ICO Timeliness audit action plan

1.1 AB & JB to develop a simple dashboard style report that will demonstrate progress against the critical IRDP leadership elements concerning staff development and accreditation within this plan.

The report to be updated and presented at the fortnightly Information Rights Development Meetings. Specifically, the report will show:

• Evidence of compliance with 2.4 (Diarised 1:1’s including PDR 1:1’s)
• Evidence of compliance with 2.5 (PERS151’s etc)
• Evidence of compliance with 2.6 (training delivery)
• Number of accredited staff in primary workstreams against target the 6-month target number of accredited staff (see 4 Quality Assurance Framework)

7 May 2020

An Excel spreadsheet has been created and shows the position as at 5^th May 2020. This was a useful exercise that generated some useful conversations with the SIOs and their staff.

The content was derived from emails direct to the staff.

Proposal to re-do this exercise as at 5^th August.

Recommended for closure.

2.1. AB & JB to amend/create a training plan setting out what training should be undertaken by each role within the wider Information Management Department. 

23 Apr 2020

Completed 23 Apr 2020. 

Amendments made 20 May 2020 to reflect NPCC training communication.

2.2. AB & JB to amend/create training profiles setting out the specific training required for each role within Information Rights.

23 Apr 2020

Completed 23 Apr 2020.

Amendments made 20 May 2020 to reflect NPCC training communication.

2.3. AB & JB to amend/create/source training products to fulfil the training profile requirements.
Training products to include: SOP’s, PowerPoints, e-learning, external/EPC/internal, general/specific for role, group/solo

21 May 2020

SoPs and PowerPoints for Court Orders and RoA and Record Deletion are complete and have been delivered to the team.  There is a programme of regular review of each SOP (incl. FOI) to ensure that changes in business processes are captured as appropriate. This is under business as usual. 

The PowerPoint in relation to FOI is outstanding.

SOPs are in draft for Insurance, Legal Aid and Civil disclosures.  These are being developed and will be finalised as the Section spreads resource across the team to deal with secondary areas as well. 

This action will be closed once all the primary SoPs and PowerPoints are in place.  However, these are dynamic documents that continue to be amended as processes change.  Once the primary areas are completed the action will hibernate but will re-open as we commence work on the secondary areas.

2.4. AB, JB & SIO’S to diarise with their subordinate staff fortnightly 1:1’s with every third 1:1 to be a PDR review meeting.

Each meeting to result in a daybook entry and updates to objectives. Performance and attendance issues to be progressed in accordance with force procedure.

23 Apr 2020 then repeat as business as usual

Diarising completed 23 Apr 2020, now moved to business as usual.

2.5. AB, JB & SIO’S to review/amend existing PERS151’s for each member of staff informed by the training profile for their role, utilise Diarised 1:1’s, QA feedback, 6-weekly reviews against PDR objectives to refine PERS151’s (PIR Rec 7).  Where skills/experience already exists, this is to be documented on the PERS151 to demonstrate compliance with the training profile

21 May 2020 then repeat as business as usual

New PERS151 training plan was developed reflecting the new training role profiles.  Rolled out to all Information Rights & Data Quality team members with an action to return completed documents by 21 May 2020.

Completed for all staff, individuals maintaining their training plans as business as usual.

2.6. AB, JB, SIO’S & IO’s Undertake training/deliver training products in accordance with training profiles[1]

23 Apr 2020 onwards

The majority of staff are in Court Orders and Rights of Access and training has been completed.

There are a small number of people working in FOI and Record Deletion who are experienced.  Training materials for these areas are being reviewed.  Training for any significant changes will be delivered where necessary.

Information Sharing training has been delivered. 

Where training already exists, it is being booked by individuals as part of the completion of the PERS151 training plan. 

The undertaking of training will be monitored through the 1:1 and PDR process.  A specific objective has been set on all PDRs to ensure training as recorded on the Role Profile is complete.

Looking ahead, as the secondary work areas come back online training will be delivered as appropriate and subject to the experience of staff being realigned.

This is closed and now business as usual.

3.1. JB & DC to conduct a lean review of Rights of Access processes (PIR Rec 2) and present to AB for approval. Outcome to be documented in revised SOP, front sheet etc.

4 Jun 2020

The RoA SoP was presented to AB on 15^th May 2020.  20^th May 2020 - with JB for review.  The associated Front Sheet is complete.

New RoA Standard Operating Procedure, front sheet and QA process + documentation has been rolled out to the team inclusive of all changes to business processes. 

Action complete

3.2. AB & JB to develop a programme for lean review of other Primary workstreams and determine to what extent Secondary workstreams will require the same treatment.

4 Jun 2020

Court Order business processes have been reviewed and resulted in a new SoP, front sheet, QA process + documentation.  Rolled out to the team inclusive of all changes to business processes.

RoA see above (3.1)

Early Deletion business processes have been reviewed by the H.I.M, IRDQ, SIO and team members.  New SoP, front sheet complete and rolled out.

Freedom of Information  business processes have been reviewed and SoP rolled out to the team.

3.3. AB & TS to determine position regarding the continuance or not of existing policy which requires master copies of evidential media to be transported in person rather than internal mail (PIR Rec 11)

8 May 2020

Completed 23 Apr 2020 at meeting #1. Decision is to continue with current processes due to experience of material being lost in the internal mail and not recovered. The long-tern solution will be delivered by the DAMS project. In interim JB and DJ (Records Manager) to discuss possible improvements to current processes within the constraints now agreed.

3.4. SP to produce a report on the potential adoption of a Single online Home payment facility (PIR Rec 14)

7 May 2020

The url payment functionality has been made available to a number of members of Information Rights.  The facility will be used in the following areas:  Insurance, Civil Discretionary, Housing.

In relation to this, SOPs and associated template documents have been created/amended. 

3.5. JB to raise job with IT and obtain 2 additional licences for download of BWV, escalating as necessary. (PIR Rec 12)

23 Apr 2020

Completed 24th April 2020. 

3.6.  JB to review the approach to generic query resolution, streamline and necessary, continue to maintain, update and expand upon the FAQ Guidance document for the team

7 May 2020

Final version of FAQ Guidance published to the team.  Rota in place to provide daily cover of the Info Rights generic mailbox.  JB working with key departments to improve Force wide understanding of Info Rights and where to direct queries.  This action is complete; work will continue in order to reduce volumes received into Information Rights.

4.1. JB & SIO’ to determine and document in revised SOP’s the criteria for Accredited status for the primary workstreams

7 May 2020

Court Orders – action completed 6^th May 2020

RoA – action completed 4^th June 2020

Early Record Deletion – action completed 4^th June

FOI – action completed 4^th June

4.2. JB & SIO’ to review existing QA methodologies in the primary workstreams, amend where necessary, and document or update in SOP’s. This to include SIO dip-checking

7 May 2020

Court Order – complete

RoA – complete

FOI – complete

Early Record Deletion – complete. 

4.3. JB & SIO’ to classify existing IO’s as Non-Accredited or Accredited in each of the primary workstreams

7 May 2020

Court Order – 2 identified

RoA – 3 identified

FOI – 1 identified

Early Record Deletion – 2 identified

Recommend action for closure

4.4. JB & SIO’ to determine target number of Accredited IO’s after six months in primary workstreams

7 May 2020

Court Order – 4

RoA – 4

FOI – 3

Early Record Deletion – 3

Recommend action for closure

4.5. JB & SIO’ to update front sheets for primary workstreams so that outcomes of QA and any training requirements are apparent and can be progressed

7 May 2020

Court Order – Complete

RoA – Complete

FOI – N/a

Early Record Deletion – Complete

4.6. JB & SIO’ to brief IO’s on the adoption and launch of QA Framework and deliver necessary training on QA activity to Accredited IO’s. Launch.

14 May 2020

Complete for all areas. 

4.7. JB & SIO’ to update, if necessary, Section’s Staff Development Framework to reflect adoption of the QA Framework.

14 May 2020

Has not proven necessary.

Recommend for closure.

4.8. JB & SIO’ to add specific PDR objectives to subordinate staff arising from the adoption of the QA Framework

21 May 2020

An objective has been set for all accredited staff.

4.9. JB & SIO’ to apply 4.1 to 4.5 to secondary workstreams as they are restarted.

Variable

When the secondary workstreams are re-started the current position is that accreditation will not be necessary, this will be reviewed as each one goes live.

This action will be hibernated until work resumes and is stabilised in these secondary areas.

Court Orders

3

4

CW, GW, CD

NOTE:  Potentially CB will have also achieved the same standard by December 2020

Rights of Access

3

4

CW, HD, GW + (PC SR on Secondment)

NOTE:  JC will be accredited for basic and intermediate by 07/11/2020

FOI

4

3

PP, MH, KG, JC

Record Deletion

2

3

GW, SP 

NOTE:  JT will be training in this area during Q4’2020

5.1. AB & JB to produce a user requirement for the Information Rights’ requirements for a CMS in order that it can be supplied to the proposed 7F Programme (PIR Rec 1)

4 Jun 2020

User Requirement and Business Case have been finalised.  The procurement process is underway.  A project timeframe has been proposed by the IT Project lead following consultation with IT and Procurement which shows an implementation date of 31^st March 2021.  T/Ch.Supt. TS has been informed as this equates to a 6-month delay on the original expectation that the solution would be implemented in October 2020.

Completed.

5.2. Additional actions to follow as required by Procurement and IT Services

Various

Fortnightly checkpoint meetings have been set-up for the remainder of the year.  A project plan has been proposed by the IT Project lead.  Actions relating to the implementation of the solution will be managed via the Project with oversight from the Heads of Information Management for both Essex and Kent Police.

Completed.

6.1. JB & KN to ensure FOI Publication Scheme is populated, maintained and expanded.

Ongoing

This is business as usual work.  The growth of the publication scheme is being reported in the weekly Information Rights performance report and on the Risk Register.

Completed.

6.2. JB & SIO’s to review generic queries and enquires received, then identify and implement measures to make customers more self-sufficient e.g. through use of improved content on websites (internal and external).

Ongoing

Effectively a duplicate of 3.6 so closed 24 Apr 2020.

6.3. JB & NJ to continue engagement with Essex Legal Services and their Southend & Thurrock Counterparts to identify means of reducing demand from them.

Ongoing

No update from Thurrock or Essex Legal Services.

7.1. AB & JB to review the potential expansion of home working in the light of greater home working during COVID-19 pandemic

Conclusion of pandemic

AB is monitoring impacts of Home Working during pandemic through daily morning calls with managers.

w/c 17/08/2020 a new approach to office support will be rolled out from 01/09/2020 for the Information Rights Section.  Predominately staff will continue to work from home.

Completed.

8.1. AB to provide TS with an evaluation of the impact of synchronisation of each IO’s line management to the appropriate SIO above according to the IO’s main workstream and adjustment of them thereafter dynamically. (PIR Rec 8)

23 Apr 2020

Completed.

On 23 Apr 2020 TS agreed to defer progress against PIR Rec 8 on the basis that the activity to be reported under 1.1 will produce the necessary reassurance around supervisors’ leadership.

8.2 AB & AS to continue to deploy secondee staff where appropriate and offer further hours to SIO’s.

3^rd July 2020

Completed.

2 x SIOs have been extended until 31^st March 2021

1 x existing secondment returned to their substantive post on 7^th October 2020.

An advert for additional secondees (1 x full time; 2 x part-time) has been placed.  Closing date was 6^th October but no applications have been received.

PERS200 completed and submitted to HR for a part-time post (23 hours pw).

Finance and HR have been approached on all the above matters.

NOTE:  3 x Police Officers remain in placements with the Section.  All are allocated to processing Family Court Orders and Rights of Access Applications.  PIU are looking to find permanent posts for these individuals.

8.3. JB & LM to undertake a Resource Allocation Model exercise (RAM) for all roles once the CMS has been delivered. (PIR Rec 15)

31 Mar 2021

Dependent on completion of work in preceding tables.

8.4. AB to produce a report on proposed changes to resourcing once RAM has been undertaken. This will deliver the response to PIR Rec 10 which required consideration of the need for further Administrative Support and will enable a review/amend flexible working patterns of SIO’s. (PIR Rec 6)

31 Mar 2021

Dependent on 8.2

8.5. JB & SP to explore income generation and hypothecation opportunities (PIR Rec 13) and report to TS.

23 Apr 2020

Completed.

6^th May 2020 – DS, Finance confirmed that the Force policy containing the fee schedule has been published on SharePoint.

Recommended for closure