Consultation on Crimes Against Older People Policy Guidance - Summary of Responses

Introduction

This is a summary of responses to the public consultation undertaken by the Crown Prosecution Service (CPS) on the Policy Guidance on Crimes Against Older People (CAOP).

The Policy Guidance was published on 10 September 2018 and consulted on for a period of seven weeks, ending 29 October 2018.

The Consultation

The purpose of the consultation was to provide an opportunity for people to comment on the draft Policy Guidance, so that the final version was informed by as wide a range of views as possible.

The Policy Guidance on CAOP sets out how we approach these crimes and communicates to complainants, witnesses, their families and communities, as well as the general public, that we understand the complex and serious nature of offences which target older people.

The CPS first developed a CAOP policy in 2008 as the result of a commitment in the Single Equality Scheme (a strategy to promote equality in the CPS) and in recognition of the ageing population in the UK. The statement was published in 2009 following a consultation and engagement with stakeholders.

The revised Policy Guidance published for consultation was developed with support and input from two National Scrutiny Panels (NSPs) created specifically for this task. The panels were held in November 2017 with one in Cardiff and one in London. Each panel consisted of academics and community partners with experience and expertise of the lived experience of crimes against older people and supporting victims.

For the purpose of our policy and guidance, the term “victim” is used to describe a person against whom an offence has been committed, or the complainant in a case being considered or prosecuted by the CPS.

The main proposed revisions to the Policy Guidance were:

Length

The proposed redraft is significantly reduced in length; from 52 to 8 pages and makes use of links to general information about the CPS, other areas of legal guidance and useful resources. This ensures the guidance contains the most important information in an easily accessible format.

The age limit

The CPS applies an electronic ‘flag’ to Crimes Against Older People on our case management system to aid monitoring these cases. In the previous policy, the age limit considered to be the starting point for the CPS flagging and monitoring of Crimes Against Older People was 60. The age limit is accompanied by a flagging definition so is not the only criteria for the CPS to consider something as CAOP. Research and discussions with partners suggested this age limit was too low and the proposed age limit was increased to 68.

Flagging definition

The proposed Policy Guidance contained a revised CPS flagging definition for CAOP:

‘Where the victim is 68 or over, any incident/criminal offence which is perceived by the victim or any other person, to be committed by reason of the victim’s vulnerability through age or presumed vulnerability through age’.

This was intended to ensure consistency across the cases flagged as CAOP by CPS prosecutors and administrators. The proposed flagging definition is based on the suggested hate crime definition proposed by the University of Sussex in their report ‘Hate Crime and the Legal Process’.  

This flagging definition will only capture cases where the victim has been deliberately targeted because of their age related vulnerability, whether this is actual or perceived. The revised definition will mean that cases where the victim just happens to be over the set age limit will not be flagged. Under the new flagging definition, the data produced from the CAOP flag will be more meaningful.

Consultation Questions

The consultation asked five questions:

1. Does the section on ‘CPS Policy’ address the key issues in prosecuting crimes against older people and clearly explain the public interest factors to be taken into consideration by prosecutors?
2. Does the section ‘Monitored crimes against older people’ clearly explain the types of cases the CPS wishes to flag and monitor? Do you think this flagging definition will capture the relevant cases? Is the age limit appropriate?
3. Do the sections on ‘Offending behaviour’ and ‘Vulnerability of older victims’ reflect and address the types of crime older people can experience and the diversity of circumstances of older people?
4. Does the policy guidance accurately reflect the barriers to justice older people can face as well as the support that can be put in place to mitigate this?
5. Do you have any further comments on the CPS policy guidance on prosecuting crimes against older people?

The consultation was published on the CPS website and publicised in a number of other ways: we sent letters from the Director of Prosecution Policy and Inclusion to key stakeholders; we presented the Guidance to CPS stakeholder groups, such as the CPS Cymru/Wales Local Scrutiny and Involvement Panel and the National Scrutiny Panel on CAOP; we circulated the statements to other Government departments; and we publicised the consultation internally on the CPS intranet.

Method of Analysis

We received 36 responses in total.

All responses have been analysed, including any received after the consultation closed. A breakdown of the source of the responses is at Annex A.  

Each response to each question was analysed separately and the main points were identified and carefully considered. Not every respondent gave specific answers to each individual question but their views were considered. However, this summary does not address every point made by respondents.

Outside Scope

We received a number of responses that addressed issues outside the scope of the consultation or the policy. For example:

• A number of respondents felt sentences for offenders who target older people are too low and that an increase would serve as a deterrent. As the Policy Guidance states, the CPS will present evidence of all aggravating factors that may increase the seriousness of the offence and the sentence. However, sentencing is a matter for the courts, not for the CPS.
• One respondent raised the issue of international crime committed overseas which targets older people. The CPS has separate legal guidance on jurisdiction and does not consider that this policy guidance needs to repeat the information.
• General observations on the police response and prevention of crimes against older people. This Policy Guidance is a CPS document and relates to the prosecution of offences, not the investigation or prevention of crime. The CPS can only prosecute cases referred to it by the police or another agency with investigative powers. While prevention is generally a role for the police, the CPS can and does use ancillary orders in order to protect victims and prevent further crime. This is already covered in the section on ‘Prosecution and Sentencing’ but this has been expanded slightly to clarify the point.
• Responses which call for crimes against older people to be considered as hate crimes. The CPS can only prosecute cases in accordance with the law as it stands and age is not currently included as a strand of hate crime in legislation. Amending legislation is a matter for Parliament.

General Observations and Key Themes

This section sets out some of the broad themes and issues that recurred in the responses we received, and provides the CPS response to each of these.
The proposed Policy Guidance was generally well-received. For example:

• Overall I think this is well thought out and written
• It is very clear, and explains complex issues well
• The objectives of the policy clearly set out a commitment to tackle an under-reported criminal justice issue within our current society and I welcome the fact that within the document there is recognition of the existence of ageism and prejudice against older people
• It recognises that older people cannot be lumped together in one homogenous group and that it would be wrong to make assumptions about them. Equally, it sets out a way of dealing with the diverse circumstances of older people who are victims. It is neither patronising not paternalistic. It is a good 'step forward' for older victims to help them receive justice
• The guidance document is a positive step forward in addressing some of the ageist attitudes that can sometimes present themselves
• We believe that the rights and needs of older people do need to be specifically considered to better enable a fair, effective and victim focused criminal justice system

However, some respondents expressed concerns about the revisions or suggested further amendments. These are outlined below under the specific questions.
Most respondents welcomed the focus on older people but there were some who questioned the need for a policy on older people:

‘People of all ages get conned, just more older than younger per-capita’

The CPS has chosen to update this policy in recognition of the fact that offenders target older people because they perceive them to be easy targets. It is also important to recognise that the impact of crime on older people can be greater. This is something that our stakeholders and experts told us during the development of this revised policy.

In addition, as a public body, the CPS is subject to the provisions of the Public Sector Equality Duty. Part of this duty is to advance equality of opportunity. The revisions to this policy guidance aim to ensure that older people have the same access to justice as anyone else.

A number of respondents requested that more detail be provided on specific issues already covered in the separate CPS legal guidance on Prosecuting Crimes Against Older People, or in other CPS guidance. As there are many pieces of legislation that could be used to prosecute CAOP, we have decided that details on specific offences and legislation would best sit in the legal guidance.

The legal guidance has been fully revised at the same time as the Policy Guidance. We provide a link to it in the Policy and therefore we do not think it necessary to repeat text from the legal guidance in the Policy.

A number of respondents highlighted that the Policy Guidance was using the terms ‘capacity’, ‘fluctuating capacity’ and ‘lacking capacity’ as general catch-all terms when they have specific meanings as defined by the Mental Capacity Act 2005. The policy has been amended to recognise and clarify this.

Revisions

In light of the responses received, we have made a number of revisions to the Policy Guidance. The main revisions are explained below under each question.

Summary of Responses to Specific Questions

This section provides a summary of the key points and themes raised in response to each of the questions, and the changes made as a result of the feedback.

Question 1

Does the section on ‘CPS Policy’ address the key issues in prosecuting crimes against older people and clearly explain the public interest factors to be taken into consideration by prosecutors?

There were 32 responses to this question.

A number of respondents felt this section was clear and showed an understanding of the particularities of crimes against older people:

‘The policy guidance clearly shows that the CPS has a good understanding of the dynamics of crime against older people which may make it different to the same crime against somebody of a different age’.

Main changes as a result of feedback:

1. We have amended the bullet point list at the start of the policy to clearly show that the policy intends to ensure that older people have the same access to justice as younger people and are given an equal voice in the criminal justice system. We agree with respondents that it is right to put this front and centre in the policy.
2. As a result of feedback, the revised Policy Guidance makes specific reference to publicising convictions for CAOP in order to send a clear message that targeting someone based on their age or their perceived situational vulnerability will not be tolerated. The CPS does this through its quarterly hate crime newsletter, its Annual Reports and both local and national press releases.
3. In the first bullet point list we have also amended the wording about sentencing and the CPS commitment to invite courts to increase sentences where the offender targeted a vulnerable victim. The CPS understands that vulnerability is situational and that older people are not inherently vulnerable and the wording of this bullet point now accurately reflects the wording of the Sentencing Guidelines.
4. We have added more detail to the misconceptions and stereotypes that exist about older people in response to feedback from a number of respondents. We have added that perpetrators can assume older people have accumulated savings and that they are perceived to be ‘out of touch’ and therefore more susceptible to scams. We have also made amendments to clarify that offenders do not only target older people with physical violence but also crimes of psychological manipulation and confidence trickery as outlined by one respondent.
5. In this section we have amended the information about capacity, fluctuating capacity and those who lack capacity. The section now focusses on not making assumptions about the credibility or competence of a witness and is consistent with the Mental Capacity Act 2005.
6. The section on public interest factors has been amended to ensure it is consistent with the revised Code for Crown Prosecutors which was published on 26 October 2018. In response to a number of consultation responses, we have made additions to the public interest factors that a prosecutor should consider. The additions cover:
   • grooming of older people so they feel a bond with a perpetrator
   • consideration of the physical, emotional and mental impact on the victim which can be exacerbated by age
   • a recognition that victims themselves are not vulnerable, but that there may be situational vulnerability exploited by an offender

Suggested changes that we have not made included:

1. One respondent suggested that, in cases of wilful neglect, the CPS should argue that the actions or inactions that gave rise to the neglect are implicitly wilful by virtue of the role, capacity, training and/or experience of the perpetrator. We disagree and feel information on legislation and case law in this area best sits in our legal guidance on Ill-Treatment and Wilful Neglect offences.
2. One respondent suggested that the public interest factors should include deliberately targeting a number of older people, and gave the example of rogue traders who target a number of houses in the same area because they know the residents are older. We consider that other public interest factors expressed in the Code and the policy guidance cover this point. Where there are a number of offences, as in the example the respondent gave, that will increase the overall seriousness of the case. The Code for Crown Prosecutors already indicates that the more serious the offending, the more likely it is that a prosecution would be in the public interest.
3. A number of respondents suggested it would be helpful to explain what is meant by ‘vulnerability’ and to show more clearly how it depends on situation and circumstances. One respondent suggested a bullet point list may help. While we have not included a list in this section, we agree that this is a useful suggestion and have added it to the next section on ‘Monitored Crimes Against Older People’.
4. One respondent asked for more information on specific prosecutions under the Mental Capacity Act 2005. This level of information can be found in the CPS legal guidance which has also been revised. We do not agree that it should be included in this document.
5. One respondent suggested that there should be more information on the intersectionality between CAOP and Violence Against Women and Girls (VAWG). The Policy Guidance acknowledges the cross overs that exist in this area of offending, however more detail is included in the legal guidance which provides links to CPS guidance on VAWG offending.

Question 2

Does the section ‘Monitored crimes against older people’ clearly explain the types of cases the CPS wishes to flag and monitor? Do you think this flagging definition will capture the relevant cases? Is the age limit appropriate?

There were 32 responses to this question.

Main changes as a result of feedback:

The age limit

This question generated a large amount of interest and a number of conflicting views, reflecting the complexity and sensitivity of the issue. The main area which generated the most feedback was the age limit suggested as a starting point for CPS consideration of CAOP:

• ‘there is a good argument to having the starting age of 68 for this policy…having said that, this does mean your policy will not align well with other organisations’
• ‘the age limit is not appropriate’
• ‘the age limit seems rather low…I suggest the age is put up to the mid 75s’.
• ‘it is highly discriminatory to raise the definition of an older person in regard to the Governments’ controlled retirement age limit’
• ‘increasing the age definition…will create an additional vulnerability for those excluded’
• ‘the use of the WHO retirement age of 65 years enables one to compare the impact of crime from a health perspective. Most studies on health use 65 years as a cut off for older age’
• ‘the CPS proposal to increase the age of the older victim to 68 ‘in line with current retirement age’ is based on incorrect information…I strongly advise that the age by kept at 60’
• ‘There are over 40,000 people under 65 with dementia in the UK and about 2 in 100 people aged between 65 to 69 have dementia. Adults with Down’s syndrome and learning disabilities are at greater risk of developing early onset dementia (1 in 10) between the age of 50 to 65. Lowering the age limit to 65 would seem reasonable to help protect those older vulnerable adults between 65–67 who may have lost mental capacity or have fluctuating mental capacity’
• ‘It would be better to leave the defined age at the commonly recognised one of 65 years, keeping it in line with the World Health Organisation, but also keeping it in line with Adult Safeguarding data monitoring and collection’
• ‘significant life changes connected with ageing, such as limiting longstanding illnesses, sensory disabilities, changes in working life and time spent in the home can reasonably be said to become more significant from the age of 65’

The comments show the wide ranging views on the age at which a person might be considered to be ‘older’, and some respondents felt that the policy should not include an age limit at all. We recognise that people age differently, however an age limit is required to enable the CPS to effectively flag and monitor cases. A policy which focussed on health conditions, or perceived vulnerability would be too nebulous to accurately flag and monitor. It would risk being a policy about something different altogether which would not reflect the specific needs of older people.
Given the wide spectrum of views on this issue, it is clear that this aspect of the policy could not satisfy all respondents, or all of the wider community. On balance, we have concluded that the age limit should be set at 65 in order to better align with other agencies.

The use of ‘vulnerable’ and ‘vulnerability’

There was disagreement amongst the responses received over the use of the terms ‘vulnerable’ and ‘vulnerability’ within the Policy Guidance.

One respondent commented:

‘The term vulnerability does not reflect the terminology as per the Care Act 2015. After extensive consultation with the public for the Care Act who did not like the term vulnerable I am surprised to find it included in this document. Would it not be better to use an older person at risk of abuse or neglect. So instead of vulnerability use the term ‘at risk’?’

Other respondents were happy with the use of the terms ‘vulnerable’ and ‘vulnerability’ in order to enable to the CPS to highlight and flag such crimes where there has been an element of targeting and exploitation.

‘We welcome the proposal to introduce a flagging definition in order to identify, highlight and monitor cases where the offender selects or exploits a victim because they perceive them as vulnerable, or to be an easy target, because of their age.’

‘the CPS definition…appears sensible, given the lack of statutory or agreed definition of such crime’.

We have been careful throughout to show that the CPS understands that older people are not inherently weak or vulnerable but that offenders often target them because they believe or perceive them to be.

We have made an amendment, for example, following respondent feedback, to the list of public interest factors to show that victims can be in a vulnerable situation but are not inherently vulnerable themselves. As a respondent noted, ‘this language removes the sense of vulnerability being an inherent condition, and highlights that it is a dynamic state’.

While the Policy continues to use the words ‘vulnerable’ and ‘vulnerability’, we have made amendments to limit their use. We have also added in a list of examples which show more clearly how vulnerability is related to the situation, not to the individual.

Flagging and monitoring

A number of respondents suggested that, as this is a public facing policy, it would be helpful to explain more fully what monitoring and flagging mean in practice. We have added a short opening paragraph to this section on the CPS processes for flagging, monitoring and reporting on data.

Other changes made:

1. We have amended the flagging definition to remove the word ‘incident’ so that it only refers to ‘crimes’. The CPS will only deal with crimes that have been investigated and referred to us by the police. Incidents will be reported to and logged by the police but they are not referred to the CPS for prosecution. The use of ‘incident’ in flagging definitions is useful when the definition is shared with the police, for example in hate crime cases, but this definition is solely for the CPS and therefore the inclusion of ‘incident’ would not be appropriate.

Suggested changes that we have not made included:

1. One respondent suggested that there should be a commonality of flagging across criminal justice agencies. This is not something the CPS can deliver and this policy, including the flagging definition, applies to the CPS only.  
2. One respondent was concerned that if the flagging definition was not applicable to a case then that case would not be prosecuted by the CPS. The flagging definition is for identification and monitoring purposes only. It will not be used to decide if a prosecution should or should not go ahead. Prosecution decisions are made in accordance with the Code for Crown Prosecutors and the flagging definition does not alter or replace this.
3. One respondent raised the point that the proposed definition would not include some types of offending behaviour: ‘the majority of domestic violence, sexual violence, homicide and burglary offences (which the current evidence does not indicate is related to age in the vast majority of cases)’. The proposed definition aims to allow the CPS to flag cases where the offender perceived the victim to be an easy target based on their age or associated age-related vulnerabilities. This may well include crimes listed by the respondent. However some of these offences will not relate to the age of the victim and it will not have been a motivating factor in their having been targeted. We think it is right that these cases are not flagged as Crimes Against Older People.
4. One respondent suggested that situational vulnerability be expanded upon within the flagging definition by including ‘the victims’ vulnerable circumstances’. We have included more detail about situational vulnerability within the body of the Policy Guidance and do not agree that this should be changed in the definition.

Question 3

Do the sections on ‘Offending behaviour’ and ‘Vulnerability of older victims’ reflect and address the types of crime older people can experience and the diversity of circumstances of older people?

There were 32 responses to this question.

There was a largely positive response to these sections, especially in relation to the CPS’ recognition of the diversity in circumstances of older people:

• ‘I welcome the commitment not to make assumptions about an older witness’s reliability or credibility and that they will be made aware of the support available to them’
• ‘This section looks comprehensive in treating all victims as individuals and ensuring that support is signposted/provided for them’
• ‘The CPS sets out promising commitments in the ‘vulnerability’ section’
• ‘We are pleased to see the recognition of various types of scams included in the offending behaviour section’

Main changes as a result of feedback:

1. A number of respondents suggested that the policy should include more information about VAWG offending and the specific barriers to reporting. As a result we have added more information about domestic abuse and age as well as a link to the CPS Domestic Abuse Guidelines.
2. At the request of a number of respondents, we have added in more information about the Mental Capacity Act 2005 which states that a person must be assumed to have capacity unless it is established that they lack capacity.
3. We have amended the start of the section on the legal framework to make it clearer that there are no specific offences relating to criminal targeting of older people but that older people are frequently targeted by offenders.
4. We have added more detail to the types of crime experienced by older people by including coercion and control and mail and doorstep scams. This was in response to comments about older people being susceptible to ‘befriending’ where they are groomed by individuals who then exert power and control over them.
5. At the suggestion of a number of respondents we have added information about isolation and loneliness and how they can increase the risk of older people becoming victims of crime.
6. We have made amendments to the bullet point list of commitments to clarify that the support needed by an older victim or witness may vary during the life of a case according to health and circumstances. We have also amended the wording to reflect the revised Code for Crown Prosecutors.

Suggested changes that we have not made included:

1. One respondent suggested that these sections should include more guidance for police conducting investigations. This is a CPS document and relates only to the prosecution of crimes against older people we therefore do not agree that this should be included.
2. One respondent requested that the CPS establish a named job role for dealing with crimes against older people and contacting specialists to obtain expert knowledge. The CPS is unable to establish specific job roles for prosecutors in relation to crimes against older people because this covers a variety of offending behaviour and may cross over with already established specialisations and teams. Some examples include specialist prosecutors in  complex casework units, rape and serious sexual offences units and specialist fraud.
3. One respondent suggested that offences against older people should be treated as hate crimes. Age is not included as a protected characteristic in hate crime legislation and therefore the CPS is unable to prosecute these cases as hate crimes or apply for a sentence uplift.
4. One respondent suggested that this section should include the feelings of shame felt by older people at having been scammed and their reluctance to report it. We agree this this is an important barrier but have included this in the section on ‘Reporting Crimes’ further down the Policy Guidance rather than in this section.
5. One respondent suggested that the relationship of the CPS with other prosecuting agencies, such as Trading Standards could be highlighted. We agree that this is an important point but have chosen to include this in the section below on ‘Reporting Crimes’.

Question 4

Does the policy guidance accurately reflect the barriers to justice older people can face as well as the support that can be put in place to mitigate this?

There were 32 responses to this question.

Respondents provided a lot of very helpful, practical feedback on this section in relation to the barriers older people face. The majority of the amendments therefore were to the sections on reporting crimes and support.

Main changes as a result of feedback:

1. Some respondents said that there was not enough consideration given to the physical condition of the victim in the section on reporting. One respondent helpfully suggested that the list of barriers should include physical barriers to attending court and giving evidence such as mobility problems, standing whilst giving evidence, difficulties in seeing and hearing. We agree that this was missing from the policy and have added in this information.
2. A number of respondents said that the reference to support in the section on reporting crimes was too fleeting and we should add more detail. We have added more information on the different roles of the police and CPS in relation to support and highlighted that further information is contained in the support section further down the document.
3. A number of respondents suggested the policy should include more information on how the CPS can support individuals who lack capacity or who have fluctuating capacity within the meaning of the Mental Capacity Act 2005. We have therefore added more detail to the section on Support.  
4. Some respondents suggested that it would be useful to sign post readers to third sector organisations who can provide additional support. We are unable to include an exhaustive list in the policy however we have added a paragraph to the end of the support section providing some information on this point.
5. Some respondents were concerned about the inclusion of the CPS Support Guide for disabled victims and witnesses. They recognised that, while the guide was useful, it should be clearly highlighted that the CPS does not assume all older people are disabled. We have amended the Policy Guidance to better reflect that.

Suggested changes that we have not made included:

1. One respondent suggested that the policy should include more information on the CPS processes for requesting additional information from the police and on evidence building. We do not agree that this is the appropriate place for this level of detail. Our legal guidance on Crimes Against Older People incorporates this kind of information.
2. One respondent said that courts do not hand down sufficient sentences for offenders who target older people. Sentencing is a matter for the courts however the policy does state that the CPS will highlight aggravating factors to the court which increase the seriousness of an offence for example ‘targeting a vulnerable victim’. This is the terminology used in Sentencing Guidelines.

Question 5

Do you have any further comments on the CPS policy guidance on prosecuting crimes against older people?

There were 32 responses to this question.

Main changes as a result of feedback:

1. One respondent made some very good points about the implementation, monitoring and updating of this policy, ‘this section should specify plans for future updating and refreshing to reflect changes’. We have added more detail about how the flagging of crimes against older people will be monitored and reported on. It is CPS policy to ensure its publications are up to date and to review them on an annual basis. This has been added to the policy guidance.  but we have not set out a timescale for review.
2. One respondent requested that the policy is communicated to interested parties once finalised. This summary of responses and the final Policy Guidance and legal guidance will be published on the CPS website. Stakeholders and members of CPS panels will also be notified.
3. One respondent suggested that the policy should acknowledge the role of Trading Standards in relation to certain types of crimes often targeted at older people. This amendment has now been made.

Suggested changes that we have not made included:

1. Some respondents used this question to highlight concerns about having a separate policy on Crimes Against Older People, with one saying ‘surely a crime is a crime’. Our stakeholders and many respondents to this consultation have expressed the real need for a policy and approach that recognises the particular circumstances of older people and the targeting and exploitation they can be victim to. We are satisfied that there is a need for this Policy Guidance and the accompanying legal guidance
2. One respondent felt the policy should address cases where older people have injured or killed intruders to their home. This policy does not address issues of older people as defendants.
3. Some respondents used this question to call for crimes against older people to be considered hate crimes. This has already been addressed above in this summary of responses.
4. One respondent requested that information on Restorative Justice is included in the Policy Guidance. The CPS has separate legal guidance on Restorative Justice and disagrees that this policy is the right place for this information.
5. One respondent stated that the Policy Guidance should not use the term ‘vulnerable’ at all. This has been covered elsewhere in this summary of responses. ‘Targeting a vulnerable victim’ is used within Sentencing Guidelines and the CPS needs to reflect this language in order to present evidence of this as an aggravating factor. The Policy Guidance stresses at various points that the CPS recognises that many older people are victims of crime because of a perception of vulnerability or because they are at risk or are in vulnerable circumstances.
6. One respondent questioned the handling of crimes against older people in the police asking, ‘How do you ensure the police are aware of and follow your criteria/policy in this regard?’ This policy is purely for the CPS. The police are not required to flag crimes against older people or adhere to the CPS definition.

Next Steps

The previous policy has now been replaced by the revised Policy Guidance, which comes into effect on 15 July 2019, and is published with this summary.

We shall also publish an Easy-Read version of the Policy Guidance on the CPS website, which will make it more accessible to a wider audience.

Conclusion

We are very grateful to everyone who responded to the consultation. We are content that the responses have led us to make changes that have resulted in clearer, improved Policy Guidance.

Annex A