MBPA policy on time-scales for consultation
The policy consultation process has long been a source of debate. The Force continues to wrestle with how this should be carried out and by whom etc. One of the main issues from the MBPA perspective is the number of requests to provide comment, often with unreasonable timescales within which to do so. Examples include receiving an e-mail on a Friday to comment and then a second e-mail the following Monday, asking if we had had time to read and comment on it. There have been several others.
Exactly what constitutes 'reasonable' continues to be debated. MBPA believes the message this conveys is, that consultation is an afterthought. What this means from our perspective is that race is an afterthought. Instead of being mainstreamed, consultation and therefore race continues to be an afterthought. MBPA should be countering this, not contributing towards it.
The Chair has stated on numerous occasions (including at our AGM of 20th May 2005) that we must counter this and if need be, set the standards for others to follow.
The MBPA Executive committee has agreed that we will not provide feedback on any policies if said feedback is expected in less than 3 weeks. In addition, we often need to canvass our membership and this will always result in an additional logistical dynamic.
Merseyside Police is in the process of trying to improve and standardise the internal consultation process. The general consensus appears to be to introduce and establish one process for the whole Force. I broadly agree with the ‘one stop shop’ idea for consultation currently being expounded, particularly on policies. MBPA would be prepared to support a process which eliminates the unreasonable requests occasionally made of us. However, MBPA have stated that we reserve the right to provide comment on any document/policy/process in mitigating circumstances, as we see fit.
In the vast majority of cases, there is no reason why the formulation of a policy should not include appropriate time on which to consult. The Morris enquiry recommendation 22 states:
“That MPS commits itself to a code of practise setting out the basis on which it will consult its workforce. This should be based on the following principles:
A Consulting with an open mind whilst proposals at are at a formative stage.
B Giving consultees full information about proposals
C Ensuring that consultation information reaches those who are being consulted.
D GIVING CONSULTEES SUFFICIENT TIME TO RESPOND
E Considering carefully the results of consultation exercise and;
F providing consultees with full information about decisions taken at the end of the consultation period and, if relevant, the reasons for taking a different view from those who were consulted”.
However, not all consultation is related to policies but we have already declined several requests to comment with more envisaged. By stating less than 3 weeks to provide feedback is unreasonable to comment on policies, we have reduced ambiguity as to what constitutes ‘reasonable’.
MBPA wants to comment and shape how the Force operates, but in asking us to provide comment within an unreasonable timescale, we are in effect, being constructively excluded from the process: the conditions in which we are being asked to provide comment are an insurmountable obstacle in them self. By excluding MBPA from consultation, the Force’s Race Equality Scheme is likely being breeched for example.
This will be a matter for the Force & respective departments making such requests to explain to the C.R.E., the Community and Police Authority etc.
MBPA’s stance on this will hopefully act as a catalyst to improve standards within the Force.
Vinny Tomlinson
Chair, Merseyside Black Police Association
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