The aim of this document is to outline the procedure for the creation, review and publishing of policies. This document also outlines the process for policy rescission. Information and templates relating to policy creation, review and rescission can be found on the intranet.
Key Principles
- A policy template is available. Policies are the “what and why” and related standards/procedures are the “how”.
- Policies are the overarching principles of our organisation. They provide direction, guide and influence decision-making as well setting out a framework for delivery within the subject area covered by the policy itself.
- The policy must only include specific processes or guidance within them if they support the parameters for decision-making or are necessary to the policy. These may be added as appendices where appropriate.
- Supplementary information such as external reference documents, legislation or national guidance may be referred to within the policy but not added as appendices.
- Telephone numbers, e-mail addresses and names must not be included within the policy (apart from details of the owner/contact and within the version control table). Policies may be proactively published or may be released through FOI and therefore, it is important to consider any sensitive information contained within and highlighting these items within the policy ready for review with the disclosure team. An author must consider ‘openness by design’. Please contact the Policy Officer to discuss in more detail.
- Policy Owners/Authors can refer to the College of Policing (Authorised Professional Practice) before creating or reviewing a policy. If there is currently APP for the area in which the policy relates to then, it may mitigate the need for a force policy. Further advice can be sought from the Policy Officer.
- Policy Owners/Authors must ensure that they keep to ‘one version of the truth’. Old documents and policy versions no longer in use must be proactively removed.
- New Policy Process
1.1 Recognising the need for a new policy
- In most cases, a business area/department lead may identify a need for a new policy, for example where a new way of working is being implemented or new legislation has been enacted. The need may also be identified by the Policy Officer, a governance meeting or through audit.
- At the earliest opportunity a policy owner and/or author will need to be determined. The policy author will receive support and guidance from the force policy officer.
- The policy owner/author must consider if there is a need for the policy, by checking the College of Policing (CoP) APP and national/regional guidance. Consideration must also be given as to whether a procedures document would be sufficient.
- The policy owner/author must consider the pertinent business area(s) and relevant staff who need to be consulted throughout. These can be listed on the policy template. As part of this, consideration must be given to those who need oversight throughout the lifecycle of the policy. Contacting stakeholders early on can be beneficial in preparing the first draft.
- The policy owner/author must contact the Policy Officer to log the draft, for advice and to check for similar/relevant policies. The Policy Officer will record that this policy is being considered on the policy log. The Policy Officer can provide support and guidance throughout the process.
1.2 Drafting a new policy and completing the Equality Impact Assessment (EIA)
- Policy authors must follow the policy template and procedure when writing the content of the policy.
- The template is watermarked as DRAFT.
- Policy authors must complete an Equality Impact Assessment (EIA) alongside the policy draft. Details on how to do this can be found on the intranet. Guidance can be sought from the Equality, Diversity and Welsh Language department. Policy authors must familiarise themselves with the requirements of the Equality Act 2010 and must fully consider the Force’s commitment to encouraging equality, diversity and inclusion in the workplace, and the elimination of unlawful discrimination.
- Every effort must be made to ensure that up to date supporting documents within the subject-area (such as other Force policies or guidance documents) are linked within the policy.
- Authors are reminded of the need to use plain, gender-neutral English/Welsh. Content must be concise, avoiding jargon and long paragraphs. Authors must avoid acronyms/abbreviations (unless made clear within the document what they mean).
- Policies must be written from the point of view of the intended audience and use present tense and active voice where possible.
- Language used must make mandatory requirements clear through the use of ‘must’, not ‘should’ or ‘shall’. Authors are encouraged to avoid use of terms such as ‘generally’ and ‘normally’. If an exception or discretionary provision is required, detail of who can approve it can be included in the policy.
- The Policy Officer can support with additional suggestions and can proofread the draft(s).
1.3 Consultation
- Once the policy author has created the first draft, the document can be discussed at relevant business area group(s) and with key stakeholders. The OPCC is a key stakeholder as they adopt many force policies or have responsibilities in terms of scrutiny of our governance arrangements.
- Other examples of key stakeholders include Health and Safety, Legal Services, Finance, People Services, Information Management and Compliance, Trade Unions, Police Federation, Supt’s Association, Support Networks, IAG, etc. (as appropriate). The EIA and Code of Ethics must also be discussed in relation to the policy. The Policy Officer can also support in facilitating feedback.
- Any policy that contains a people-related element must follow the Joint Negotiating Consultative Committee (JNCC) Constitution and Governance Framework for People Related Policy Consultation & Approval (copy can be obtained from HR or Policy Officer if required). Additionally, where the policy was proposed at, or identified through, the Joint Audit Committee (JAC), consultation must be sought from the JAC.
- The Policy Officer and policy owner can discuss and agree the timescale for future review cycle.
1.4 Legal Services
- At final draft, the policy officer will submit the policy and completed EIA to Legal Services and obtain a Human Rights Certificate. Legal Services will sign and date the relevant section of the policy confirming this.
1.5 Policy Sign-off
- A new policy must have been discussed and approved at the relevant governance group pertaining to the relevant business area(s).
- Once agreed to in principle by the governance group, the policy must be raised as an agenda item for a relevant Chief Officer chaired Board
Dyfed-Powys Police aims to proactively publish policies where it is safe and suitable to do so. This aligns with the requirement to routinely publish policies and procedures as part of a Publication Scheme under the Freedom of Information Act. Once approved, the document must be considered for suitability for publication.
1.6 Disclosure
- In the case where the document is fully available for publication, the policy owner/author can complete the appropriate section on the policy template to confirm this and move to the next stage.
- Throughout the process, if the policy owner/author identifies any content within the policy that could be harmful in terms of publication (for example, that the policy would inform of tactics or intelligence that would be harmful to release to the public), the policy owner/author must highlight these areas within the document and send it to the Disclosure Unit for review. The Disclosure Unit apply appropriate exemptions where necessary. This may mean that there will be two versions of the policy. A full policy for internal use and publication and a redacted version for external publication.
- In small cases, the whole policy may be harmful if released. The Disclosure Unit will advise and apply exemptions in this instance. A report will be prepared by the Policy Officer outlining why we do not publish a particular policy in readiness for future FOI requests or questions raised pertaining to the Publication Scheme obligations.
- Where there is any uncertainty as regards to publication or exemption, the policy author/owner can consult with the Policy Officer.
1.7 Welsh Translation
- The Welsh Language Standards in relation to policy can be located here.
- Dyfed-Powys Police aims to proactively publish policies where it is safe and suitable to do so. This aligns with the requirement to routinely publish policies and procedures as part of a Publication Scheme under the Freedom of Information Act. This means that policies are likely to need translation, in preparedness for publication externally.
- Welsh translations can be requested here. Please read the Service Level Agreement before sending work to the Translation Unit and check the Translation Unit’s checklist to ensure that the work sent is compatible. The Policy Officer can support in submitting a request on behalf of the policy owner/author.
1.8 Obtain Policy Number and Publish
- The Policy Officer will be able to provide the policy number and will consult with policy owners around publication.
- Ensure that the new policy is communicated to relevant employees. The policy owner/author may wish to seek support from corporate communications).
- The Policy Officer will publicise the new/reviewed policy internally within the quarterly Policy Newsletter.
- Review Process
2.1 Reviewing a policy
- In most cases, the Policy Officer will contact the policy owner/author three months prior to review date and provide a link/attach the most recent version of the policy. However, the policy owner may be prompted to review the policy sooner than scheduled. Please contact the Policy Officer to log the review, to seek advice and to check for similar/relevant policies.
- The policy owner/author must refer to any recommendations received (as part of an audit, for example), College of Policing APP and national/regional guidance. It may be that the policy is no longer required.
- The policy owner/author must consider the relevant business area(s) and staff who need to be consulted throughout the review. These can be listed on the policy template. Contacting stakeholders early on can be beneficial in the review process. Some suggested key stakeholders are detailed within 2.3 below.
2.2 Proposing changes to policy and referring back to the Equality Impact Assessment (EIA)
- Policy authors must follow the policy template and guidance when reviewing and updating the content of a policy.
- The document must be watermarked as DRAFT (the Policy Officer will have done this if review is scheduled).
- Policy authors must use the original Equality Impact Assessment (EIA) alongside the policy review and relate back when changes are made. Details on this can be found on the intranet. If the EIA is on an outdated template, the EIA will need to be transferred to the most recent version (and reviewed/updated in the process, if necessary). If there are any changes, these must be made clear.
- All changes to the policy must be highlighted or recorded via Track Changes. This is to allow the changes to be made visible and to allow for a more informed review from stakeholders when consulting on the document.
- If the policy has/requires supporting standards/procedures documents to formulate how the policy will be implemented, these must be made available (where appropriate) during consultation. Checks must be made to ensure that the policy refers to the correct/most recent version(s).
- At this point, the policy owner/author and the Policy Officer will be aware of the scale of change(s) to the policy. There are two pathways to consider – 1) minor change, or 2) major change:
Examples of Minor Changes
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Examples of Major Changes
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- Spelling
- Update to legislation included within policy that does not affect the content/responsibility too much (e.g. GDPR to UK GDPR)
- There is no change to policy content and wider context since previous review
- Moving to a new Force Policy template where there is little change or no change to the content
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- Merging of two policies
- Large-scale change to process of how DPP conducts its work
- Large-scale change to responsibility
- Moving to a new Force Policy template and addressing large changes in the process
- Large change in the wider context
- Policy may be identified as no longer needed – see ‘policy recission’
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- The Policy Officer can advise on scale of changes and advise on the best course of action at review. This information is stored on the Force policy log.
- The Policy Officer and policy owner can review, discuss, and agree the timescale for future reviews.
2.3 Consultation
- Once the policy author has created the draft, the document must be discussed at relevant business area group(s) and with key stakeholders. The OPCC is a key stakeholder as they adopt many force policies and have responsibilities in terms of scrutiny of our governance arrangements.
- Other examples of stakeholders include Health and Safety, People Services, Information Management and Compliance, Trade Unions, Police Federation, Supt’s Association, Support Networks, IAG etc. (as appropriate). The EIA and Code of Ethics must also be discussed in relation to the policy. The Policy Officer can also support in facilitating feedback.
- The policy officer collates consultation feedback that is received throughout the consultation period, reporting to the policy owner for any suggested amendments/changes to the policy.
- Any policy that contains a people-related element must follow the Joint Negotiating Consultative Committee (JNCC) Constitution and Governance Framework for People Related Policy Consultation & Approval (copy can be obtained from HR or Policy Officer if required). Additionally, where the policy was proposed at, or identified through, the Joint Audit Committee (JAC), consultation can be sought here.
- Initial approval of the changes can be sought at the relevant governance group
2.4 Legal Services
- For minor changes proposed during the review, the policy only needs to be sent to Legal Services if the changes affect the Human Rights Certificate.
- For major changes proposed during the review, the policy is highly likely to need consideration from Legal Services.
- If the policy is sent to Legal Services, policy owners/authors must send their policy and reviewed/renewed EIA to Legal Services and obtain a Human Rights Certificate.
2.5 Policy Approval
- A minor change to a policy must be discussed at the relevant governance group pertaining to the relevant business area(s) and can be signed off and ratified at the governance group If an urgent change is required, the business-area lead can sign off and ratify the changes if they are satisfied. The Policy Officer can provide clarity on the appropriate course of action.
- A major change must be discussed at the relevant governance group pertaining to the relevant business area(s). Once agreed to in principle in the governance group meeting, the policy can then be raised as an agenda item for a relevant Chief Officer chaired board meeting for ratification.
- Any policy that contains a people-related element must follow the Joint Negotiating Consultative Committee (JNCC) Constitution and Governance Framework for People Related Policy Consultation & Approval (copy can be obtained from HR or Policy Officer if required).
- If approved, the document can be considered for suitability for publication.
- The Policy Officer can advise on a case-by-case basis in the event of any changes or amendments raised during sign-off and/or ratification.
2.6 Disclosure
- Throughout the process, the policy owner/author will have identified if there are any parts of the policy that are harmful in terms of publication.
- In the case where the document is fully available for publication, the policy owner/author can complete the appropriate section on the policy to confirm this and move to the next step.
- In the case where areas of harm have been identified, the policy owner/author must highlight these areas. The policy must be subsequently sent to the Disclosure Unit for review and to apply appropriate exemptions where necessary. This may mean that there will be two versions of the policy. A full policy for internal use and publication and a redacted version for external publication.
- In small cases, the whole policy may be harmful if released. The Disclosure Unit will advise and apply exemptions in this instance. A report will be prepared by the Policy Officer outlining why we do not publish a particular policy in readiness for future FOI requests or questions raised pertaining to the Publication Scheme obligations.
- Where there is any uncertainty as regards to publication or exemption, the policy author/owner can consult with the Policy Officer.
2.7 Welsh Translation
- The Welsh Language Standards in relation to policy can be located on the intranet.
- Dyfed-Powys Police aims to proactively publish policies where it is safe and suitable to do so. This aligns with the requirement to routinely publish policies and procedures as part of a Publication Scheme under the Freedom of Information Act. This means that policies are likely to need translation, in preparedness for publication externally.
- Welsh translations can be requested here. Please read the Service Level Agreement before sending work to the Translation Unit and check the Translation Unit’s checklist to ensure that the work sent is compatible. The Policy Officer can support in submitting a request on behalf of the policy owner/author.
- Where the policy may have been translated previously, please submit the prior translation to the Translation Unit to support them – this will provide them with information as to terminology and may help them prepare the translation faster.
2.8 Publish
- The Policy Officer will consult with policy owners around publication.
- Policy Archive and Rescission Process
3.1 Rescinding a policy: first steps
- The rescission of a policy occurs when an active policy is obsolete or has been combined with another policy. It may also be due to changes in procedures, where DPP use College of Policing APP, for example.
- The policy rescission process usually follows on from the review process, in the instance where the policy is identified as no longer effective/required during the scheduled review. It may also be identified as part of a different policy’s review process (for example, where it is recommended that the effective parts of a policy are merged with another, rendering the original policy no longer fit for purpose).
- When considering rescission, and if not done as part of the review process, the policy owner can refer to the College of Policing APP website. Consideration must be made as to whether there is still a need for this policy or if we simply need a standards/procedures document. Consideration must also be made as to whether anything has been identified within any recommendations or audits (internal/external) that must be included or researched. The Policy Officer can support with research and provide advice and guidance.
3.2 Consultation
- The policy owner, with the support of the Policy Officer, will compile a report and submit their findings and the policy to the relevant business area group(s) as well as key stakeholders. The OPCC is a key stakeholder as they adopt many force policies or have responsibilities in terms of scrutiny of our governance arrangements.
- Other examples of key stakeholders include Health and Safety, Legal Services, Finance, People Services, Information Management and Compliance, Trade Unions, Police Federation, Supt’s Association, Support Networks, IAG etc. (as appropriate). The Policy Officer can also support in gathering feedback.
- Any policy that contains a people-related element must follow the Joint Negotiating Consultative Committee (JNCC) Constitution and Governance Framework for People Related Policy Consultation & Approval (copy can be obtained from HR or Policy Officer if required).
- Policy owners must use this information to further refine their report for policy rescission. The Policy Officer can provide advice and guidance and support with proofreading.
- Initial approval of the proposed rescission must be sought at the relevant governance group meeting.
- Rescission Sign-off
- Once agreed in principle by the relevant business area group(s), the policy rescission must be raised as an agenda item for a relevant Senior Officer chaired board for ratification.
- The decision must be relayed to the Policy Officer to keep an accurate account of decisions relating to the rescission.
3.4 Archive, Retention and Disposal
- The policy will be retained and archived by the Policy Officer.
- The policy and/or procedure retention period is a minimum of 10 years, followed by a review (NPCC Review Retention and Disposal Schedule 2020 Version 4; Home Office Retention and Disposal Standards). This relates to the retention of the final policy/procedure itself, not the supporting developmental paperwork.
- At the end of the 10-year minimum period, the Policy Officer in consultation with the Force Records Manager must consider the operational need, public interest and/or historical records in relation to the decision of retaining or disposing.
- A single copy of the record must be stored within the Policy Archive folder and must be logged within the Archive and Disposal Register (held by the Policy Officer). All other copies and versions must be deleted from force systems.
- The deletion and disposal of records must be completed to the extent that they cannot be recovered.
- Policy owners must support the Policy Officer to ensure that all copies are removed from accessible areas (consider DPPi, DPPi2, training, departmental folders and M365 packages, printed copies, SOH).
- Version Control
- A version control is included within the policy template. Version control tables provide historical data about each update made to a document. It is useful to include the author, date and notes about each change made so you can refer back to what these changes were.
- In instances where the version control is long, the historical information can be moved to the appendices.
- Here is an example to show how to apply the version numbering:
0.1
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First draft
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0.2
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Minor change to draft (e.g., Updated Code of Ethics section to include more relevant and detailed examples)
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1.0
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First version – approved
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1.1
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Minor amend – (e.g., Typographical errors amended within Sections 2 and 3)
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2.0
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Major change – approved (e.g., X policy now absorbed by this policy; includes changes to responsibility and ways of working throughout document)
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2.1
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Minor change – (e.g., Section 4 – updated reference to GDPR to UK GDPR)
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- Useful information
- The Policy Officer is able to support with the whole process – it may be beneficial to organise a meeting when broaching this process to clarify plans and expectations.
- The Policy Officer and policy owner/author can discuss and agree the timescale for a review. The following can be used as a guide (however factors may still necessitate the need to review at a sooner point, or if imminent legislative changes are due outside of the review period, it may be possible to delay the planned review to allow for planning to those changes):
High Risk
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Annual Review
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Medium Risk
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Biennial Review
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Low Risk
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Triennial Review
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Risk determined by the impact that the policy has to the organisation and the public. E.g. breaches and non-compliance that could result in misconduct/criminal proceedings are deemed high risk. Policies that have a lower impact are deemed lower risk.
- All policies must be on the most current Force template or must seek to move onto the most current template through the scheduled review process.
- The template must be completed using the Arial font and use a font size of 12.
- All policies must be assessed for equality impact which must be documented in the Equality Impact Assessment (EIA). Policy owners can refer to this during review or will need to draft a new version in instances where the EIA is on an outdated template or when drafting a new policy.
Ends.