every 28 days, in line with expectations. 

 

South Yorkshire Police provided us with information recognising the importance of working with specialists such as ISVAs and child independent sexual violence advisors to support child sexual exploitation survivors, help police maintain contact with survivors, and help officers gather evidence.  

They described the process they follow to make a referral to these services, explaining the need to obtain a victim or survivor’s consent or that of a parent/guardian.  

However, the local ISVA service manager told us that when an investigating officer does not fully understand or explain the ISVA role, this can directly impact whether or not someone provides consent for their contact details to be passed on. This has the effect of delaying any contact with and support from the ISVA service.  

Additionally, ISVAs are not always used as effectively as they could be. Sometimes they are used just to pass on updates instead of there being any direct contact between the officer and the survivor. Sometimes they are not used at all. 

Recommendation 7 The IOPC recommends South Yorkshire Police continues to work with the local ISVA service to improve its working arrangements.  This should include:  

  • a named point of contact at South Yorkshire Police for use by the ISVA service ensuring that South Yorkshire Police representatives who have contact with victims and survivors fully understand the ISVA service’s role and can explain this to others when needed  

  • agreement on how updates are provided to victims and survivors  

  • how the ISVA service could be involved in South Yorkshire Police training to help raise awareness about its role and responsibilities and how they can work together 

  • Working with the local community 

 

When investigating the handling of child sexual exploitation in South Yorkshire, we found there were missed opportunities to approach community leaders for their views on how to develop community cohesion and/or identify any actions South Yorkshire Police could consider to help tackle child sexual exploitation.  

South Yorkshire Police told us it has started a mapping exercise across its four districts to ensure it has contacts in all identified communities to respond more promptly in the future to their needs, understand the potential impact of any national or international incidents on them, and to offer reassurance and support when necessary. 

Recommendation 8 The IOPC recommends that during its mapping exercise South Yorkshire Police continues to engage with communities to strengthen and build trust and confidence in the police service to encourage a willingness to provide information/intelligence to help tackle local issues.  

 

Areas for further consideration and recommendation 

In addition to the recommendations detailed above, we identified further areas we invite forces and policing stakeholders to reflect on and consider whether further action needs to be taken. Recommendations in this section are made under Section 10 of the Police Reform Act.11  

In light of the public concern about Operation Linden, we would strongly encourage named organisations to provide a written response to the additional recommendations we have made under section 10.  

Long-term impact on survivors of exploitation 

Many survivors we spoke to during our work on Operation Linden now have criminal records as a result of their actions when they were being exploited. The Crown Prosecution Service recognises in its Guidelines on Prosecuting Cases of Child Sexual Abuse that:  

“victims may sometimes commit what is called 'survival crime', i.e. committing crime to find safety or committing crime to ensure justice. An example of this is damaging property belonging to the offender or an associate. Offending might also be a reaction to the abuse which a child or young person is suffering, i.e. externally expressing their internal trauma. The victim may also have committed an offence whilst under the influence of the abuser and this may be used by the abuser as a means of controlling the victim and deterring them from making a complaint about the abuse they are experiencing.” 

As a result, survivors’ lives have been adversely impacted and this has affected issues like employment.  

The criminalisation of exploited children also crosses over into child criminal exploitation. If a child is viewed as a ‘criminal’ this may affect the way they are dealt with by the police and the likelihood of appropriate safeguarding action being taken.  

Looking beyond criminal actions to the underlying reasons behind them is a key part of police officers using their professional curiosity. However, we also recognise that there is a difficult balance to strike in that if the police took no action against children and young people this could make them more vulnerable to exploitation.  

Section 45 of the Modern Slavery Act 2015 created a non-prosecution principle for victims of trafficking or modern slavery, however this does not apply clearly to child sexual exploitation. The national protocol on reducing unnecessary criminalisation of looked-after children and care leavers published jointly by the Department for Education, Home Office and Ministry of Justice in 2018 states: 

“Every effort should be made to avoid unnecessary criminalisation of looked-after children and care leavers, including through prevention activity. This is in recognition of the fact that looked-after children’s experiences can contribute to behaviours that make them particularly vulnerable to involvement in the youth justice system, potentially affecting their future life prospects.”  

It recognises that looked-after children and care leavers can be particularly vulnerable to exploitation and states that “any decision to charge and prosecute a young person should take into account whether their actions are due to such exploitation or human trafficking or modern slavery.” 

The same considerations in terms of both prevention and decisions about charging and prosecution could be applied more widely to other children and young people who are at risk of, or victims of, exploitation in addition to those who are looked-after or care leavers. 

Recommendation 9  The IOPC recommends that the Law Commission reviews the legislative framework around offences committed while a child or young person is being groomed or exploited to identify whether any changes to legislation would be appropriate to reduce the impact on their future life prospects. This should include both the availability of substantive defences and the potential to filter convictions which occurred in such circumstances during criminal records disclosure. 

 

Sharing information across force borders 

In some of our investigations, girls were found in cars with older men. South Yorkshire Police has provided information about the steps they have taken to equip officers to understand the potential risks to children and young people in this situation and what questions should be asked of the occupants when this happens. We spoke to some roads policing officers who confirmed this is the case.  

However, the roads policing officers also said they sometimes encounter incidents of this type where someone had crossed the border from another police force area. They described the threshold for sharing information in this situation as ‘quite high’ and told us that individual police force systems are generally not visible to officers in another area.  

Once someone crosses a force border, they are only able to see any information that is on the Police National Computer (PNC). To access any additional information they would need to email a request to the other force and wait for a response, which could take a while and expose vulnerable children and young people to further risk. This is a significant issue as it has the potential to delay any opportunities to protect and safeguard a child who has been taken across a force border. 

Recommendation 10 – The IOPC recommends that the Chair and CEO of the Police Digital Service consider whether existing ICT solutions could be used differently or any changes to ICT (and any other supporting systems and protocols) are required to enable frontline officers to have more immediate access to relevant information from other forces to enable them to more effectively protect and safeguard vulnerable people. This should include working with the NPCC to encourage good practice across forces.  

 

Ensuring learning is actioned and embedded 

South Yorkshire Police has told us about many changes it has made since the matters we investigated took place. We have not assessed whether these changes have led to improvements in practice but remain worried that despite multiple reports and recommendations, there are still areas of concern. 

South Yorkshire Police was the subject of an HMICFRS national child protection inspection in May 201412 and a post-investigation review in April 2015. The post-inspection review recommended that South Yorkshire Police continue to work to put into effect the recommendations made in 2014 to ensure that they were fully implemented.  No joint targeted areas inspections have been carried out in the South Yorkshire Police area to date. 

Additionally, the ISVA service manager told us that although they had seen some improvement in 2015-16, there had been some deterioration since then. 

We have shared these recommendations and in due course will share our full report with HMICFRS to inform any future inspection work in relation to South Yorkshire Police.

It is important for public confidence that local communities and stakeholders understand the progress that South Yorkshire Police has made and continues to make in this area since the cases we have investigated. Through its community and stakeholder engagement, South Yorkshire Police can not only provide this reassurance on an ongoing basis but also understand the experiences of those who have had contact with the police and use this to feed into continuous improvement in this area. 

Recommendation 11 - The IOPC recommends South Yorkshire Police considers how it can assess and demonstrate the impact of action taken to address issues in handling child sexual exploitation. This should include how it understands whether actions have achieved the intended effect and considering how they inform the community of progress made to help improve public awareness and confidence. 

 

One of the key findings in Operation Linden was that the issues around child sexual exploitation were not recognised quickly enough and officers were not equipped sufficiently with the skills or experience they needed to deal with the problems they were faced with. Training and development activity can play a key role in preventing this happening in future, particularly with new or less common crime types.  
We acknowledge that the policing landscape means that police forces, either individually or collectively, receive requests from multiple sources to provide extra training on different priority areas of policing and demand will often outstrip capacity. A more strategic and collaborative approach to identifying and responding to priorities across England and Wales could support police forces, provide more consistency and streamline the work required to develop and deliver resources and training. 

Recommendation 12The IOPC recommends that the College of Policing and NPCC work together to explore the creation of a forum to identify the major issues for policing, agree priorities for learning and development at a national level and provide leadership, advice and support to police forces. It is anticipated that such a forum would involve as a minimum the College of Policing, NPCC, IOPC and HMICFRS. Such an approach would also need to take into account the need for individual chief officers to make their own decisions about priorities taking into account local context and issues. 

 

Other areas of learning we considered 

We are not an inspectorate and South Yorkshire Police’s current practice did not form part of our investigations under Operation Linden.  However, it was important for us to identify policing practice had changed sufficiently in areas of concern. We sought assurance from South Yorkshire Police, stakeholders and information available from inspections carried out by other bodies and concluded there was little benefit in making additional recommendations.  

For transparency, the additional areas we considered are detailed below. 

Leadership 

An absence of strategic leadership was an issue which was raised across multiple Operation Linden cases. We considered whether to make a recommendation about leadership and specific points of focus for child sexual exploitation at a senior level. 

In 2019, HMICFRS published a thematic report on national child protection inspections it had carried out.

A section about the roles of leaders and leadership states that “in every force we have visited we find senior leaders, PCCs, frontline officers and staff who are committed to keeping vulnerable children safe”.  
It also says that “Without exception, PCC police and crime plans, and force priorities reflect an unambiguous commitment to the protection of children and other vulnerable people”.  

While the report recognises some issues still exist including capacity, the ability to develop more preventative approaches and a lack of consistency, it also notes that police leaders are more aware of the need to ensure governance and processes support better outcomes for children, forces know more about the wider context surrounding child abuse and understand the need for plans to tackle all the different features of the abuse and exploitation of children. 

Each police force in England and Wales has a member of the Senior Command Team who has responsibility for child protection, often as part of a wider portfolio of protecting vulnerable people or safeguarding. South Yorkshire Police has an Assistant Chief Constable who as part of their responsibilities for Specialist Crime Services, is responsible for Public Protection and Safeguarding. It also has a strategic lead for child abuse at detective chief inspector level. 

Professional curiosity 

In many of the cases we investigated we found a lack of professional curiosity on the part of officers. Rather than looking at the broader picture and identifying potential safeguarding concerns, officers often focused only on looking at specific crimes. We considered how the approach to professional curiosity had changed in South Yorkshire Police and more widely. 

At a national level, the College of Policing developed and began delivering a one-day vulnerability training package in 2018. The package encourages frontline officers and staff to look beyond the obvious and feel empowered to use their professional curiosity when dealing with those who are vulnerable. The training focuses on early intervention by equipping frontline officers and staff to identify signs of vulnerability and take effective action at the earliest possible opportunity. 

This training package, among others, is used by South Yorkshire Police to train relevant staff. At the time we spoke to South Yorkshire Police training had been delivered to all Protecting Vulnerable People Officers (160), Uniform Response and Neighbourhoods Officers (1138), PCSOs (143), Investigations Officers (87), Enquiry desk staff, Operational Support Services, Atlas Court Communications staff, Special Constables (70), Custody Staff (106) partners from NHS (149) and the Fire Service (340).  

Use of protective orders  

We had concerns about South Yorkshire Police’s use of Risk of Sexual Harm Orders and Abduction notices. We found that South Yorkshire Police had the option of using these orders during the period we have investigated but found little evidence that it was. Officers in Sheffield appeared to be using them but officers in Rotherham were not. We asked South Yorkshire Police if these orders were used now, by whom, if there were any guidance documents and policies regarding their use, how the Public Protection Unit (PPU) staff use them and whether districts are now working together and communicating regarding the use of orders. 

In 2015, Civil Risk of Sexual Harm Orders were replaced by two new civil orders – Sexual Risk Orders (SRO) and Sexual Harm Prevention Orders (SHPO).  A Sexual Risk Order is used to impose restrictions on a person’s behaviour where the police consider that they pose a risk of sexual harm to the public. This does not require there to have been a criminal conviction. Sexual Harm Prevention Orders are generally used following a conviction for a sexual or violent or other dangerous offence listed in Schedule 3 or Schedule 5 of the Sexual Offences Act 2003. 

South Yorkshire Police told us its primary aim would be to secure a criminal conviction and Sexual Harm Prevention Order so there is a larger number of these than Sexual Risk Orders. It advised it is now a routine consideration for investigators within the Protecting Vulnerable People teams to apply for a SHPO as part of a criminal prosecution for relevant offences.  

While there is no force policy on the use of SHPOs, South Yorkshire Police told us how it promotes its use through staff development. This includes a training session aimed at all Protecting Vulnerable People investigators including details on how and when to apply for an order, effective SHPO conditions and case studies to demonstrate best practice. The use of SHPOs is measured in force through the senior leadership group and forms part of the performance framework which is currently under development. 

South Yorkshire Police also told us how it uses Child Abduction Warning Notices (CAWN) as a safeguarding tool. It advised that between April 2015 and March 2020 a total of 588 CAWNs were issued across the force area. A review and audit of the use of CAWNs was carried out by the Protecting Vulnerable People Performance and Governance team in 2020 which prompted revision of a force procedural instruction. South Yorkshire Police is currently developing training for frontline officers and staff to highlight these revisions. 

The College of Policing has Authorised Professional Practice which provides guidance on SHPOs, SROs and CAWNs.  

The Home Office also provides statutory guidance on Part 2 of the Sexual Offences Act 2003 which includes a chapter on civil orders. This covers both SHPOs and SROs and includes what the orders are, applying for them, specific information about gangs, interim orders, the role of the CPS, time limits, procedure in court, legal aid, reporting restrictions and various other topics. When making an application for a SHPO or SRO, officers are obliged to have regard to this guidance. 

Earlier identification of children at risk of or victims of child sexual exploitation 

Early identification of children who are at risk of or victims of child sexual exploitation can enable appropriate support to be put in place and for them to be diverted from committing offences themselves rather than being criminalised. We considered whether to make a learning recommendation to address this alongside our recommendation about a review of the statutory framework surrounding offences committed while a child is being exploited. 

As part of our consideration we consulted with a range of bodies and looked at the work and initiatives that are already ongoing that may contribute to this. 

In January 2021 the Government published the Tackling Child Sexual Abuse Strategy. This sets out a whole-system response to all forms of child sexual abuse. It sets out measures for early intervention and prevention, including equipping frontline safeguarding partners with the tools and training to identify CSA, and raising awareness through communications and engagement with parents. 

The £13.2 million Trusted Relationships Fund is currently funding 11 local authority-led projects across England working with children and young people, aged 10-17, who have been identified locally as at risk of child sexual exploitation or abuse, child criminal exploitation and peer on peer abuse. The work is aimed at building resilience to harm through fostering health, trusting relationships with responsible adults. It also aims to improve understanding emerging local threats and reduce victimisation of children at risk of exploitation. Evaluation of this will add to the evidence base on what works to protect children and young people from abuse and exploitation and feed into future policy making. 

The Home Office is funding a prevention programme, delivered by the Children’s Society which works with a range of partners across England and Wales to tackle and prevent CSA, CCE and Modern Slavery Human Trafficking. This involves work at a local and regional level to combat exploitation and deliver tailored interventions, based on police intelligence, to improve collaboration in prevention of exploitation, help identify hot spot locations, priority areas and specific threats in each region. It has helped increase professional understanding of exploitation, leading to increased victim identification and is seeing a shift in local areas responding contextually, holistically, and more proactively to extra-familial threats. 

In addition to this, work has been carried out within policing to increase the likelihood of early identification and intervention of those at risk or victims of child sexual exploitation. This includes improved guidance and training as referenced elsewhere in this report and the police-led Vulnerability Knowledge and Practice Programme (VKPP) to improve the strategic policing responses to vulnerability at a local and national level, leading to longer term reductions in threat, harm and risk in all vulnerability threat areas.  

Case ownership and supervision 

In some of our investigations we found there was a lack of supervision. It was unclear who was responsible for the police investigations, the allocated actions and finalisation of the investigation. We asked South Yorkshire Police how it ensures it is clear who is responsible for a case and any other allocated actions and roles. We also asked how investigation plans are developed, how line management review cases and what checks are made before a case is finalised. 

South Yorkshire Police told us a supervisor (detective sergeant rank) will allocate investigations to individual officers and investigators. The allocated officer is recorded on the Connect computer system and clearly shown on the first page of an investigation report. 

A bespoke investigation plan is completed on the Connect system. Cases are reviewed every 28 days by the supervisor and this is documented. These reviews include consideration of both lines of enquiry and welfare.  

The supervisor goes through the investigation plan with the allocated officer and looks at what they still need to do. An inspector rank will review any active cases that are over four months old, documenting the progress of the investigation and any outstanding lines of enquiry. 

When an investigation is finished, South Yorkshire Police advised a closure report is completed by the allocated officer detailing the action taken against each point of the investigation plan. These closure reports are then reviewed by the supervisor. Dip sampling of cases is carried out to monitor quality. 

In 2020 the College of Policing consulted on guidelines for supervisors. These will provide guidance on how to effectively support people across all levels of policing, staff and volunteers. The IOPC provided feedback as part of this consultation based on what we have seen in Operation Linden investigations and other areas of our work. 

Multi-agency working 

Information about concerns was shared in multi-agency meetings but social workers were often left frustrated at the lack of direction and action from South Yorkshire Police. Roles and relationships between different agencies were not always clear.  

We considered various aspects of multi-agency working and whether any recommendations may be beneficial including structural aspects, more collaborative leadership and collective problem solving to address these issues. We asked South Yorkshire Police how it now works with partner agencies to safeguard children. 

South Yorkshire Police told us it has Local Referral Units (LRUs) in each of its four districts. The officers and police staff who form the LRU are co-located with partner agencies within the four Multi Agency Safeguarding Hubs (MASH), one in each local authority area, which operate in accordance with the Working together to safeguard children statutory guidance. Each local authority also has individual arrangements to reflect local need and demand. 

South Yorkshire Police advised the LRUs receive and research all reports of concern for children and share information with statutory partners. This shared information is used to make a joint risk and safety planning assessment. If it is believed that a child is or may be at risk of significant harm, a strategy meeting will be convened with the required core partners and any other persons able to share relevant information or assist in addressing identified risks. They also said that South Yorkshire Police should encourage its partners to submit intelligence on an ongoing basis and not wait until the next multi-agency meeting. 

From the feedback provided by South Yorkshire Police, all partners agree that the hubs are working extremely well. They have facilitated timely and detailed information sharing, enhanced shared assessment of risk and much broader safety planning to protect children.  

An Ofsted focused visit to Rotherham children’s services in October 2020 found that “Effective multi-agency working in the multi-agency safeguarding hub (MASH) and the wider partnership means that children and families receive an appropriate service to identified need” and that “Management direction and decision-making in the MASH are timely, appropriate and, in most cases, clearly recorded.”  

Reports of Ofsted to visits to Sheffield (2019) and Barnsley (2018) contain similarly positive comments. The report in relation to Doncaster (2020) said that the response to contacts and referrals was not yet consistently timely but that partnerships are developing and this is contributing to improved information sharing and consideration of thresholds. 

South Yorkshire Police also advised its child sexual exploitation officer has developed strong links with all four local authority areas across South Yorkshire and encouraged partner agencies, business and local communities across the region to identify and act upon the signs of child exploitation. This has included work with Barnardo’s and Fearless40 and raising awareness in hotspot communities across South Yorkshire. 

Training and involving other agencies in training 

Many officers told us they had no knowledge or understanding of child sexual exploitation at the time of the events we investigated, and they were not informed in briefings about issues in the area.  
We asked South Yorkshire Police what improvements in training it had made since 2013, including training jointly with other agencies. They detailed various training programmes that have taken place in relation to child sexual exploitation and child sexual abuse.  

Detectives working in child protection must attend the accredited Specialist Child Abuse Investigator Course (SCAIDP) to be an accredited child abuse investigator. SCAIDP is jointly trained with police officers and social workers to reflect real life where they would be working together. 

The College of Policing Authorised Professional Practice (APP) on Major Investigation and Public Protection sets out expectations for training in relation to investigating child abuse and safeguarding children. 
The child sexual exploitation training delivered by South Yorkshire Police was developed with the College of Policing and Barnardo’s and incorporated the learning points from the Jay report. Joint training has been carried out with an academic from Sheffield University which helped with looking at how complex models of child sexual exploitation were. The training included the different routes and pathways of child sexual exploitation and some of the situations young people might find themselves in where they are entrenched in the exploitation, unable to get themselves out and unable to tell anyone. 

South Yorkshire Police is working on joint training with children and adult services around exploitation, trafficking and modern slavery. It has worked with local councils, the National Police Chiefs’ Council and other police forces to identify and share good practice. They also told us they are delivering joint training to vulnerable people, children and organisations to educate others about child sexual exploitation. 

Record keeping 

Our investigations saw issues where previous versions of South Yorkshire Police operational policing policies, job descriptions or other documents were no longer available and hampered us from looking at the procedures and standards expected of officers and staff at the time.  

We were also unable to review older records such as the operational intelligence system and missing persons records as they had been deleted. We asked South Yorkshire Police several questions about record keeping including how it stores previous versions of documents, how long for and how people know which is the current version of a policy. 

South Yorkshire Police advised it has a policy which is compliant with the National Police Chiefs’ Council (NPCC), National Guidance on the Minimum Standards for the Retention and Disposal of Police Records which directs that policies should be kept for 10 years. It told us that previous versions of policy documents are now archived in a central drive with access restricted to members of the policy team. 

All policies and procedures are published on the force intranet and only the current version of the document can be accessed. Each time an amendment is made, the system automatically saves the previous version of the document in full. Each document has a date stamp at the bottom of the page which also details who made the amendment.  

South Yorkshire Police created a Chief Information Officer role in May 2018. This role is responsible for Management of Police Information (MoPI), data quality, legacy data systems and decommissioning, creating and updating policy on retention and disposal of paperwork, property and electronic data in line with the NPCC National Retention Schedule. The Chief Information Officer is also responsible for creating and building a force archive to store paperwork and property which the force is under a legal duty to retain. 

As well as the NPCC documents mentioned above, the College of Policing has published Authorised Professional Practice on the Management of Police Information.  

We also reviewed HMICFRS inspections of South Yorkshire Police over the last five years. Record keeping was not noted as an issue. 

Tracing individual officers 

In one of the cases we investigated, the complainant did not know the name of the traffic officer who had stopped the car she was in with a child sexual exploitation perpetrator but described them as Asian. We were unable to identify the officer because records from the time could not be searched by officers’ department or ethnicity. South Yorkshire Police has told us that its systems do now allow for HR systems to be searched by individual characteristics, such as age, rank, location/department and ethnicity.  More steps could be taken to identify officers if a complainant was only able to provide limited information. 

Authorised Professional Practice 

We considered whether any of the issues arising from Operation Linden investigations would require amendments to Authorised Professional Practice (APP).  

APP is guidance authorised by the College of Policing as the official source of professional practice on policing. Police officers and staff are expected to have regard to APP in discharging their responsibilities unless there is a clear rationale for deviating from it. 

APP is subject to regular review by the College of Policing either on a scheduled basis or as required. At the time of writing, the APP on child sexual exploitation was last updated in January 2020 and the broader major investigation and public protection APP within which it sits was last updated in March 2021.

We did not identify any areas that required updates to APP. 
 

An act of parliament that provides the core framework of police powers to combat crime and provide codes of practice for the exercise of these powers.
Leads and manages the development of the police service in England, Wales and Northern Ireland.
The body that represents the interests of all police constables, sergeants, and inspectors.
Deals with someone’s inability or failure to perform to a satisfactory level, but without breaching the Standards of Professional Behaviour.
Focuses on putting an issue right and preventing it from happening again by encouraging those involved to reflect on their actions and learn. It is not a disciplinary process or a disciplinary outcome.
Department within a police force that deals with complaints and conduct matters.
Refers to lower-level misconduct or performance-related issues, which are dealt with in a proportionate and constructive manner.
This means doing what is appropriate in the circumstances, taking into account the facts and the context in which the complaint has been raised, within the framework of legislation and guidance.
The average is calculated using the individual results of the forces in that most similar force group.
An investigation carried out by IOPC staff.
Carried out by the police under their own direction and control. The IOPC sets the terms of reference and receives the investigation report when it is complete. Complainants have a right of appeal following a supervised investigation (unless it is an investigation into a direction and control matter).
This act sets out how the police complaints system operates.
How a police force is run, for example policing standards or policing policy.
An investigation carried out by the police under the direction and control of the IOPC.
The organisation that is responsible for assessing how to deal with a complaint. For example – whether it can be handled locally or reaches the criteria for referral to the IOPC. The appropriate authority may be the chief officer of the police force or the PCC for the force. If a complaint investigation finds that someone has a case to answer for misconduct, the appropriate authority is responsible for arranging any misconduct proceedings. If you make a complaint, the appropriate authority for your case will contact you.
An intelligence-led agency with law enforcement powers, it is also responsible for reducing the harm that is caused to people and communities by serious organised crime.
Policing bodies include police and crime commissioners, the Common Council for the City of London, or the Mayor's Office for Policing and Crime.
Investigations carried out entirely by the police. Complainants have a right of appeal following a local investigation (unless it is an investigation into a direction and control matter).
IOPC guidance to the police service and police authorities on the handling of complaints.
A complaint or recordable conduct matter that doesn’t need to be referred to the IOPC, but where the seriousness or circumstances justifies referral.
Parameters within which an investigation is conducted.
A person is adversely affected if he or she suffers any form of loss or damage, distress or inconvenience, if he or she is put in danger or is otherwise unduly put at risk of being adversely affected.
This is where a manager deals with the way someone has behaved. It can include: showing the police officer or member of staff how their behaviour fell short of expectations set out in the Standards of Professional Behaviour; identifying expectations for future conduct; or addressing any underlying causes of misconduct.
This could be the Police and Crime Commissioner, the Common Council for the City of London, or the Mayor's Office for Policing and Crime.
A flexible process for dealing with complaints that can be adapted to the needs of the complainant. It may involve, for example, providing information and an explanation, an apology, or a meeting between the complainant and the officer involved.
A flexible process for dealing with complaints that can be adapted to the needs of the complainant. It may involve, for example, providing information and an explanation, an apology, or a meeting between the complainant and the officer involved.
A breach of standards of professional behaviour by police officers or staff so serious it could justify their dismissal.
A matter where no complaint has been received, but where there is an indication that a person serving with the police may have committed a criminal offence or behaved in a manner that would justify disciplinary proceedings.
Disapplication means that a police force may handle a complaint in whatever way it thinks fit, including not dealing with it under complaints legislation. This may only happen in certain circumstances where the complaint fits one or more of the grounds for disapplication set out in law.
The ending of an ongoing investigation into a complaint, conduct matter or DSI matter. An investigation may only be discontinued if it meets one or more of the grounds for discontinuance set out in law.
Quarter 1 covers 1 April - 30 June Quarter 2 covers 1 April - 30 September Quarter 3 covers 1 April - 31 December Quarter 4 covers the full financial year (1 April - 31 March).
You can request a review/appeal if you’re not satisfied with how your complaint has been handled.
Used to house anyone who has been detained.
Complainants have the right to appeal to the IOPC if a police force did not record their complaint or notify the correct police force if it was made originally to the wrong force.
The purpose of an investigation is to establish the facts behind a complaint, conduct matter, or DSI matter and reach conclusions. An investigator looks into matters and produces a report that sets out and analyses the evidence. There are three types of investigations: local, directed and independent.
The ending of an ongoing investigation into a complaint, conduct matter or DSI matter. An investigation may only be discontinued if it meets one or more of the grounds for discontinuance set out in law.
The type of behaviour being complained about. A single complaint case can have one or many allegations attached.
A person who makes a complaint about the conduct of someone serving with the police.
The ending of an ongoing investigation into a complaint, conduct matter or DSI matter. An investigation may only be discontinued if it meets one or more of the grounds for discontinuance set out in law.
List of officers and staff who have been dismissed from policing, or would have been if they had not retired or resigned.
The type of behaviour being complained about. A single complaint case can have one or many allegations attached.
Disapplication means that a police force may handle a complaint in whatever way it thinks fit, including not dealing with it under complaints legislation. This may only happen in certain circumstances where the complaint fits one or more of the grounds for disapplication set out in law.
An independent judicial officer, the coroner enquires into deaths reported to him/her.
A breach of the Standards of Professional Behaviour that would justify at least a written warning.
No further action may be taken with regard to a complaint if the complainant decides to retract their allegation(s).
A record is made of a complaint, giving it formal status as a complaint under the Police Reform Act 2002.
This is a format where information is written in plain English and short sentences.
The IOPC must be notified about specific types of complaint or incidents to be able to decide how they should be dealt with.
No further action may be taken with regard to a complaint if the complainant decides to retract their allegation(s).
Casework involves assessing appeals. Casework staff also have a role in overseeing the police complaints system to help ensure police forces handle complaints in the best possible way.
Disapplication means that a police force may handle a complaint in whatever way it thinks fit, including not dealing with it under complaints legislation. This may only happen in certain circumstances where the complaint fits one or more of the grounds for disapplication set out in law.
Conduct includes acts, omissions, statements and decisions (whether actual, alleged or inferred). For example: language used and the manner or tone of communications.
You can request a review/appeal if you’re not satisfied with how your complaint has been handled.
You can request a review/appeal if you’re not satisfied with how your complaint has been handled.

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