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Complaints Handling

1. Introduction

As the Police and Crime Commissioner for Warwickshire, I know that our police officers and staff work incredibly hard to serve our communities. Whilst they endeavour to deliver an outstanding service to all the county’s residents and communities, I know that on occasions this unfortunately does not always happen and sometimes mistakes are made and public expectations are not met.

In such instances, I am determined to ensure that any errors are quickly rectified and lessons are swiftly learnt. This will serve to increase public confidence in the conduct of the force’s officers and staff and improve the service that Warwickshire Police provides to meet the needs of the county’s diverse communities.

I hope that the following information and narrative will illuminate the important subject of police complaints, and in doing so provide reassurance as to the guidance processes, scrutiny and assurance that is applied to both the force and my own performance in this critical area of police legitimacy and accountability.

Philip Seccombe

Police and Crime Commissioner for Warwickshire

2. Specified Information Order

The Elected Local Policing Bodies (Specified Information) (Amendment) Order 2021 requires the Police and Crime Commissioner to publish a link on their websites to the Independent Office for Police Conduct (IOPC) annual statistics report and publish the most recent quarterly complaints data for their force. The data and reports are to be published within one month of publication by the IOPC and reviewed quarterly.

At the time of publishing by the Commissioner, a narrative must also be provided   setting out how the Commissioner is ‘holding to account’ the Chief Constable for the complaint handling performance of the police force, together with an assessment of the Commissioner’s own performance in carrying out certain statutory complaint handling functions.

This report encompasses both the IOPC’s latest published annual statistics for 2022/23, and the IOPC statistics for Q1 2023/24 (1 April 2023 to 30 June 2023).

3. Annual complaint statistics

The IOPC ‘Police Complaints statistics for England and Wales report –  2022/2023’ was published on 5 October 2023, it can be viewed at: –

The Acting IOPC Director General provided the following comments on the report:

“Our annual police complaints statistics broadly reflect public concern with day-to-day policing issues and the level of service that people directly experience, rather than high-profile police misconduct cases that have repeatedly dominated news headlines. 

It is notable that by far the most commonly recorded complaint type continues to relate to police service delivery such as a lack of updates or delays in responses, rather than concerns around police misconduct.

The 8% rise in the total volume of complaints is likely linked to the simplifying of the system and the widening in the definition of a complaint to ‘any expression of dissatisfaction’.

While needing to be treated with caution, this year’s figures suggest more complaints are being dealt with more quickly, as the new system intended, with fewer resulting in lengthy investigations. In many lower-level cases, investigations are being replaced with responses that are more proportionate with relevant explanations and apologies. I am pleased the figures indicate that over nine in ten people whose complaint was handled informally had it resolved to their satisfaction or did not wish to pursue it any further. 

It is also welcome that police forces have significantly improved how quickly they respond to complainants, almost halving from a previous average of nine working days, to five days.”

“I recognise there is more work needed to properly embed new ways of working in all forces to ensure we deliver a complaints system that is accessible for all, more straightforward, and better aligned to the needs of the complainant. 

I would encourage police forces, where possible, to focus on learning for individuals and themselves as an outcome. I believe that learning from reflection and the use of the reflective practice review process represent positive actions resulting from complaint cases and can help to prevent issues re-occurring. 

I would like to see the numbers of reviews requested reduce in the future and we will continue to work closely with forces and provide further handling guidance to help them get complaints right first time. However, while there is room for improvement and steps that police forces can take to improve how complaints are dealt with, I am heartened that this year’s figures indicate we are moving in the right direction in establishing a healthy complaints system, where people have confidence to raise concerns and in the knowledge they will be taken seriously.” 

4. Responsibilities

Complaints made against Warwickshire Police are primarily handled by the force’s Professional Standards Department (PSD), under the delegated responsibility of the Chief Constable. The IOPC has a statutory responsibility for investigating a small number of these complaints, in circumstances where the allegations are deemed to be more serious and / or sensitive.

The Police and Crime Commissioner for Warwickshire has a responsibility to ‘hold to account’ the Chief Constable for the strategic performance of Warwickshire Police – including complaint handling. Also, for conducting ‘complaint reviews’ for certain categories of complaints in circumstances where the complainant remains dissatisfied with the handling and / or outcome to their complaint.

5. Holding to account

The principal mechanism for the Police and Crime Commissioner (PCC) to ‘hold to account’ the Chief Constable for the performance of Warwickshire Police is through the monthly Governance Performance Board (GPB), which is also attended by senior officers from the police force and members of staff from the Office of the Police and Crime Commissioner (OPCC).

In addition to this strategic performance meeting, as part of the OPCC’s assurance arrangements regular meetings are held between the PCC and the Head of PSD to discuss performance issues to ensure that the OPCC and PSD teams work together to ensure that continuous improvement is made to the way in which complaints and complaint reviews are handled. At the meeting Key Performance Indicators (KPIs) are provided for discussion, including metrics on: –

  • the number of complaints recorded.
  • the timeliness of the response to complainants.
  • those complaints requiring a proportionate handling under Schedule 3 of the legislation.
  • the proportion of complaints that are subject to ‘service recovery’ outside of Schedule 3 of the Police Reform Act 2002.
  • any reoccurring themes identified from complaints and complaint reviews.

To complement these meetings and provide additional scrutiny and assurance, a system of dip-sampling of complaint cases is undertaken by the OPCC in conjunction with an independent member of the Joint Audit and Standards Committee (JASC). To provide further independent scrutiny and assurance, a report is submitted by the OPCC as an agenda item to meetings of the JASC. This report provides an overview of the force’s complaints handling performance and that of the OPCC complaint reviews.

6. Complaint handling

Some of the key performance metrics from the IOPC annual statistics report 2022/23 are: –

6.1. Complaints made

In February 2020, significant changes were made to the complaints system including widening the definition of a complaint to “any dissatisfaction with the police service”. As a result, more complaints have been logged than in previous years. The system also allows for more complaints to be handled informally, where appropriate, such as by an apology or explanation. A person can request a review if they are unhappy with the way their complaint was handled.

In 20222/23, Warwickshire Police recorded a total of 702 complaints, representing a small decrease on the previous year’s figure of 733 complaints. This figure translates into 375 complaints per 1,000 employees and is a marginal increase on the previous year. Amongst the 43 police forces of England and Wales the range varied between 82 and 736 complaints per 1,000 employees.
In 20222/23, Warwickshire Police dealt with 73% of complaints as ‘service recovery’ outside of Schedule 3. This compares to an average of 44% for the forces of England and Wales.

6.2 Complaint type

The IOPC records a broad range of categories as to the topic of a complaint.

In 2022/232, in Warwickshire the top three complaints topics were: –
1. Delivery of Duties and Service at 63%, with an average of 54% for the forces of England and Wales.
2. Powers, policies, and procedures at 14%, with an average of 20% for the forces of England and Wales.
3. Individual Behaviours at 11%, with an average of 13% for the forces of England and Wales.

6.3. Timeliness

The time taken to finalise a complaint varies according to whether it is dealt with outside of Schedule 3 of the Police Reform Act 2002 as a ‘service recovery’ matter or handled under Schedule 3 of the Act or handled ‘otherwise than by investigation’ (OTBI) under the same legislation.


In 2022/232, the average time to contact the complainant was 1 day and as such Warwickshire Police was one of the best performing forces in England and Wales with an average response time of 5 days.


The force also finalised ‘service recovery’ complaints in 36 days on average, longer than most forces. Those investigated under Schedule 3 as Otherwise by Investigation were finalised in 87 days on average, and those investigated were finalised in 129 days on average – both shorter than most forces.

7. Complainant satisfaction

Complainant satisfaction is assessed based on the outcome of complaint. For less serious complaints it is measured by PSD’s rate of service recovery that operates outside of Schedule 3 Police Reform Act 2002.

Where the complaint cannot be resolved to the complainant’s satisfaction then it is dealt with under Schedule 3 and consequently subject to either a reasonable proportionate investigation or handled Otherwise Than By Investigation (OTBI). The complainant is then afforded a right to review to the ‘relevant review body’, namely either the OPCC (as the Local Policing Body) or the IOPC depending upon the nature of the allegations.

8.  Complaint reviews

In February 2020, the ‘Police (Complaints and Misconduct) Regulations 2020’ came into effect. These reforms are aimed at making the police complaints system more responsive, independent and customer focused. The intention is to remove the focus of attributing blame when things occasionally go wrong, to one of learning and service improvement. The legislation permits Police and Crime Commissioners to select from one of three models available to implement locally: –

  1. Basic Statutory. This model provides Commissioners with improved powers of oversight to ‘hold to account’ the Chief Constable for the handling of complaints. It also requires the Commissioner to deal with complaint reviews in cases that do not meet the threshold to be dealt with by the IOPC.
  2. Triage. This model requires the Commissioner to operate the Basic Statutory model and additionally take on the on the initial handling, assessment, and resolution of complaints. More serious complaints are still required to be dealt with by the force.
  3. Customer Contact. This model requires the Commissioner to be operating both the Basic statutory and Triage models, and in addition the Commissioner can take on continued contact with the complainant throughout the complaints process to improve customer focus

8.1 Complaint review officers

The OPCC for Warwickshire continues to operate the Basic Statutory model, with the mandated responsibility to conduct complaint reviews. In 2021/22, the OPCC utilised the services of a dedicated Complaints Manager to fulfil this function, however this arrangement ceased at the end of the fiscal year. During Q1 2022/23, as an interim measure the OPCC contracted the services of an independent company to conduct the reviews. From Q2 2022/23 this responsibility was brought ‘in-house’ to the OPCC following an increase in capacity and is now conducted by two trained members of OPCC staff.

8.2 Complaint reviews

During the period 2022/23, the OPCC received a total of 32 applications for a complaint review and competed 37 within this same period.

In 2022/23, of the OTBI complaint reviews conducted 58% were ‘upheld’ in that the handling and / or outcome of the complaint by PSD was not considered to be reasonable and proportionate.

Of the investigation complaint reviews 33% were ‘upheld’ in that the handling and / or outcome of the complaint by PSD was not considered to be reasonable and proportionate.

These figures are broadly consistent with the reviews conducted by the IOPC at 44% and 32% respectively.

All recommendations or learning derived from a complaint review are forwarded to Warwickshire Police for consideration and tracked by the OPCC to their conclusion.

8.3 Quality assurance

In January 2022, the OPCC policies and processes in respect of complaint reviews were subject to an internal audit by Warwickshire County Council’s Audit team. A total of nine recommendations were made following the review, all of which were accepted and have now been completed. These include the production of a ‘Complaint Review Frequently Asked Questions’ report that is provided to those complaints seeking a complaint review.

8.4 Organisational learning

A complaint review will consider whether the complaint process was ‘reasonable and proportionate’, with recommendations made to the Warwickshire Police if the review is ‘upheld’. Any recommendations made to the force are monitored by the OPCC, although under the legislation the force does not have to accept the recommendations made.

Where recommendations concern a reoccurring theme or an issue of particular strategic importance, then the Police and Crime Commissioner is able to raise it with the Head of PSD through existing assurance mechanisms, or with the Chief Constable through formal reporting and ‘holding to account’ arrangements.

9. Continuous improvement

Regular meetings are held between representatives of the OPCC and the IOPC Oversight Liaison Officer to discuss performance in respect of complaint handling and complaint reviews. The meeting also provides a useful ‘sounding board’ to discuss and resolve any procedurally complexities in conducting reviews.

A Regional Practitioner’s Forum has been instigated, with a focus on complaint reviews providing an opportunity to identify themes and share good practice within the West Midlands region.

The Association of Police and Crime Commissioner Chief Executives (APACE) has restarted the National Complaints Network. The network discusses complaint reviews, the holding to account responsibility, persistent complainants, and police misconduct tribunals.

Through these meetings, forums, and networks there is a real desire to work together by sharing ideas and better understand the technicalities of the legislation and how best to interpret and implement it.

10. Complaints Statistics – IOPC Data Q1 2023/24

The ‘Warwickshire – Q1 2023/24 Police Complaint Information Bulletin’ is published on the IOPC website, it can be viewed at: –

Police complaints information bulletin Warwickshire Police – Q1 – 23/24

In compliance with the Specified Information Order, the information contained within the IOPC bulletin has been reviewed.

On 30 August 2023, these statistics were discussed at meeting held between the OPCC, PSD, and the IOPC Oversight Liaison Officer. The following key performance issues were identified: –

10.1 Warwickshire Police

  • Achieved excellent timeliness for contacting complainants (0 day) when compared to the national average of 5 days.
  • Recorded 184 complaints, representing a ratio of 95 cases per 1,000 employees and was marginally above the Most Similar Forces (Warwickshire’s are – Devon and Cornwall, Wiltshire, Gloucestershire, West Mercia, Cambridgeshire, Suffolk, North Wales) of 87 cases per 1,000 employees.
  • Managed more allegations as ‘service recovery’ issues outside of Schedule 3 (75%) than the national average (45%). The average time to deal with these allegations (19 days) was comparable to the national average (17 days). The allegations were resolved in 94% of the cases handled by this method.
  • Managed fewer allegations as OTBI under Schedule 3 (15%) than the national average (43%). The average time to deal with these allegations (175 days) was significantly above the national average (94 days). It had been previously identified through further evaluation of the data that a number of ‘outliers’ had distorted the OTBI mean figure for timeliness and that the median value was closer to the national average.
  • Managed fewer allegations as an investigation (8%) under Schedule 3 than the national average (12%). The average time to deal with these allegations (88 days) was significantly shorter than the national average (166 days).
  • The main category of allegations was ‘Delivery of duties and services’ (73%) with the sub-category of ‘Police action following contact’ accounting for the majority (52%) of this total. The predominate issue of complaint was ‘Investigation’. These percentages are significantly above the national averages (54% and 44% respectively). It was identified that Warwickshire Police’s recent implementation of its Empower operating model, with enhanced investigation as a cornerstone, should generate an improvement in this position.
  • The second largest category for allegations was ‘Police powers, policies, and procedures’ (12%) with the sub-category of ‘Use of Force’ accounting for the majority (38%) of this total. These percentages were inconsistent with the national averages (21% and 28% respectively).
  • There were no recorded allegations of ‘Discriminatory Behaviour’, nor of ‘Sexual Conduct’.

10.2 OPCC

Where a complaint has been recorded under Schedule 3 to the Police Reform Act 2002, the complainant has a right to apply for a review if they are dissatisfied with the way their complaint was handled, or with its outcome. This applies whether the complaint has been investigated or handled OTBI. The application for a review will be considered by the ‘relevant review body’ – either the OPCC (Local Policing Body) or the IOPC, depending upon the nature of the complaint.

From the IOPC data, in Q1 2023/24: –

  • The OPCC received 7 applications for a complaint review.
  • In 25% of the cases reviewed by the OPCC the handling and / or outcome of the complaint was found not to have been ‘reasonable and proportionate’.
  • The average time for the OPCC to conclude a complaint review (53 days) was comparable to the national average (56 days).

11. Assurance

11.1 Professional Standards Department

On 5 June 2023, a meeting was held between the Police and Crime Commissioner and the Head of PSD, together with representatives from their respective offices. The agenda covered PSD’s responsibility for police complaints, anti-corruption, and vetting. The meeting considered issues of capacity, capability, and resilience; performance; cases of reputational damage. A further meeting is scheduled for 9 October 2023.

11.2 Joint Audit and Standards Committee

The terms of reference for the JASC requires the committee to be enabled to have oversight and to provide an independent review of the effectiveness of the adherence to appropriate standards and ethics by Warwickshire Police, the Police and Crime Commissioner, and the Chief Constable.

On 5 July 2023, a meeting of the JASC was held at which a paper was submitted by the OPCC on the subject of ‘Standards and Ethics’, providing an opportunity to the committee to scrutinise, support, and challenge the Police and Crime Commissioner on this subject.

11.3 Complaint review dip-sampling

On 14 June 2023, a member of the JASC conducted dip-sampling of a random sample of recent complaint cases handled by PSD. The observations arising from this review were very positive with no concerns identified.

12. Continuous improvement

12.1 Ethics Committee

On 17 May 2023, a meeting of the Ethics Committee was held, at which both the OPCC and PSD were represented. The Chair of the committee is Associate Professor Catherine Hale from Warwick University Medical School, who has an extensive background in ethics, and law.

Two topics of dilemma were discussed: –

  1. A new policy initiated by the force’s Corporate Communications Department in relation of the media circulation of CCTV images of persons suspected of involvement in crime. This policy has arisen as a direct result of a police complaint, and an OPCC complaint review; these matters are currently subject to civil litigation against Warwickshire Police.
  2. Sexual objectification in circumstances where there is a perceived power imbalance – is there a double standard in the workplace where female objectification of men may be tolerated?