Action plan
Hertfordshire Constabulary response to the Super Complaint submitted by Suzy Lamplugh Trust: Stalking
Executive summary
An investigation into a police super-complaint submitted by the Suzy Lamplugh Trust (on behalf of the National Stalking Consortium) in November 2022 has found that significant changes are needed to improve the police response to reports of stalking.
29 recommendations have been identified as required and all organisations named are expected to act upon them and consider whether others are needed to bring about change.
Police have 15 action headings to address and develop an action plan to remedy any areas for improvement.
By 22 November 2025 (56 days from publication), forces will publish on their website an action plan which explains what their force will do in response to each of the recommendations made to them and send the NPCC a link to where this action plan can be found.
1. Introduction
1.1 Upon receipt of the Super Complaint DCS Head of Crime for Hertfordshire was appointed as lead to respond to the recommendations and development of the plan for stalking.
1.2 A cross departmental working group was formed to conduct a timely review of the ‘as is’ position of Hertfordshire Constabulary against the recommendations and develop a plan to address any areas of concern or underperformance. This activity is contained within Operation Stride (Op Stride).
2. Operation Stride
2.1 The role of the working group, which meets fortnightly, is to ensure that all departments are joined up and there is no unnecessary duplication of effort or activity.
2.2 Op Stride brings together department heads and deputies to understand the recommendations, be involved in the planning for any remedial action, and helps socialise the importance of developing a response to stalking which is victim focussed and aims to be constantly striving for excellence.
2.3 Before addressing the recommendations, the Op Stride working group has examined the stalking process from start to end i.e. reporting an offence to police, to support at trial. This was done to understand the process, identify gaps or strengths in service provision, ensure that victim focus was prevalent at each stage, and identify weaknesses in language and culture in relation to stalking.
3. Hertfordshire’s response to each recommendation
3.1 By 27 March 2025, where required, seek changes to their crime recording systems to enable staff and officers to document and search for crimes not recorded as the principal crime, as included classifications on crime records.
3.1.1 Recording practice and Athena data searches in Hertfordshire already recognise and return offences that are recorded as both primary classifications (principal crime) and included classifications. Data returns in relation to crimes recorded can be selected to include those recorded as principal or included too. The Athena tool displays POLE (Person, Object, Location, Event) data as a snapshot. Training and awareness for the staff in the control room will emphasise effective use of the POLE data and elements of stalking which may be present in reporting that may appear initially as non-crime or as an alternative crime e.g. harassment.
3.1.2 Due to the above practice, no alternative measures are required.
3.2 By 27 March 2025, review and update their learning and training provision relating to stalking. Chief constables should also make sure that their policies and practice are reviewed and updated in accordance with the findings in the super-complaint investigation report.
3.2.1 Due to the joint service provision across Bedfordshire, Hertfordshire and Cambridgeshire forces the learning outcomes of training are assessed and monitored by a collaborated learning unit. This work will be completed by March 2025.
3.2.2 Hertfordshire constabulary has made good use of the e-learning product developed by the College of Policing. In total 1798 officers have completed the package, however, Since the package was updated in September 2024 only 49 officers have completed it. To ensure the updated package is completed this will be made a mandatory package for all PCSO’s, constables, sergeants, and Inspectors – uniform or detective. The completion rate will be monitored on the Learning Management System. We will further scope adoption of the e-learning packages developed by the Suzy Lamplugh Trust for first line responders, investigators and supervisors.
3.2.3 Safer Places will be presenting an input to the DA Influencers. They are also going to be hosting lunch and learn sessions for the Constabulary through January and February 2025. Sessions will include a case study. From January to October 2025, all frontline officers and staff will be attending Lived Experience training which is facilitated by survivors of DA. It is recognised by Hertfordshire police that this is currently predominantly domestic abuse stalking in nature, and that stalking by a rejected partner only accounts for around 60% of all stalking. Efforts are underway to identify stalking survivors from outside the domestic abuse sphere, so that their lived experience can also be shared.
3.2.4 Hertfordshire Constabulary is about to launch an IAG (Independent Advisory Group) which will include members from the third sector, victims of crime and women from the community. This is a VAWG related activity but sessions will be themed and stalking will feature as one of the main themes. Advocates will be in attendance to support these meetings and reduce any possibility of further trauma.
3.2.5 The Hertfordshire Constabulary Stalking policy is currently being written and was underway prior to publication of the super complaint. Policy writers are now ensuring that matters identified within the super complaint are addressed and covered within the new policy, as well as ensuring that the correct language is utilised and set the correct context of ex-intimate and rejected partner stalking as only one of the five typologies of stalker. The policy will establish stalking as a priority within the constabulary. Publication of the New Hertfordshire Strategy is expected early in the New Year.
3.2.6 Training and learning will be provided to all officers and staff who are in key roles to deliver victim focussed outcomes. As part of the initial scoping, it was identified that extra focus should be placed on the force control room – call handlers, investigation management unit (IMU), and supervisors. Training slots have been identified for the IMU teams and will be begin before the new year, and a continuum of refresher training will be developed and built into the training cycle from the new year.
3.3 By 27 March 2025, make sure that appropriate mechanisms are in place to fully understand the scale and types of stalking behaviour within their force and the effectiveness of their response. This should align with the VAWG national delivery framework.
3.3.1 The value of problem profiles in providing an understanding of a particular issue or crime type can often be greatly outweighed by the length of time it takes to complete and often once published they are out of date. Rather than focus initial valuable time on the creation of a yearly problem profile designed to help understand stalking, instead a stalking dashboard is being created which will draw from live crime and intelligence systems. Scoping will also be undertaken to include information from stalking support services in Hertfordshire. This will then provide the ability to understand trends in victimology, suspects and themes covering temporal, geographical and crime methodology. Hertfordshire police are also scoping a method to have the dashboard present breakdowns of stalking, in particular online stalking. A non-automated trial of this will be attempted to identify stalking hotspots and deploy resources to reduce the incidence of stalking offences in those geographic areas. This work will be completed by March 2025.
3.2.2 Monthly crime investigation audits assess the standards of investigation and service offered to victims by the HMIC audit team. These audits focus on the investigation quality and supervision as well as victim focus and outcomes. The use of protective powers is also assessed. A thematic is included each month which will include stalking to assess the quality of our response. To assist with this a dashboard is in creation which will display, amongst other orders, Stalking Protection Orders (SPOs). The dashboard will be able to display where SPOs have been considered as well as those applied for and those obtained, and the timeliness of consideration i.e. at the beginning of an investigation. To achieve this force policy will be amended to direct all recording to be made on Athena. Hertfordshire will work with partners to establish a comprehensive dataset and performance framework. This work will be completed by March 2025.
3.3.3 Hertfordshire Constabulary currently obtain victims feedback through the Victim Support Team, and this is governed in the Victims and Vulnerability Strategic Board chaired by ACC Local Crime. Going forwards the plan will be to report on stalking victims feedback as a stand-alone item and have this included on the Stalking dashboard. The professional standards team have also been included in the working group to bring police complaints regarding stalking cases and is combined in the VVSB to provide the greatest amount of feedback from victims available to Hertfordshire Police. This is shared with heads of department in Hertfordshire Constabulary and partners. This work will be completed by March 2025.
3.3.4 Stalking will be specifically covered in the Force Management Statement which is currently being written and due for publication at the end of March 2025.
3.4 By 27 March 2025, take steps to make sure that risk identification, assessment and management is effective in all stalking and breaches of orders cases.
3.4.1 As part of the BCH joint provision of services, Cambridgeshire Police are currently trialling a stalking risk identification tool. Upon conclusion of the trial, it is expected that this will be rolled out to Hertfordshire police. Prior to roll out across Hertfordshire Police all standard operating procedures, policies, and service level agreements will be reviewed and amended. Awareness of the tool will also be spread across the organisation using a communication plan that ensures officers and staff effectively understand the differences between Ss. 2A and 4A of the Protection from Harassment Act 1997. This work will be completed by March 2025.
3.4.2 Hertfordshire Police are creating a risk assessment to be added to Tuserv (crime recording system used at scene and uploads to Athena) so that risk can be managed and assessed by relevant departments and safeguarded. The importance of professional curiosity and including sufficient detail when recording crime will be emphasised in training. This tool is to be embedded and in operation by March 2025. Secondary and ongoing risk assessments are being addressed through the re-launch of supervisor investigation standards and is governed by the Strategic Crime Management Board.
3.4.3. The current process for recognising the heightened risk around breaches of protective orders is being reviewed with regards to recording and tracking of protective orders, which will lead to a revision of policies, guidance and training. The intention of change will lead to a better understanding and management of breaches, and the recognition that a breach is a furtherance of the course of conduct. This change is due to be implemented in January 2025.
3.4.4 Slight changes to daily morning management meetings will now flag stalking cases for early identification of risk and suitable management and oversight for stalking cases. A live dashboard is to be created for all stalking crimes and management information. The dashboard aspires to show suspects who have SRO/MAPPA and who does not to identify gaps and high-risk suspects/victims. Dashboard to be created, tested, and fully operational by March 2025.
3.5 By 27 March 2025, take steps to make sure that force strategies, structures and processes are in place so that police consider an SPO in every stalking case, and apply for an SPO where relevant and appropriate to prevent harm and further offending. To achieve this, chief constables should review, and revise policy, guidance and supporting processes where necessary.
3.5.1 Officers from the Domestic Abuse investigation team have developed and delivered a stalking awareness package to frontline officers and staff. In January 2025 training will be delivered to officers and staff within the force control room, and in February 2025 stalking will be part of the continual professional development training for all detectives. Emphasis has been and will be made on considering an SPO in each stalking case. Whilst the CPD element will be well underway by March 2025, it may not be fully completed until April 2025.
3.5.2 Processes and procedures are being reviewed to allow better support for investigating officers to identify cases where an SPO would be appropriate. A dedicated team is being scoped, whilst at the same time the stalking dashboard aims to assist investigators with a rounded risk assessment view of cases. Both these elements will be assessed and the aspiration is for them to be in place by March 2025.
3.6. By 27 March 2025, take steps to make sure stalking victims receive the rights they are entitled to under the victim’s code and have access to support services.
3.6.1 Hertfordshire police currently conduct Individual Victim Needs Assessments (IVNA) for each crime that is reported and screened in. Each morning IVNA completion is raised at management meetings and completion to 100% is achieved.
3.6.2 The Victim Support Team (VST) contact all victims of crime and ensure that all stalking victims are provided with their rights and entitlements under the victims’ code. The Constabulary will also raise awareness within the VST of the reasons for enhanced rights and why this is particularly important to stalking victims. Timely information sharing with a victim is critical to ensure their safety, where often victims must self-regulate, changing their own lives to safe. This will be completed by March 2025.
3.6.3 Specialist stalking support services are managed in Hertfordshire through several services and covers all types of stalking. IDVSA advocates and Beacon provide advice and guidance to survivors. Currently Hertfordshire County Council (HCC) are procuring advocate services to bring all advocacy for stalking under one umbrella which will make advocacy more easily accessible for the public, victims, officers and staff. The umbrella approach from HCC is not expected to be fully operational until September 2025, however in the interim available support is mapped and published for the public and officers alike.
3.6.4. Timeliness of referrals to support services for stalking will be measured on the dashboard which is currently under construction. This will allow for identification of victims who have not been referred and allow for swift rectification, whilst also providing management information that will allow for feedback to partner agencies and provide scrutiny of service provision, particularly if referral numbers are low. This dashboard to be created, tested, and fully operational by March 2025.
3.7 By 27 March 2025, work together to review commissioning arrangements and make changes as soon as possible to ensure they embed collaborative working and information sharing between policing and services providing victim support to stalking victims.
3.7.1 Partnership working with the Office of the Police and Crime Commissioner (OPCC) and their commissioning arrangements, commissioning across the partnership, collaborative working, and information sharing will be monitored within the Domestic Abuse and Violence Against Women and Girls Partnership Board. Stalking will be a focus of the board, which is chaired by Detective Chief Superintendent Head of Crime for Hertfordshire Constabulary. Mapping of the current arrangements is underway and will be complete by March 2025.
3.8 27 March 2025, make sure the new College of Policing investigations APP content on case allocation is reflected in the relevant policies relating to the allocation of stalking and breach of order cases for investigation.
3.8.1 The Hertfordshire Constabulary Operational Strategy Team (OST) are currently assessing the stalking case allocation and reviewing whether low and medium risk stalking and harassment should be allocated to intervention officers (front line emergency response). The OST is currently undertaking benchmarking nationally with well-performing forces and reviewing data including length of investigation and outcome rate. Before any changes are enacted the Constabulary will ensure changes meet the most up to date APP guidance. Timescales for completion estimated December 2024.
3.9 By 27 March 2025, take steps to improve the quality of stalking investigations by taking a victim centred, suspect focussed and context led approach.
3.9.1 Assessing the Constabulary’s capacity and capability are to address the organisation's response to stalking demand and this will be specifically covered in the Force Management Statement consultations and will guide future decision making. Innovation in relation to digital lines of enquiry is currently being sourced by the cyber-crime DCI and will be raised with officers and partners as options for improving service. Consideration to visiting sites of best practice in Cheshire (Harm Reduction Unit) and London (Op Atlas) will be made. This will be complete by March 2025.
3.9.2 Work is underway to improve the standards of investigations across the Constabulary. This will include stalking investigations and is focused on pursuing all proportionate lines of enquiry. The Strategic Crime Management Board, chaired by the Detective Chief Superintendent Head of Crime, is reviewing investigation and supervision standards as part of the response to the recent HMICFRS PEEL inspection areas for improvement. Audit of stalking investigations will be undertaken to show improvement by March 2025.
3.9.3 The improvements in investigation standards will include the use of arrest and search powers to fully investigate relevant lines of enquiry and build evidential packages around suspects. This will also form part of the audit taking place. Searches conducted in investigations is also being scoped for inclusion in the Stalking Dashboard for management information. Audits will also consider the timeliness of arrests, proportion of voluntary interviews, and incorrect use of S.18 search for S.2A offences. Audit of stalking investigations will be undertaken to show improvement by March 2025.
3.9.4 Victim personal statements (VPS) in stalking cases will be monitored through the Administration of Justice (AoJ) team in Hertfordshire, and where possible added to the Stalking Dashboard for management information and daily monitoring. VPS completion rates and qualitative content will also form part of the audit process in stalking. Dip sampling and qualitative feedback on the content of MG11s will also be undertaken to ensure the impact on the victims is also included in the evidential statement. Audit of stalking investigations will be undertaken to show improvement by March 2025.
3.10 By 27 March 2025, take steps to improve how their force effectively recognises and responds to online elements of stalking.
3.10.1 Assessment of online stalking in Hertfordshire will be taken to the Victims & Vulnerability Strategic Board which is chaired by Assistant Chief Constable for Local Policing. Discussions and decisions from that board will inform policy and training. This will be complete by March 2025.
3.10.2 The review and creation of local awareness raising products for stalking linking with training will include the voice of survivors and their lived experiences for all types of stalking. Efforts will be made to ensure that different types of stalking – including online stalking – are included to ensure stalking education is rounded in its nature.
3.10.3 Online safety advice is available for officers via the Vulnerability Online Portal. The online advice is in line with the APP; however a review of content will be conducted in light of changes being made within Hertfordshire Constabulary to ensure content reflects the work underway in response to the super complaint. The review, any re-writes and publication will be completed by March 2025.
3.10.4 Procurement for Hertfordshire Constabulary is largely governed by the seven-force region and the Bedfordshire, Cambridgeshire, and Hertfordshire collaboration. Across all these forces there is a high level of awareness and sharing of practice and trials to improve service. Centrally under the BCH the Joint Strategy and Transformation Team are working towards the delivery of the Stalking and Harassment Single Online information pages and reporting services. The content is Nationally approved. Delivery is not expected until early 2025.
3.10.5 Victim Services also provide preventative and safeguarding advice, practical tools such as alarms and access to the Hollie Guard app. Hertfordshire Constabulary refer to specialist support services such as the ISACs who sit within the charity Victim Support, the Suzy Lamplugh Trust or Paladin which is the National Stalking Advocacy Service. This is in place and current practice now. The effectiveness of this will be reviewed to satisfy that this is effectively used by the Constabulary. Addition of this into the stalking dashboard will be scoped and if possible, will be added by March 2025.
3.11 By 27 September 2025, using the information collated by the NPCC lead under recommendation 21, to consider whether and how dedicated stalking officers and staff, or other subject matter experts, can be used to add value and support the force response to stalking.
3.11.1 Hertfordshire Police are working with the OPCC to glean learning from the Independent Stalking Advocates and input at a strategic level via Op Stride. The creation of a dedicated team for stalking, covering all stalking areas, will be considered by DCS Head of Crime for the organisation. Considerations have already begun and include the provision of the team being PIP2 investigators, being appropriately trained in stalking and having regular professional development, and holding the ability to obtain SPOs, and swiftly deal with breaches.
3.12 By 27 March 2025, implement a mechanism for early screening of crimes to improve the identification, recording and management of all stalking cases.
3.12.1 Due to causes for concern raised by HMICFRS in the recent PEEL inspection, there is significant activity being undertaken in the force control room surrounding the recording of crime. These improvements are being managed manage through ACC Operations - Operation Souvenir Board, and to include screening of incidents where it is believed the risk is in terms of missed opportunities. QA processes and policies within the control room are being reviewed for amendments that will improve service to the public and remove the identified risk. These changes will be in place by January 2025.
3.13 By 27 March 2025, explore opportunities to improve how their force works with partners to contribute to a multi-agency response to stalking.
3.13.1 Hertfordshire Constabulary is part of the Joint Partnership Protocol whereby all partners from the MARAC and MATAC work together to identify, address and reduce the risk to individuals. Stalking is also a standing agenda item on the Domestic abuse and Violence Against Women and Girls Partnership board, which is a strategic partnership board. Consideration is currently being made to the creation of a subgroup to focus solely on stalking and addressing any improvements to a partnership approach to reducing, tackling and supporting victims of stalking. One area of focus will be to assess appetite for creating a Multi-Agency Stalking Intervention Programme (MASIP) which sits separate to domestic abuse forums and focusses on all types of stalking.
3.13.2 Hertfordshire police are part of the Regional Stalking Meeting (Eastern Region) which sits monthly. Cambridgeshire attend the national meeting on behalf of the region and filter the updates back through this group and the domestic abuse performance board. Best practice, collaboration and problem solving is achieved at the regional meeting. This is in place now.
3.13.3 Where MAPPA can be used to effectively manage stalking offenders it is. However, of the 21 offenders subject to SPOs in Hertfordshire, 12 were not charged with the stalking behaviour that led to them receiving the SPO. They also do not have any other relevant convictions that would make them eligible for MAPPA, nor are they exhibiting seriously violent or sexual behaviour that would allow them to be referred in. Of the seven who were convicted, only three of them received a sentence of 12 months or more. One has previously been heard at MAPPA, one is engaging well and not exhibiting concerning behaviour so is not necessary to refer in, one request is being made of probation to consider referring him in as lead agency (he is a London offender so will not fall under our MAPPA), two are awaiting sentencing and may become eligible following this. Two have recently been charged and have no other relevant convictions so we will need to await the outcome of their trials. This is being considered and implemented where possible now. The increase in stalking crimes being reported and identified may lead to increases in MAPPA referrals and this should be anticipated across the partnership.
3.14 22 November 2024 (56 days from publication), write to HMICFRS, the IOPC and the College of Policing setting out their response to the recommendations made to them. Chief constables should direct their response to the NPCC which should provide a collective response on behalf of all police forces.
3.14.1 On target for completion.
3.15 By 22 November 2025 (56 days from publication), publish on their force website an action plan which explains what their force will do in response to each of the recommendations made to them and send the NPCC a link to where this action plan can be found.
3.15.1 On target for completion.
3.16 By 27 March 2025 (six months from publication) provide an update to the NPCC describing the progress they have made against their action plans.
3.16.1 On target for completion.