Prevention of Future Deaths reports · 2019

Michael Hoolickin

Regulation 28 report to prevent future deaths, reference 2019-0292, written 29 Aug 2019. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report29 Aug 2019
Reference2019-0292
DeceasedMichael Hoolickin
CoronerJoanne Kearsley
Coroner areaManchester North
CategoryOther related deaths
Sourcejudiciary.uk record · original PDF
Responses published4

The report

Text recovered by OCR from a scanned PDF. OCR is imperfect: check anything you rely on against the source PDF. Reproduced verbatim, including the scan's own layout.

REGULATION 28: REPORT TO PREVENT FUTURE DEATHS (1)

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS
THIS REPORT IS BEING SENT TO:
1. Rt Honourable Robert Buckland MP, Secretary of State for Justice
2. EEE National Probation Service North West (NPS)
3. Chief Constable, Greater Manchester Police (GMP)
4. PY Chair of National Chief Police Council (NPCC)
5. Chief Constable, Lancashire Constabulary

CORONER

| am Joanne Kearsley, Senior Coroner for the Coroner area of Manchester North

}_

CORONER’S LEGAL POWERS

| make this report under paragraph 7, Schedule 5, of the Coroner’s and Justice Act 2009 and
Regulations 28 and 29 of the Coroners (Investigations) Regulations 2013 ;

INVESTIGATION and INQUEST

On the 8" November 2016 | commenced an investigation into the death of Michael Hoolickin who
died on the 17" October 2016 at the Manchester Royal Infirmary. The Inquest concluded on the
16" August 2019.

The details as to how Michael’s death occurred were recorded as follows: Michael Hoolickin died
on the 17" October 2016 at the Manchester Royal Infirmary. He had been attacked and stabbed in
an unprovoked assault on the 14" October 2016. The perpetrator of the attack was subject to
licence conditions and management by the National Probation Service having been released from
prison in February 2016. Organisational failures and failures in the management of the perpetrator,
including the lack of implementation of Pl 30/2014, lack of organisational knowledge on how to
access drug test results and a failure to provide or seek out all relevant pertinent information meant
there was a missed opportunity to initiate recall of the perpetrator on the 3 August 2016, which
whilst not causative of the attack on Michael, on the balance of probabilities, probably contributed
to his death.

The conclusion of the Inquest was that Michael Hoolickin was unlawfully killed.

During the course of the Inquest the Court heard evidence from a number of witnesses including
Offender Managers (OM), Senior Probation Officers (SPO) and Assistance Chief Officers (NPS).
GMP officers from the Spotlight Team and also from an independent expert instructed to consider
aspects of the NPS involvement.

+

CIRCUMSTANCES OF DEATH

As indicated above on the 14" October Michael Hoolickin was stabbed by an offender in an
unprovoked attack. The offender Timothy Deakin (TD) had been released from prison in February
2016 having previously received a 56 month sentence for an assault during which he had bitten
someone’s ear off. He was released half way through his sentence as he was a determinate
sentence prisoner and was therefore managed by the NPS. He was subject to a number of
additional licence conditions, in particular:

o Drug testing for class A and class B drugs. (The Court heard this was required to be
undertaken weekly).
o__Curfew and residence requirements. )The Court heard evidence his curfew requirements

at times were varied but for the majority of his time on licence he was subject to curfew
which required him to be home in the evening from differing times).
o Non-association with his co-defendant

His OASYS assessment in March 2016 had concluded he was a high risk of serious harm to adult
males. His nature of the risk he presented was recorded as being associated with extreme
violence, with a propensity to use instant violence when faced with confrontation and a concern
was noted as to the offenders nonchalance to the violence he perpetrated. Of importance was the
fact that the offenders risk of violence was recognised as being linked to his use of cocaine.

In addition he was classed as a Prolific and Priority Offender (PPO) so was managed jointly with
GMP as part of the Integrated Offender Management Unit (IOM). The Court heard evidence as to
the offenders behaviour during the time whilst he was being managed on licence. He had a period
of time where he resided in Approved Premises before returning to live at his Mother's address in
Rochdale in April 2017.

During his time on licence the offender had three OMs and whilst the Court found there were
significant individual failings on the part of 2 of the OMs there were also numerous organisational
failures.

One of the most significant organisational failures which will be dealt with below was in relation to
drug testing, which meant throughout the entire licence period there was a failure by a trainee
Probation Officer, 2 OMs, 3 SPOs and an ACO to realise the offender was testing positive for
cocaine. Hence no referral to drug treatment services was ever made.

During the offenders time on licence there were key and significant events during the following time
periods:

2-4" May 2016

In the early hours of the 2“ May the offender was arrested and was charged with no licence, no
insurance and failing to stop for a PC (following a police pursuit, him crashing his vehicle and being
chased and apprehended by a police dog). Following a RAMA meeting on the 3% May there was a
failure by the SPO to recognise the fact there had been a police pursuit and to pass this
information onto the ACO for her information when considering the level of enforcement action. A
managers warning was issued on the 4" May 2016.

10" May 2016

On the 10" May 2016 the offender was arrested by Lancashire Constabulary. The information
provided by GMP to the NPS was that the offender had been arrested in possession of a tin of
drugs (believed to be cannabis) which were in his under garments and he had been arrested for
intention to supply.

During the course of the Inquest it became clear that there was a discrepancy in the evidence from
Lancashire Constabulary and GMP. The Officer from Lancashire Constabulary gave a statement
to the Court in which he clearly believed he was contacting GMP in relation to the person with
whom the offender was arrested (DC). GMP had believed the call related to the offender Timothy
Deakin. The result was the NPS were provided with incorrect information. However based on the
information they had been provided with, the case was reviewed by an SPO who considered recall
was appropriate subject to a decision by the ACO.

At no stage during the course of this offenders involvement with the NPS was there any attempt to
clarify any information with GMP or to request evidence in order to support any of the shared
intelligence or information.

The Court heard the ACO was contacted by the SPO and due to the fact the offender was in
custody, deferred any recall decision until the morning. The following morning the ACO did meet
with the OM in the Rochdale Office but there was a failure to have a proper discussion with the OM
about the offender who had now been arrested twice within a week and within three weeks of
leaving the Approved Premises. There was also a failure at this stage by the OM to provide all
relevant information to the SPO and ACO in order for them to make an informed decision.

As it transpired the offender was not charged with any offences by Lancashire (although clarity as
to why not was never requested by the NPS) and therefore a decision was taken to issue an ACO

warning. No discussion took place between the ACO and the SPO to explain the rationale for this
decision and nowhere was there a documented rationale for the issuing of an ACO warning as
opposed to recall.

21° June

On the 21% June a member of the GMP Spotlight (IOM) team forwarded an email to the OM
expressing her concerns about the offender. The Court heard there was a close working
relationship between the IOM and NPS witnesses. A number of GMP officers gave evidence to the
Court as to their escalating concerns about the offender and the fact they were of the opinion his
risk of serious harm (and his risk to life) was increasing. They were also of the opinion such views
were shared with the NPS OM and trainee. Upon receipt of this email the OM had a telephone
discussion with a SPO as to how to respond to GMP. Again the Court was not satisfied with the
quality and quantity of the information provided by the OM to the SPO about the case.

22nd -23" June

On the 23 June NPS were forwarded an email by the GMP IOM officers which provided details of
an incident which had occurred on the 22™ June. This intelligence report detailed an incident in
which the offender and his co-accused from whom he was subject to licence conditions not to
associate with, were believed to have attended a property with knives. The officer who attended
this incident gave credible evidence to the Court that whilst the people at the house would not
provide a statement, he believed the incident involved the offender. At this stage, the evidence
from GMP was in their opinion the offender by now be recalled, as they felt the ability to manage
his risk within the community was such that he could not be managed. Whilst it was accepted the
decision to recall lies with the NPS the opinion of the Police in circumstances where they have joint
management responsibilities is clearly a relevant factor. This information was forwarded by the OM
to the SPO however there was a failure by the SPO to respond and there was a failure by the OM
then to escalate this significant information.

GMP IOM/NPS Integrated Working

A significant finding from this Inquest was the fact that in all likelihood the close integrated working
led to a significant failure to pass on concerns in a recorded and appropriate format. The Court
found a culture and practice had developed of expressing concerns through informal
conversations, telephone calls none of which were recorded. Hence the informal nature of such
discussions meant that the rationale for such concerns and the recording and documenting of
concerns was lost. Moreover it meant information was not then provided in a structured way to
SPOs and the ACO.

It was clear to the Court that the IOM officers had significant concerns about the offender
throughout the time he was on licence. Despite these concerns there was a failure to escalate their
concerns to Senior Management.

May — June 2016

During the period the 16" May 2016 — 23% June 2016 the Court found there were failures by both
GMP and the NPS in the management of this offender. During this time he was subject to one
drug test, 2 curfew checks, and only 4 home visits which all occurred in the week commencing the
13" June and in which he was seen on only one occasion.

11" 13" July 2016

On the 11". July the OM escalated the case to the SPO for advice this was following intelligence
from GMP to suggest the offender had been at a festival for the weekend. This led to a discussion
between the SPO and the ACO. There was a failure by the OM and the SPO to provide full and
detailed information including the OMs genuinely held belief by this time that consideration should
be given to recalling the offender. A decision was taken to issue a further SPO warning to the
offender.

Fr

3 August 2016 |

On the 3° August the offenders case was escalated by the OM to the ACO. The reason for the
escalation was due to threats made by the offender to a specific individual (linked to his family).
This was the first time the ACO had been made aware of the intelligence from the 22 June of the
offender potentially being involved in an incident with knives. Given the passage of time and the
fact this had not been raised previously with her it was wrongly assumed this incident had been
considered and clarification sought from GMP. No information was sought/provided with regards to
his drug test results despite the ACO being aware he was subject to weekly Class A and Class B
drug testing. No information was soughi/provided with regards to the outcome of any curfew
checks. On the basis of the information provided the ACO met with the offender to reinforce his
licence conditions.

The Court found as a matter of fact that had all relevant information which was available been
provided to the ACO on the 3% August then on the balance of probabilities it is more likely than not
recall would have been initiated. Had recall been initiated the Court was satisfied from the
evidence, it was more likely than not the offender would have been in custody on the 14" October
2016 when he attacked Michael Hoolickin.

25" August - 14" October

A third OM took over the responsibility for the management of the offender during this period of
time. During this entire period there was a lack of drug testing and a failure by the OM to have a
clear understanding of the offenders licence conditions and therefore a failure to enforce those
licence conditions.

Handover and Allocation or Work — The Court heard evidence as to the quality of the handover
provided to the third OM who was a newly qualified OM (and new to the Rochdale office). The
Court questioned the allocation of this offender to this OM which was done on an ad-hoc
uninformed way. In addition the handover provided was inadequate.

During the course of the Inquest the Court received evidence on a number of generic matters
which are relevant throughout the time of the offenders management:

Drug Testing - The failure to implement PI/2014 which should have been implemented by
November 2014 meant the Rochdale NPS office were not using instant drug testing which would
have shown the offender was testing positive for cocaine. As it was, in 2016 Rochdale NPS were
still using laboratory drug testing methods.

Frequency of testing — despite the offender being subject to weekly testing there were significant
periods of time when no testing was undertaken. Particularly from the 24" May 2016 — 4" July
2016 and from the 21* August 2016 — 14" October 2016.

Drug test results ~ due to a failure nationally to realise that the case management system did not
‘pull through’ drug test results which had been requested by way of a “tick box” (ie the drug tested
for), there was a failure to realise the offender was testing positive for cocaine on 9 occasions from
the 4" May 2016.

Staffing shortages — The court heard there were significant staffing shortages in the Rochdale,
Oldham and Bury cluster, in part due to Transforming Rehabilitation although other reasons also
impacted such as sickness. As a result OMs had an excessive workload which the Court is
satisfied in part contributed to the lack of effective management in this case. In addition a severe
lack of SPOs (in part due to sickness) meant that there was ineffective oversight and formal
management of cases during this period of time. The Court does recognise some attempts were
made to minimise this issue.

CORONER’S CONCERNS

During the course of the inquest the evidence revealed matters giving rise to concern. In my
opinion there is a risk that future deaths will occur unless action is taken. In the circumstances it is

my statutory duty to report to you.

The MATTERS OF CONCERN are as follows:-
For Everyone

Serious Further Offence Reviews — Following the death of Michael Hoolickin the NPS
conducted a single agency Serious Further Offence Review. No internal investigation
review was conducted by GMP.

The ability to prevent future deaths is predicated on the recognition of issues or failures
from which lessons can be learnt. Despite the fact this was a high risk offender who was
jointly managed within a multi-agency integrated team there was no multi-agency review.
The Court did not consider the involvement of any other agencies such as the offenders
GP, drug and alcohol services or Social Services (he was a leaving care young adult) as
these were not within the scope of the Inquest. Some of these agencies were also
supposed to be part of the IOM cohort.

The failure to undertake a multi-agency review in cases where a high risk offender subject
to multi-agency management has gone on to take someone’s life means both
organisational and individual failings are not identified and there is a missed opportunity to
learn lessons in order to prevent future deaths.

For the Secretary of State for Justice and the National Probation Service

Transforming Rehabilitation. The Court heard evidence as to the catastrophic impact the
Transforming Rehabilitation Programme had had on the staffing levels within the NPS. In
addition of the immense difficulties placed on the service in implementing new procedures,
policies, working practices and training staff in the new service. Of note this programme
caused particular difficulties in certain parts of the country, the Rochdale, Oldham and Bury
cluster being one such area. The Court was satisfied this, in part, contributed to the failure
to implement PI 30/2014. The Court heard evidence of the planned move away from
Transforming Rehabilitation and the plan to reintegrate the current divided service (NPS
and CRCs) into one service which is due to come into force in the future. The Court has
concerns as to the planning and preparation required for the amalgamation of any new
service in order to alleviate the evidenced problems which occurred as a direct result of the
previous Transforming Rehabilitation programme.

N-Delius Case management System. The Court heard evidence in respect of the difficulties
of utilising the case management system N-Delius. One Senior NPS witness confirmed, “ it
could be argued this system needs a complete revision.” Numerous witnesses gave
evidence as to the difficulties in accessing this system, its design and the time it takes to
access the different parts which hold pertinent information about an offender, describing
this as prohibitive. For example for Offender managers trying to read through the file to
obtain current information there is nowhere which would easily show the most up to date
curfew or the most up to date position as to how often drug testing is being conducted. All
such matters may be subject to: revision during an offenders licence period. The last
Offender Manager completely missed the fact that the offender was subject to drug testing
hence no drug tests were conducted, bar one by the trainee OM, from 21% August — 14'
October 2016. The Court was extremely concerned as to whether this system is fit for
purpose, particularly when attempting to capture all relevant, recent information about a
high risk offender in order to reach an informed decision such as recalling them to prison.

Moreover the decision to initiate recall is the responsibility of an Assistant Chief Officer
(ACO). The Court heard their decision is based solely on the information provided to them
by the Offender Manager (OM) usually via a Senior Probation Officer (SPO) who would
have been consulted in the first instance. The decision therefore to deprive someone of
their liberty and recall them to prison is totally reliant on the OM accessing the case
management system (described above) and forwarding all relevant information. There is no
expectation for an ACO to access an offenders records on the case management system in
order to inform themselves or to consider whether there is any further relevant information.
There may not even be any direct contact between the OM and the ACO. In this case the
Court heard evidence of the complete lack of “professional curiosity” from a number of

witnesses which in conjunction with no expectation to read or access the information meant
crucial information was not known to the ACO who ultimately responsible for the decision
on recall.

Drug Testing — the Court found there was an ineffective national system in use in 2016 (N
Delius) for which there had been no training on how to access Drug test results. As a result
individual offices had implemented their own systems for storing drug test results. However
there is no induction training, information available to staff in individual offices by way of
office procedures which informs staff of local practices. This is particularly pertinent if staff
transfer from other offices.

ACO and SPO warnings - During the course of the Inquest the Court heard differing
opinion from the ACO and the expert as to whether an ACO is a final warning. In this case
the offender received a SPO warning, an ACO warning and then a further SPO warning
within a 9 week period. National Standards suggest an ACO warning is a “final” warning.
The ACO told the Court that there is no reason why a further SPO warning cannot be
issued following an ACO warning. The expert suggested this was incorrect and that the
guidance is clear that an ACO warning is a final ie last warning. The Court found there is a
lack of clarity and specific instructions to the NPS on this point.

Record Keeping - The Court heard evidence as to the record keeping by NPS witnesses in
this case. The Court had serious concerns as to the poor records or complete lack of
records particularly by SPOs and the ACOs.

OASYS Assessments - At no stage after March 2016 was the offenders OASYS risk
assessment updated. Moreover the lack of formal supervision meant this was not
addressed.

Cross Referencing Intelligence of Offenders subject to Licence and Management — During
the course of the Inquest questions were raised around the ability of the NPS to cross

reference intelligence received in respect of different offenders. In addition whether there
was capacity to cross reference intelligence held by other agencies such as the Youth
Offending Team. For example the offender was arrested on the 10" May with a PPO
nominal who was known to YOT. It is not known whether YOT received any further
information about the incident or whether they held information which may have assisted
the NPS.

For National Police Chief Council , Greater Manchester Police and National Probation Service

Curfew Requirements. The Court was satisfied from the evidence that there is no clear
understanding as to the initiation of curfew checks. It was clear to the Court there was
confusion as to whether an offender on a curfew will automatically be subject to curfew
checks carried out by the Police or whether such checks will only be conducted following a
specific request by the NPS. As a result in this case the offender was only subject to 2
curfew checks in 8 months. In addition there was a lack of clarity as to whether the Police
would only report a curfew check if the offender was not present at the time of the check.

Police National Computer & Licence Conditions The Court heard that an offenders’ licence
conditions are not held on the Police National Computer database. Hence if an offender is
arrested by a different force they are unlikely to know whether the offender may be in
breach of their licence. Hence it is not clear how any potential breaches would ever be
shared effectively with the NPS.

Integrated Working The evidence before the Court was there are no Standard Operating
procedures or formal processes in place for the sharing of information when teams are
integrated. As indicated above in this case the Court found this led to a culture of more
informal discussions and means of sharing information.

Integrated Offender Management Cohort Meetings The evidence before the Court was that
in respect of the multiagency IOM meetings there was no formal agenda, no formal

minutes, no accurate record kept of these meetings by either GMP or the NPS and no way
of ascertaining who had attended these meetings. Of note these meetings are to discuss
the ongoing management of high risk offenders being managed in the community and is an
opportunity to discuss how effective the management plan is. There is no national guidance
to forces or agencies on how these meetings should be structured or recorded.

For Greater Manchester Police and Lancashire Constabulary

e Information Sharing - The importance of ensuring accurate detailed information is shared
between police forces is vital. Both offenders arrested on the 2"? May were PPO nominals.
There was a complete breakdown of communication and information sharing between GMP
and Lancashire Constabulary which lead to only information about one of the two offenders
being passed on. More importantly there was confusion between the forces as to which
offender was being discussed. The impact of this goes directly to decisions made by the
NPS on matters such as recall.

ACTION SHOULD BE TAKEN

In my opinion action should be taken to prevent future deaths and | believe each of you
respectively have the power to take such action.

YOUR RESPONSE

You are under a duty to respond to this report within 56 days of the date of this report, namely 24"
October 2019. |, the Coroner, may extend the period.

Your response must contain details of action taken or proposed to be taken, setting out the
timetable for action. Otherwise you must explain why no action is proposed.

COPIES and PUBLICATION

| have sent a copy of my report to the Chief Coroner and to the following Interested Persons
namely:-

- The family of Michael Hoolickin and their legal representatives
- Greater Manchester Police and their legal representatives

- National Probation Service and their legal representatives

- and her legal representative

- and his legal representative

| am also under a duty to send the Chief Coroner a copy of your response.

The Chief Coroner may publish either or both in a complete or redacted or summary from. He may
send a copy of this report to any person who he believes may find it useful or of interest. You may
make representations to me the coroner at the time of your response, about the release or the
publication of your response by the Chief Coroner.

Date: 29th August 2019 Sign

Responses

4 responses published against this report on judiciary.uk. A response is a body's written reply to the coroner's concerns; publication is at the discretion of the Chief Coroner's office, so an absent response does not mean nobody replied.

Response from Greater Manchester Police (PDF)
GREATER MANCHESTER

lan Hopkins QPM “(ER 5
Chief Constable Nas

HM Senior Coroner Ms Joanne Kearsley

The Coroner’s Office

The Phoenix Centre

Stephen Shaw MC Way

Rochdale 31 October 2019
OL10 1LR

Dear Ms Kearsley

Re: 28 day letter following the Inquest touching upon the death of Mr Michael
Hoolickin

Thank you for your report sent by email dated 29 August 2019 in respect of Michael
Hoolickin (deceased) and pursuant to Regulations 28 and 29 of the Coroners (investigations)
Regulations 2013 and paragraph 7, Schedule 5 of the Coroners and Justice Act 2009.

Having carefully considered your report and the matters therein, | reply to the concerns
raised as follows:-

Extract from Requlation 28:

For Everyone

Serious Further Offence Reviews - Following the death of Michael Hoolickin the NPS
conducted a single agency Serious Further Offence Review. No internal investigation review
was conducted by GMP.

The ability to prevent future deaths is predicated on the recognition of issues or failures from
which lessons can be learnt. Despite the fact this was a high risk offender who was jointly
managed within a multi-agency integrated team there was no multi-agency review.

The Court did not consider the involvement of any other agencies such as the offenders GP,
drug and alcohol services or Social Services (he was a leaving care young adult) as these
were not within the scope of the Inquest. Some of these agencies were also supposed to be
part of the [OM cohort.

The failure to undertake a multi-agency review in cases where a high risk offender subject to
multi-agency management has gone on to take someone’s life means both organisational
and individual failings are not identified and there is a missed opportunity to learn lessons in
order to prevent future deaths.

Response: It is accepted that there may be missed opportunities to learn from incidents
where an offender subject of multi-agency management causes death or serious injury and a
multi-agency review does not take place. At present there is no national police guidance in
relation to the internal reviews of incidents where an offender, subject of supervision by the
integrated offender management (IOM) team, is involved in a further serious offence such as
homicide.

Location address: GMP Force Headquarters, Central Park, Northampton Road, Manchester M40 SBP
Postal address: Greater Manchester Police, Openshaw Complex, Lawton Street, Openshaw, Manchester M11 2NS.
Tel: 101

AN

A.8&

In these circumstances where the offender is subject of multi-agency protection panel
arrangements (MAPPA) there is a statutory framework in existence to ensure lessons are
identified and learned. This framework requires the agencies involved in the management of
the offender to carry out a multi-agency review.

Following discussion with local partners Greater Manchester Police will adopt that best
practice and hold a similar multi-agency review of such IOM cases. Further that the multi-
agency review should complement the serious further offence (SFO) review carried out by
the NPS through an agreed action plan with the objective of identifying and addressing any
single agency or partnership learning and opportunities to improve practice.

The results of the multi-agency review and any action taken or required will be reported at
borough level to the reducing re-offending board. The recently formed Greater Manchester
adult offender management reform board will provide the strategic oversight of multi-agency
organisational learning and will ensure this learning is shared throughout Greater
Manchester. This shared approach to reviews will be included in updates to the Greater
Manchester IOM Manual of Guidance (August 2018).

Extract from Requlation 28:

For National Police Chief Council, Greater Manchester Police and National Probation
Service

Curfew Requirements - The Court was satisfied from the evidence that there is no clear
understanding as to the initiation of curfew checks. It was clear to the Court there was
confusion as to whether an offender on a curfew will automatically be subject to curfew
checks carried out by the Police or whether such checks will only be conducted following a
specific request by the NPS. As a result in this case the offender was only subject to 2
curfew checks in 8 months. In addition there was a lack of clarity as to whether the Police
would only report a curfew check if the offender was not present at the time of the check.

Response: It is accepted that there is no clear understanding of how curfew checks on IOM
subjects should be initiated and reported upon. There is currently no national guidance on
how agencies should ensure compliance with curfews as a licence condition.

It has been agreed with local partners that the responsibility for carrying out curfew checks
on offenders within the IOM cohort is owned by the police. Moreover that on a case by case
basis there should be an agreed curfew management plan with NPS which is set and
regularly reviewed in the IOM case review meetings. The plan should include: what the
checks are intended to achieve; the anticipated frequency and timing of curfew checks; and
the approach should be justified, necessary and proportionate in accordance with ECHR.

The IOM sergeant has responsibility to task out the curfew checks to officers within the IOM
team or alternatively to district officers, either neighbourhood or response officers. The
feedback and updates from curfew checks conducted by the police will be shared with other
OM partner agencies, including NPS, during the case review meetings. In the event curfew
check completion is prevented by other demands on the available police resources, as
identified in your ruling at point 83, then it is the IOM sergeant’s responsibility to ensure
resources are made available to provide a robust assurance of compliance with curfew
requirements. If relevant information is obtained as a result of a curfew check an intelligence
record will also be created on police systems.

Location address: GMP Force Headquarters, Central Park, Northampton Road, Manchester M40 5BP
Postal address: Greater Manchester Police, Openshaw Complex, Lawton Street, Openshaw, Manchester M11 2NS
Tel: 101

AY

This agreed approach to ensuring compliance with curfew licence conditions will be included
in the next update to the Greater Manchester |OM Manual of Guidance.

Police National Computer & Licence Conditions - The Court heard that an offenders’ licence
conditions are not held on the Police National Computer database. Hence if an offender is
arrested by a different force they are unlikely to know whether the offender may be in breach
of their licence. Hence it is not clear how any potential breaches would ever be shared
effectively with the NPS.

Response: The PNC is a national database and an entry on the CU page of a person
record, concerning supervision or licence details, is completed using a set wording. This
includes contact details for the national probation service or Spotlight team managing the
subject and the dates between which the licence or supervision is effective. It is accepted
that the PNC does not hold specific licence conditions. All persons authorised for detention at
a police station should be checked on PNC and it is the responsibility of officers in the force
where the subject is arrested to make contact with the relevant probation service office to
share details of the arrest from which the NPS can assess whether the licence or supervision
conditions have been breached.

In this case on 10 May 2016, Lancashire police were alerted to the fact that the offender Mr
HEE “2s subject of licence conditions when he was arrested and the PNC was
checked. Contact was made with the Spotlight team, which is consistent with the flagging
principles of PNC; the confusion arose because of a lack of effective information sharing that
followed between Lancashire Constabulary officers and GMP officers.

Custody staff in GMP who carry out PNC checks on detained persons have been reminded
of the importance of their role in identifying individuals on licence and under supervision and
ensuring that the they or the arresting officers make appropriate contacts with the relevant
probation service or spotlight office. The importance of accurate information sharing and
management has been highlighted to officers and staff in GM integrated offender
management teams.

At this time the PNC does not hold the specific licence conditions because of the volume of
offenders on licence, many of whom have multiple conditions, which are subject to variation.
After respectful consideration of the evidence gathered in this inquest and the concerns
expressed in the Regulation 28 letter the disadvantages it is felt that maintaining a timely and
accurate record of all licence conditions would require a significant increase in administrative
time which would not be justified given the information is accessible from the NPS who will in
any case make a determination on breach.

Integrated Working - The evidence before the Court was there are no Standard Operating
procedures or formal processes in place for the sharing of information when teams are
integrated. As indicated above in this case the Court found this led to a culture of more
informal discussions and means of sharing information.

Response: The model of integrated working is intended to facilitate discussion between
people from different agencies to improve understanding of cohort members and how their
offending might best be managed and or reduced. The fluidity of the information exchange is
therefore important to the success of the integrated teams.

It is accepted that documenting discussions upon which actions are set or decisions made is
important and whilst the court heard testimony that this had improved since 2016 it is an area
that GMP will look to improve though better structured and documented cohort meetings (see
below).

Location address: GMP Force Headquarters, Central Park, Northampton Road, Manchester M40 5BP
Postal address: Greater Manchester Police, Openshaw Complex, Lawton Street, Openshaw, Manchester M11 2NS
Tel: 101

A.10

Integrated Offender Management Cohort Meetings : The evidence before the Court was that

in respect of the multi-agency [OM meetings there was no formal agenda, no formal minutes,
no accurate record kept of these meetings by either GMP or the NPS and no way of
ascertaining who had attended these meetings. Of note these meetings are to discuss the
ongoing management of high risk offenders being managed in the community and is an
opportunity to discuss how effective the management plan is. There is no national guidance
to forces or agencies on how these meetings should be structured or recorded.

Response: The concerns raised about |OM practice in 2016 are accepted. However, it is
important to emphasize that since 2016, there have been improvements to record keeping in
line with the content of the revised IOM framework circulated in August 2018. The framework
is supported by new paperwork and templates, including draft agendas and action logs with
names and timescales.

Learning from this case will inform further revision to the IOM guidance to include the
process for escalating cases where police officers consider recall is required with the
associated rationale. The revised guidance will also ensure that cases with increasing levels
of risk are not only escalated but considered for referral into MAPPA within the individual
case reviews.

Extract from Regulation 28:
For Greater Manchester Police and Lancashire Constabulary

Information Sharing - The importance of ensuring accurate detailed information is shared
between police forces is vital. Both offenders arrested on the 2" May were PPO nominals.
There was a complete breakdown of communication and information sharing between GMP
and Lancashire Constabulary which lead to only information about one of the two offenders
being passed on. More importantly there was confusion between the forces as to which
offender was being discussed. The impact of this goes directly to decisions made by the NPS
on matters such as recall.

Response: Whilst it is accepted that the exchange of information in this case between police
officers from Lancashire Constabulary and GMP could and should have been more effective
it is respectfully submitted that evidence from this this single incident does not amount to a
systemic issue.

Furthermore the purpose of the initial contact is to make the relevant NPS or IOM team
aware of the basic circumstances of the arrest of a person on licence. As in this case, at the
time of the initial contact it is unlikely that the full circumstances of the incident leading to
arrest will be known or the outcome. It is incumbent on those managing the licence to ensure
they have sufficient reliable information upon which to base a decision on licence variation or
recall.

Custody suites are a conduit for sharing information between forces for out of area arrests
including those in breach of licence conditions.This type of contact is daily business and
there isn’t any specifc guidance for custody staff in relation to how to pass information
between police forces. This approach to sharing information about the arrest of a person who
is subject to licence conditions meets the requirements for initial notification of arrest to the
team responsible for managing that offender.

It is appropriate and proportionate to remind all staff working within custody offices of the
importance of paying attention to detail when sharing information. A briefing note has been
produced by the custody branch to advise and remind the custody teams across Greater
Manchester Police of their responsibilities around detainees who are on licence or under
supervision and the importance of accurate and timely information sharing with the contact
detailed on the CU page of PNC

Location address: GMP Force Headquarters, Central Park, Northampton Road, Manchester M40 5BP
Postal address: Greater Manchester Police, Openshaw Complex, Lawton Street, Openshaw, Manchester M11 2NS
Tel: 101

A.11

Summary

On behalf of Greater Manchester Police | acknowledge the areas in which we can
improve our approach to integrated offender management.

There is work already underway in relation to reviewing the OM Manual of guidance
(August 2018) and this will cover the areas of escalation, information sharing, and
expectations for integrated working, particularly in relation to record keeping and
recording key decisions.

This ongoing work is collaborative across the IOM partnership and all agencies are
committed to continually improving integrated offender management.

The GM adult offender management reform board, chaired by Chief Supt Paul Savill
will provide the governance to the ongoing work in this area.

On 8 October 2019 an IOM sergeants’ meeting was held and the concerns from this
case have been discussed thoroughly with all the district representatives.

A GM wide IOM workshop has been planned for 28 November 2019, during which the
lessons learned from Mr Hoolickin’s death and the consequent changes to guidance
will be the focus of the day.

The concerns raised in this regulation 28 letter have been shared with the NPCC tead
for IOM, DCC John Stratford and will be included on the agenda of the next meeting
of the National OM Working Group (January 2020)

| hope that this response is helpful in outlining the actions that we are taking to address the
issues you raised and in demonstrating our total commitment to learning from the tragic
death of Mr Hoolickin, so that we can prevent death or serious injury arising in similar
circumstances in the future.

Yours sincerely

!

lan Hopkins
Chief Constable

Location address: GMP Force Headquarters, Central Park, Northampton Road, Manchester M40 SBP

Postal address: Greater Manchester Police, Openshaw Complex, Lawton Street, Openshaw, Manchester M11 2NS.

Tel: 101

A.12
Response from Hm Prison and Probation Service (PDF)
H M Senior Coroner Ms Joanne Kearsley, 
The Coroner’s Office,  
Manchester North. 

Amy Rees  
Director General of Probation and Wales 
 HM Prison and Probation Service 
3rd Floor Churchill House 
Churchill Way 
Cardiff CF10 2HH 

e-mail: DirectorGeneralProbation@justice.gov.uk    

9 December 2019      

Dear Ms Kearsley  

Inquest into the death of Mr Michael Hoolickin 

Thank you for your Regulation 28 Report, issued following the Inquest into the death of Mr. Hoolickin.          
I am replying as the Director General of Probation and Wales, part of Her Majesty’s Prison & 
Probation Service (HMPPS) on behalf of the Secretary of State for Justice and Ms Hamilton of the 
National Probation Service North West Division. 

I know that you will share a copy of this response with the family and I would first like to express my 
sincere condolences that they were victims of such a terrible crime.  The implementation of learning 
from this case is my absolute priority.  We are grateful for your comments and recommendations for 
improvement, which we have considered in detail.  

I set out below the responses to the matters you have raised giving rise to concern. 

The failure to undertake a multi-agency review in cases where a high-risk offender subject to multi-
agency management has gone on to take someone’s life means both organisational and individual 
failings are not identified and there is a missed opportunity to learn lessons in order to prevent future 
deaths.  

There are arrangements in place for undertaking Serious Case Reviews on a multi-agency basis in a 
range of circumstances, including for certain offenders managed under Multi Agency Public Protection 
Arrangements (MAPPA) and for cases of Domestic Homicide. These reviews support organisational 
learning across agencies. The management of the perpetrator in this case was not captured under 
these arrangements as he was managed as MAPPA level 1 and under the current statutory guidance, 
his management did not meet the criteria for a mandatory MAPPA Serious Case Review. The MAPPA 
Guidance is statutory guidance issued by the Secretary of State for Justice under the Criminal Justice 
Act (CJA) 2003, to help the relevant agencies in dealing with MAPPA offenders. We will review the 
MAPPA guidance on which cases should be subject to a mandatory Serious Case Review. As part of 
the process we will consult with partners, including the Home Office and police, on strengthening the 
guidance on undertaking Serious Case Reviews where high risk MAPPA offenders have been 
convicted of Murder.      

A.55

 
 
 
 
 
 
 
 
 
  
 
 
 
 
    
 
 
 
 
 
 
 
 
 The Court has concerns as to the planning and preparation required for the amalgamation of any new 
service in order to alleviate the evidenced problems which occurred as a direct result of the previous 
Transforming Rehabilitation programme. 

The Department is determined to ensure a smooth transition to future probation arrangements which 
minimises disruption for staff and service users.  We are working closely with the Community 
Rehabilitation Companies to ensure we get the transition to the new system right. Extensive planning 
for the transition is underway within HMPPS, drawing on lessons learned from Transforming 
Rehabilitation and from our experience in Wales, where offender management functions transfer over 
to the National Probation Service (NPS) in December 2019 ahead of Divisions in England. 

The Court was extremely concerned as to whether the N Delius case management system is fit for 
purpose, particularly when attempting to capture all relevant, recent information about a high-risk 
offender in order to reach an informed decision such as recalling them to prison 

HMPPS is engaged on a programme of work to modernise tools available to probation practitioners in 
their management of offenders. Those responsible for this work closely with operational staff in NPS 
to ensure that changes we make reflect their priorities and support front line staff in the way that they 
work.  The team will look at the issues raised in this case as soon as possible, and establish what 
improvements can be made quickly.  The team will consult front line staff to ensure any solutions 
developed reflect practitioners’ needs.  Updated Guidance on professional judgment decision making 
and recording on NDelius has already been added to the EQUIP database.   

There is no induction training, information available to staff in individual offices by way of office 
procedures which informs staff of local practices. This is particularly pertinent if staff transfer from 
other offices. 

It is fully accepted that where there are local office practices in place there must be effective 
communication of such local practices to staff new to an office.  I have therefore taken immediate 
steps to ensure that the National Induction Pack is updated so that it makes clear that specific 
induction on local practice and processes must be completed both for staff new to the organisation 
and for staff moving offices. We will also put in place a mechanism to record that this has taken place. 

Lack of clarity and specific instructions to the NPS on the system of SPO and ACO warnings issued to 
offenders and serious concerns as to the poor records or complete lack of records particularly by 
SPOs and the ACOs. 

The requirement for recording evidence of professional judgment has always been an essential 
element of record keeping in individual cases. In April 2019, HMPPS strengthened guidance by 
publication of the ‘Compliance and Engagement on Licence’ document. This paper outlines evidence 
based best practice guidance that encompasses several critical areas of management of offenders on 
licence from pre-release engagement to licence variation and recall thresholds. There is a chapter 
which provides specific guidance and outlines expectations relating to recording of and accountability 
for all decisions taken.  

At no stage after March 2016 was the offender’s OASYS risk assessment updated. Moreover, the 
lack of formal supervision meant this was not addressed. 

The Probation Instruction on sentence planning sets out the expectation that Offender Managers 
review OASys assessments and update the risk management plan in response to changes of 
circumstance and, in particular, changes which may impact on risk. The assessment and risk 
management plan should have been reviewed and updated in this case. The fact that that this had not 

A.56

 
 
 
 
 
 
 
 
 
 
 been done should have been picked up through management oversight and our supervisory 
arrangements.   

We have developed a new National Supervisory and Line Management Framework to better support 
front line probation staff in their role which is being rolled out across the NPS Divisions.  This 
Framework is designed to ensure a consistent and appropriate level of management oversight 
through practice supervision sessions and observation of practice as well as review of cases.  
Through observation of practice, senior probation officers will be able to see whether staff are being 
sufficiently challenging and adopting a properly investigative approach in their face to face supervision 
of the offender. There is a minimum requirement of four practice supervision meetings and two 
practice observations per annum for all probation officers with their Senior Probation Officer/line 
manager. Within this framework, Senior Probation Officers with line management responsibility will 
ensure that work is undertaken in line with expected standards and that decision making is being 
properly recorded.   

Questions were raised around the ability of the NPS to cross reference intelligence received in 
respect of different offenders. In addition, whether there was capacity to cross reference intelligence 
held by other agencies such as the Youth Offending Team.  

We recognise the importance of sharing information about offenders both within teams and our own 
organisation and with partner agencies, including YOT.  In March, HMPPS published a new Policy 
Framework on Intelligence Collection, Analysis and Dissemination and recently updated the policy in 
October. Its purpose is to ensure staff within HMPPS adopt consistent approaches to the collecting, 
handling, analysis and dissemination of intelligence. Its stated aims include that staff are confident in 
submitting and collecting intelligence to combat ongoing criminality. Staff are required to share 
intelligence appropriately within HMPPS or disseminate it to other agencies, so that through the 
proactive use of intelligence to identify potential risks, the public are protected as far as possible from 
the threat of harm. In addition, it is a clear principle of Integrated Offender Management (IOM) that all 
partners manage offenders effectively together, which means agreeing the means to share 
information and intelligence as a basis for multi-agency problem solving. This is set out in HMPPS 
guidance on IOM.   

There is no clear understanding as to the initiation of curfew checks.  It was clear to the Court there 
was confusion as to whether an offender on a curfew will automatically be subject to curfew checks 
carried out by the Police or whether such checks will only be conducted following a specific request 
by the NPS.  As a result, in this case the offender was only subject to 2 curfew checks in 8 months. In 
addition, there was a lack of clarity as to whether the Police would only report a curfew check if the 
offender was not present at the time of the check. 

The process for undertaking curfew checks should be set out in the risk management plan, stating 
clearly who is responsible for what, and in cases such as this it should be agreed at multi-agency IOM 
meetings. I have set out further below the arrangements that have now been put in place to 
strengthen IOM arrangements in Greater Manchester.  You may also be interested to know that 
electronic monitoring is also available to monitor curfews for certain offenders, as is location 
monitoring, which allows an offender manager to request retrospective information about a subject’s 
whereabouts at any time during the lifetime of their supervision.  

An offenders’ licence conditions are not held on the Police National Computer database. Hence if an 
offender is arrested by a different force they are unlikely to know whether the offender may be in 
breach of their licence. Hence it is not clear how any potential breaches would ever be shared 
effectively with the NPS. 
There is an established process for prisons to inform the police about an offender’s release on licence 
and a specialist central unit uploads information on to the Police National Computer (PNC). The 

A.57

 
 
 
 
 
 
 system is owned and operated by the police and sits under the Home Office. HMPPS works 
collaboratively with the PNC Bureau to keep the process under review and ensure that we are 
providing them licence information in the most effective manner and will continue to do so.    

There were no Standard Operating procedures or formal processes in place for the sharing of 
information when teams are integrated.  The Court found this led to a culture of more informal 
discussions and means of sharing information. 

The Greater Manchester Combined Authority Integrated Offender Management Framework was 
launched in August 2018 which established a clear governance structure for Greater Manchester IOM 
schemes. The Framework establishes steering groups, exit/entry meetings, and regular case 
discussion/tasking meetings for IOM cohorts and specifies the need to record and circulate minutes 
and actions and timescales for doing this. It identifies key cohorts and their criteria as well as the IOM 
offer. It provides clear guidance regarding the sharing, reviewing and recording by IOM partners of 
criminogenic and risk information relating to nominals.   

In respect of the multi-agency IOM meetings there was no formal agenda, no formal minutes, no 
accurate record kept of these meetings by either GMP or the NPS and no way of ascertaining who 
had attended these meetings. Of note these meetings are to discuss the ongoing management of 
high risk offenders being managed in the community and is an opportunity to discuss how effective 
the management plan is. There is no national guidance to forces or agencies on how these meetings 
should be structured or recorded. 

The Home Office has set out the key principles for IOM, one of which is that it delivers a local 
response to local problems. While we have issued national guidance for NPS staff on IOM, we think it 
is right that detailed arrangements should be agreed locally. The Greater Manchester Combined 
Authority IOM Framework establishes tasking meetings for all Greater Manchester IOM schemes. 
These meetings cover specific tasking, sequencing of delegated tasks, reviewing and concluding on 
outcomes. Partnership attendance is voluntary, but intelligence sharing is mandatory. These meetings 
provide an opportunity to review individual action plans, emerging intelligence, set priorities for action, 
enabling risk management planning to be implemented and contingency plans to be reviewed. The 
Framework requires the sharing of minutes from these meetings in a timely manner. It also requires 
these meetings to be held a minimum of three times per week.  

The Greater Manchester IOM Framework is currently subject to review and your concerns will be 
considered as part of this review.  Where deemed necessary further guidance or clarification including 
templates such as draft agenda, minutes and action logs will be included.   

Thank you again for bringing these matters of concern to my attention.  Please be assured that 
learning from the circumstances of this tragic death will also be shared more widely with colleagues 
across the NPS Divisions.   

Yours sincerely  

Amy Rees,  
Director General of Probation and Wales, HM Prison and Probation Service 
Cyfarwyddwr Cyffredinol y Gwasanaeth Prawf a Chymru, Gwasanaeth Carchardai a Phrawf EM   

A.58
Response from Lancashire Constabulary. Redactedf (PDF)
Lancashire
Constabulary

police and communities together

PUBLIC PROTECTION UNIT

Public Protection Unit

Detective Chief Inspector Michael Gladwin

Lancashire Constabulary Headquarters, Hutton, Preston, Lancashire. PR4 5SB
Telephone:_01772 412432

Email:

Our ref: —IN/00002/19
Your ref:

04 November 2019

Ms J Kearsley

HM Senior Coroner

The Phoenix Centre

L/Cpl! Stephen Shaw MC Way
Heywood

OL101LR

Dear Ms Kearsley,
Inquest into the death of Michael Hoolickin

Please accept this letter as the response on behalf of Lancashire Constabulary to the
Regulation 28 Report to prevent future deaths with specific reference to the information sharing
between Lancashire Constabulary and GMP on 10 May 2016.

On 10 May 2016 was travelling in a vehicle driven by Hen both men were
arrested for drug offences. From research of records in this case and the recollection of the
Custody Sergeant who was involved that day ‘a it is clear that following the
arrest of and ae: whilst they were in custody, Sergeant [I has promptly
made contact with Greater Manchester Police Integrated Offender Management Team to pass
detail inly, the arrest fe té‘ This was conducted in response to a ‘marker’ placed
on ec, record. It is believed this was endorsed by the GMP IOM team to flag
he was an IOM nominal managed by them. What cannot be established due to of
time and with any certainty is what, if any, information was exchanged in respect of

The lack of certainty as to what information was being shared was an isolated incident and was
not demonstrative of any systemic failing(s). We have detailed below how Lancashire
Constabulary operates in practice in this area.

Lancashire Constabulary works in partnership with the National Probation Service to establish
the passage of information concerning prisoners released from custody on licence with
conditions to the force via their Force intelligence Department. This was the practice in May
2016 and still occurs now.

A new system is being developed (in response to a separate review) and will be adopted
whereby a ‘flag’ will be raised on the force’s ‘Connect’ system (a recently introduced intelligence
and case management IT system) which indicates to the user (for example Contact
Management Staff, Custody Staff, Investigators etc.) researching the specific nominal, that they
are on licence in the community. This will include guidance that they must consider referral to

A.13

the NPS Offender Manager's office where a potential breach of licence has occurred. This of
course will depend upon the specific nature of the police contact with said nominal. In ‘out-of-
hours’ cases this will be via the NPS duty ‘Approved Premises’ Manager who will instigate
breach proceedings where appropriate. The intention of this measure is to account for missed
opportunities, which may arise through officers/staff not routinely checking the “CU” custady
page of the nominal’s PNC record, which can be overlooked in some cases of police contact
with a nominal on licence.

Additionally, (again as part of the separate review referred to above) an exercise will be
undertaken to share the list of nominals currently in the community under licence and effectively
‘back-record’ the fact they are on licence with the same flag and guidance as above.

Directed messages will be cascaded to reinforce this message.

Yours faithfully

ME.

Detective Chief Inspector Michael Gladwin
Lancashire Constabulary Offender Management Lead
HQ Crime Public Protection Unit

A.14
Response from The National Police Chiefs Council 1 (PDF)
Ms Joanne Kearsley 

Her Majesty’s Senior Coroner 

County of Greater Manchester – North District 

The Phoenix Centre 

L/Cpl Stephen Shaw MC Way 

Heywood 

OL10 1LR 

[by email] 

Dear Ms Kearsley, 

18 November 2019 

Prevent Future Deaths Report for Michael Hoolickin (Deceased) 

Thank you for your correspondence of 29 August 2019 in relation to the Inquest into the death of Michael 
Hoolickin, along with the Regulation 28 Report to Prevent Future Deaths. 

I  was  not  previously  aware  of  this  incident,  and  I  am  very  sorry  to  learn  of  the  tragic  circumstances 
surrounding the death of Mr Hoolickin.  You will appreciate that I am unable to comment on the specific 
facts of this case, but I can address your concerns regarding policing practice more generally.  I understand 
that  you  have  made  contact  with  the  chief  constables  of  Greater  Manchester  Police  and  Lancashire 
Constabulary, both whom will no doubt wish to respond separately in addressing the issues you have raised 
with specific reference to the actions of their respective forces.   

It is important to understand the distinct role of the National Police Chiefs’ Council (NPCC).  As you know, 

each chief constable is ultimately responsible for operational matters within their own force area, which 

includes all of those issues referred to within the matters of concern you have raised. Whilst the NPCC seeks 

to encourage chief constables to work collaboratively in the national interest (for example, the way in which 

forces implement policies or practice), the NPCC does not have the authority to direct a chief constable to 

take (or not to take) a specific course of action.  That said, we do recognise the need for consistency across 

forces whenever possible, which we know can lead to better outcomes for the public.  The way the NPCC 

 National Police Chiefs’ Council (NPCC) 1st Floor, 10 Victoria Street, London SW1H 0NN - 020 3276 3795 

A.15

      
 
 
 
 
 
 
 
 
 
 
 
 achieves this is by allocating specific areas of national responsibility to  different chief officers in various 

forces across the country.  These chief officers act as the NPCC’s national lead on specific matters of policy 

and practice on behalf of their colleagues across all forces.   

Your report raises a number of very important matters of concern: 

1.  Serious Further Offence Reviews 
2.  Curfew Requirements 
3.  Police National Computer and Licence Conditions 
4. 
5. 

Integrated Working 
Integrated Offender Management Cohort Meetings 

In order to provide a useful response to the matters of concern you have raised, it has been necessary for 

me to consult with a number of national leads across several portfolios.  I am unfortunately not able to 

provide you with a full response to all of your concerns today because some of those I have consulted with 

are still in the process of considering the matters of concern, and no doubt further consulting with subject 

matter experts. However, I hope you are willing to accept this letter in part response to the issues raised. 

I  have  discussed  the  matters  of  Integrated  working  (concern  4)  and  Integrated  Offender  Management 

(concern 5) with the national lead for this area, Deputy Chief Constable Jon Stratford of Gloucestershire 

Constabulary.    DCC  Stratford  advises  me  that  unlike  Multi-Agency  Public  Protection  Arrangements 

(MAPPA),  Integrated  Offender  Management  (IOM)  operates  on  a  non-statutory  basis.  The  agencies 

involved commit to joint working voluntarily in furtherance of their individual aims and because it is in the 

public interest for them to do so. This means that the precise nature of each IOM scheme is very much a 

function of the local partnership landscape, circumstances and priorities.  The resultant diverse range of 

ways of working does not lend itself to strict codification at a national level, however IOM guidance does 

exist,  and  I  have  attached  to  this  letter  two  “IOM  Key  Principles”  guidance  documents  that  have  been 

designed to provide best practice guidance within which local schemes can operate.  

The  guidance  documents  attached  do  specify  the  need  for  effective  information  sharing.  For  example, 

paragraph  1.6  of  the  2015  document  states  that  “all  necessary  Information  Sharing  Agreements  (ISAs), 

protocols and processes are in place to ensure swift and appropriate real time sharing of information and 

intelligence”.  However, the precise ISA and ways of working must be built around the needs and ways of 

working of each individual scheme, which is impractical to provide at a national level.  The guidance also 

describes cohort selection in detail, again emphasising the requirement for this to be tailored to meet local 

needs.  

  2 
National Police Chiefs’ Council (NPCC) 1st Floor, 10 Victoria Street, London SW1H 0NN - 020 3276 3795 

A.16

 
 
 
 
 
 
 
 
 
 Being statutory in nature, MAPPA arrangements will always have primacy over IOM schemes although, as 

set out in the Key Principle documentation, IOM working can be useful in complementing the measures 

agreed in MAPPA. 

I am therefore content that sufficient IOM guidance does exist to support forces alongside the statutory 

requirements of MAPPA, but as I described earlier, it is a matter for each chief constable to ensure that 

appropriate arrangements are in place within their force.  In order to encourage learning from this Inquest, 

it is my intention to share your report, this response and the IOM guidance with chief constable colleagues 

in all forces across the country, in case there are areas of practice within their own force which they feel 

may benefit from review. 

I am sorry that at this stage I have been unable to provide you with a response to matters of concern 1, 2 

and 3.  I assure you these are being carefully considered by subject matter experts, and I will endeavour to 

provide a full response to these recommendations in the coming days. 

Thank you for providing me with the opportunity to comment on the areas of concern you have identified. 

Please do not hesitate to get in touch if you have any further queries about the content of this letter. 

Yours Sincerely, 

Martin Hewitt QPM 
Chair, National Police Chiefs’ Council 

  3 
National Police Chiefs’ Council (NPCC) 1st Floor, 10 Victoria Street, London SW1H 0NN - 020 3276 3795 

A.17

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