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The police super-complaints system allows designated organisations to raise issues on behalf of the public about harmful patterns or trends in policing.
Her Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS), the College of Policing and the Independent Office for Police Conduct (IOPC) are responsible for assessing, investigating, and reporting on police super-complaints.
There are a number of outcomes of investigation, which could include an inspection by HMICFRS, an investigation by the IOPC, changes to existing policing standards or support materials from the College of Policing, as well as recommendations to one or more police forces to change practices or local policies, or to another public body or government department to consider responding to the super-complaint or a related matter.
Where recommendations are made, decision-making bodies expect the organisations named in the recommendations to act on them and consider whether they need to involve others to bring about change.
HMICFRS, the College of Policing and the IOPC may individually, or as a group, monitor the implementation of recommendations made after each super-complaint investigation.
All super-complaints that have been assessed by HMICFRS and senior representatives from the IOPC and the College of Policing as being eligible for investigation can be found on the gov.uk website.
Liberty and Southall Black Sisters put forward this super-complaint about the treatment of victims of crime and witnesses with insecure immigration status. It focuses on how information about them is passed to the Home Office for immigration enforcement.
Further details about police super-complaints: police data sharing for immigration purposes.
Northamptonshire Police submitted a joint response with Northamptonshire’s Police, Fire and Crime Commissioner (PFCC) to HMICFRS on 3 December 2021. Responses to recommendations made in the report are detailed below.
"As an interim measure, where officers only have concerns or doubts about a victim's immigration status, they immediately stop sharing information on domestic abuse victims with Immigration Enforcement. Instead, police officers should link the victim to a third party that can provide advice and assistance."
Amending practice: Northamptonshire Police implemented an immediate change in practice to allow a separation between the response to a victim's report of domestic abuse and the handling of their immigration status. There has never been a bespoke process which dictates that officers and staff should share immigration concerns with the Home Office.
The amendment to practice was effectively communicated to staff internally and delivered/reiterated within core Domestic Abuse training. A clear communication of the expectations was disseminated - domestic abuse and being a victim of crime will always take priority over upholding immigration law. Where officers only have concerns or doubts about the domestic abuse victim's immigration status, they will not share information with Immigration Enforcement.
Building relationships with third party agencies that can provide advice and assistance to victims: Northamptonshire Police has shared its position and expectations on staff who deal with migrant victims of domestic abuse, with all relevant local support services and through to the Multi Agency Risk Assessment Conference (where all high-risk domestic abuse cases are addressed by key partners including Northamptonshire Police).
"Take steps to ensure that all migrant victims and witnesses of crime are effectively supported through safe reporting pathways to the police and other statutory agencies."
Safe reporting pathways: Safe reporting pathways for all migrant victims and witnesses are provided by Northamptonshire Police’s Control Room, website and importantly via our local support services. Support services have been advised on how to relay reports of domestic abuse to police and have been reassured that information is not and will not be shared with Immigration Enforcement.
Communication to migrant victims: The report found that immigration and data sharing with the Home Office were significant deterrents to migrant victims reporting domestic abuse. Northamptonshire Police have actively publicised its position through a press release, highlighting that domestic abuse and being a migrant victim of crime will be dealt with sensitively and robustly, reiterating that it is a confidential process. For those with an insecure immigration status who still have concerns about speaking to the Police directly, support services have been listed as an alternative reporting mechanism. This has also been shared with support groups so that the message can be shared with members of their communities and those individuals they are working with who are affected by immigration status concerns.
"In consultation/collaboration with local or national specialist organisations, chief constables and police and crime commissioners should take steps, to promote migrant victims' and witnesses' confidence in reporting crimes to the police through safe reporting pathways, without fear of prioritised immigration control."
A joint communication was sent out to all local support services on behalf of the Chief Constable and Police, Fire and Crime Commissioner (PFCC) to promote that domestic abuse and being a migrant victim of crime will always take priority over upholding immigration law. In this communication, safe reporting pathways were encouraged through direct contact with the police and via support services. Additionally, engagement was made with support services via the OPFCC, to seek support as to how this message could be more firmly and widely strengthened in relevant communities.
Conduct an assessment of local access to specialist victim support organisations or networks and take any necessary steps to build up such networks.
The Office of the Police, Fire and Crime Commissioner has considered this point in some depth with VOICE in the County. VOICE is an arm’s length company, wholly owned by PFCC for Northamptonshire, set up to deliver the PFCC statutory responsivities in relation to victims. VOICE has a number of routes that can provide a wide range of generic and specific services across a range of victim’s needs and requirements. This assessment has satisfied us that individual needs and requirements can be met, either through directly supplied services or through effective signposting to external services, such as: