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Criminal Justice Inspection
Northern Ireland
a better justice system for all
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Royal Mail Group
An Inspection of the Royal Mail Group
Crime Investigations Function
Jul 2008
Presented to the Houses of Parliament by the Secretar
of State for Northern Ireland under Section 49(2) of the
Justice (Northern Ireland) Act 2002.
Criminal Justice Inspection
Northern Ireland
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Content
List of abbreviations iv
Chief Inspector’s Foreword v
Executive Summary vii
Recommendations ix
SECTION 1: Inspection Report
Chapter Introduction 3
Chapter Oversight and Governance 5
Chapter Partnership and Results 7
Chapter Equality, Development and Learning 13
SECTION 2: Appendices
Appendix Methodology 18
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List of abbreviations
CHIS
cl
cjs
cP
E&
GL
HMRC
locco
Mo
NI
NPIA
os
PACE
PaLMS
PITO
PNC
POL
PostCOM
PostWatch
PPS
PSN
RIPA
RMG
RML
SPoC
UK
Covert Human Intelligence Source
Criminal Justice Inspection Northern Ireland
Criminal Justice Syste
Crown Prosecution Service (in England and Wales)
England and Wales
General Logistics Services
Her Majesty’s Revenue and Customs
Interception of Communications Commissioner’s Office
Investigation Team Manager
Memorandum of Understanding
Northern Ireland
National Police Improvement Agency
Office of the Surveillance Commissione
The Police and Criminal Evidence (NI) Order 1989
Performance and Learning Management System
Police Information Technology Organisation
Police National Computer
Post Office Ltd
Postal Service Commission
Independent watchdog for postal services in the United Kingdom
Public Prosecution Service for Northern Ireland
Police Service of Northern Ireland
Regulation of Investigatory Powers Act 2000
Royal Mail Group
Royal Mail Limite
Single Point of Contact
United Kingdom
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Chief Inspector’s Foreword
Royal Mail Group maintains a security function responsible for investigating crime against
its businesses. Locally this function is made up of a small unit of investigators reporting
through a territorial head whose responsibility includes Northern Ireland. Royal Mail
pursues its local prosecutions through the Northern Ireland criminal justice system
The inspection looked at the investigative function of the Royal Mail Group in Northern
Ireland using the five main elements of our common core; Openness, Partnership, Equality,
Learning and Results. Royal Mail Group produced a detailed self-assessment of good
quality and had already identified some areas for development.
The small investigative team operating in Northern Ireland was effective and well managed.
An excellent quality assurance system had developed skilled investigators who produced
good quality case files based on sound investigations.
Inspectors found that the methods of case submission in Northern Ireland differed from
England and Wales and there had been some anomalies in case outcomes. Case files are
channelled through an internal quality assurance system before being submitted to the
PSNI for onward transmission to the PPS for a prosecutorial decision. This system is
more complex than it should be and increases the risks of delay and Lost files. Inspector
recommend that Royal Mail Group in Northern Ireland establishes a more direct method
of presenting their cases for a prosecution decision.
Inspectors also believe that a direct case submission link between the PPS and Royal Mail
would better enable prosecutors to provide investigators with reasons for decisions.
Under the existing complex submission system involving PSNI as a third party, reasons for
decisions are not made available directly to Royal Mail investigators. We therefore reiterate
the recommendation made in our report, ‘Public Prosecution Service Northern Ireland’
published in July 2007: ‘Directing lawyers should explain fully their reasoning to the agency i
cases where they direct no prosecution or where their decision is different from that recommended
by the investigator’.
This inspection was led for Cjl by Bill Priestley. I would like on his behalf to thank all those
whom he contacted in the course of the work
Chief Inspector of Criminal Justice
in Northern Ireland
July 2008 Northern Ireland
Criminal Justice Inspection
v
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Executive Summary
This inspection looked at the operation of the investigative element of the Royal Mail
Group (RMG) in Northern Ireland (NI) using the five main headings of Criminal Justice
Inspection’s core matrix: Openness, Partnership, Equality, Learning and Results.
RMG is subject to inspection and regulation by the Interception of Communications
Commissioner's Office (LOCC ) and the Office of the Surveillance Commissioner (OSC
under the Regulation of Investigatory Powers Act 2000 (RIPA). The most recent RIPA
inspections had taken place during 2007 and this aspect of the business was excluded
from the terms of reference of this inspection. Nationally, RMG had also been subject to
oversight by the Police Information Technology Organisation (PITO) with regard to its
usage of the Police National Computer (PNC). However, NI criminal records had been
held locally and RMG in NI had made limited use of records held on the PNC.
Inspectors found that the RMG investigative element in NI was a small, effective and
efficient unit that was subject to excellent quality assurance systems. These systems had
produced good quality case files, professional investigations, and skilled investigators.
The quality assurance systems had been operated robustly for two years and this had
improved case file quality and the standard of investigations. Inspectors recommend that
the system should now move to one based on dip-sampling rather than a detailed
examination of every case file submitted.
Case files were of high quality and casework staff and managers said that files submitted by
the team of investigators compared favourably with those from other areas. However there
were anomalies in case outcomes between the two jurisdictions. Case numbers in NI had
been low so direct statistical comparison with E & W was not possible. Nevertheless, in
the few cases submitted in NI the percentage dealt with by way of caution had been higher
than in E &W. There had also been fewer immediate custodial outcomes as compared t
the rest of the UK.
In E &W prosecution advice and direction is provided by the RMG Criminal Law team
which is positioned independently from the RMG Crime Investigations function applying
Crown Prosecution Service (CPS) guidelines. In NI advice and direction is provided by the
PPS using similar guidelines. However, the overly complex case submission process had
meant that reasons for decisions made by prosecutors had not been made available to the
RMG case investigators. In the absence of explanation by the prosecutor as to why
caution or no prosecution was directed (as opposed to prosecution) RMG had been
unable to establish detailed reasons for apparent anomalies in case outcomes in the figures
between the two different jurisdictions. The CJl report ‘Public Prosecution Service
Northern Ireland’ published in July 2007 recommends that, ‘Directing lawyers should explai
fully their reasoning to the agency in cases where they direct no prosecution or where their decision
is different from that recommended by the investigator’. Inspectors believe that the provision of
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reasons for prosecutorial decisions directly to RMG investigators may help clarify reasons
for discrepancies in outcomes between the jurisdictions and therefore reiterate that
recommendation.
The small team of investigators in NI comprised three from Royal Mail Letters as well as
one team leader. In addition there was one investigator from Post Office Limited and
Royal Mail Security Risk manager. The extended team had worked well together and had
assisted with investigations that had strictly fallen outside their particular business area.
This had improved resilience and had provided support for investigators at short notice but
it had been done informally. Inspectors recommend that RMG security should formalise
flexible approach to investigations so that local investigative staff can be shared across it
business areas in NI in response to demand.
Inspectors found that on first submission RML investigators’ case files contained only tape
summaries whilst those submitted by the POL investigator had full transcripts included.
Transcribing taped interviews is a time consuming exercise and Inspectors were told that it
had impacted on investigation time. Inspectors recommend that the requirement for
routine preparation of full tape recorded interview transcripts should be reviewed in
consultation with the PPS
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Recommendations
* Inspectors recommend that arrangements between RMG and the PSNI are reviewed to
produce an agreed Memorandum of Understanding (paragraph 3.2)
* To improve efficiency and reduce delay Inspectors recommend that RMG establishes
more direct method of presenting their cases for a prosecution decision (paragraph 3.6).
* Inspectors recommend that the quality assurance system for investigations should be
revised to adopt dip-sampling of case files as the default method of maintaining quality
(paragraph 4.5)
* Inspectors recommend that to improve efficiency and reduce the risk of delay that Post
Office Ltd cases are submitted by a more direct method as recommended for RML cases
(paragraph 4.6)
* To improve resilience and support Inspectors recommend that RMG security formalises
a flexible approach to investigations so that local investigative staff can be shared across
its business areas in NI in response to demand (paragraph 4.7).
* Inspectors recommend that the routine preparation of full tape recorded intervie
transcripts should be reviewed in consultation with the PPS (paragraph 4.8).
* Reiteration of previous recommendation made in Cjl report, Public Prosecution Service
Northern Irelan * published 2007 Directing lawyers should explain fully their reasoning to the
agency in cases where they direct no prosecution or where their decision is different from that
recommended by the investigator’ (paragraph 3.10).
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i ——
: : =
Section
Inspection Report
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11
1.2
CHAPTER 1
Introduction
Royal Mail is the state owned
provider of postal services for
England, Scotland, Wales and
Northern Ireland. The Royal Mai
Group (RMG) is made up of four
business units
* Royal Mail Letters (RML)
* Post Office Limited (POL
* Parcel Force
* General Logistics Services (GLS).
The legislative framework is well
established. Postal Services in the
UK operate under The Postal
Services Act 2000 (The Act . The
Act enabled the Postal Service
Commission (PostCOMM) to include
conditions in the RMG licence under
section 13 of the Act. Condition 8 i
Royal Mail’s licence concerns the
integrity of the mail and requires
Royal Mail to agree Mail Protection
Procedures with PostCOMM. Under
these procedures Royal Mail is
committed to investigate and
prosecute those who dishonestly
acquire Royal Mail property or asset
or the property or assets of Royal
Mail customers and clients whilst in
Royal Mail custody. RMG is als
under obligation to allocat
responsibility to specific personnel
for meeting the recording, reporting
and other requirements.
13
14
15
1.6
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Since 1989 RMG Investigators in
Northern Ireland (NI) have had to
comply with The Police and Criminal
Evidence (Northern Ireland) Orde
1989 (PACE) and its respective Codes
of Practice. RMG is a schedule
public authority for the purposes of
conducting covert surveillance and
for the purpose of the acquisition o
communications data under RIP .
RMG NI delivers on average 1.9
million mail items a day to around
785,629 addresses. This equates to
around 2% of the National average.
Reported losses of mail items in NI
represent around 0.002% of delivered
mail.
POL has 532 branches (4% of the
national total) in NI. Royal Mai
Group Ltd has 3,440 staff (2% of the
national total), based in N . This is
comprised of around 3,200 in RML
150 in POL and 90 in Parcel Force
World Wide.
RMG maintains a security function
that is responsible for investigating
crime against its constituent
businesses. The function is the
successor to Post Office Security
and Investigation Services, the Post
Office Investigation Department and
the Investigation Branch.
1.7. RMG investigators are bound by the 1.9
requirements of legislation such as
PACE and RIPA but do not have the
powers of police Constables. As
result interviews of alleged offenders
are carried out with their consent on
a voluntary basis. Investigators at
times seek the assistance of police
officers for various elements of
the investigation. There are 104
investigators spread across three
territorial divisions but the
establishment in NI for Royal Mai
Letters (RML) is one team leader and
three investigators. In addition, POL
has one investigator based in NI and
though Parcel Force has no local
staff, investigations of cases in NI are
conducted by staff based in England.
When necessary investigators ca
move from region to region t
provide support and this means
that they have to be aware of th
differences in legislation and context
in each area. Royal Mail Security
Risk Management has one securit
manager based in NI.
1.10
1.8 External crime such as Post Office
robberies, burglaries, attacks on
postal workers, thefts of deliver
pouches and vehicles are investigate
by the Police Service of Norther
Ireland (PSNI) with support from
each of the business unit securit
teams. Internal crimes such as theft
from the post, accounting fraud, and
intentional delay are investigated b
the company. RMG applies a syste
of investigation trigger points detailing
the incident type, category of
investigation, procedure to be
followe ,and guidance on external
police involvement.
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In England and Wales (E & W) RM
investigators have access to the
Police National Computer (PNC) t
retrieve details of conviction details
of employees for the purpose of any
criminal investigation. In NI the
same information had been source
through the PSNI but the recent
introduction of Access N ' shoul
improve the system of retrieval of
criminal records for RM
investigators.
RMG conducts its own English and
Welsh prosecutions according to
the Code for Crown Prosecutors.
In Scotland completed investigation
files are forwarded to the Procurator
Fiscal’s office and in NI complete
investigation files are forwarded via
the PSNI to the Public Prosecution
Service (PPS). At the time of
inspection fieldwork consultation
with the PPS to enable RMG case
files to be submitted directly to them
was under way. A direct submission
process would reduce the potential
for delay in processing files.
1 The system for the disclosure of an individual's criminal history established by the NI
Office (NIO) as a result of the introduction in N. Ireland of PartV of the Police Act 1997.
4
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2.2
CHAPTER 2:
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Oversight and Governance
The Board of Royal Mail Holdings.
plc is appointed by The Government
which owns 100% shareholding.
Monitoring of performance and
development and agreement of
strategic plans are overseen by the
Board who report directly t the
Shareholder Executive under the
Minister for Employment Relations
and Postal Affairs in the Department
for Business, Enterprise and
Regulatory Reform. Royal Mail
Group ple Ltd. is the operating
company, a wholly owned subsidiar
of Royal Mail Holdings plc.
Regulation of RMG criminal
investigation activities is provided
by a number of organisations. RIP
empowered the OSC to provide
oversight and inspection for sourc
handling (CHIS) and covert
surveillance whilst the OCC
provides the same assurance for
the acquisition and disclosure of
communications data. Monitoring
of usage of the PNC had been
undertaken by PIT . However, this
has been superseded by the National
Police Improvement Agency (NPIA)
which at the time of inspection had
not yet audited RMG with regard t
its use of the PNC.
2 The independent watchdog for postal services.
3 A Postal Packet conveyed pursuant to a licence.
2.3
24
2.5
Internally, RMG uses OSC
methodology to conduct audits of
CHIS and covert surveillance on an
annual basis between each OSC
inspection. Previous OSC reports.
have made positive comments about
RMG as regards its surveillance
operations and its performance i
implementing OSC recommendations.
RMG is also regulated by PostCOMM
and by PostWatc *. RMG is require
to ‘record all incidents of loss or thef
of, damage to, or interference with Cod
Postal Packets in reasonable detail.
RMG must report relevant incident
and prosecutions to PostCOMM on
a quarterly basis and is obligated t
analyse data ‘with a view to identifyin
any trends, patterns or other notable
features (such as above average incident
levels at certain premises).”
RMG submits an Annual Report to
both PostCOMM and PostWatc
which includes:
¢ the number of Code Postal
Packet ° lost, stolen, damaged or
interfered with;
¢ details of any trends, patterns or
other notable features in relation
to the incidence of loss or theft of,
damage to, or interference with,
Code Postal Packets; and
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* a statement of the measures that staff and any visiting investigators
RMG intends to take to remedy from elsewhere in the UK continue
any failures or patterns of failure to operate under the correct
to achieve the Mail Integrit legislation.
Objectives and to reduce the
numbers of Code Postal Packets
lost, stolen, damaged or interfered
with.
2.6 The RMG security function had bee
organised to devolve autonomy and
accountability to business units.
Royal Mail Letters, Post Office Ltd.
and Parcel Force Worldwide each
have a head of security responsible
for managing crime risks and criminal
investigation. The heads of securit
report to Directors in thei
respective business units and are also
members of the Group Security
Council. The Council is chaired b
the Security Director and supports
the effective management of crime
risks across the group, to develop
group-wide strategies and to monitor
performance
2.7 RMG operates under a clear and
comprehensive investigation and
prosecution policy which Inspector
found was well known b
investigators and casework team
members. The policy had last bee
reviewed in December 2007 and was
scheduled to be reassessed again
in November 2008. The policy
had taken into account different
jurisdictions, including NI. However,
it refers exclusively to investigators
operating in compliance with the
PACE Act 1984 but not to the PAC
(NI) Order 1989. There are only
very slight differences but for
complete accuracy it may be useful t
refer in the policy to the PACE (NI)
Order 1989 as well to ensure that NI
3.1
3.2
CHAPTER 3:
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Partnership and Results
Externally the main partner is the
PSN but there are also links to HM
Revenue and Customs (HMRC) and
other external agencies including the
Public Prosecution Service (PPS)
Links with the PSNI are wel
established and generally are good
with clear lines of demarcation as t
where responsibility for investigations
lies. In some cases when a crim
involves internal and external
elements, investigations are carried
out by RMG investigators and passed
to the PSNI once complete. In other
cases the responsibility for
investigation was share
appropriately.
Many cases requiring partnership
work with the PSNI concern the
use of the mail system to transpor
drugs. A Single Point of Contact
(SPoC) arrangement is in place and
there were very good links with the
PSNI drugs units. However, personal
contact played a big part in facilitating
the effective flow of information
between the organisations and
recently much of this had been
lost due to changes in personnel.
Effective sharing of information to
ensure comprehensive risk
assessment prior to operations and
ultimately successful outcomes i
essential to many joint RMG/PSN
operations It would be useful t
3.3
review the SPoC arrangement to
take account of changing personnel,
structures and processes.
Inspectors recommend tha
arrangements between RMG
and the PSNI are reviewed t
produce an agreed Memorandum
of Understanding.
Internal partnerships are essential to
enable the RMG investigative element
to pursue its goals. There is good
partner working between the
investigative unit in NI and the
casework teams based in Great
Britain. Case files are subject to
standard handling process once
investigations are initiated. Case fil
preparation is the responsibility of
the allocated investigator and
Inspectors found that a robust
check-list system ensures files ar
complete before they are forwarde
for quality checking. Inspectors
examined a number of completed
files and found them to be of high
quality. Completed files ar
forwarded through the Investigation
Team Manager (ITM) to a casework
team based in Leeds. Good link
with the casework team had bee
maintained through a series of formal
meetings as well as informal contact
regarding case file issues. The team
provided feedback regarding case fil
quality to investigators and the ITM
3.4
3.5
3.6
and this had directly impacted on
identified training needs and
investigator development
It is the responsibility of the
casework team to check files for
quality and assess the evidence
presented using a comprehensive
quality assurance system. Casewor
team members are not legally
qualified. However, based on
evidence presented in the case file
and applying prosecution guideline
the team mad recommendations
whether or not a prosecution shoul
be pursued. The file then passes to
the RMG Personnel Director for
NI for organisational approval t
prosecute. Once approval is given
files are passed to the Investigation
Manager who forwards them to the
relevant PSNI District Commander
Finally, the PSNI forward the file t
the PPS for a prosecution decision.
This system is more complex than it
needs to be. Passing case files to the
PSNI prior to submitting them to
the PPS is an unnecessary step.
However, Inspectors found that
within RMG case handling there had
been little delay. Targets and case
milestones were applied robustly and
performance against those target
was good. Some cases had suffere
delay after being passed to the PSNI
and Inspectors found that during the
past year four files had been mislaid
resulting in cases being out of time.
3.7
RMG prosecutes its own cases in
E &W through a retained criminal
law team which is positione
independently from the RMG Crim
Investigations Function. This
8
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arrangement enables more direc
contact with courts and more direct
control over the passage of case
through the prosecution system
Results of cases in E & W ar
reported directly by the RM
Prosecution team so that cases ar
finalised immediately. This is not the
case in NI. There is no direct contac
with courts or with prosecutors and
the casework team had experienced
protracted delay in finalising cases so
that they could be reported promptly
to the regulator. RMG has a legal.
obligation to report relevant issue
quarterly to PostCOMM and delay i
finalising cases affects performanc
figures and other data reported t
the regulator. At the time of
fieldwork effort was being made to
establish whether RMG could submit
case files direct to the PPS. This
would be a more direct system and
would lessen the risk of protracted
delay. To improve efficiency
and reduce delay Inspectors
recommend that RMG
establishes a more direct
method of presenting their
cases for a prosecution decision.
Inspectors interviewed members of
the casework team in Leeds and
examined case notes and statistical
information regarding files submitte
from NI. The present system had
been in operation for two years and
Inspectors found that the quality
assurance process was an excellent
example of good practice in action.
Investigators spoken to recognised
the system as thorough. However,
when it was first introduced it had
been regarded as overly exacting.
Investigators and manager
3.8
recognised that quality had been 3.9
improved and all took pride in
achieving high quality scores. The
scoring system was sufficiently
sophisticated to highlight areas for
development, for example, conduct
of taped interviews, and these wer
addressed by focused further training
for investigators
Case files were of high quality an
had not been subject to unnecessar
delay whilst being investigated by
RMG staff. Casework staff and
managers said that files submitted by
the team of investigators in NI
compared favourably with those from
other areas. However, across the two
jurisdictions, two different systems of
case handling had produced some
differences in case outcomes. Case
numbers in NI had been low and
therefore comparisons with cas
outcomes in E & W where there had
been much higher numbers of cases
should be regarded with caution.
Nevertheless, the percentage of cases
dealt with by way of caution is
consistently higher in NI than i E
W. Table 1 (see page 10) shows the
figures dealt with by way of caution
during 2005-06; 2006-07; and the
total to the end of December 2007
for the year 2007-08. The figures for
cases dealt with in 2006-07 show that
16% of total cases dealt in E &
were by way of caution as compared
with 33% in NI for the same period.
Complete figures for 2007-08 were
not available at the time of fieldwor
but up to the end of December 2007,
cautions in NI were running at 71%
compared to 21% for E & W
3.10
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The comparative scale of cases dealt
with by the small investigative team in
Northern Ireland is illustrated i
Table (see page 11). Figures for
the year 2007-08 refer to those
recorded up to the end of Decembe
2007. In 2006-07 the percentage
of crime incidents reported that had
resulted in investigations in NI was
25% compared with a figure of
18.08% for the rest of the UK.
In the same year the percentage of
investigations raised that resulted i
interviews under caution being
conducted were 58.3% for E &
compared with 67.3% for NI.
All RMG case files pass through the
same quality assurance process up
to the prosecution decision stage
In E & W the prosecution advice and
direction is provided by the RM
criminal law team which is positione
independently from the RMG Crime
Investigations Function applying
Crown Prosecution Service (CPS)
guidelines. In NI the decision is
taken by the PPS using similar
guidelines. However, the overly
complex case submission process
had meant that reasons for decisions
made by prosecutors had not bee
made available to the RMG case
investigators. In the absence of
explanation by the prosecutor as to
why a caution or no prosecution was
directed (as opposed to prosecution
RMG had been unable to establish
detailed reasons for apparent
anomalies in case outcomes betwee
the two different jurisdictions. The
Cjl report ‘Public Prosecution Servic
Northern Ireland’ published in 2007
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Table
RMG Security Statistics
Royal Mail Letters
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Year
Crime incidents reported (All)
Crime incidents reported (NI)
Investigations raised (All)
Investigations raised (NI only)
Interviewed under caution (All)
Interviewed under caution (NI only) I 33 a 24
2005-06 2006-07 2007-08
8150 6993. 4475, 345
163 158 95 5
16171312, 924 37
49 51 24 0
944 832 519
recommends that, ‘Directing lawyer
should explain fully their reasoning to
the agency in cases where they direct no
prosecution or where their decision i
different from that recommended by the
investigator.” Because of the third-
party submission process through the
PSNI the PPS had been unable t
clearly distinguish Royal Mail cases.
If RMG pursues direct submission of
its case files to the PPS then it woul
follow that prosecutors would be
better enabled to provide reasons
for decisions directly to RMG as
the originating agency rather than
operating indirectly through the PSNI.
The present indirect submission
system hampers proper monitoring
of case progression and outcomes.
Case outcomes are important t
RMG as there are financial
consequences to a low rate of
successful prosecutions. Recovery
of costs and compensation is possibl
if cases are dealt with through
the courts whilst costs are not
recoverable in cases dealt with
2005-06 2006-07 2007-08
2005-06 2006-07 2007-'08
482 308 163329231957
3 3 48 195 131
58 32 716 535, 228
0 0 19 30 10
262 172 105
3 14 12
by caution. In E & W applications
for costs are routinely made b
prosecutors on behalf of RMG and
awarded as appropriate by the courts.
There had been many less cases in
NI but of those a higher percentage
had been dealt with by way of caution
and therefore costs had not been
recoverable Costs awarded in all
cases prosecuted in E & W in
2006-07 amounted to £110,311.
In the same period in N , nil costs
were awarded.
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CHAPTER 4:
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Equality, Development and Learning
RMG is subject to and operate
under equality legislation. It woul
not be valid to draw conclusions
regarding equality in the workforce
from such a small team of
investigators but it was broadl
representative of the population in
general. In RMG internal incidents
of harassment and bullying ar
investigated independently of the
Criminal Investigation function by
appropriately trained harassmen
investigators. At the time of
fieldwork no such incidents had bee
reported for investigation in NI.
Individual performance of
investigators had been monitore
using performance scorecards and
monthly feedback had been provided.
Areas for development had bee
linked through from performanc
measures to focused training and
investigators had also highlighte
areas for development through the
Performance and Learning
Management System (PaLMS). Team
performance is also measured and
monitored using a scorecard syste
against agreed Key Performance
Indicators (KPIs).
RMG had conducted surveys of staff
opinions annually through a survey
called ‘Have Your Sa ’. Results from
44
led to the development of
organisational Action Plans being
taken forward. Staff had been
involved in the deployment and
monitoring of Action Plans and had
spoken positively to Inspectors about
how RMG had sought to properly
consult with staff at the service
delivery end of the business.
There had not been a high turnover
of staff in the investigations side of
the business in NI. Most investigators
were very experienced and all had
attended structured investigativ
training. Investigators had completed
an Introduction to Investigation
Programm ’ involving distance
learning, practical elements (includin
court procedure), and on-the-job
training. Investigators had bee
assessed whilst on the programm
and to be successfully confirmed had
to be awarded a pass. Som
investigators had also attende
refresher programmes and focuse
training identified from thei
development plans. Surveillanc
training had been identified as an
organisational need and all the
investigators had been scheduled t
attend surveillance training later i
2008. All staff spoken to by
Inspectors had attended a generi
RMG Diversity course.
the survey had been analysed and had
13
45
4.6
Most training had been delivered in-
house by the RMG training unit based
in England. However, some training
had been delivered by the police
Investigative training had bee
accredited to NVQ level. Trainin
had been linked to personal and
organisational need. The qualit
assurance system administered by
the casework team in Leeds had
contributed to both personal and
organisational development by
identifying areas for development
through a structured and
comprehensive scoring system.
At the time of fieldwork Inspectors
were told that a review of this system
was being considered. Given that
case files and the quality of
investigations had been improved
investigators had been developed,
and that there had been minimal
turn-over of NI staff a review of this
system would be timely. The syste
had been in operation for two year
and Inspectors believe that the
adoption of a less rigid system based
on dip-sampling rather than detaile
assessment of every case file
submitted would now be adequate to
maintain quality and identify training
needs. Inspectors recommend
that the quality assurance
system for investigations shoul
be revised to adopt dip-sampling
of case files as the defaul
method of maintaining quality.
Typical cases dealt with by RML
investigators included theft of post
and criminal damage. The POL
investigator typically dealt wit
offences committed by PO employees
against customer accounts. These
investigations had been mor
complex in nature and had ofte
47
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involved elements of fraudulent
behaviour or false accounting.
Because the offences had bee
committed in NI and were subject t
different submission processes and
legislation, the RMG criminal la
team had been unable to eithe
provide advice nor decide on
prosecution regarding these cases.
The POL investigator had access
to advice regarding employment
legislation if required. For PO
criminal cases in NI the internal
prosecution decision rests with the
Head of Security. Files had then
been forwarded to the PSNI for
onward transmission to the PPS. As
previously raised in the report this i
an overly complex submission system
which increases the risk of delay.
It would be helpful if cases submitted
in NI by the POL investigator went
through the same, less complex
process as recommended for RM
cases. Inspectors recommend
that to improve efficiency and
reduce the risk of delay tha
Post Office Ltd cases are
submitted by a more direct
method as recommended fo
RML cases.
There was only one POL investigator
for NI but at the time of fieldwor
two other investigators based i
England and Scotland were being
trained to deal with NI cases t
improve resilience and to provide
support. Inspectors found that there
was capacity within the existing RM
investigators in NI to provide suppor
and cover. There had been cases
when the POL investigator had
assisted with RML investigations and
this had been reciprocated informally.
To improve resilience and
48
support Inspectors recommend
that RMG security formalises a
flexible approach to
investigations so that local
investigative staff can be shared
across its business areas in NI
in response to demand
Inspectors found that POL cases had
been generally more complex and
had required several tape recorded
interviews. Case files examined had
contained full tape transcripts as
opposed to tape summaries that
had been found in RML case files.
The preparation of full tape
transcripts had been done by the
POL investigator and had been tim
consuming; impacting on time spent
actually investigating. Inspectors
were told that the preparation
of full transcripts had been under
instruction from the PPS. The routine
preparation of full tape transcripts
for every POL case is a costl
exercise and should be reviewed i
consultation with the PPS. In similar
cases prepared by other bodies, suc
as the PSNI, full transcripts are not
routinely required by the PPS.
Inspectors recommend that th
routine preparation of full tap
recorded interview transcript
should be reviewed in
consultation with the PPS
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Section oO
Appendices
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Appendix 1: Methodology
This Inspection commenced in November 2007 and consisted of the following main
elements:
* Research and Organisational self-assessment
* Fieldwork
¢ Report refinement
Fieldwork
Visits to RMG took place during February and March 2008. Interviews wer conducted
with relevant staff in all areas concerned with the investigative process. All members of th
investigative team in NI were interviewed together with relevant supervisors. A selection of
case files was also examined. All members of the casework team based in Leeds having any
responsibility for NI cases were also consulted and the quality assurance structures and
statistical monitoring functions were examined.
Report refinement
Draft reports were shared with RMG for factual accuracy checking prior to sharing the
report with interested organisations.
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