National recommendations - National Police Chiefs' Council, August 2020

Yes

RE: Skeleton or Stub Records on PNC and Microfiche Library
Thank you for the letter from an IOPC Lead Investigator dated 4th September 2019 and the helpful conversation with you on Tuesday 10th November 2020 in my position as the National Police Chief’s Council Lead for PNC.
I will below attempt to provide responses to a few strategic issues as well as the three key points you raise in the letter.
 
Background Context
The IOPC letter clearly highlights the issues relating to a specific Greater Manchester Police case in 2016 where Police attended an assault allegation by a female, who was also mother to young children. It was clear the children were all subject to Child Protection Plans (CPP). 
The Children’s grandfather requested to take the children away for a few days and to support this GMP undertook some checks to ensure there were no issues with the suitability of the grandfather’s access. Subsequently in February 2018 the grandfather notified authorities that his DBS check had identified his previous sexual offending history towards children. This fact should have been known to GMP at the time they were conducting their initial checks in 2016 and one would argue had this information been known the grandfather would not have been allowed immediate temporary access to the children.
The PNC check on the grandfather contained limited personal antecedents’ details but did not record what were historic sexual offending towards Children, which would have been held on a microfiche in London and had not at that time been back record converted onto PNC.
When the Police officers conducted the PNC check in 2016, an Administration Data (AM) page would have contained a marker saying: ‘BRC STATUS – NO CONVICTIONS ON THE PNC’, resulting in the officers concluding that no offending of concern was present. Due to a lack of understanding of the BRC marker and this resulted in the Police officers not appreciating that a ‘separate Microfiche’ record held in a microfiche library and how to request information, would have contained the historic sexual offending. I am convinced that had the officers known of this key information this would have informed their decision making and not allow the children to stay temporarily with the grandfather.
Helpfully you identified the grandfather’s PNC record was back record converted onto the PNC by the ACPO Criminal Records Office (ACRO) on 25 January 2018. 
At the heart of this matter is that officers may not have appreciated that a ‘stub record’ is an incomplete record and that in such cases a microfiche exists, how to request the microfiche and then undertake an assessment in deterring threat, harm or risk. In this case it was the vulnerability of children at risk and that to from a from a grandparent. 

PNC Overview
Historically and prior to 1995, all UK Police Forces would send criminal conviction details and other associated data to the Metropolitan Police Service, New Scotland Yard where records were manually stored on paper. 
In 1980, the original documentation was then placed onto microfiche and stored in the Archive Library in New Scotland Yard and a PNC ‘stub record’ created.  The microfiche library has since moved to the Home Office, Hendon Data Centre.   
However, in 1995 as part of the OP Phoenix project all Forces became responsible for the entry and maintenance of PNC information, including arrest and disposal data.  
As part of a Phoenix back record conversion project the Metropolitan Police Service ‘Back Record Converted’ microfiche to ‘conviction level’ approximately 4.2 million of the 5.3 million microfiche records onto the PNC.  This exercise included inputting the disposal detail, but did not include, for example, antecedent information, the Modus Operandi (MO) or any warning signals.  Effectively this means that microfiche records created between 1981 and 1995 have already been BRCd to ‘conviction level’. 
As and when forces come across a stub record and subsequently in receipt of the associated microfiche it becomes their responsibility to ‘back record convert’ the data on to PNC.  Except for specific serious offences, Forces in receipt of microfiche records are expected to BRC to “Conviction level only” i.e. update the corresponding PNC “Nominal” record with conviction information extracted from the microfiche. 
There remains approximately 1.5 million microfiche records that require updating as November 2020 and we need to get the number down to zero, however the unprecedented COVID-19 demand placed on police forces over the last 10 months has meant that the PNC Bureaus who would undertake this work have had limited resources and capacity.
Finally, where a Microfiche request is made of the microfiche library in urgent cases a response can be provided within 3 hours, and for non-urgent cases information can be returned with a few days. 

PNC Future 
As you will be aware the Police National Computer is now 47 years old and in 2015-2016 a national Police and Home Office technology programme was launched named the ‘National Law Enforcement Data Service. (NLEDS). The NLEDS programme is aimed at replacing the PNC onto a 21st Century architectural platform and also bring in the Police National Database  into one cohesive system to allow better risk-based decisions. 
The NLEDS programme is aiming to decommission the PNC by 2023 and in view of this there is limited appetite to undertake considerable or expensive change in PNC which is becoming more dated by the day. In support of this transition of PNC to NLEDS an Important aspect will be to ensure that all offences contained within the Microfiches are BRC’d onto PNC, well ahead of the PNC de-commissioning date of 2023.  
 
Options to be considered
I will now seek to respond specifically to the options/questions you have raised:
1.     Recommend that all forces across the country include stub records and Microfiche on their PNC training.
The College of Policing have previously issued a guidance pack as part of the PNC training course on this issue having sought advice from the Home Office PNC team at Henson-London. I will forward a copy of this guidance for you.  I am confident that the personnel who work in dedicated PNC bureaus are very familiar with the issues, but I accept it is the operational officers outside of bureaus who are more un-familiar with the detailed workings of the PNC that need the training. 
As highlighted COVID-19 police response has limited police training which includes PNC training and I cannot see considerable training until we get COVID-19 under control.  
ACTION: Deputy Chief Constable (DCC) to confirm previous guidance was issued. If felt to be inadequate or too dated this is to be re-circulated to all forces PNC Bureau’s, training departments to ensure the specific training is included once training resumes.
2.     PNC to change their system so that it is clear in showing that the additional information is held on Microfiche and that officers should check this for additional details about a person.
I currently co-chair the PNC application and risk prioritisation meeting with a senior Home Office Colleague, where we consider PNC change requests in terms of threat, harm and risk. As I have already stated we are very mindful of undertaking a lot of change on PNC as the system is becoming more unstable and the priority is to move to the NLEDS system. However, recognising the importance of this matter, I will ask for some scoping work to be undertaken in understanding what the time, complexity and costs of this change would be. 
ACTION: DCC to scope the change within PNC for the potential of a clearer marker on a skeleton or stub record to make clear additional information is available on a microfiche. 
3.     PNC to complete the back-record conversion of all records from Microfiche so that it is up to date.  
As alluded to, considerable in roads are being made in respect of the 1.5 million records still contained on microfiche and their back-record conversion onto PNC. I am re-assured through my national PNC governance meetings that forces are undertaking this as and when they are encountering a ‘skeleton’ or ‘stub record’.
ACTION: DCC to re-enforce importance of this key BRC work.
I hope I have provided a helpful response to the important issue raised and would welcome ongoing dialogue with the IOPC, linked to our regular engagement with the Information Commissioners Office.
I will keep you updated and if I can be of any further assistance in this matter please do not hesitate to contact me.
Yours sincerely
Deputy Chief Constable
National Police Chief’s Council lead for Police National Computer  

Yes

RE: Skeleton or Stub Records on PNC and Microfiche Library
Thank you for the letter from an IOPC Lead Investigator dated 4th September 2019 and the helpful conversation with you on Tuesday 10th November 2020 in my position as the National Police Chief’s Council Lead for PNC.
I will below attempt to provide responses to a few strategic issues as well as the three key points you raise in the letter.
 
Background Context
The IOPC letter clearly highlights the issues relating to a specific Greater Manchester Police case in 2016 where Police attended an assault allegation by a female, who was also mother to young children. It was clear the children were all subject to Child Protection Plans (CPP). 
The Children’s grandfather requested to take the children away for a few days and to support this GMP undertook some checks to ensure there were no issues with the suitability of the grandfather’s access. Subsequently in February 2018 the grandfather notified authorities that his DBS check had identified his previous sexual offending history towards children. This fact should have been known to GMP at the time they were conducting their initial checks in 2016 and one would argue had this information been known the grandfather would not have been allowed immediate temporary access to the children.
The PNC check on the grandfather contained limited personal antecedents’ details but did not record what were historic sexual offending towards Children, which would have been held on a microfiche in London and had not at that time been back record converted onto PNC.
When the Police officers conducted the PNC check in 2016, an Administration Data (AM) page would have contained a marker saying: ‘BRC STATUS – NO CONVICTIONS ON THE PNC’, resulting in the officers concluding that no offending of concern was present. Due to a lack of understanding of the BRC marker and this resulted in the Police officers not appreciating that a ‘separate Microfiche’ record held in a microfiche library and how to request information, would have contained the historic sexual offending. I am convinced that had the officers known of this key information this would have informed their decision making and not allow the children to stay temporarily with the grandfather.
Helpfully you identified the grandfather’s PNC record was back record converted onto the PNC by the ACPO Criminal Records Office (ACRO) on 25 January 2018. 
At the heart of this matter is that officers may not have appreciated that a ‘stub record’ is an incomplete record and that in such cases a microfiche exists, how to request the microfiche and then undertake an assessment in deterring threat, harm or risk. In this case it was the vulnerability of children at risk and that to from a from a grandparent. 

PNC Overview
Historically and prior to 1995, all UK Police Forces would send criminal conviction details and other associated data to the Metropolitan Police Service, New Scotland Yard where records were manually stored on paper. 
In 1980, the original documentation was then placed onto microfiche and stored in the Archive Library in New Scotland Yard and a PNC ‘stub record’ created.  The microfiche library has since moved to the Home Office, Hendon Data Centre.   
However, in 1995 as part of the OP Phoenix project all Forces became responsible for the entry and maintenance of PNC information, including arrest and disposal data.  
As part of a Phoenix back record conversion project the Metropolitan Police Service ‘Back Record Converted’ microfiche to ‘conviction level’ approximately 4.2 million of the 5.3 million microfiche records onto the PNC.  This exercise included inputting the disposal detail, but did not include, for example, antecedent information, the Modus Operandi (MO) or any warning signals.  Effectively this means that microfiche records created between 1981 and 1995 have already been BRCd to ‘conviction level’. 
As and when forces come across a stub record and subsequently in receipt of the associated microfiche it becomes their responsibility to ‘back record convert’ the data on to PNC.  Except for specific serious offences, Forces in receipt of microfiche records are expected to BRC to “Conviction level only” i.e. update the corresponding PNC “Nominal” record with conviction information extracted from the microfiche. 
There remains approximately 1.5 million microfiche records that require updating as November 2020 and we need to get the number down to zero, however the unprecedented COVID-19 demand placed on police forces over the last 10 months has meant that the PNC Bureaus who would undertake this work have had limited resources and capacity.
Finally, where a Microfiche request is made of the microfiche library in urgent cases a response can be provided within 3 hours, and for non-urgent cases information can be returned with a few days. 

PNC Future 
As you will be aware the Police National Computer is now 47 years old and in 2015-2016 a national Police and Home Office technology programme was launched named the ‘National Law Enforcement Data Service. (NLEDS). The NLEDS programme is aimed at replacing the PNC onto a 21st Century architectural platform and also bring in the Police National Database  into one cohesive system to allow better risk-based decisions. 
The NLEDS programme is aiming to decommission the PNC by 2023 and in view of this there is limited appetite to undertake considerable or expensive change in PNC which is becoming more dated by the day. In support of this transition of PNC to NLEDS an Important aspect will be to ensure that all offences contained within the Microfiches are BRC’d onto PNC, well ahead of the PNC de-commissioning date of 2023.  
 
Options to be considered
I will now seek to respond specifically to the options/questions you have raised:
1.     Recommend that all forces across the country include stub records and Microfiche on their PNC training.
The College of Policing have previously issued a guidance pack as part of the PNC training course on this issue having sought advice from the Home Office PNC team at Henson-London. I will forward a copy of this guidance for you.  I am confident that the personnel who work in dedicated PNC bureaus are very familiar with the issues, but I accept it is the operational officers outside of bureaus who are more un-familiar with the detailed workings of the PNC that need the training. 
As highlighted COVID-19 police response has limited police training which includes PNC training and I cannot see considerable training until we get COVID-19 under control.  
ACTION: Deputy Chief Constable (DCC) to confirm previous guidance was issued. If felt to be inadequate or too dated this is to be re-circulated to all forces PNC Bureau’s, training departments to ensure the specific training is included once training resumes.
2.     PNC to change their system so that it is clear in showing that the additional information is held on Microfiche and that officers should check this for additional details about a person.
I currently co-chair the PNC application and risk prioritisation meeting with a senior Home Office Colleague, where we consider PNC change requests in terms of threat, harm and risk. As I have already stated we are very mindful of undertaking a lot of change on PNC as the system is becoming more unstable and the priority is to move to the NLEDS system. However, recognising the importance of this matter, I will ask for some scoping work to be undertaken in understanding what the time, complexity and costs of this change would be. 
ACTION: DCC to scope the change within PNC for the potential of a clearer marker on a skeleton or stub record to make clear additional information is available on a microfiche. 
3.     PNC to complete the back-record conversion of all records from Microfiche so that it is up to date.  
As alluded to, considerable in roads are being made in respect of the 1.5 million records still contained on microfiche and their back-record conversion onto PNC. I am re-assured through my national PNC governance meetings that forces are undertaking this as and when they are encountering a ‘skeleton’ or ‘stub record’.
ACTION: DCC to re-enforce importance of this key BRC work.
I hope I have provided a helpful response to the important issue raised and would welcome ongoing dialogue with the IOPC, linked to our regular engagement with the Information Commissioners Office.
I will keep you updated and if I can be of any further assistance in this matter please do not hesitate to contact me.
Yours sincerely
Deputy Chief Constable
National Police Chief’s Council lead for Police National Computer