The Application of KLoE

Inspection to Public
Sector CCTV
Or Quis Custodiet Ipsos Custodies

Malcolm Gardner
Meritec Ltd
In general, most service areas within LAs
have benefited from a range of additional
performance funding
In many areas this has now dried up and
councils can expect that funding will be
much, much tougher in the next few years
So, instead of additional funding there is
more likely to be budget cuts
The expectation is more with less
◦ Described as the “Burning Platform”

The Harder Test

Inspection has been evolving starting
with BVPI and then CPA (Continual
Performance Assessment) Inspections
Largely target based
◦ in which the stats were “Duked”
Then in 2000 was the introduction of
Key Lines of Enquiry Inspections
◦ Performance and policy driven aimed at
specific local Services

Inspections
Approximately 4000 inspections since
August 2000 covering
◦ Corporate governance and assessment
◦ Culture and leisure
◦ Environment
◦ Health
◦ Housing
◦ Use of resources
◦ Fire and rescue services
◦ From 2008, Housing & Council Tax Benefits

Inspections
More recently the Inspectorates have
introduced a number of cross-cutting service
inspections
These are involving into the Comprehensive
Area Access (CAA) inspections
◦ These look at the way in which strategic
partnerships operate
◦ CAA inspections are in themselves a strategic
partnership between Audit Commission, Care Quality
Commission, HM Inspectorate of Constabulary, HM
Inspectorate of Prisons, HM Inspectorate of
Probation and Ofsted

Inspections
CAA is intended to cover a range of social
high level subjects such as
◦ Teenage pregnancy
◦ Providing choice in social care
◦ Educational attainment
◦ Reducing unemployment and worklessness, and
improving skills
◦ Improving the environment and housing
through energy efficient homes
◦ Data handling, use and retention
Itis a evolved version of the KLoE
Inspection methodology

Inspections
Judgement 1
◦ What has the service
• Judgement 1 aimed to achieve?
◦ Meeting the needs
• Zero of the community and users?
stars—Poor
• One star—Fair
◦ Delivering value for money?
Two star—Good
•
Judgement 2 star—Excellent
• Three
◦ Service track record in delivering improvement?
◦ How well does the service
• Judgement 2 manage
performance?
• Zero stars—Poor
◦ Does the service
• One have the capacity to improve?
star—Uncertain
• Two star—Promising
• Three star—Excellent

Two Key Judgements

Services are not judged by a narrow
definitions
Where as before a service was judged on the
performance of those who work for it
Now anyone or any other service who
undertakes some aspect of servicing the
function under inspection will be judged
The department, customer services,
receptionists any one who collects and
manages evidence or data (internal and
external partners), all line managers up to
and including the Chief Executive and Elected
Members

What is being Inspected

 Placing this into a Police Authority Context (new
inspection currently under consultation)
 It will not be the police and direct staff alone who
will be inspected but anyone involved in
community safety and policing.
 The same is true of housing and environmental
service inspections
 So any service where CCTV monitoring
contributes to some aspect another service’s
performance then that facet could be subject to
inspection, especially around
◦ The consultative process
◦ Risk assessment
◦ Access to data
◦ Security of personal information

What is Being Inspected

From Tenancy and Estate Management
Inspection Methodolgy
◦ Does the organisation have a holistic approach
to tackling ASB which places emphasis on
prevention… as well as enforcement?
◦ Have effective partnerships been formed at a
local level with … appropriate agencies, council
departments and other landlords on the sharing
of information, and tackling ASB?
◦ Uses a range of cost effective methods to
gather evidence – for example professional
witnesses, CCTV, video cameras, and noise
monitoring equipment.

What is Being Inspected

There may be an assumption that if CCTV is
supplied by a third party that contractor does
not have to worry about KLoE because it
applies only to the LA
The Audit Commission expect that the client
ensures that any third party helps the LA
meet the KLoE requirements
◦ Same principle as third party investigators and RIPA
A word of warning: 60% of the early benefit
inspections highly criticised contracted out
services as being amongst the poorest
performers

Contractors, Suppliers and Partners

Judgement 1 is all about how the service is
currently performing
Under the old CPA that was about specific
performance measure set by central
government
◦ How many bits of dog poo per square meter
◦ Assessing a new claim for benefit in so many days
◦ The length of time homeless families remain in short
term accommodation
◦ How many children pass their exams
◦ % reduction in crime
◦ The numbers game

Judgement 1
This judgement now looks at the question
of performance in its broader terms to get
a picture of how the service is operating
This runs deep into policy
◦ Local targets for local people
◦ While they may vary the questions remain
fundamentally the same

Judgement 1
Example from Police Inspection
Consultation:
How well does the police authority achieve
results through community engagement,
partnerships and collaboration to deliver
its ambitions and strategic priorities?
The Police demonstrated this by showing:

What has the service aimed to

achieve?
has secured and understood the views of
local people about policing priorities in its
area;

What has the service aimed to

achieve?
acts upon community concerns by setting
priorities for policing that reflect local
needs and will lead to improvements in
public confidence

What has the service aimed to

achieve?
provides feedback on how issues raised
through consultation and community
engagement have been considered;

What has the service aimed to

achieve?
ensures that local policing services are
accessible to all communities, including
hard to reach and vulnerable groups;

What has the service aimed to

achieve?
secures desired outcomes for local policing
and community safety priorities through
effective partnership;

What has the service aimed to

achieve?
promotes and supports collaboration/joint
working between forces and other local
public service partners to improve
efficiency, reduce costs, manage risk more
effectively

What has the service aimed to

achieve?
Meeting the needs of the
community and users?
Links to equalities – big theme
◦ Operational policies and procedures need to have
gone through Equalities Impact Assessment
“Need” not “Want”
◦ Even the political agenda must be built around
“need” rather than “want”
◦ You do “want” if you can afford it and it is in the
public interest to do so
CCTV examples could be:
◦ Numbers and locations of cameras
◦ Purpose of use
◦ Data retention
◦ Codes of conduct

Meeting the needs of the

community and users?
Delivering value for money?
 In its 2006 Report “Neighbourhood, Crime and Anti-
social Behaviour” the AC said
 “There is a growing body of academic research about
the cost effectiveness of specific interventions,
including … CCTV” so things that AC will expect to see
◦ Police sharing arrest and other data that can demonstrate
value for money
◦ Cost of managing a staffed control room
◦ The 50p cost of a DVD recording for the defence to see in
advance
so that they can properly advise their clients -- “Guilty” pleaded
trials are cheaper than “Not Guilty” one
 Anexample is the Stadium Housing Association -
Housing Association Inspection showed how a co-
ordinated approach to CCTV can bring financial
benefits

Delivering value for money?

This is all about the ability of the organisation
to introduce change
In the view of the inspectors the ability of the
service to introduce change is not enough
It has to be supported by strong leadership
and support from the top down
A Local Authority is the sum of its parts and
service inspections are not about how the
service performs but about how the Council
manages the service
Golden Thread from LAA to the frontline

Judgement 2
Has the Service Delivered improvements
◦ This has to be demonstrated through (as many
of these as possible) the following
Proposals
Project plans
Business plans
Executive and Council Reports
Approvals
Minutes
Consultation
Impact Assessments
And results and the reviews
◦ Of course they want to know if it was a success

Service track record in delivering

improvement?
This is where they expect to see that the
Golden Thread runs from the LAA themes
through the council to front line service
staff and processes
One key theme is “safer communities”
The sort of things that you need are
◦ Service plans
◦ Improvement plans
◦ Staff development programme/performance
management
◦ Finance strategy
◦ Training needs analysis and training plans

How well does the service manage

performance?
You need to have a corporate, improvement,
financial and service plans that are long-term
◦ Five to ten years
Service plans have to be integrated with each
other
So, CCTV services plans will need to be
integrated with those of hospitals, police,
schools, housing, estates, social services,
business and community safety and any
council service that you have real impact on
This ensures that there is no reinventing the
wheel and resources are not wasted
More importantly the local government has to
control those resources and its priorities
Does the service have the capacity
to improve?
The Audit Commission are already looking
closely at contracted out services and the
management of CCTV by contractors will be
under scrutiny because of its sensitivity
The expectation will be that the client
manages the contracts and proper
governance is in place
CCTV is a sensitive area and needs to be able
to demonstrate the benefits, social and
financial that it brings to communities
I believe that well run CCTV should be a jewel
in the crown of what organisation in
partnership can achieve

Does the service have the capacity

to improve?
“Excellent”CPA services are consistently
coming out as “Poor performers with
uncertain prospects for improvement”.
Key themes are emerging
◦ Equalities
◦ LAA Golden Thread
◦ Value for Money
◦ Knowing who your customers are (will be)
◦ Consultation
◦ Partnership working and shared services
◦ Responsibility for the service to run from the top to
the bottom
It is the Harder Test

Finally: Inspections in Practice

 The End
Malcolm Gardner
Meritec Ltd/Counter-Fraud Group
mg@counterfraudgroup.co.uk
malcolm.gardner@meritec.co.uk
07946800171
0113 286 8828
http://www.counterfraudgroup.co.uk
http://www.meritec.co.uk
http://www.netshare.org.uk