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Consultation on CPS Equality and Diversity Objectives 2015-2018 - summary of responses

October 14 2015

Introduction

This is a summary of the responses to the consultation on the CPS Equality and Diversity Objectives 2015-2018.

It sets out:

  • The background to the consultation;
  • A summary of the overall responses;
  • A summary of the responses to the specific questions; and
  • Our conclusions.

Further copies of the summary of responses can be obtained by contacting:

Christine Pember
Strategy, Policy and Accountability Unit
Private Office
Crown Prosecution Service
Rose Court, 2 Southwark Bridge Road
London SE1 9HS

Telephone: 020 3357 0766
or by email to: christine.pember@cps.gsi.gov.uk

Copies are also available on the CPS website: www.cps.gov.uk

Background

The public sector Equality Duty (PSED) requires public bodies to have due regard to the need to eliminate discrimination, advance equality of opportunity and foster good relations between different people when carrying out their activities.

The Equality and Diversity Objectives 2015-2018 outline our commitments in response to the legal requirements defined in the Equality Act 2010.

The CPS Equality and Diversity Objectives 2015-2018 have been developed through a sub group of our Community Accountability Forum (CAF). CAF's membership includes our community partners and representatives from our staff networks. Membership of the Group is detailed at Annex A. The CPS Board, CAF and our network of Equality and Diversity and Community Engagement managers were also consulted on our proposed objectives.

Five Objectives were developed encompassing the CPS obligations for employment and service delivery throughout 2015-2018;

  • (i) Governance;
  • (ii) Policy;
  • (iii) Hate Crime;
  • (iv) Violence Against Women and Girls; and
  • (v) Employment.

As part of the public and staff consultation, respondents were asked to answer three questions for each objective. The consultation period closed on 10 July 2015. A list of respondents can be found at Annex B.

This is the second Equality and Diversity Objectives report to be published by the CPS. Our Equality and Diversity Objectives for the period 2012-2015 and subsequent annual reports can be found on our website.

Summary of responses

In total there were 23 responses. Respondents were divided into the following categories:

  • Responses from individuals;
  • Responses from third sector organisations;
  • Responses from criminal justice agencies; and
  • Responses from CPS Community Panels, staff and staff networks.

Table 1: Table of respondent type

Category of Respondents Number Percentage of Total
Individual Respondents 1 4%
Third Sector Organisations 6 26%
Community Partners 8 35%
CPS Staff and Staff Networks/Representatives 8 35%
Total 23 100%

Not every respondent gave specific answers to each individual question in the consultation.

Each individual response under each objective has been reviewed by the CPS lead for that objective.

No. Objective Lead
1 Governance CPS Equality and Diversity Policy Advisor
2 Policy Senior Policy and Performance Advisor
3 Hate Crime Hate Crime Stakeholder Manager
4 VAWG Violence Against Women and Girls Strategy Manager
5 Employment Human Resources Strategy Manager

Not all of the respondents have followed the specific questions posed in the consultation document but the views of the respondents are reflected in the detailed analysis of the responses that follows.

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Summary of responses to specific questions

Objective 1: Governance

To consistently meet our legal obligations regarding equality in our approach to prosecutions, staff and structure.

Question 1: Is the Objective Clear?

There were 21 responses to this question and of these, 13 respondents felt that the objectives were clear.

One participant responded that the objective gives a clear commitment to take those obligations seriously and that external accountability, as set out, is key.

Of the remaining responses, suggested amendments were as follows:

  • More emphasis to be considered on the value of the feedback from the local LSIP panels to inform the CAF.
  • Make the objective to review recruitment and selection criteria within procured services clearer.
  • Include measurable criteria for success and make the actions SMART.
  • Publish a governance structure for Equality and Diversity.
  • Identify and include CPS specific aspirations in regards to Equality and Diversity.
  • Include an explicit statement in the document with regards to applying the principles of the Public Sector Equality Duty in the opening statement.
  • Make an assessment of equality and diversity gaps and challenges, reviewing actions taken, direction of travel and whether or not the CPS are making progress.

CPS Response:

We will better emphasise the partnership approach to working with our LSIPs and the feedback from LSIPs to CAF.

We will reword the objective to review recruitment and selection criteria in procured services to be clearer.

We will update the action within the plan to SMART actions and include a new action to refresh the CPS equality and diversity policy.

A recent review of CAF has highlighted the need for a diagram of the Governance Structure for equality and diversity for clarity, particularly in light of the HQ review.

The finalised version of the equality and diversity objectives makes a number of references to the Public Sector Equality Duty.

The annual reports highlight our progress in relation to the Equality and Diversity Objectives for 2012-2015 and are available on CPS website.

Question 2: Are the actions to achieve the objective the right ones for the CPS?

There were 19 responses to this question, and of these 13 indicated that these were the right actions for the CPS.

One participant responded that there was good external scrutiny from various levels.

One participant felt that the commitment to the Local Scrutiny and Involvement Panels (LSIPs) should be removed and believed that we could learn the same from regional or national panels.

Of the remaining responses, suggested amendments were as follows:

  • A better connection with LSIPs and national consultation forums
  • Ensure that Community Engagement adds value to the Business
  • LSIP review to include wide spread consultation with all stakeholders
  • Ensure National Scrutiny Panels do not duplicate Areas' work and have the power to commission further research
  • Refrain from the use of abbreviations and acronyms
  • Nominate an Equality Champion for each Equality Objective, with a clear role description, with training and mentoring to ensure consistency
  • Inclusion specific reference to Transphobic Hate Crime in the National Scrutiny Panels Objective.

CPS Response

A review of LSIPs will take on board issues highlighted and all stakeholders in particular Equality and Diversity and Community Engagement Managers (EDCEMs) and external members will be consulted as part of the process.

Engaging with communities is the primary method through which we are able to demonstrate compliance with our legal obligation to 'public duty' to promote equality in our policy development and service delivery, and our corporate commitment made through Community Engagement Standards.

The level of public involvement in policy development has led to the positive responses to the policy outcomes. For example, the prosecution policies on cases involving victims and witnesses with learning disabilities and/or mental health problems were positively transformed as a result of the direct involvement of disabled people in their development.

We have followed this approach in developing key CPS policies in recent years including the revised Code for Crown Prosecutors, the Violence against Women and Girls (VAWG) Strategy, the Domestic Violence Policy, Human Trafficking Policy, and all Hate Crime Policies.

We will develop a job description for the Equality Champion role, linked to areas of work with the opportunity for the Champion to receive training and mentoring.

The National Scrutiny Panel was introduced to provide a new national engagement mechanism to support the CPS in identifying key lessons learnt in high profile hate crime and VAWG cases on an ad hoc basis. The outcomes of the panel enables lessons learnt to be identified at national level and disseminated across the CPS. A panel looked at transphobic hate crime in March 2013 which resulted in key actions and changes, such as flagging and the development on transphobic management guidance. Priorities for the national scrutiny panel are developed at the Equality Objectives setting stage and due to this very recent activity, transphobic hate crime is not a current priority of National Scrutiny Panels.

Specific actions in relation to Transphobic Hate Crime are included in Hate Crime work.

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Question 3: Do you have any other comments?

There were 12 additional comments relevant to the governance objective arising from this consultation exercise.

One participant responded that it is good to see that CPS is considering and seeking to mitigate discriminatory impacts of its work and procedures in order to meet its obligations under the Equality Act Public Sector Equality Duty (PSED), and that it is publishing the Objectives for public comment.

One participant raised concern over the continuation of the EDCEM role and commitment to the Community Engagement Standards, stating that "EDCEMs have made very valuable contributions to community engagement and improving confidence in the CPS in their Areas. In austere times, in particular there is a need to safeguard these types of roles".

Some of the suggested amendments were as follows:

  • Reinstating of internal Area review boards.
  • Review the Transgender Equality Management Guidance ("the TEMG") dated February 2014.
  • Include Deaths in Custody in the work on National Scrutiny Panels.
  • CAF membership to include all groups representing protected characteristics especially Black Minority Ethnic matters.
  • How will the Governance objective be evaluated and how is the CPS going to get engaged/known to all communities?

CPS Response

An Area Operations Centre review is taking place and a strong case has been made for the EDCEM to continue in the role, particularly to deliver the actions required to comply with the recently published CPS Community Engagement Standards. A request has also been made for EDCEMs to be represented at the Operations Directorate's recently developed Business Boards.

CAF, at their last meeting, agreed to review the Transgender Equality Management Guidance.

As a result of the community engagement work on Deaths in Custody, it has been agreed that Deaths in Custody be included in the priorities for National Scrutiny Panels.

CAF have recently appointed new members representing different faiths, and seek out representation of all groups at CAF. However Black and Minority Ethnic (BAME) groups have not been represented for over a year and representing such groups has become a priority.

One of the main objectives of CAF is for members to provide external scrutiny and critical challenge on the delivery of and performance in relation to the CPS' Equality and Diversity Objectives. CAF receives and reviews Equality Objectives, mid-year and annual reports.

CAF members also provide a means of community accountability by, and representing, a range of community perspectives. One of the Community Engagement Standards requirements is for all CPS Areas to engage with groups representing all communities particularly those with protected characteristics.

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Objective 2: Policy

To consider the diverse needs of victims and witnesses as we take decisions about policy and how this is implemented in a practical, inclusive and proportionate way.

Question 1: Is the objective clear?

There were 23 responses to this question. Thirteen felt the objective was clear with no further comment. However, others suggested changes to clarify the scope of the objective (i.e. is it fully focused on victims and witnesses or does it cover others too?). Other felt it needed to be made clear that the objective related to policy regarding prosecution rather than the internal operation of CPS systems processes etc.

CPS Response

Having received this feedback we suggest a re-drafting of the objective to say:

"To ensure we take decisions about prosecution policy and how this is implemented in a practical, inclusive and proportionate way to consider the diverse needs of communities and, in particular, victims and witnesses"

Question 2: Are the actions to achieve the objective the right ones for the CPS?

There were 22 responses to this question. Most were supportive of the actions but there were some alternative views.

One response felt there was a real disconnect between CPS's policy development (which worked well) and its implementation (which was patchier) which needed to be addressed.

Some responses felt that the actions should mention more specific policy issues such as the implementation of the EU Directive on victims and witnesses.

A number of responses were concerned about the lack of detail on how success would be measured against the actions. In a related point, one response felt that there was more for the CPS to do to be transparent about its policy development and implementation activity.

One response asked how CPS would take the views of victims and witnesses into account in measuring whether the actions had been achieved.

Finally, one response suggested clarification on 2.6 that views sought in consultations would be both internal and external.

CPS Response

The actions were drawn up to be broad-ranging rather than policy-specific in most cases to allow for flexibility of delivery.

We recognise the point about ensuring that policy and delivery are better joined up. This was a key driver behind our review of HQ functions, implemented in January 2015, which moved the majority of policy development responsibility to our Operations Directorate.

We are currently developing more detailed measures for the actions. In terms of transparency we will continue to work to improve the public access to the relevant documentation.

We have recently completed a national victim and witness survey of 7,700 victims and witnesses. This gives us an excellent base of information on their views. We intend to re-survey on this basis during the period to which the objectives apply, giving us an opportunity to ask relevant questions if necessary.

We are happy to clarify that views sought in consultations will be both internal and external.

Question 3: Do you have any other comments?

There were 11 answers to this question.

A number of respondents raised effective measurement and a lack of detail on metrics for the objectives and actions.

One comment was made regarding the duties of CPS towards fairness to defendants, families and other parties and the need to capture these.

One comment pointed to the importance of good data to enable judgements to be made around the impact of policies.

Some points were made about specific policy areas such as hate crime and victims and witnesses which will be passed on to the relevant operational policy lead.

CPS response

We have developed a first set of indicators for each of the actions but will continue, where possible, to refine these and the data we collect to improve our ability to show that we have met the objectives.

A commitment to deliver justice to all parties in the case is at the heart of the prosecution business. We are amending the wording of the objective to broaden out to communities. The reason that victims and witnesses are mentioned specifically is because this is in line with the strategic priorities of the organisation.

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Objective 3: Service Delivery (Hate Crime)

To increase the volume of prosecutions and successful convictions in Hate Crime and crimes against older people cases and ensure an effective service for victims and witnesses.

Question 1: Is the objective clear?

There were 21 responses to this question, of which 18 agreed it was clear.

The question as to whether the objective might be SMARTER was raised with a focus on percentage increases.

Other responses raised included:

  • the relevance of crimes against older people and wider intersectionality;
  • whether an increase in prosecutions may increase the current disproportionality in criminal convictions, especially among BAME individuals; and
  • the need to focus on sentence uplift performance.

CPS Response

RAG rated levels of ambition are set overall within CPS for hate crime, for internal monitoring and assessment through Area Performance Reviews and Hate Crime Assurance systems. The ambition for hate crime is 85%.

The prosecution of cases involving crimes against older people is covered by distinct guidance and its performance reported within the hate crime annual report. There is not the same legal framework and therefore any enhanced sentence would be on the basis of sentencing guidelines around vulnerability, not hostility. The volume and conviction rates for these prosecutions has been steadily increasing since the policy was introduced and we are encouraging prosecutors to review cases for potential for evidence of disability hostility as well as age related hostility.

In relation to increasing prosecutions and successful convictions of hate crime, CPS includes details on the volume and proportion of prosecutions by gender, ethnicity and age of defendants in the hate crime annual report. Previous assessment of the ethnicity of defendants in hate crime cases identified no unjustified disproportionality. CPS strives to ensure that any defendants or victims in these crimes, irrespective of their gender, ethnicity, age or disability benefit from the policies and are treated equally to ensure fairness and justice.

There has been a specific focus on increasing the recording and use of sentence uplift across all hate crime offences over the past year. This work needs to continue but we have started to see the effects with an increase in the proportion of cases recorded as having a sentence uplift appropriately announced. The data for 2014/15 will be reported within the hate crime annual report to be launched in October 2015.

For the most recent hate crime annual report 2013/14 and related data go to: Crown Prosecution Service Hate Crime Report 2013-14 data

Question 2: Are the actions to achieve the objective the right ones for the CPS?

There were 23 responses of which 17 agreed the actions are the right ones for the CPS.

Three focused on victims and witnesses and, in particular, concerned the availability of special measures and other support to victims and witnesses.

Two focused on training for prosecutors, one in particular looking at wider issues than the law. Other respondents highlighted:

  • a desire to know more about the hate crime assurance scheme.
  • a concern at the Disability Hate Crime Action Plan when there was under-reporting in other areas such as the transgender community.
  • the focus on increasing volume as opposed to reducing offending behaviour.

CPS response

In addition to the development outlined in relation to victim and witness services, the hate crime assurance scheme provides an opportunity to focus on the service provided to victims and witnesses as the case is progressing. During 2014/15, work will be undertaken to identify any lessons that might help address the experience of victims and witnesses supporting hate crime prosecutions. These cases are more likely to fail due to victim issues than other offences.

We are working with the National Police Chiefs' Council and its working group on hate crime to identify good force practice that might be shared with others to encourage best practice.

Training packages have been devised and developed covering the relevant law and best practice in relation to disability hate crime and homophobic and transphobic crime. A mandated training package will be delivered to all Area prosecutors before the end of 2015 on disability hate crime and includes a section on the victim's perspective. In assessing any case, prosecutors need to be aware of the impact of hate crime. This is one reason for highlighting the value of the Victim Personal Statement.

The Hate Crime Assurance scheme was introduced in January 2015 after discussion with CPS Areas and the identification of processes that appeared to support improved performance. The resulting approach focuses on live checks on case files and provides the opportunity to feedback to lawyers, ultimately improving outcomes. The hate crime annual report 2014/15 will carry more information about the process to date.

The disability hate crime action plan was devised in response to the joint criminal justice inspectorate thematic investigation into the handling of disability hate crime by the police, prosecution service and probation. Our response needed to be specific and detailed. We have largely put that plan in place and are currently monitoring its impact.

The Crime Survey of England and Wales (CSEW) clearly shows the scale of under-reporting across strands and the CPS continues to work to improve awareness of hate crime and reporting. Given the situation described by the CSEW and many voluntary and community based pieces of research, it is perhaps not surprising that as a prosecuting authority, the CPS remains committed to dealing as effectively as possible with all offenders brought to us by the police.

Question 3: Do you have any other comments?

There were 14 responses including a number of other comments, of which those that had not already been dealt with in Question 2, and were for CPS action, are detailed below:

A need to:

  • monitor the transphobic crime flag;
  • consider out of court disposals;
  • make use of impact assessments;
  • monitor prosecutor performance; and
  • consider how is the plan delivered.

CPS response

The transphobic crime flag was introduced in August 2014. Whilst this will not give us a full year to report on, we are keen to share what data we can in the first hate crime annual report to include data for 2014/15.

The Ministry of Justice is currently operating an out-of-court disposal pilot including hate crime in three force areas. The pilot will conclude towards the end of the year and the results will be assessed closely before any next steps. The CPS were cautious of moves in this direction without the necessary experience from a well-structured and delivered pilot and without the expected supporting framework to help address the root causes of offending behaviour in relation to hate crime.

Hate crime policy has not fundamentally changed since the introduction of the legislation but we do keep performance under review and refresh and revise policy and guidance in the light of that performance. We regularly use sampling techniques as well as, since January 2015, the results of the hate crime assurance checks to help direct support to prosecutors on issues of interest.

The hate crime assurance scheme enables direct feedback to individual lawyers which provides a tremendous opportunity for learning.

There are a range of mechanisms for helping to deliver the hate crime related objectives. Ensuring that supporting police and guidance is up to date and accurate is one, the network of Area Hate Crime Coordinators and hate crime leads along with Equality and Diversity and Community Engagement Managers provide a local resource and strategic oversight is provided by Deputy Chief Crown prosecutors. The Hate Crime Assurance scheme provides a good checking process but also an effective health check on what might be missing, what we need more of, etc.

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Objective 4: Service Delivery (VAWG)

To increase the volume of prosecutions and successful convictions of Violence Against Women and Girls (VAWG) cases and ensure an effective service for victims and witnesses.

Question 1: Is the objective clear?

There were 22 responses to this question, of which 15 agreed it was clear.

One stated 'reasonably clear', and one thought VAWG could be part of overall policy or Hate Crime. Two stated the objectives could be SMARTER, with a target on percentage improvement in prosecutions.

Three, two of which were from the National Black Crown Prosecutors' Association (NBCPA), questioned which policy, function or practice this related to and whether an increase in prosecutions may increase the current disproportionality in criminal convictions, especially among BME individuals.

CPS Response

RAG (Red, Amber, Green) rated levels of ambition are set overall within CPS for both domestic abuse and rape convictions, for internal monitoring and assessment through Area Performance Reviews and VAWG assurance systems. The ambition for domestic abuse is 75% and for rape 60%.

The policies referred to in relation to VAWG are outlined in all CPS VAWG documentation including the CPS VAWG report-domestic abuse, rape, sexual offences, stalking, harassment, forced marriage, honour-based violence, female genital mutilation, child abuse, prostitution, trafficking and pornography.

In relation to increasing prosecutions and successful convictions of these crimes, CPS includes details on the volume and proportion of prosecutions by gender, ethnicity and age of defendants in the VAWG report. Previous assessment of the ethnicity of defendants in domestic abuse cases identified no unjustified disproportionality. CPS strives to ensure that any defendants or victims in these crimes, irrespective of their gender, ethnicity, age or disability benefit from the policies and are treated equally to ensure fairness and justice.

The CPS : Violence Against Women and Girls

Question 2: Are the actions to achieve the objective the right ones for the CPS?

There were 19 responses of which nine totally agreed, seven agreed with specific additions and three disagreed.

The specific additions requested included the following:

The three who disagreed included one respondent who was unhappy about VAWG excluding men who are victims of these crimes. Another specifically was concerned that CPS is not robust enough in highlighting the overwhelmingly disproportionate use of violence by men towards women. The latter also wished for more focus on implementation, accountability and research. A third stated that women did not have equality of access to justice and that the actions did not go far enough to address this. They provided a list of requested annual monitoring, analysis and public reporting, including detailed qualitative assessment of all cases and evaluation of victim feedback.

Of the seven with additional requests, they included;

  • Request for review of lessons learned through scrutiny panels and case reviews;
  • Addressing issues related to Trans people;
  • VAWG training programme need to include local VAWG organisations; VAWG LSIP panel members to be invited to CPS training;
  • More community learning through EDCEMs;
  • Address justice for vulnerable people including those with learning disabilities;
  • Include obligations across victims in the Victim's Code; and
  • Publication of Victims' Right to Review (VRR) data including VAWG issues.

CPS response

In relation to gender issues:

CPS provides a collective grouping of gender-based crimes within the overarching framework of 'VAWG' to address the crimes that have been identified as being committed primarily, but not exclusively, by men (93%) against women (84% of the cases where gender is recorded). However, the CPS strives to ensure that any victims of these crimes, irrespective of their gender, ethnicity, age or disability benefit from the policies and are treated equally to ensure fairness and justice. To this end, all CPS policies are gender neutral and are applied fairly and equitably to all perpetrators and victims of crime - including men and boys.

The VAWG report will be updated to show the volumes of men and women defendants and victims, where possible, and will continue to report these details in future iterations. Further explanatory notes will be provided about the overall VAWG approach including the terminology used and the difference in volumes and proportions.

In relation to the request for further monitoring and analysis, some of the information is covered in the VAWG report and some is for the Ministry of Justice. The qualitative information requested would require a manual review of files that would incur a disproportionate cost.

The additional issues can be considered for incorporation into the overall VAWG action plans.

Question 3: Do you have any other comments?

There were 10 responses including a number of other comments, of which those that had not already been dealt with in Question 2, and were for CPS action, are detailed below:

A need to:

  • ensure CPS meet EU directives;
  • address specific issues for lesbians and transwomen;
  • address specific actions on forced marriage, FGM etc.; and
  • address downgrading of charges, case preparation, updates for victims, communication with victims and witnesses (although a number of issues were related to the police only).

CPS response

The issues will be considered for incorporation into the overall detailed VAWG action plans, including actions on forced marriage, honour-based violence and FGM. Issues on charging, case preparation and updating victims are included in updates on guidance. Communication with victims is being addressed in guidance following the public consultation on Speaking to Witnesses at Court.

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Objective 5: Employment

Question 1: Is the Objective Clear?

There were 20 responses to this question and of these 15 respondents felt that the objectives were clear.

Of the remaining 5 responses 2 suggested that there should be a clearer link to the Civil Service Talent Action Plan (TAP) and 2 identified that the outcomes should be made clearer and link to the Annual Equalities in Employment Report (AEER). The 1 remaining response suggested that CPS employees may not wish to engage in this objective.

CPS Response

The CPS is pleased that the majority of respondents found the objective clear and fully support the need to link outcomes to both the TAP and AEER. The CPS is currently drafting its formal programme arising from the TAP and is consulting with staff groups on this prior to publication in the autumn. The data which supports the publication of the AEER is not all available until August for the preceding year and therefore the 2014/2015 publication is not yet written, however, following the availability of the data the CPS is committed to producing an AEER in September 2015. Both publications will link to these objectives, reinforce them and inform additional success measures as required.

The CPS accepts that there may be a risk that not all employees may wish to engage with the inclusion agenda but has accepted policies and procedures for dealing with these situations. However, this risk does not override the CPS firm commitment to drive forward the Diversity and Inclusion agenda.

Question 2: Are the actions to achieve the objective the right ones for the CPS?

There were 18 responses to this question and of these 10 indicated that these were the right actions for the CPS.

Of the remaining 8 responses 6 felt that the actions were the right ones with some minor additions. The minor additions/amendments suggested were:

  1. That the actions should link to the AEER;
  2. That the actions should link to the TAP;
  3. The need to include monitoring of the make-up of recruitment and selection panels;
  4. Inclusions of stronger references to working with staff networks;
  5. Clearer reference to improving the working life of those with protected characteristics;
  6. The inclusion of reference to gender reassignment surgery;
  7. The publication of Area specific diversity information; and
  8. Completion of unconscious bias training should be supplemented by context from line managers.

Only 2 respondents felt that the actions were not the right ones, one because there was no reference to bullying and harassment which the respondent felt was the major concern for CPS on the diversity and inclusion employment agenda. This respondent also flagged the risk that CPS employees may not engage in this agenda. The other respondent whose feedback indicated that the actions were not correct, felt that the objectives were not worded strongly enough and did not offer sufficient robust challenge for the CPS in meeting these commitments.

CPS Response

The CPS is pleased that the majority of respondents found the actions identified to be the rights ones, and again recognises the need for the objectives to link to the AEER and TAP as referenced in response to question 1. In relation to the other minor additions/amendments put forward (numbered 3-6 above) the CPS is happy to take these on board and has made the required amendments to the objective. In relation to actions 7 and 8 the CPS is pleased to report that these actions are already in place. Local diversity data is published on the CPS infonet and can be accessed by all employees. In relation to unconscious bias training, this has been carried out as per the usual training arrangement which involves line managers and employees discussing a learning need and including this on the Personal Development Plan. Following the training, the line manager is encouraged to discuss the benefits of the training with the employee and agree the need for any further action.

In relation to bullying and harassment the CPS is currently undertaking some analysis of the experience of staff in relation to bullying and harassment. The outcome of that research is not yet determined and therefore specific actions not set out. However, the CPS accepts that this is an important area and will seek to take action as required in future and incorporate this into future objectives.

Finally, the CPS believes there are a number of mechanisms in place to provide robust challenge on the inclusion in employment agenda including from staff networks, Trade Unions, and wider staff groups. However, CPS HR is now to attend Community Accountability Forum (CAF) meetings to strengthen this commitment.

Question 3: Do you have any other comments?

There were 8 comments relevant to the employment objective arising from this consultation exercise. The comments were:

  1. Gender Identity Research and Education (GIRES) e learning should be undertaken by CPS employees;
  2. All the objectives should be more measurable;
  3. There should be improved publicity on trans management guidance;
  4. There is a need for improved education of senior managers on fair and open competition;
  5. Unconscious bias training should be built on and developed;
  6. The Departmental Trades Unions (DTUs) should be consulted more widely;
  7. There should be an improved commitment to use smarter working to develop the diversity and inclusion agenda; and
  8. The strong links to existing staff networks are very welcome.

CPS Response

  • Comments 1 and 3 - The CPS is happy to consider all suggestions in relation to improving employee awareness in relation to Diversity and Inclusion and will review the GIRES e-learning in relation to its suitability for CPS use. CPS will also improve the publicity of the trans management guidance.
  • Comments 4 and 5 - The CPS has a strong track record of developing its workforce in this area and demonstrated this by asking all employees to undertake unconscious bias training. Senior managers involved in recruitment and selection have all completed unconscious bias training along with a longer programme on recruitment methods including the importance of fair and open competition. This knowledge will be further developed as part of the upcoming senior leaders programme. We will keep under review the need for further skills development in this area.
  • Comment 6 - the DTUs have been consulted on these objectives and will also be part of the consultation process on the CPS response to the TAP and the AEER.
  • Comment 7 - The CPS recognises the links between the SMARTER working and diversity and inclusion agenda as referenced in the disability 7 point plan. However, the CPS Estates Committee lead this piece of work and have identified separate terms of reference and outcomes.
  • Comments 2 and 8 - The CPS is pleased to have strong links with active staff groups and will continue to forge positive relationships in this regard. While we accept that there is always room for improvement we are happy that sufficient success criteria are in place to measure the outcomes for this objective, however, this may be developed further based on the TAP and AEER as outlined above.

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Annex A - Membership of the Community Accountability Forum

External:
Asker Husain Her Majesty's Crown Prosecution Service Inspectorate (HMCPSI)
Barney Leith Faith Based Regeneration Network
Christl Hughes The Gender Identity Research and Education Society GIRES)
Danny Stone antisemitism.org.uk
Emma Scott Rights of Women
Juliet Chard Stonewall
Kaylee Wildman Victim Support
Mervyn Kohler Age UK
Peter Kelley Galop
Rosanne Pearce Childline
Stephen Brookes MBE DRUK Ambassador and Disability Hate Crime Network Adviser
Internal
Alan Jenkins Non-Exec Director
Baljit Ubhey CCP London
David Chrimes/David Orman Disability Staff Network
Joanne Anderson Equality and Diversity Policy Advisor, Strategic Policy and Accountability
Jude Watson/Asha Odedra Violence Against Woman and Girls (VAWG) Strategy Manager
Kate Scott-Hughes/Claire Scott-Hughes LGBT Staff Network
Mick Conboy Hate Crime Stakeholder Manager
Ogheneruona Iguyovwe/Yvette Williams National Black Crown Prosecutors Association
Peter Lewis (Chair) Chief Executive, CPS
Rotating Member Equality and Diversity Community Engagement Manager (13 CPS Areas)
Sara Carnegie Director's Strategic Policy and Accountability Advisor
Equality Objectives Sub-Group:
Claire-Scott Hughes LGBT Staff Network
Joanne Anderson Equality and Diversity Policy Advisor, Strategic Policy and Accountability
Juliet Chard Stonewall
Kaylee Wildman Victim Support
Parveen Hassan Equality and Diversity and Community Engagement Manager, CPS West Midlands
Roseanne Pearce Childline
Stephen Brookes DRUK Ambassador and Disability Hate Crime Network Adviser
Yvette Williams National Black Crown Prosecutors Association
Past Members:
Andrew Copson, Pavan Dhaliwal The British Humanist Association
Davina James-Hanman Against Violence and Abuse (AVA)
Deborah Gold Galop
Doreen Lawrence Stephen Lawrence Charitable Trust
Elizabeth Henry Race on the Agenda (ROTA)
Gary Buxton, Daryna Plysak Young Advisors
Hannah Camplin Rights of Women
Mark Brookes Values into Action
Mark Shrimpton Disability Rights UK
Norbert Marjolin NSPCC
Polly Rossetti Victim Support
Roy Rudham Neighbourhood Watch (UKNWT)
Sam Dick, Alice Ashworth Stonewall
Susan Alexander The Travellers' Aid Trust
Vivienne Hayes Women's Resource Centre (WRC)

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Annex B - Respondents to consultation

Anonymous
Martyn Sullivan Mankind Counselling
Isobel Shirlaw Refuge
Clare Walker DV Consultancy
Emma Roebuck LGBT Foundation
Amjad Malik QC Association of Muslim Lawyers
Chris Wilkinson British Transport Police
Christl Hughes GIRES - Community Partner
Heather Harvey Eaves - Community Partner
Catherine Poulton CPS North West LSIP - Community Partner
Ben Vollans Outreach Cumbria - Community Partner
Clare Walker CPS West Midlands LSIP - Community Partner
Josh Durham Hate Crime Worker - Community Partner
Stephen Brookes DRUK - Community Partner
Sandy Marks Disability Action - Community Partner
James Davies PCS - Trade Union
Babatunde Alabi Staff Network
David Chrimes Staff Network
Kate Scott-Hughes Staff Network
Yvette Williams Staff Network
Ogheneruona Iguyovwe Staff Network
Adele Clarke CPS Staff
Caroline Airs CPS Staff

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