The College of Policing and NPCC have jointly just launched a new ‘Anti-Racism Commitment’, as a 2025 addendum to the 2022 Police Race Action Plan (PRAP). Three years on from publishing the original PRAP report, the Commitment aims to explain what ‘anti-racism’ actually means, set out some specific objectives and actions, and introduce ‘performance standards’.
But it also represents a major shift in the thrust of the original PRAP report. The original intention was to explain or reform where there are disparities for Black people in policing tactics. As I highlight in this police leadership interest-piece, it’s all swung to reform. The objective being to simply eradicate any disparities, an approach that hasn’t landed well.
If forces follow this ‘guidance’ (what NPCC / College say normally goes), this will cause a massive shift away from evidence-based policing, impartiality, and officers ‘dealing with what they’re presented with’. The inevitable result will be wholly unevidenced and quota-based tactics, attempting to paper over uncomfortable cracks in society with some comfortable statistics…
Background on PRAP
If you’re aspiring to leadership and promotion in policing, it’s important to stay abreast of key national reports and developments. (That’s why I summarise key ones for you in my police leadership development podcasts and dedicate time to condensing HMIC inspections or even the Casey Review for time-pressed cops.) The ‘Police Race Action Plan: Improving Policing for Black People’ (PRAP) is another such report.
The PRAP was initiated in 2020 by the College of Policing and National Police Chief’s Council (NPCC), in response to unrest following the murder of George Floyd in the USA. Published in 2022, it had some major ambitions and planned actions towards its goal of “improving policing for Black people”.
PRAP came about because “although much has been done over the years to tackle racism, discrimination and bias in policing, change has not been fast enough nor significant enough.” The PRAP aims to improve policing’s relationship with Black communities once and for all, after decades of difficulties, inaction following other high profile reports, and claims of persistent ‘institutional racism’ in policing.
“Our vision is for a police service that is anti-racist and trusted by Black people.” – PRAP report
Most of the concerns and evidence for change revolve around statistical disparities and disproportionality in the rates of Black People encountering policing (benchmarked versus White people), when compared to their representative demographics in the general population. In doing so, it makes the big assumption that operational policing should be encountering different ethnicities at the exact rate at which that ethnicity exists among the general public.
For example, see below the latest relative arrest rates reported on the Ethnicity Facts and Figures service cited in the PRAP. It would be no mean feat for policing to engineer these nuances to become the same across all groups!
Such an assumption has gaping logical flaws and is easily critiqued (e.g. how it simply doesn’t work and most reasonable people would notice the logic doesn’t extend for any other Protected Characteristic). Read more about these critiques and notions of disparity, discrimination, disproportionality and so on in my 2024 guest blog, ‘The Public Confidence Disaster of Disproportionality Stats’.
PRAP takes a wide-ranging scope to eradicate racism and institutional bias both within police organisations and how police forces interact with the public. Where disparities exist, it states that policing should take an ‘explain or reform’ approach. I.e., explain what the societal or other factors are causing the differences observed, and for that which cannot reasonably be explained, assume that it’s down to the biases or even racism in policing, which therefore must be changed.
“Policing will adopt an ‘explain or reform’ approach to address the negative impact and outcomes experienced by Black people.” – PRAP 2022 Commitment
I encourage and invite aspiring leaders and promotion candidates to read the PRAP report in full. There’s plenty of helpful information in there and it has four broad goals:
- Not Under-Protected: A police service that protects Black people from crime, and seeks justice for Black victims.
- Not Over-Policed: A police service that is fair, respectful and equitable in its actions towards Black people.
- Involved: A police service that routinely involves Black people in its governance.
- Represented: A police service that is representative of Black people, and supports its Black officers, staff and volunteers.
This is all very reasonable and right. But as always with such grand plans, ‘the devil is in the detail’.
There have been well-documented bumps along the way for PRAP, with frustrations for example coming from the National Black Police Association and the formal PRAP Independent Scrutiny and Oversight Board (ISOB) about slow and limited progress being made. This has prompted the NPCC and College to now publish a significant and refreshed update to the PRAP, including a new “Anti-Racism Commitment”…
A New Commitment…
On 25 March, the College and NPCC announced with great fanfare their new Anti-Racism Commitment (let’s call it ARC from now). After what they describe as “extensive consultation”, including with YouTubers, this update is described as central to the PRAP’s original anti-racist goals. Three years on from the original PRAP report (and five since it was announced), they state that this new Commitment now…
- Clearly defines the objectives of an anti-racist police service,
- Explains what anti-racism means in a policing context, and
- Outlines the specific actions needed to achieve these goals
The PRAP Programme Director adds further context about the longer-term intent for policing…
“The original [PRAP] plan focused on action and activity, to reflect the need for policing to be seen to be doing something after decades of inaction. This update shifts the plan into a more long term, strategic mission that will ultimately put anti-racism into the DNA of policing.” – T/Deputy Assistant Commissioner Dr. Alison Heydari, PRAP Programme Director
To embed this longer-term mission, alongside the new ARC is a new ‘Maturity Matrix’. This Matrix is to assess how well forces are doing against the goals of PRAP on a mix of qualitative and quantitative performance measures. Forces achieving the desired “equality of outcomes” will get assessed as ‘mature’, with those with disparities (aka ‘disproportionality’) persisting between Black and White people considered ‘immature’. Chiefs will be held to account on their performance, and no doubt this will add to the performance priorities and focus within forces.
“The maturity matrix will measure a force’s progress in delivering anti-racism through both quantitative performance measures, as well as asking forces to provide narrative on their work on more qualitative performance measures.” – NPCC
The performance measures in the maturity matrix span across 14 standards across four themes, as summarised in the below graphic. As always, the devil is in the detail. So what exact metrics are forces going to be held to account against? Well, that’s not quite clear yet, because the specifics have not yet been published (but apparently will sometime soon).
However, you can be sure for example that core to the operational policing ‘Powers and Procedures’ there will be Black vs. White arrest rates, stop and search rates, and so on. The ultimate target being openly discussed here is to create 1:1 parity between Black and White people. Creating what they state as “equality of outcome” in the use of police powers, and as they say, “no matter how impossible that may seem” for policing.
Many of these performance objectives seem laudable and reasonable ways of assessing how things are going. The main problems of course (to any neutral observer) arise with the hard target of parity and particularly for the operational police tactics and use of powers. The assumption being that for the demographic of Race (and Race alone), there’s no inherent, real-world differences between the different groups when it comes to crime and therefore likelihood to be involved with the police.
Reform, Don’t Explain?
Let’s be clear: This new update shifts the focus to reform, with the former ‘explain’ bit of the original PRAP commitment taking far more of a back seat (almost kicked off the bus even). To demonstrate the point, the original 2022 PRAP mentions ‘explain’ 7 times and ‘reform’ 5 times, matching the gist of its contents and request to policing. This new 44-page PRAP update report to the original 57-page PRAP now mentions ‘explain’ just twice, and ‘reform’ 14 times. It’s all about going straight to ‘addressing’ (i.e. removing) disparities, not about attempting to explain them first.
In the original PRAP report glossary, “disparity” is defined as a neutral thing, rightly distinct from any sort of bad things like discrimination, prejudice or racism. And they similarly innocuously define “racial disparity” as when the proportion of a racial/ethnic group within the criminal justice system is greater than the proportion of such groups in the general population. It is of note that now ‘disparity’ is being used synonymously with ‘disproportionality’, and even often with ‘discrimination’.
“Disparity: A noticeable and usually significant difference or dissimilarity.” – PRAP 2022
With this new emphasis on removing disparities, responsibility is being laid at policing’s door to gatekeep and ensure demographics are only entering the criminal justice system at rates proportional to their existence in the general population. But only for the protected characteristic of Race for now; not for Sex, Age, or any of the other numerous demographic factors, which have obvious ‘disparities’ in its general population vs. criminal population. There are no calls (yet) for example to ensure parity between men and women, or old and young, in the use of policing tactics.
This is serious stuff, now having a consensus of support among the decision-making parties, so it will go ahead. In her foreword, the Policing Minister Dame Diana Johnson is clear she will hold Chief Constables to account for the outcomes (of reduced disparities), while also signalling legislative policing reform is on the horizon:
“I will hold police leaders to account for delivering the tangible outcomes that policing has committed to, but I will also support them to achieve the PRAP’s aims.”
The HMIC will lead on the inspection of forces against such disparities…
“The inspection of racial disparity, and what forces are doing to reduce disparity and increase confidence, will remain central to our inspections for the coming years.” – Sir Andy Cooke, HMIC
NPCC Lead Chief Constable Gavin Stephens is “determined to lead police reform” and “tackle discrimination and disparities proactively”, equating the two concepts.
Police and Crime Commissioners are also fully on board with this pure reform approach to eradicate disparity. The APCC have even published a Racial Disparity Toolkit, to help remove observed racial disparities in the data.
“The Police Race Action Plan is policing’s acknowledgment of the harm they have caused to members of our Black and minority ethnic communities over generations. Addressing and reducing race disparities in policing and criminal justice is a key priority across all Association of Police and Crime Commissioner (APCC) portfolios.” – Alison Lowe, Race Disparities, Equality and Human Rights Lead, APCC
While the Police Federation are yet to formally comment on this new update, the Superintendent’s Association have signalled their full support.
Maybe this is the path of least resistance, as forces avoid stepping on eggshells by talking about different factors affecting different groups of people on the sensitive topic of Race. Of course, there are well-documented problems in police culture to solve; and if you’re an aspiring leader, you’ll need to be on the forefront of solving them.
But there are also societal issues policing can’t (and arguably shouldn’t) fix. Taking ownership of such flawed policing metrics will no doubt lead to unintended (but predictable) consequences for police legitimacy, public confidence and public safety, while also distracting from the real problems which no doubt do need fixing.
Equality of opportunity and equality of treatment under the law are unarguable goals policing should abide by. But this report openly calls for equality of outcome, with “an end to racial disparities” between Black and White people. To achieve equality of outcome inevitably requires inequality of action.
“Equality of policing outcomes: Our commitment calls for overall improvements in policing outcomes alongside an end to racial disparities in those outcomes, however seemingly impossible both may be.” – Anti-Racism Commitment
From 200-Year Principles to Two-Tier Policing?
A week after its publication, the report has now been picked up on in several media outlets, hot on the heels of ‘two-tier justice’ proposed changes from the Sentencing Council. It’s also caused a stir in Parliament, with the Shadow Justice Secretary Robert Jenrick describing the NPCC’s proposals as “disgraceful” and “deeply unjust”. The Shadow Home Secretary meanwhile called the guidelines “unacceptable social engineering”.
The oft stated (yet rarely truly understood) Peelian Principles are relevant here. There is a real risk that through such sweeping change and guidance, policing will be seen to pander to (a specific subset of) public opinion. The inevitable result being the loss of wider public approval of actions, and so in turn losing the ability to effectively prevent and detect crime.
“The power of the police to fulfil their functions and duties is dependent on public approval of their existence, actions and behaviour, and on their ability to secure and maintain public respect… To seek and preserve public favour, not by pandering to public opinion, but by constantly demonstrating absolutely impartial service to law.” – Peelian Principles
‘Impartial service to law’, alluded to above, is a core principle of UK policing. Some may say this has long already been under attack in a politicised battleground surrounding policing. All police officers in England and Wales swear allegiance to the Crown through the oath they take on joining the police service. This includes swearing that they will act with impartiality. Officers must act fairly and without bias, ensuring equal application of the law to all, regardless of status or background. The Oath (or ‘Attestation’) new police constables are required to take is as follows:
“I (Name), of (Town), do solemnly, sincerely declare and affirm that I will and truly serve the King in the office of constable, with fairness, integrity, diligence and impartiality, upholding fundamental human rights and according equal respect to all people; and that I will, to the best of my power, cause the peace to be kept and preserved and prevent all offences against people and property; and that while I continue to hold the said office I will to the best of my skill and knowledge discharge all the duties thereof faithfully according to law.”
The recent HMICFRS report, Activism and Impartiality in Policing, makes very interesting wider reading on impartiality in policing, including clear recommendations on systemic issues. Here’s a few insights:
- “A near-total absence of any definition, guidance or judicial consideration of impartiality insofar as it relates to policing”.
- “The Police Regulations 2003 and relevant guidance need to change to provide greater clarity on the impartiality duty.”
- “There is no national guidance that describes precisely what the impartiality duty means, or what it does and doesn’t cover. Although we have seen that training for Chief Officers now includes a greater focus on impartiality, it is still not covered well enough in the training given to all police officers and staff.”
Until recently, impartiality was prominent as one of four espoused values in the College of Policing’s Competency and Values Framework (CVF) 2016. In the 2024 replacement version of the CVF, impartiality has disappeared, replaced with greater emphasis on the 2024 Police Code of Ethics.
Are the Peelian Principles still relevant? Does the oath of allegiance need to change? What are your thoughts?
Policing should be able to respond to evidence and be led by intelligence. In the real world, every intelligent person knows the evidence points to the below observation being true. This statement is considered uncontroversial and not ‘eggshell territory’ for most demographics and Protected Characteristics:
Different demographics of the public commit different types of offences and in different proportions to how they present among the general public.
What is Anti-Racism?
Since publication of the original PRAP, the goal of policing to become “anti-racist” has hit quite a stumbling block: Few in policing know what the nebulous term “anti-racist” actually means. And being a popular buzzword in recent years, every organisation defines it differently. Through this update, the College and NPCC have explained what they mean by anti-racism in a policing context.
So what does “anti-racism” mean? Below is how it is now explained in the PRAP update report. In short, it’s about being more than just ‘not racist’, by being proactive and vigilant…
Hmmm. That’s still a little woolly. But then there’s a bit more detail…
And being anti-racist also means proactively working towards racial equity, which is now defined as…
“Our commitment to racial equity means producing equality of policing outcomes for people from different ethnic groups by responding to individuals and communities according to their specific needs, circumstances and experiences, with understanding that these will be racialised and with the aim of reducing harm. It does not mean treating everyone ‘the same’ or being ‘colour blind’ (racial equality).” – NPCC
All clear now?
There Is a Better Way, it’s Not All Black and White
There is clearly much to fix in policing regarding race relations, but many would argue that this ‘Black vs. White’ approach isn’t the way to go about it. Moving from intelligence-led and evidence-based policing to a quota-led and statistics-based approach will end in tears.
Firstly, it will divert resources from public safety. Police powers may well be used where not required, and/or crime prevention tactics will be refrained from in a bid to chase ‘parity quotas’. Not to mention the questionable use of ‘White’ as the benchmark.
Secondly, it completely distracts from the things which do need change and rooting out of policing. These changes cannot be done through statistics or hammering through a clunky agenda, it just polarises people in this ideological battleground. The people who want reform (and for good reason) will get nowhere, and the folk who think all is hunky dory in policing and ‘it’s them, not us’ will dig their heels in.
“Over the next 12 months, the programme must confront institutional resistance and deeply ingrained attitudes that hinder change.” – Abimbola Johnson, ISOB Chair
Success requires a more qualitative and far less divisive approach to ‘confront resistance’. Cases must be dip-sampled, Inspectors must inspect, better use of and review of body-worn video, and ensuring there are clear consequences when wrongdoing is found. Where statistics can be useful is ensuring parity in things like find rates for stop and search (which would suggest that something other than the person’s demographic accounted for the searches).
Explain what you can about why there are disparities between the protected groups (comparing against the general public is clearly a flawed place to start). Then reform the rest, that which cannot be explained by reasonable rationale.
Surely it’s not too difficult to explain things first? And how can you proactively root out racism if you have no understanding or explanation of the factors that cause disparities? Clearly the residual, unexplainable amount will vary by force and is dependent on the relative existing cultures between forces (there’s disparity even there!).
What are your views on all this? Do you have a view? Whatever your views, if you aspire to promotion, don’t be suprised to face an interview question on your promotion board about the PRAP, anti-racism, or similar subjects. So what will you do as a police leader?
I hope you’ve found this police leadership interest piece helpful.
Kind Regards, Steve
Seeking police promotion? Want a MASSIVE head start right now? Hit the ground running with your personal digital promotion toolkit, and/or my market-leading Police Promotion Masterclass and CVF explainers. There’s nothing else like it to effectively prepare you for success in your leadership aspirations. You can also contact me to arrange more personal coaching support. Or try my podcast for your ongoing police leadership CPD covering a range of fascinating subjects.
