Comprehensive Report on PSA Recommendations

5.7 We recommend that the CRNS provide information on the CRNS's website about support that would be offered for anyone facing difficulty in completing a written letter of complaint.

5.8 We recommend that, as part of the triage process steps are included to identify cases where complainants may require assistance to produce a written complaint.

5.9 We recommend that the CRNS develop a clear policy or procedure to allow the CRNS or Investigation Committee to report an ‘own motion’ complaint or authorise an investigation.

5.10 We recommend that the CRNS develop a clear policy or procedure to address additional conduct or competence matters that come to the CRNS’s attention during an investigation.

5.11 We recommend that the CRNS develop a process for considering information obtained from the competence assurance process survey and developing and implementing improvements to the process.

5.31 We recommend that the CRNS share the analysis of complaints data with bodies with similar interests.

5.32 We recommend that the CRNS exchange information with other bodies with a relevant interest where complaints cases indicate information that may be of interest to them in relation to public protection or the wider public interest.

5.12 We recommend that the CRNS provide detailed guidance for the Investigation Committee on the questions to be answered in each case at each stage of the decision-making process such as evidential sufficiency, whether the facts amount to misconduct and/or incompetence, whether there is evidence of undesirable practice and whether the case is appropriate for CCRA. (Standards 3, 5 and 8)

5.13 We recommend that the CRNS develop sanctions guidance setting out the factors that will be taken into account when determining the appropriate outcome in an individual case.

5.14 We recommend that the CRNS develop published criteria setting out those matters that would not meet the CRNS’s threshold for establishing professional misconduct and/or professional incompetence.

5.33 We recommend that the CRNS develop a system of quality control that enables it to identify inconsistency in the decisions that are taken or the investigation steps that are followed and details of how learning from this is used to improve the investigation process.

5.34 We recommend that the CRNS develop an induction procedure for new staff and policies dealing with the allocation and handover of files between investigators.

5.15 We recommend that the CRNS review the current triage process and develops this further to include preliminary investigations, safety risk analyses and prioritisation and establishes processes to support staff in prioritising cases.

5.16 We recommend that the CRNS introduce guidance for staff with tools for consistently: identifying agreed areas of risk; making reasoned decisions about prioritisation of cases; and recording the reasons for decisions about the progression of cases and for taking/not taking action.

5.17 We recommend that the CRNS introduce timeframes and guidance for the ongoing risk assessment of cases as new information arises and at relevant and appropriate stages of the case to demonstrate that appropriate action has been taken once risks have been identified.

5.13 We recommend that the CRNS provide detailed guidance for the Investigation Committee on the questions to be answered in each case at each stage of the decision-making process such as evidential sufficiency, whether the facts amount to misconduct and/or incompetence, whether there is evidence of undesirable practice and whether the case is appropriate for CCRA. (Standards 3, 5 and 8)

5.18 We recommend that the CRNS provide guidance to the Investigation Committee, members and the public as to those matters that will not ordinarily amount to professional misconduct or professional incompetence and those matters that might constitute undesirable practice.

5.19 We recommend that the CRNS review the competence assurance procedure to ensure complainants are not treated differently from members without justification.

5.20 We recommend that the CRNS review the process for submitting investigations to be considered by the Investigation Committee to increase transparency and avoid any perception of bias.

5.21 We recommend that the CRNS consider whether it could introduce a process for internal review of decisions not to refer a case to the Discipline Committee

5.35 We recommend that the CRNS conduct a review of the resources in the complaints and investigation function to determine what additional resources may be required to expedite the handling of cases and to eliminate the backlog of cases that has been accrued without any consequential negative impact on the newer cases that are being received.

5.36 We recommend that the CRNS introduce a regular reporting mechanism to Registrar and senior management that includes an analysis of the length of time taken to progress cases through each stage of its complaints process to ensure cases are progressed as quickly as possible and that improvements are maintained.

5.37 We recommend that the CRNS undertake work to map the pathway of a complaint from receipt to closure.

5.22 We recommend that the CRNS develop guidance on the timeframes within which members and complainants are updated in individual cases.

5.38 We recommend that the CRNS develop guidance on the timeframes within which members and complainants are updated in individual cases together with a system for monitoring the steps taken by investigators or administrators to keep parties updated.

5.12 We recommend that the CRNS provide detailed guidance for the Investigation Committee on the questions to be answered in each case at each stage of the decision-making process such as evidential sufficiency, whether the facts amount to misconduct and/or incompetence, whether there is evidence of undesirable practice and whether the case is appropriate for CCRA. (Standards 3, 5 and 8)

5.23 We recommend that the CRNS develop guidance as to what may constitute undesirable practice warranting a letter of guidance where a complaint is not substantiated.

5.24 We recommend that the CRNS revise its guidance on cases where a CCRA may be considered appropriate and specify circumstances where it will be necessary to refer a case to the Discipline Committee for determination.

5.25 We recommend that the CRNS develop guidance and provide education/training for the Investigation Committee to support decision-making around the issuing of letters of guidance or agreeing CCRAs. In particular, the guidance should assist the Investigation Committee to give reasons explaining how the outcome addresses public protection, confidence and professional standards.

5.26 We recommend that the CRNS develop a policy setting out the CRNS’s positions on what sanctions will and will not be published, what information will and will not be anonymised, and the timescales for publication.

5.27 We recommend that the CRNS develop procedures for staff under its policy on confidentiality of investigation files to link with other information security policies and ensure action is taken when breaches occur to prevent recurrence.

5.28 We recommend the CRNS address the secure retention of postal communications on receipt and general security of those areas where investigations information is held within the CRNS’s offices.

5.29 We recommend that consideration be given to rationalising investigation files and the way they are accessed by staff and the Investigation Committee.