Prevention of Future Deaths reports · 2024

James Furlong, Joseph Ritchie-Bennett and David Wails

Regulation 28 report to prevent future deaths, reference 2024-0276, written 20 May 2024. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report20 May 2024
Reference2024-0276
DeceasedJames Furlong, Joseph Ritchie-Bennett and David Wails
CoronerSir Adrian Fulford
Coroner areaCentral Criminal Court
CategoryOther related deaths
Sourcejudiciary.uk record · original PDF
Responses published7

The report

Text extracted from the PDF text layer. Reproduced verbatim, including the scan's own layout.

SIR ADRIAN FULFORD PC 
SITTING AS NOMINATED JUDGE CORONER 

 INQUESTS ARISING FROM THE DEATHS IN THE FORBURY GARDENS 
TERROR ATTACK OF 20 JUNE 2020 

JAMES FURLONG 
JOSEPH RITCHIE–BENNETT 
DAVID WAILS 

__________________________________________________ 

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS 
__________________________________________________ 

Addressees 

1. This Report is addressed to the following:

a) The Secretary of State for the Home Department
b) The Secretary of State for Justice
c) The Chief Constable of Thames Valley Police
d) Berkshire Healthcare NHS Foundation Trust (“BHFT”)
e) Midlands Partnership University NHS Foundation Trust (“MPFT”)
f) Oxford Health NHS Foundation Trust (“OHFT”)
g) NHS England

 Coroner 

2.

I am Sir Adrian Fulford PC, and I heard these Inquests (having held office as a
judge of the Court of Appeal) following nomination by the former Lord Chief
Justice, Lord Burnett of Maldon, pursuant to Schedule 10 to the Coroners and
Justice Act 2009 (“CJA”).

Coroner’s Legal Powers 

3.

I make this report under paragraph 7, Schedule 5, of the Coroners and Justice
Act  2009  and  Regulations  28  and  29  of  the  Coroners  (Investigations)
Regulations 2013.

The Investigation, the Inquests and the Circumstances of the Deaths 

4. The  Inquests  to  which  this  Report  relate  concerned  James  Furlong,  Joseph
Ritchie-Bennett  and  David  Wails  who  were  murdered  by  Khairi  Saadallah
(“KS”) on 20 June 2020 in Forbury Gardens, Reading, Berkshire.

5. The  Inquests  were  heard  at  the  Central  Criminal  Court  between  15  January
2024 and 23 February 2024. I delivered my Factual Findings on 26 April 2024.
These can be found at:

https://www.judiciary.uk/wp-content/uploads/2024/04/Forbury-Gardens-
Factual-Findings-for-Publication.pdf 

6. The three Records of Inquest additionally can be found at:

https://www.judiciary.uk/wp-content/uploads/2024/04/Record-of-Inquest-
WAILS-D.pdf 

https://www.judiciary.uk/wp-content/uploads/2024/04/Record-of-Inquest-
FURLONG-J.pdf 

https://www.judiciary.uk/wp-content/uploads/2024/04/Record-of-Inquest-
RITCHIE-BENNETT-J.pdf  

7.

In each case the medical cause of death was a fatal stab wound. On 11 January
2021 at the Central Criminal Court KS pleaded guilty to the murders of James
Furlong, Joseph Ritchie-Bennett and David Wails for which he received three

 “whole  life”  sentences.  He  additionally  pleaded  guilty  to  the  attempted 
murders of Stephen Young, Patrick Edwards and Nishit Nisudan, which also 
occurred on 20 June 2020.  

8.  As set out in the Factual Findings and the Records of Inquest, the deaths were 
the result of a premeditated attack by KS. His intention was to take multiple 
lives within a short timeframe, thereafter escaping. His purpose was to advance 
a  terrorist  Islamist  cause.  He  was  not  suffering  from  a  mental  disorder  or 
mental  disability  which  lowered  his  degree  of  culpability  although  he  had 
developed  post-traumatic  stress  disorder  (“PTSD”)  symptomology  and  an 
emotionally  unstable  and  antisocial  personality  disorder 
(“EUPD”), 
characterised by mood instability, impulsivity, irritability and aggressivity. It 
was  accepted  during  the  Inquests  that  “working  diagnoses”  of  EUPD  and 
symptoms of PTSD were reasonable.  

9.  In  2011,  KS,  following  military  training,  fought  for  at  least  8  months  as  a 
member of the extremist Islamist militia, Ansar al-Sharia, during the uprising 
against  the  Gaddafi  regime  and  after  its  fall.  During  the  present  attacks  in 
Forbury Gardens, he used his combat experience to target a vulnerable area on 
each  of  the  three  deceased  (the  neck  or  the  left  subclavian  artery  and  left 
common carotid artery). 

Coroner’s Concerns 

The Failures that Contributed to the Deaths 

10.  The critical context of this Report is that there were notable failures on the part 
of multiple bodies which both probably and possibly contributed to the three 
deaths.  These  have  been  explained  in  extenso  in  my  Factual  Findings.  In 
summary form, however, there was a failure to: 

a)  assess  the  intelligence  in  its  entirety  (there  was  an  extensive  intelligence 
history  concerning  KS’s  extremism  and  capacity  for  violence)  and  then 
share  the  intelligence  appropriately;  instead  –  certainly  on  occasion  – 
limited pieces of information only were made available, which were thereby 
rendered potentially misleading; 

b)  address  the  substantial  consequential  risks  created  by  this  lack  of 
dissemination of the overarching intelligence picture (which included KS’s 
extremist views and associations, military training and violent impulsivity, 
which were potentiated by his personality disorder); 

 
 
 
 c)  provide an adequate and integrated response to the true risk posed by KS, 

based on a consideration of the entirety of the relevant material; and 

d)  offer  KS  adequate  mental  healthcare  in  the  community  and  secondary 

mental healthcare in prison. 

11.  These failures principally involved the Home Office, Counter Terrorism Police 
South-East  (“CTPSE”),  HMPPS,  BHFT  and  MPFT.  There  were  concurrent 
deficiencies  in  the  approach  adopted  within  the  Prevent,  Pathfinder  and 
MAPPA schemes. A common enduring error during the relevant period was 
the  tendency  to  downplay  or  discount  KS’s  extremist  risk  on  account  of  his 
EUPD and symptoms of PTSD.  

12.  I have been assisted by detailed evidence from these organisations on changes 
to policies, practices, and structures as a result of reviews following the attack 
in  Forbury  Gardens  and  earlier  terrorist-related  incidents  including  the 
Fishmongers Hall attack. It is still the case that during the course of the inquest 
the evidence revealed matters giving rise to significant concern. In my opinion 
there  is  a  risk  that  future  deaths  could  occur  unless  action  is  taken.  In  the 
circumstances it is my statutory duty to report to you.  

The failure to maintain and disseminate an adequate intelligence picture (the 
Secretary of State for the Home Department, the Secretary of State for Justice, 
the Chief Constable of Thames Valley Police) 

13.  Between  [13]  and  [41]  of  my  Factual  Findings,  I  rehearsed  the  numerous 
occasions  when  it  was  reported  (frequently  by  KS  himself)  that  i)  he  was 
(certainly, in the main) motivated by an Islamist terrorist ideology, ii) he had 
received military training, iii) he had personally fought during a violent civil 
war,  iv)  he  had  a  long  record  of  violent  impetuosity  and  v)  his  behaviour 
notably deteriorated when he was in crisis.  I concluded at [40], “the matters […] 
concerning KS’s history and ideological statements were, or should have been, available 
to all the key state agencies who had substantive dealings with, or were responsible for, 
KS, particularly given the context of his serious mental health problems, his extremism 
and the high/very high risk he posed to the public”. Indeed, KS ought to have been 
assessed as posing a very high risk to others in the community in the period 
following  his  release  from  prison  on  5  June  2020,  given  the  totality  of  the 
intelligence picture as recorded by different bodies and agencies, which was, 
or should have been, available. 

 
 
 
 
 14.  It is to be stressed in this context that during her evidence, Ms Rogers (the Head 
of Probation National Security Unit (East and South Central)) accepted she had 
been  unaware,  for  instance,  of  KS’s  link  to  Ansar  al-Sharia,  his  potential 
psychopathic tendencies, and the extent of his sometime grievances against the 
UK. If she had been more fully informed of these and other factors, HMPPS’s 
view of KS’s risk level could well have changed to very high risk. That could 
have led to him being designated a Critical Public Protection Case (“CPPC”). 
He may well, additionally, have been managed at MAPPA level 3. This in turn 
could  have  altered  his  licence  conditions,  the  approach  taken  to  Approved 
Premises and the level of contact with KS. As a CPPC MAPPA 3 case with an 
identified  terrorist  risk,  his  recall  to  prison  and  detention  for  breach  of  his 
licence conditions would have been effected within a timeframe of less than 2 
hours.  

15.  Bearing  the  above  factors  in  mind,  the  combination  of  KS’s  renewed  use  of 
cannabis  and  the  extreme  statements  he  made  on  19  June  2020  (viz.  to  his 
brother that “he is going to go to heaven […] he is going to harm himself and others. 
He said he was going to blow himself up […]”) should have led to his immediate 
recall  to  prison.  Instead,  the  relevant  members  of  the  probation  and  police 
services on 19/20 June 2020 were simply unaware of the true nature of the risk 
that KS posed; indeed, as a consequence of this lack of knowledge, the threats 
made by KS were not shared with the probation service by the police. Given 
the  speed  with  which  recall  can  be  effected  in  circumstances  such  as  these, 
taking this step would probably have avoided the attack. As a separate matter, 
there was also a failure by CTPSE to share relevant information with MI5 – see 
[270-271] and [276] of my factual findings.  

16.  I note that steps have been taken since the attack in Forbury Gardens to rectify 
the intelligence and risk assessment failures identified above. The “CT Step Up 
Programme”  was  rolled  out  in  September  2020.  Its  aim  is  to  “transform” 
HMPPS’s capability and capacity to manage and reduce the national security 
risk of those under the supervision of HMPPS and it “covers the full spectrum of 
control, rehabilitation and intelligence capabilities across both prison and probation”. 
As part of this Programme, a “Joint Counter Terrorism Prison and Probation 
Hub” was created in around August 2020. Its core  function  is  to  co-ordinate 
“quicker  and  better  information  and  intelligence  exchange  between  operational 
partners”. The National Tactical Management Command was set up within the 
Joint Extremism Unit (“JEXU”) and is now co-ordinating the allocation of all 
high-risk  terrorist  offenders  across  the  prison  estate.  The  Counter  Terrorism 
Assessment  and  Rehabilitation  Centre  (“CT-ARC”)  was  established  in 
response to the diverse and changing nature of terrorist offending or threat. It 
commenced full operations in September 2022 and has specialist staff drawn 
from psychology, probation, research and quality assurance backgrounds. The 

 
 
 National Security Division (“NSD”) of the Probation Service was established in 
late 2020, with a specialist multi-disciplinary workforce trained to monitor and 
manage terrorist offenders, serious organised criminals, and CPPC offenders.  

17.  Assistant  Chief  Constable  (“ACC”)  Metcalfe  set  out  extensively  in  his 
statement the many and various steps taken by CTPSE to address the failures 
in  intelligence  sharing  and  assessing  risk,  to  which  I  have  made  partial 
reference below.  

18.  The  failure  to  handle  the  intelligence  concerning  KS  appropriately  had  a 
notable impact on the Prevent, Pathfinder and MAPPA processes. In my view 
none  of  them  contributed  positively  to  the  handling  of  KS.  This  was 
particularly the case given there was a wholesale failure to revisit and review 
the overall intelligence and risk assessment picture in light of newly acquired 
information. Indeed, each assessment took the most recent piece of intelligence 
as  the  starting  point,  with  the  risk  that  prior  intelligence  (e.g.  the  Ansar  al-
Sharia/Omar  Brooks  link)  was  overlooked  and  was  not  reflected  in  the 
assessment of the current threat. ACC Metcalfe expressed the clear view that 
when  revisiting  intelligence,  the  officer  needed  not  just  to  consider  the  last 
report  but  the  totality  of  the  material,  to  check  the  assumptions  previously 
made. As a consequence, ACC Metcalfe accepted that the failings in this context 
fell far below the standard necessary.  

19.  Addressing Prevent first, the four referrals to Prevent were closed, certainly in 
part, because of the widely accepted assessment that any risk posed by KS was 
based  on  his  mental  health  difficulties,  as  opposed  to  an  adherence  to  an 
extremist ideology. It is critical for the  future that these bodies are provided 
with  a  properly  considered  assessment  of  the  risk  posed  by  the  individual 
under  consideration.  There  was  a  persistent  lack  of  understanding  of  KS’s 
sometimes inconsistent but nonetheless persistent extremist/terrorist mindset 
which regrettably permeated the approach to him throughout the period under 
review. DS Stanley accepted that if he had known the full background, such as 
KS’s  association  with  Ansar  al-Sharia  and  Omar  Brooks,  this  might  have 
changed his assessment, leading to the conclusion that KS was vulnerable to 
being drawn into terrorism. 

20.  The  evidence  additionally  revealed  notable  failures  of  training,  supervision 
and  selection in this  important  work by Prevent. There was some  very poor 
work and a marked failure in supervision and support. The overall standard of 
Prevent’s dealings with KS’s case was not acceptable (see, for instance, [145] 
and [146] of my Factual Findings).  

 
 
 
 
 
 21.  As  set  out  in  my  Factual  Findings  at  [145],  it  has  been  indicated  that 
improvements have been made since 2020 in a number of areas, which have 
included the Home Office establishing a new joint enhanced casework team. 
This team is to work alongside a wide range of “partners”, including the police, 
local  authorities  and  the  immigration  system,  and  its  role,  inter  alia,  is  to 
identify and manage individuals displaying early indications of extremist and 
radicalised behaviour or a vulnerability to such influences. It is acknowledged 
there is still work to be done, for instance “around the interface between the Prevent 
system and the mental health system”. Mr Stewart, the Director of Prevent, agreed 
that mental health should never be a reason not to make a Prevent referral. I 
am encouraged that these issues are seemingly being substantively addressed 
but it is vital that the Secretary of State for the Home Department ensures there 
is  effective  monitoring  as  to  whether  the  steps  that  have  been  taken  have 
rectified the particular deficiencies I have identified.  

22.  Turning next to MAPPA, meetings concerning KS occurred on 3 August 2018, 
7 September 2018 and 4 October 2019. They were characterised by i) the failure 
on 3 August 2018 properly to characterise KS (he was designated as Category 
3 Level 1 which does not exist), along with misconceptions about mental health 
provision (e.g. OHFT Pathfinder) and an absence of CMHT staff to correct those 
misconceptions; ii) the failure on the part of BHFT, at least from 7 September 
2018, to send appropriate attendees (leading, inter alia, to an overly restrictive 
focus  on  PTSD,  ignoring  KS’s  personality  disorder);  iii)  the  absence  of  other 
stakeholders who could have assisted, such as representatives of immigration 
enforcement  and  CTPSE;  iv)  the  incorrect  decision  on  7  September  2018  to 
remove  KS  from  MAPPA  (there  were  outstanding  actions);  v)  a  wholly 
deficient report sent by Mr Dunford (based, in turn, on comments by DS Spiers) 
for consideration at the meeting on 4 October 2019, in which it was stated that 
there was no evidence to suggest that KS’s crimes were rooted within terrorism 
or  extremism;  vi)  a  failure  to  obtain  relevant  prisons  intelligence  and  vii)  a 
failure  to  bring  KS  back  to  MAPPA  before  his  release  in  2020.  It  was  also 
suggested  that  the  main  priority  was  addressing  and  stabilising  his  mental 
health  issues  by  treating  his  PTSD,  given  this  was  the  trigger  for  his  violent 
outbursts. 

23.  There  have  been  changes  instituted  since  the  attack  in  Forbury  Gardens.  By 
way of example, HMPPS Psychology Service Group “support” is now located 
within the Probation Service NSD with a senior forensic psychologist located 
in each NSD unit. NSD psychologists provide psychological consultations on 
cases with Specialist Probation Practitioners and Senior Operational Leads in 
the probation regions. NSD psychologists play a role within MAPPA meetings, 
in the sense of assessing risk and contributing to case plans by assisting with 
risk management,  including  release planning.  As ACC Metcalfe additionally 

 
 
 explained in his comprehensive statement and evidence, a significant number 
of  changes  have  been  made  by  Thames  Valley  Police  (“TVP”)  since  these 
events. Simply by way of example, notification flags are now used by TVP on 
the  Niche  Record  Management  system  to  provide  MAPPA  with  relevant 
information; there is now a defined process at the end of MAPPA supervision; 
information  sharing  has  been  improved  between  TVP  and  probation  along 
with training for officers within CTPSE. There have been many other detailed 
changes which I have not set out herein, albeit I note steps have also been taken 
to address the fact that KS's MAPPA status was not obvious to police officers 
and  staff,  and  there  have  been  adjustments  to  improve  the  quality  of 
investigations.  

24. Notwithstanding this extensive evidence, given the extent and seriousness of
the lack of adequate assistance provided to KS as regards his serious mental
health difficulties, I remain concerned that a risk of future fatalities still subsists
in relation to which action should be taken. MAPPA is the responsibility of the
Prison and Probation Service and the police, and I encourage the Secretary of
State  for  Justice  and  the  Chief  Constable  of  Thames  Valley  Police  to  work
together to ensure that the deficiencies identified above concerning procedure,
information sharing and the approach to intelligence and risk assessments have
been comprehensively  addressed,  in light of the suggested improvements to
the  system.  If  the  true  position  in  relation  to  KS  had  been  appreciated,  I
anticipate MAPPA would have been active in attempting to secure long term
psychological intervention and further measures would have been in place in
relation to the management of KS’s risk (e.g. advanced steps in relation to recall
before his release from prison in June 2020).  In my view it is important that
adequate  monitoring  is  in  place  to  ensure  that  the  inadequacies  I  have
identified have been rectified.

25. Finally,  addressing  Pathfinder,  although  KS’s  case  was  discussed  at
Community and Prison Pathfinder meetings, at no stage was he provided with
any substantive assistance as a result. One feature that struck me as being of
particular  importance  is  a  well-timed  final  review  of  a  prisoner  such  as  KS,
sufficiently in advance of their release. As a former Pathfinder “nominal” (but
in  “dormant  review”  on  the  suggested  basis  that  the  risk  he  posed  had  been
explored and addressed to the extent possible), KS should have been reassessed
prior to his release in June 2020 but this did not happen.

26. It follows that the involvement of Pathfinder did little or nothing to mitigate
the  real  risk  that  KS  posed.  Most  particularly,  Pathfinder  did  not  assist  in
securing  the  assistance  he  needed  for  his  serious  psychiatric  problems.  As
explained in summary below, the steps that have been taken since the events

 in  Forbury  Gardens  are,  at  least  to  an  extent,  reassuring  but  they  tend  to 
underscore the deficiencies that existed at the time of KS’s attack.  

27.  At [204] of my Factual Findings I rehearsed the improvements that have been 
made since these attacks in Forbury Gardens. For instance, in March 2021 the 
Dormant Review Standard Operating Procedure was introduced. In June 2022, 
HMPPS  and  NHS  England  issued  Guidance  for  healthcare  staff  entitled 
“Increasing  the  Engagement  of  Prison  Integrated  Healthcare  Teams  in Pathfinder”. 
This  was  a  result  of  JEXU’s  Review  of  the  Mental  Health  Provision  in  the 
context  of  national  security  after  the  Forbury  Gardens  incident.  The  review 
identified  the  need  to  improve  the  engagement  of  healthcare  teams  in 
Pathfinder. In October 2022, the Pathfinder Guidance Framework Operational 
Delivery Guidance was issued alongside the Operational Delivery Guidance. 
Since  2020,  certain  changes  have  been  made  to  assist  the  counterterrorism 
“sector”  (particularly  Pathfinder),  with  the  identification  and  ongoing 
management of foreign national offenders. For instance, within Thames Valley 
additional  training  in  the  Pathfinder  processes  is  now  being  provided.  The 
Prison Prevent Lead for HMP Bullingdon is involved in training prison staff on 
the  Pathfinder  processes,  which  includes  Prison  Prevent  Leads  dealing  with 
new  intelligence  concerns  for  an  individual  on  dormant  review,  given  they 
attend Pathfinder meetings. 

28.  Mr Pilkington (the then Regional Counter-Terrorism Lead for Thames Valley) 
and Ms Rogers testified that there is a new Pathfinder IT process, including “a 
single platform”, for custody and community practitioners to use. It is said that 
this is now much clearer in relation  to non-TACT  offenders who historically 
have  posed  a  risk  and  might  require  a  further  conversation  at  a  Prison 
Pathfinder meeting before release. It additionally provides alerts as to when a 
prisoner’s release date has changed to allow planning for release to start as soon 
as  possible.  Mr  McAndrew,  the  Head  of  the  Security  Department  at  HMP 
Bullingdon,  similarly  testified  that  processes  are now in place to ensure that 
this always happens. 

29.  Notwithstanding this evidence, given the extent and seriousness of the lack of 
adequate  assistance  provided  to  KS  as  regards  his  serious  mental  health 
difficulties,  I  remain  concerned  that  a  risk  of  future  fatalities  still  subsists  in 
relation to which action should be taken. Most particularly in  my  view, it  is 
critical  that  Community  and  Prison  Pathfinder  meetings  are  furnished  with 
reliable and properly informed intelligence and risk assessments, and that they 
react  appropriately  to  the  information  provided.  Pathfinder  is  a  Prison  and 
Probation Service led, multi-agency process. It is, therefore, the responsibility 
of  the  Secretary  of  State  for  Justice.  I  strongly  recommend  that  proper 

 
 
 
 monitoring  takes  place  in  this  context  to  ensure  the  effectiveness  of  the 
Pathfinder system. 

30. My overall conclusions as regards Prevent, Pathfinder and MAPPA were set

out at [228] of my Factual Findings:

“I am of the view that neither Prevent nor Pathfinder nor MAPPA provided 
any intervention of utility during the material stages of this case – when KS 
was in the community and when he was in prison – to address the threat 
he posed on account of the combination of serious mental health problems 
and the extremist risk that he posed, a risk that was, or should have been, 
well  known.  Indeed,  the  particular  danger  he  presented  was  repeatedly 
emphasised, including that he could become a “lone actor”, but there was 
no effective intervention. I agree with Ms Rixon that MAPPA, and, I would 
add,  Pathfinder  should  have  been  active  in  securing  mental  health 
assistance in the community and in prison. The steps that have been taken 
subsequent  to  the  events  in  Forbury  Gardens  in  June  2020  and  other 
terrorist-related  events  are  perhaps  a  measure  of  the  substantive 
acknowledgement of the failings in this regard. Mr Vince recognised the 
prison  and  probation  services  were  working  as  separate  entities  in  this 
context  –  the  system  was  “under-resourced  (and)  non-integrated”.  The 
difficulties included the fact that the community offender manager (e.g. Ms 
Rixon)  had  no  direct  access  to  the  prison  MIRs,  albeit  some  of  this 
information might reach her indirectly. As of June 2020, there were about 
90  records  concerning  KS  on  the  system  involving  reports  of  his 
involvement  with  drugs,  violence,  weapons,  extremism,  bad  behaviour 
and self-harm.”  

31. It is self-evident that this is a wholly unsatisfactory state of affairs, common to

the three agencies.

The failure to provide KS adequate mental healthcare in the community and
to provide KS adequate secondary mental healthcare in prison (the Secretary
of State for Justice, Berkshire Healthcare NHS Foundation Trust and
Midlands Partnership University NHS Foundation Trust)

32. In my Factual Findings, I determined that BHFT failed to provide KS adequate
mental healthcare in the community and MPFT failed to provide KS adequate
secondary mental healthcare in prison.

33. It  is  to  be  stressed  that  consistent  case-management/care  coordination  and
long-term  therapy  provided  a  real  potential  to  reduce  KS’s  aggressivity,
impulsivity and substance abuse, along with his offending, between 2015 and

 2019  (albeit  the  impact  this  would  have  had  on  his  extremist  beliefs  is  more 
difficult to determine). There was a real risk that on his release from prison on 
5 June 2020 he would commit a violent offence, and this included the risk that 
he could kill someone, and I have concluded that it was at least possible that 
this risk could have  been avoided  if  KS’s  psychological difficulties had  been 
addressed over the long term, both in the community and in prison. 

34.  MPFT  correctly  decided  in  December  2016  that  psychology  sessions  were 
appropriate for KS on the basis that although the recovery process could take 
time, if he was persistent, patient and open to trying different approaches, it 
would  have  been  possible  to  identify  the  most  effective  treatment/skills  to 
enable him to "take back the control". Whilst recognising that for a brief period in 
February  2017  KS  wanted  to  concentrate  on  his  impending  release,  he  was 
never offered psychological intervention during his repeat periods in prison, 
partly  as  a  result  of  the  failure  to  restore  him  to  the  waiting  list  and  partly 
because of an unfounded assessment that he was unwilling to cooperate.  

35.  At [140] of my Factual Findings, I highlighted five particular failures by BHFT 

Community Mental Health Team (“CMHT”) that merit focus: 

i) 

There was a failure to recognise that the CMHT should play a treatment 
role in helping KS gain stabilisation, for instance by providing low level 
psychological assistance and coordination of the services necessary for 
treating his mental health and by formulating a medium to long term 
treatment  plan.  Instead,  he  was  referred  to  other  bodies  via  various 
suggested “Pathways”, all of which were unable to assist. This resulted 
in  KS  being  caught  in  a  “Catch  22”  dilemma  (viz.  as  a  result  of  his 
personality disorder and/or PTSD, he abused alcohol or drugs but this 
rendered him permanently ineligible for treatment). 

ii)  CMHT should have communicated with the relevant agencies in clear 
terms as to the extent or lack of care coordination they could provide, 
identifying  particularly  the  areas  where  there  needed  to  be  input  but 
CMHT did not have the ability to take on the particular role. 

iii)  To the extent  that KS’s needs were social  needs, most  particularly  his 
consumption  of  drugs  and  alcohol,  there  was  a  failure  by  CMHT  to 
communicate  adequately  with  the  other  relevant  agencies  the 
consequential limits of the treatment the Trust could provide. 

iv)  There  was  a  wholesale  failure  to  resolve  the  differences  between  the 
professionals that arose as to the approach that should be taken to KS, 
most vividly exemplified by the effective stand-off between Dr Ahmad 

 
 
 
 
 
 and  CMHT.  It  meant  that  there  was  no  senior  determination  by  a 
director,  the  Positive  Risk  Panel  or  via  some  other  mechanism  as  to 
whether  Dr  Ahmad’s  concerns  were  valid  and  whether  his 
recommendations should prevail. 

v) 

The  failure  to  accept  any  responsibility  for  KS  prior  to  coming  out  of 
prison because he had not been on the CMHT caseload when he went 
into custody. 

36.  These were, in my view, serious failings, but BHFT has helpfully set out the 
manifold  and  substantive  changes  that  have  been  implemented  since  these 
tragic  events.  There  have  been  substantial  changes  to  the  Care  Programme 
Approach and care coordination, which are now governed by the Community 
Mental Health Framework (“the Framework”). The Framework was published 
by NHS England in 2019 and its objectives are to develop new and integrated 
models of community mental health care. The Framework acknowledges that 
community mental health services needed transformational change in light of 
the  lack  of  alterations  to  the  model  over  30  years.  The  Framework  proposes 
moving  away  from  the  “siloed”,  “hard-to-reach”  services  towards  a  more 
integrated  model.  It  advocates  breaking  down  the  barriers  between  mental 
health  and  physical  health  and  between  health,  social  care,  voluntary, 
community  and  social  enterprise  organisations  and  local  communities 
(something the British Red Cross suggested had been missing). It encourages 
primary  and  secondary  care  to  deliver  integrated,  personalised,  place-based 
and well-coordinated care. 

37.  Critically in my view, in July 2021, NHS England indicated that everyone in 
need of mental healthcare should be allocated a named 'key worker'. BHFT has 
responded by publishing a programme named “One Team”. This encapsulates 
new  ways  of  approaching  care  in  order  for  GPs,  mental  health  teams,  local 
authorities, and other support organisations in the community to work more 
effectively together, ensuring that patients can receive the care they need in a 
timely  way  without  having  to  navigate  confusing  systems.  This  has  many 
elements, but it includes a named key worker.  

38.  In light of Mr Fraser’s evidence that the British Red Cross were not informed 
on  a  consistent  basis  via  MAPPA  meetings,  or  by  other  routes,  as  to  vital 
information concerning KS – perhaps most importantly the extremist risk he 
posed – in my view it is critical that information sharing, to the fullest possible 
extent permissible, should form a part of these new ways of working. This is 
vital for ensuring the individual is dealt with appropriately and increases the 
opportunities for protecting the organisation’s staff and the public.   

 
 
 
 
 39.  The previous model of teams of mental health professionals are to be replaced 
by  multi-agency  teams  with  a  particular  focus  on  ensuring  that  information 
about a patient is not lost or misunderstood. I have seen the status update for 
“One  Team”  dated  September  2023  and  this  tends  to  indicate  that 
transformational  change  is  underway.  As  applicable  to  the  present  case,  Dr 
Bonner,  on  behalf  of  BHFT,  has  accepted  that  in  KS’s  case  if  the  One  Team 
approach had been in place, there would have been clearer access routes into 
Mental Health care and less confusion for those such as KS’s Probation Officer 
when she attempted to refer into BHFT’s services. A “psychologically informed” 
key  worker,  either  from  BHFT  or  a  partner  agency  would  have  offered  him 
consistent  input,  if  he  was  willing  to  engage,  and  would  have  provided  the 
relevant agencies with a single point of contact. The assigned key worker will 
in future attend MAPPA meetings, along with the “core member”. 

40.  Of  considerable  importance  given  my  concerns  at  to  what  happened  in  the 
present case, those described as being in “community connector roles” are now 
well placed to help and encourage those in KS’s position to use, for instance, 
drug  and  alcohol  services.    The  new  approach,  furthermore,  to  those  with 
personality disorders provides for a flexible and more inclusive approach and 
is intended to capture those not yet in a position to engage in formal therapy. 
BHFT  is  committed  to  formulating  the  individual's  needs  early  on,  with  the 
assistance of any relevant outside agencies such as, in this case, the British Red 
Cross and the Probation Service. 

41.  Significantly, when tensions emerge as to whether someone should receive the 
support, for instance, of secondary mental health services, there is now a layer 
of decision-making to resolve any conflict. 

42.  There  is  essential  agreement  between  Dr  Bonner  on  behalf  of  BHFT  and 
Professor  Blackwood  that  the  use  of  concepts  such  as  “signposting”  and 
“pathways” had become unhelpful in the ways they were used, along with the 
too-frequent exclusionary response: “not for our team!”. This understanding is 
critical, in my view, given the difficulties organisations such as the British Red 
Cross observed along, no doubt,  with others navigating the  complex mental 
health  system  in  Reading  and  Berkshire  via  the  common  point  of  entry,  the 
CMHT, the Crisis team, Berkshire Traumatic Stress Service, the adult social care 
mental  health  team  and  the  local  GP  services.  The  roles  and  responsibilities 
were often unclear, and it was difficult to engage with even when referrals were 
made.  

43.  In the future, I have been assured the needs of those with EUPD and symptoms 
of PTSD, together with a long offending history, who have previously not been 
open to secondary mental health care at the time of going into prison will be 

 
 
 
 
 assessed, and appropriate assistance will be provided in anticipation of their 
release.  

44.  These changes, along with the others I have not described, appear promising, 
with  one  particular  reservation.  The  changes  reveal  an  appropriate 
understanding of, and a focus on, all the main matters that went profoundly 
awry  in  the  present  case.  I  strongly  recommend  that  the  Trust  regularly 
assesses whether those who pose a major risk akin to that of KS will hereafter 
be  included  rather  than  excluded  by  medium  and  long-term  mental  health 
services,  and  that,  within  the  inevitable  limits  of  finite  resources,  they  will 
receive the appropriate support, treatment and coordinated care they need. My 
single  main  reservation  is  that  Mr  Fraser  on  behalf  of  the  British  Red  Cross 
indicated that he had not noticed any significant change in terms of access to 
mental  health  care,  particularly  via  care  coordinators,  since  these  changes 
started to be applied. This makes it all the more important that the effectiveness 
of these services is rigorously and regularly assessed. 

45.  As  regards  MPFT,  they  no  longer  provide  secondary  healthcare  services  in 
HMP Bullingdon and Huntercombe. Therefore, this Report (in this context) is 
directed  primarily  at  OHFT;  nonetheless  it  will  be  provided  to  MPFT  who 
continue to provide services in other prison establishments. I have also directed 
that it is sent to NHS England so that appropriate national action in this area 
can be considered. Pippa Williams, service manager for OHFT, was specifically 
asked to address the “tracking” of prisoners as they moved between prisons. It 
became  clear  during  the  evidence  that  there  were  wider  issues  with  the 
shortage  of  staff  in  prisons  to  provide  psychological  treatment  and  with  the 
processes to prioritise and track prisoners on the waiting list to ensure that they 
were  seen  (regardless  of  whether  they  transferred  or  not).  As  a  result,  and 
without criticism of her statement, Ms Williams does not address the current 
position on the level of psychological services at HMP Bullingdon and HMP 
Huntercombe  against  the  background  of  the  previous  failure  by  MPFT  to 
provide these to KS at any stage whilst he was in prison. I suggest that for a 
prisoner demonstrating KS’s risk factors, he should have been offered, within 
the  limits  of  available  resources,  the  opportunity  to  participate  in  long  term 
psychology  sessions.  I  request  that  this  issue  is  addressed  by  OHFT  in  its 
response to this Report, in order to prevent future deaths.  

The Failures that did not Contribute to the Deaths 

46.  There  were  other  failures  which  did  not  contribute  to  the  three  deaths  but 
which  I  consider  had  the  potential  to  do  so  in  the  future.  These  have  been 
explained in extenso in my Factual Findings. I have set these out in summary 
form below. 

 
 
 Immigration Status/Deportation Issues (the Secretary of State for the Home 
Department) 

47.  There were a series of failures by Home Office immigration teams in managing 
KS’s immigration status. By way of two examples only, first, KS’s visa expired 
on 28 September 2012, meaning that from that date he was an “over-stayer” and 
was unlawfully in this country. There was no system in place to identify this 
fact. Second, on 10 July 2015 the Criminal Casework Intake & Triage Team, in 
determining  that  KS  did  not  meet  the  threshold  for  deportation,  relied  on 
guidance which was out of date by two versions. Had the correct policy been 
followed,  deportation  would  have  been  considered  on  the  grounds  that 
removal was conducive to the public good (albeit this step at that point in time 
was infeasible). 

48.  As I observed in my Factual Findings, the Home Office needs to reflect with 
considerable care on the training requirements of the relevant staff along with 
the sufficiency of the systems and procedures that are in place, to ensure that 
correct decisions are made in this context on an accurate basis. The handling of 
KS’s case fell, at times, far below the standard that could properly be described 
as  acceptable.  However,  these  failures,  while  serious,  did  not  contribute 
towards the attack. 

49.  Given  the  multiple  failures  by  the  Home  Office  which  Ms  Sutton  candidly 

accepted, various changes have been introduced:  

i) 

ii) 

The Home Office re-introduced exit checks in April 2015. The vast 
majority (but not all) of passengers leaving the country on scheduled 
commercial international air, sea and rail routes now go through exit 
checks. The data collected is said to be providing the police and 
security services with information to help track the movements of 
known criminals and terrorists. With the introduction of e-gates and 
biometric chips in passports, the Home Office now has/will have a 
better audit trail now of those entering and leaving the country.  

In 2018 Immigration Enforcement started development of a new 
workflow system to better manage and understand the cases they 
hold. In July 2022 a dataset of all those of interest to Immigration 
Enforcement was introduced called Define (the Population of 
Interest). This system triages cases from the Population of Interest 
for immigration action. 

iii)  Without going into detail, since KS’s application for Assisted 

Voluntary Return in September 2013 there have been, I am told, 

 
 
 
 
 significant changes to this programme which is now called the 
Voluntary Returns Scheme. 

iv) A workflow tool now sends cases at the appropriate time to the

correct team. This includes when a person becomes a failed asylum
seeker, and the case is automatically routed to Returns Preparation
(now National Returns Progression Command) to consider the next
steps.

v) A Detention Gatekeeper was introduced in June 2016 to assess the
suitability of all those referred for detention in this context,
independently of those making the referral, bringing consistency
and scrutiny to prevent potentially vulnerable individuals being
detained.

50. On the limited evidence I have received, I am not able to assess whether these
and other changes have been effective. I am told that had the issues in KS’s case
arisen  now,  his  case  would  be  assessed  by  National  Returns  Progression
Command and the relevant safeguarding referrals would have been made. It is
reassuring that steps are being taken, including with training and the creation
of an independent casework unit, but the extent of the failures revealed in KS’s
case  have  profoundly  called  into  question  the  ability  of  the  systems  then  in
place and the personnel operating them to handle the problem of those illegally
in  this  country  in  an  effective  way.  The  Secretary  of  State  for  the  Home
Department should direct that the new systems are adequately monitored and
evaluated  to  ensure  that  the  problems  that  emerged  in  KS’s  case  have  been
properly addressed.

Discontinuance of Proceedings (the Secretary of State for the Home
Department)

51. On 29 May 2020, KS’s impending prosecutions for being drunk and disorderly,
criminal  damage  and  assault  on  an  emergency  worker  were  discontinued,
following  a  misapprehension  by  the  Home  Office  that  KS  was  soon  to  be
deported. This was a clear failure by the Home Office as the decision was made
on  a  plainly  erroneous  understanding  of  KS’s  immigration  status  and
removability. This mistake had no impact on what occurred on 20 June 2020,
but in different circumstances it could have been of real significance. Changes
have been instituted, most particularly that such a request is only made to the
Crown  Prosecution Service  when written approval has been provided by  an
assistant director (Grade 7). However, given the potential gravity of this error,
it  is  my  view  that  the  Secretary  of  State  for  the  Home  Department  should
provide reassurance that systems are in place which will ensure that the right

 information  is  before  the  relevant  Grade  7,  who  in  turn  has  received 
appropriate training to assess the prospects of removal in circumstances such 
as KS. 

Operation Plato and the FIM (the Chief Constable of Thames Valley Police) 

Operation Plato 

52. The police handling of the scene in the immediate aftermath of the attack was
admirable. I noted in my Factual Findings (at [318]) that both with the benefit
of hindsight and based on the information available to Acting Detective Chief
Inspector  (“ACI”)  Turner  at  the  time,  it  was  the  correct  decision  not  to  call
Operation  Plato.  However,  when  Operation  Plato  was  eventually  called  by
Inspector Summers at 19.48 this step was unjustified given the information then
available. I note that under arrangements since instituted, Operation Plato can
only be declared by a Tactical Firearms Commander (who in practice is likely
to be the FIM). I was struck during the evidence by the range of advantages
and  disadvantages  in  declaring  Operation  Plato,  and  it  is  of  especial
significance that this step can inhibit access by the emergency services to the
scene of an incident at which individuals may be seriously injured or dying. It
is of the upmost importance, therefore, that the Tactical Firearms Commanders
have the appropriate skills and training to make properly informed decisions
in this context, given their potential impact.

The FIM

53. I  was  notably  troubled  during  the  evidence  by  the  potential  for  serious
mistakes  to  have  occurred  because  the  FIM  was  at  times,  in  a  real  sense,
overwhelmed by the demands of the role. I note from the evidence that many
of  the  problems  that  emerged  on  20  June  2020  have  been  addressed  for  the
benefit of future major incidents. Indeed, subsequent to the events in Forbury
Gardens a new Contact Management Platform (“CMP”) has replaced the UNIX
log  and  this  has  seemingly  resolved  the  problem  of  simultaneous  messages
being recorded by way of intersecting text. ACI Turner expressed the view that
the  CMP  is  “as  good  as  it  can  (presently)  get”,  in  that  there  is  now  a  more
efficient display of information and the messages appear as they were sent, in
the  sense  that  the  lines  of  text  are  not  intermingled  with  other  messages  or
information.  Two assistants are now assigned to the FIM, along with a third
individual who “walks the floor” to deliver messages. The number of FIMs in
the force has increased from 8 to 10.

54. I am particularly concerned, however, that ACI Turner remains uncertain as to
whether the new arrangements will sufficiently filter the incoming information,
thereby leaving the FIM free to focus on the significant issues which require his
or her attention. He considers that these new arrangements should be “stress

 tested” rather than evaluating them by way of desk or paper exercises. It is my 
strong  view  that  due  regard  should  be  paid  by  the  Chief  Constable  to  ACI 
Turner’s  thoughtfully  expressed  concerns.  He  was  an  extremely  impressive 
witness.  As  a  consequence,  I  recommend  that  the  relevant  systems  and  the 
available technology are given careful scrutiny and that a rigorous and reliable 
process of evaluation of the new arrangements is put in place. 

55. As I have set out above, these are matters for the Chief Constable of Thames

Valley Police.

Action that should be taken 

56. In my opinion action should be taken to prevent future deaths. I have made
some observations above on areas where action may be taken. However, it is
the  duty  of  those  receiving  this  Report  to  identify  the  action  that  should  be
taken to address the risk of future fatalities about which I have raised concern.
I believe that the respective individuals and organisations have the power to
take such action.

Your Response 

57. You are under a duty to respond to this report within 56 days of the date of this
report, namely by 15 July 2024. I, the Judge Coroner, may extend the period.

58. 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 

59. I  have  sent  a  copy  of  my  report  to  the  Chief  Coroner  and  to  the  following

Interested Persons:

The families of James Furlong, Joseph Ritchie-Bennett and David Wails
Reading Borough Council
South Central Ambulance Service
Practice Plus Group
Change Grow Live
British Red Cross
Reading Refugee Support Group

a)
b)
c)
d)
e)
f)
g)
h) MTC Novo
i)

The Crown Prosecution Service

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

and all interested persons who in my opinion should receive it.

61. I may also send a copy of your response to any other person who I believe may

find it useful or of interest.

62. The  Chief  Coroner  may  publish  either  or  both  in  a  complete  or  redacted  or
summary  form.  He  may  send  a  copy  of  this  report  to  any  person  who  he
believes may find it useful or of interest.

63. You may make representations to me, the Judge Coroner, at the time of your

response, about the release or the publication of your response.

DATED:        

20 May 2024

SIGNED:

Responses

7 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 Berkshire Healthcare (PDF)
8th July 2024 

Sir Adrian Fulford PC 
His Majesty's Judge Coroner 

Dear Sir 

London House 
London Road 
Bracknell 
Berkshire 
RG12 2UT 

Inquests  arising  from  the  deaths  in  the  Forbury  Gardens  terror  attack  of  20  June  2020;  James 
Furlong, Joseph Ritchie-Bennett and David Wails 

Regulation 28 Response – Berkshire Healthcare NHS Foundation Trust 

I  write  on  behalf  of  Berkshire  Healthcare  NHS  Foundation  Trust  ("BHFT")  further  to  the  above  inquests 
which took place between 15 January 2024 and 23 February 2024, and the Factual Findings delivered on 
26 April 2024. I have set out below BHFT's response to the Regulation 28 Report dated 20 May 2024. 

Introduction  

BHFT acknowledges the Findings and Conclusions of the Inquests and has carefully reflected upon any 
failings or areas of concern that were highlighted. BHFT is grateful that Sir Adrian noted in his Regulation 
28 report the promising changes made by our organisation since the events in July 2020. BHFT shares the 
view that it is of utmost importance that the effectiveness of the services and those changes are rigorously 
and regularly assessed. 

As described by 
 in the written and oral evidence on behalf of the Trust, there has been a 
wholesale change in the framework for delivery of community mental health services and necessarily this is 
an evolutionary process. I wanted to therefore provide an update on the matters relevant to BHFT's services 
since  February  2024  which  demonstrate  that  BHFT  continues  to  drive  forward  and  monitor  these 
improvements.  

As an initial comment, the actions described herein are included in the BHFT audit programme where a 
review of progress on key topics is audited by an externally commissioned partner. 

One Team / Care Coordination / Communication with other agencies  

BHFT  have  continued  the  development  of  the  One  Team  model  as  described  in  February  and  helpfully 
summarised in the Regulation 28 report. This is an ongoing and gradual roll out of associated changes to 
service  delivery.  There are monthly team  updates and  a  number  of  engagement  events  that  have taken 
place with BHFT staff, external stakeholders (such as local authorities in Berkshire, Primary Care Networks, 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 Voluntary, Community and Social Enterprise (VCSE) events, and local communities (including service users 
and carers)) to socialise the changes and take feedback from interested parties to influence the approach 
we are taking.  The changes noted in the Regulation 28 evidence remain a clear focus and evaluating the 
impact of service changes will be measured over time.   

The One Team model is being implemented in stages and the new One Assessment and multidisciplinary 
team post assessment place-based meetings (MDT) will be implemented with a gradual transition starting 
on July 8th 2024 with full roll out in August 2024. The One Assessment has been developed in response to 
feedback relating to referrals bouncing between services and was noted in the KS case where there were 
referrals between CPE, CRHTT, BTSS, CMHT, with no clear plan at times.  The One Assessment is carried 
out by the local team. This is a full mental health assessment which captures all the details any team/ service 
may need to know. The assessment is available for all teams to access to prevent the patient from having 
to retell their story to each person they interact with.  

This central assessment will provide the basis, and each time it’s revisited, up-to-date information can be 
added. The post assessment review will have a range of professionals from Health, Adult Social Care and 
increasingly our (VCSE) sector and Lived Experience Practitioners (LExP) colleagues to help staff identify 
the most suitable interventions to address the assessed need.  All mental health teams within a locality will 
work jointly for people in their area so the patient won't feel like they are bouncing between the teams. This 
puts the patient at the centre and the professionals come to them rather than the other way around.  This 
could include how to support with stabilisation prior to any structured psychological intervention being able 
to commence.  

For example, the PFD evidence described how Elmore Community Services had been commissioned by 
BHFT  to  provide  community  support  (non-mental  health  treatment)  for adult residents  in  Berkshire,  with 
significant and/or enduring complex mental health needs, often associated with a diagnosis of personality 
disorder.  The post assessment review would formalise a plan to engage with Elmore, potentially supported 
by a community connector. 

Since February the Peer Support Network (LExPs) has been established and this would be an additional 
support that could help to engage the individual with short term stabilisation working towards a longer-term 
plan around more formal treatment interventions (e.g. trauma therapy). 

The MDT will identify a named worker when agreeing individual plans for those referred into services. The 
named worker will be assigned to anyone who is opened to services and receiving treatment, and a named 
worker  will  be  assigned  to  people  awaiting  treatment  held  on  waiting  lists.  A  workstream  dedicated  to 
defining the elements of the named worker role is established and the named key worker role will be formally 
rolled out in September 2024. As set out in the national guidance, there will be a named key worker for all 
service  users  open  to  BHFT  services  with  a  multidisciplinary  team  approach  at  Place  (i.e.  geographical 
locality) taking overall responsibility for coordinating care - this will be integrated with social care and VCSE 
and an example is offered above.  

There will be a streamlined, holistic, personalised care and support plan, co-produced between the service 
user and the named key worker and regularly reviewed. A new risk form went live on 15 June 2024, and 
this is a more streamlined record of risk assessment that is easier to navigate for all clinicians involved.  

 
 
 
 
 
 
 
 
 More focus within this assessment has been given to risk to others.  Alongside this more contemporary risk 
assessment is a new care plan format which will complement the risk assessment and is due to be launched 
in July 2024. 

The MDT described above will agree a clear formulation which will help inform the care plan, as well as 
identify the best person to lead on the plan of care using the named key worker approach.  Where mental 
health services are not indicated, a clear rationale will be communicated to referrers and any other relevant 
parties.    Risk  training  has  been  reviewed  and  a  new  programme  of  risk  training  has  started  which  will 
encapsulate elements discussed within this response and case studies based on real clinical cases will help 
to inform this training. 

The direction of the changes will ensure that people referred back into services are considered in a timely 
manner  and  that  would  include  the  MDT  decision  around  CMHT  input.  Our  mental  health  services  are 
moving away from the potential for a 'catch 22' dilemma as described in the Regulation 28 report, rather 
they will use the resources available to them to help support stabilisation, working closely with partners such 
as drug and alcohol services to maximise opportunities to support people to reach the stability required to 
engage in more formal therapies.  

These  changes  offer  more  robust  communications  with  other  organisations  such  as  sharing  plans  for 
patients  that  are  offered  care  coordination  as  well  as  a  clear  rationale  where  CMHT  decline  care 
coordination. Multi-agency and multi-disciplinary forums will ensure information is not lost or misunderstood 
and holistic, trauma informed care plans are collaboratively created. This mechanism will also ensure needs 
are being met by the most appropriate service and expectations are realistic and clearly communicated.   

In addition, BHFT Drug and Alcohol Lead chairs a COMAD (Co-occurring mental health, alcohol and drug) 
forum  which  is  a  cross  agency  group  and  includes  all  drug  and  alcohol  service  providers  from  the  six 
localities in Berkshire alongside mental health services, including CMHTs.  This forum has a shared learning 
focus, provides opportunity to discuss particular cases, and has helped to facilitate a shared understanding 
of each other’s services and which services are, or are not, involved in a particular individual's care.  

Escalation of differences between professionals 

An escalation Standard Operating Procedure was produced for the Judge Coroner at the  Inquests. Since 
the Inquests, escalation processes have been further aligned with the new One Team model.  The MDT 
described above will enable shared decision making and where agreement cannot be reached this will be 
escalated to Heads of Service.  An enhanced MDT can be arranged to support this process.  On the rare 
occasion that the Head of Service decision and enhanced MDT is challenged, this will be escalated to the 
Clinical Director who will make the final decision regarding the plan.  In addition to the Positive Risk Panel 
referred to in the inquest proceedings, an additional ‘Harm to Others’ MDT risk panel is being established.  

This is in recognition of the increasing awareness of vulnerable individuals who may not fit neatly into a 
forensic  pathway  but  carry  a  level  of  risk.    This  panel  will  be  made  up  of  clinicians  with  experience  of 
managing people with a risk of harming others and can offer expertise to inform care planning for this group.  
The Harm to Others MDT Risk Panel will be effective from July 2024. 

 
 
 
 
 
 
 
 
 
 
 BHFT Mental Health Service Dashboard 

A Mental Health Service Dashboard will monitor impacts of the changes described through One Team in 
addition to existing national and internal processes, such as waiting list monitoring.  A method of flagging 
cases that are referred into BHFT on more than three occasions over a year on the RIO system is being 
explored.    These  processes  will  allow  Place  level  managers  and  performance  managers  to  see  what  is 
working and what isn't to allow increased focus on any gaps.   The new One Assessment means that CPE 
will  manage  any  urgent  responses  if  needed  or  short  term need  and  those  put  through  for  a  Place  one 
assessment (routine) will now be subject to a collaborative MDT discussion straight after the  assessment 
clinic  (or within 1 working day) where rather than bounce around services to consider at another allocation 
meeting for teams, there will be representatives from all disciplines who can make a decision on that day, 
as described above. This should support an appropriate offer of something being agreed and avoiding the 
potential for exclusion. A monthly schedule of reviews has been designed to monitor impacts more broadly.  
Any  risks  that  may  emerge  will  be  managed  through  existing  processes  escalating  through  Heads  of 
Service, to Director, to Executive if necessary. 

The Service User Network 

The Service User Network (SUN) has been reviewed and data from 2020 to June 2024 indicates that there 
has been a 20.3% reduction in appointments with the crisis team, a 21.2% reduction in appointments at 
emergency departments, and a reduction of inpatient admission by 60.1% for this particular patient group. 
This suggests that the SUN model is effective and a more helpful approach to working with people who 
experience some of the personality difficulties and distress that KS experienced when he touched BHFT 
services. 

Nurse Consultant Network 

Our Nurse Consultant Network has expanded, and this has allowed for an enhanced focus on supporting 
our  teams  to  improve  clinical  effectiveness  across  our  inpatient  and  community  services.  The  evidence 
presented at the Inquests described a pilot project between Probation and BHFT using Nurse Consultants 
as a conduit to offer a layer of decision-making where conflict arises. This project has now been evaluated. 
Recommendations have been made to Probation and BHFT are building upon the learning that has come 
from the Pilot.  The Nurse Consultants will continue to offer this additional support to Probation colleagues, 
and  the  learning  sessions  delivered  by  the  Nurse  Consultants  to  Probation  will  continue  twice  yearly.  
Internally, BHFT sessions have been reviewed to reflect the findings of the project alongside the learning 
from these Inquests. Twice yearly ‘harm to others’ sessions will continue to facilitate ongoing learning and 
refresh  for  our  staff,  alongside  shorter  bespoke  sessions  for  individual  teams.    The  feedback  from  the 
Probation and BHFT sessions has been positive and has helped both to gain a better understanding of each 
other’s  ways  of  working.  The  increased  escalation  processes  that  have  come  about  following  the  early 

release scheme described below will also supplement these processes. 

 
 
 
 
 
 
 
 
 
 
 
 
 Reconnect Service & ECSL  

Our Reconnect service has seen increasing numbers of service users over time and are playing a valuable 
role  in  bridging  the  gap  between  leaving  prison  and  accessing  the  best  community  support  to  meet  the 
needs of vulnerable people. Reconnect offers the bridge between prison, probation and health, and we have 
good evidence of those workers playing a key role in engaging prisoners prior to leaving prison, or soon 
after,  with  community  services that  best  support  their  needs.    For  example,  supporting  people  to  attend 
housing appointments or drug and alcohol appointments. We have noted below the additional challenges 
that early release may bring alongside mitigations agreed with Probation colleagues.  BHFT will be closely 
monitoring impacts and escalating concerns locally and nationally as they arise. 

It should be noted that the End of Custody Supervised License (ECSL) and Probation reset which has been 
implemented  since  the  Inquest  proceedings,  has  been  an  additional  driver  to  increase  scrutiny  of 
communications  regarding  people  released  from  prison  with  mental  health  vulnerabilities.    BHFT  are 
engaged locally and nationally as the impact of these changes evolve. While these changes are not directly 
related to this case, it has provided an opportunity to double down the focus on inter-agency communication. 
To this end BHFT are working closely with Probation and Prison colleagues to establish additional escalation 
processes for this client group.  A weekly multi-agency forum, chaired by Probation and attended by a range 
of partners including drug and alcohol providers and VCSE, has allowed for concerns to be raised in a timely 
way and share examples for learning across organisations.   Probation colleagues have been responsive to 
working closely with us and agree shared escalation processes.  

'Harm to Others' Steering Group  

A  'Harm  to  Others'  Steering  Group  has  been  set  up  internally  within  BHFT  to  focus  specifically  on  this 
agenda and will supplement the work that was shared in PFD evidence presented at the inquest. Objectives 
of the steering group in include –  

i) 
ii) 
iii) 

iv) 
v) 

To agree areas of priority related to the harm to others agenda;  
To identify key data sources to identify gaps and measure progress; 
To agree any workstreams that need to support the work of this group (e.g. early release, 
probation pilot work, MAPPA processes/standard work); 
To oversee the progress and outputs of workstreams; and 
To ensure effective communication to relevant stakeholders, internally and externally. 

A quarterly oversight group has also been set up with senior Probation and Prison colleagues to continue 
this  focus  and  allow  for  shared  decision  making,  shared  learning  and  consider  together  risks  across 
organisations.  

Strategic Planning  

A broader piece of work, led by our Director of Specialist Mental Health Services, has reviewed data from a 
range of sources more recently to help inform strategic planning.  This review has identified that there is a 

 
 
 
 
 
 
 
 
 
 
 
 
 cohort of men in Berkshire (predominantly Slough and Reading) who are affected by multiple inequalities 
(lack  of  stable  housing,  higher  levels  of  deprivation,  diagnosed  serious  mental  illness)  who  also  have 
overlaps  with  the  criminal  justice  system  and  increased  detention  under  the  Mental  Health  Act.    A  case 
study has been developed by our Criminal Justice Liaison & Diversion (CJLD) service to highlight how early 
intervention can improve these health outcomes at an earlier stage, supporting engagement with  support 
services, and improving life outcomes.  This work will be built upon and conversations with other partners 
(e.g. the Police) to consider this particular cohort in terms of future early intervention work. 

Entry / navigation between services 

In addition  to  the  community  connector  roles  described in the  Regulation 28  evidence,  we  now have an 
additional  resource  in  our  Common  Point  of  Entry  (CPE)  by  way  of  mental  health  Care  Navigator  roles.  
These  workers  help  people to  navigate the  complex variety  of  support  on offer  within  the  community for 
people with mental health vulnerability.   

The role of these practitioners is to support individuals that have been referred to mental health services, to 
access  VCSE  and  external  partner  agencies  where  they  may  be  best  placed  to  support  an  individual’s 

primary presenting problems or where there might not be an appropriate treatment pathway within BHFT. 
This includes access to services such as Drug and Alcohol support, debt advice and housing support. Where 
an individual requires more intensive support than the navigators can offer, they will bridge the individual 
into appropriate local services such as Berkshire Mind, Wokingham CAB project, drug and alcohol services, 
or the East Berkshire wellbeing service. This role has expanded within CPE and there are now 4 full time 
navigators. The support offer is also increasing with the Trust introducing direct access to non-clinical CBT 
programmes such as sleep, money worries and stress modules. This means the navigators can provide 
direct access to individuals using silver cloud which is a platform providing online CBT modules. Work is 
also  underway  to  develop  a  trust  wide  service  directory  and  social  prescribing  software  that  will  mean 
clinicians across Berkshire will more easily be able to refer individuals to VSCE and partner agencies to 
support  their  psychosocial  or  low  level  psychological  and engagement  needs.  The  care  navigators  have 
supported over 500 people to access support since they started. That is primarily with just 2 of them as 
another 2 have just recently joined us.  As a core role in CPE the navigators can escalate cases directly to 
clinicians where there are concerns of risk or escalating mental health needs.  

A Peer Support Network is now established which aims to offer support to vulnerable people from others 
who have lived experience of mental health problems.  The service is led by a team of Lived Experience 
Practitioners (LExPs). LExPs use their own lived experience of mental distress, alongside their training and 
professional experience of supporting others, to help service users achieve their personal recovery goals. 
All LExPs receive ongoing training and supervision to make sure that they are confident and competent in 
their role.  

In addition, the Let’s Connect service has also been established in Berkshire and is hosted by BHFT.  Let’s 

Connect is a social network to support the wellbeing of citizens over the age of 18 by connecting with each 
other, with organisations and services and with the many opportunities in our community. Those who join 
the network will bring their own strengths as well as gaining from the support of others, based on their own 
personal choices. 

 
 
 
 
 
 
 
 
 Transition between community / custody 

Where individuals move between the community and custody, there will be greater proactive engagement 
with  Prison  and  Probation  colleagues  both  principally  and  on  a  case-by-case  basis.    Where  someone 
receives a short sentence, it would be important to maintain CMHT input and involvement in planning for 
post  release.  For  more  lengthy  sentences  requiring  ongoing  mental  health  input  in  custody,  they  will 
transition  from  community  (e.g.  CMHT)  to  Prison  Mental  Health  Services.  In  such  situations,  the named 
worker in the community will ensure that a handover takes place with prison colleagues. The Reconnect 
roles, as described above, will allow for easier transition back into CMHT's on release if required. Where 
CMHT input is not indicated, a clear rationale will be shared between relevant parties and our teams will 
support other organisations, such as probation, to understand the rationale and help them to navigate other 
more appropriate services if necessary. Clarity around responsibilities will be made explicit for all cases.  

In addition, an option to include an automatic flag for people that have been referred into services over three 
times in a year is being explored with our RIO (electronic records) team.  This would be an additional way 
to flag a review of these cases.  Where these cases are flagged, an additional review of the case could be 
undertaken by Head of Service/MDT to ensure that all options have been fully explored. 

Information sharing 

BHFT recognises that we play a key role in sharing communications particularly around risk.  While we are 
not responsible for the organisation of MAPPA meetings, we are committed to supporting these processes, 
ensuring that the right people attend the meetings and that we continue to have named representatives from 
each CMHT within BHFT. This attendance includes contributing to discussions/providing advice to MAPPA 
case discussions for those that may not be under CMHT.  In addition, those named workers will act in a 
liaison  role for  inpatients  and CRHTT.    CRHTT and inpatient teams  are less likely  to be  in a  position  to 
attend MAPPA, particularly at short notice, and CMHT representatives are best placed to communicate into 
and out of MAPPA where inpatient or CRHTT may have been involved in a case. We are active participants 
in  a  range  of  mental  health  collaboratives  where  other  partners,  including  VCSE,  people  with  lived 
experience, and carers, can escalate concerns, working together to inform strategy and direction, and agree 
priorities across Berkshire.  

Within BHFT our Mental Health Transformation Board is chaired by our Director of Transformation and our 
Director of Strategic Planning oversees our partnership work.  A recent VCSE workshop had 81 attendees 
to consider a shared vision of co-production.  A commitment to regular meetings and a forum which will 
supplement existing collaboratives has been made. 

We are disappointed that 
on behalf of the British Red Cross did not feel that progress had been 
made regarding the impact of changes that are in progress, and we acknowledged in our evidence that it is 
early days in terms of transformational changes that will take place over a period of time.  We have reached 
out to 
 to try and get a better understanding of the particular concerns of British Red Cross and 
hope  that  will  help  inform  the  broader  range  of  ongoing  work  that  we  are  undertaking  with  our  VCSE 
partners. To date he has not responded to an initial approach.   BHFT Director of Strategic Planning has 
advised that British Red Cross were included as a member in the BHFT VCSE task and finish group that 

 
 
 
 
 
 
 
 
 
 ran throughout 23/24 with oversight of the development of the BHFT VCSE strategy.  She reports that they 
engaged in the first few meetings and then dropped out of attending.  They would have continued to receive 
papers  and  would  have  been  invited  to  attend  the  above  VCSE  conference  however  we  do  not  have  a 
record of them attending the conference.  We will continue to reach out to British Red Cross as part of our 
wider VCSE engagement described above.  

The  Regulation  28  evidence  outlined  BHFT  input  into  MAPPA  processes  as  well  as  monitoring  of  key 
performance  indicators  which  includes  CMHT  attendance.    An  escalation  process  is  in  place  where  any 
concerns around MAPPA attendance can be raised up to Director level.  For example, a recent case was 
escalated  where  it  was not  clear  that  the  named  worker  would  be  attending  a  MAPPA  meeting.    It  was 
established that the worker had the meeting in his calendar and was intending to attend the meeting.  This 
example suggests that escalation processes are working effectively. 

Summary  

BHFT takes the matters raised throughout the proceedings, the Judge Coroner's Findings and Regulation 
28  report  extremely  seriously  and  is  continuously  working  to  improve  its  practice  to  provide  the  highest 
possible standard of care. Representatives from Berkshire Healthcare were present in court throughout the 
inquest to ensure that the learning from this matter was captured understood and disseminated. 

The substantive changes and introduction of new services aim to promote the inclusive nature of mental 
health  assistance  in  Berkshire  and  seek  to  avoid  the  'not  for  our  team'  exclusionary  response  perhaps 
illustrated in KS's case. Such offerings are to enable service users such as KS to build up better community 
links and support, which in turn may help to improve mental health stability to be in a position to be able to 
engage in the therapies relevant to addressing underlying difficulties and mitigating potential risks.   

I hope that this response provides some measure of reassurance to HM Judge Coroner and the families of 
James Furlong, Joseph Ritchie-Bennett and David Wails. 

Yours sincerely 

Chief Executive
Response from Midlands Partnership NHS (PDF)
Trust Headquarters 
St George's Hospital 
Corporation Street 
Stafford 
ST16 3SR 

www.mpft.nhs.uk 

18 July 2024 

Dear Sir Adrian,  

Re: Regulation 28 Report to Prevent Future Death arising from the inquest into the deaths at Forbury 
Gardens June 2020   

Further to your correspondence dated 20th May 2024 please find a summary below of the actions being 
taken by Midlands Partnership NHS Foundation Trust (“MPFT”), and specifically the Health in Justice Services 
department, to address the concerns that you identified regarding   secondary mental health care during the 
periods that Mr Saadallah was in custody at HMP Bullingdon and HMP Huntercombe between 2016-2020.  

Responses to the points raised by Judge Fulford  

• 

It was identified that there was a ‘(F)ailure by MPFT to take steps to retain Mr Saadallah on the 
waiting list for psychological treatment or restore him to that waiting list, in order to provide him with 
adequate psychological treatment’  

Following the tragic deaths in Forbury Gardens MPFT undertook an internal review; the report 
summarising the outcome of this internal review was disclosed to the inquest and formed part of the 
evidence bundle.  The internal review identified the need to address psychological care pathways 
and the management of psychology waiting lists.  

Action was taken to refresh the psychology pathway, including updating referral criteria. There has 
been a further piece of work across the Prisons we work in to standardise practice in regard to 
psychological care pathways which is due to be completed by the end of August 2024.  

MPFT have existing guidance for all clinicians as to the process to be followed when an individual 
who is receiving treatment from the Trust whilst in Prison is transferred to another establishment. 
This stipulates that a handover must be provided to the receiving team which details the current 
plan of care and identified risks.  

• 

It was identified that ‘prisoners demonstrating Mr Saadallah’s risk factors should have opportunity to 
participate in long term psychology sessions’  

Together we are making life better 
for our communities 

 
 
 
 
 
 
  
  
 
   
 
 
 
 
  
 
 All individuals currently referred to Mental Health Services within MPFT Health in Justice Services 
receive a face-to-face assessment in order to identify immediate needs, risk and their 
appropriateness to be taken onto caseload. This is a holistic assessment which is designed to assist 
with the identification of need and allocation to the most appropriate clinician to take forward 
comprehensive assessment, risk management, care planning and delivery of interventions. Following 
assessment, complex cases are discussed in a weekly Multi-Disciplinary Team meeting to agree the 
appropriate plan of care.   

If a specific Psychological assessment is indicated this will be conducted and this assessment will 
consider all information and an agreed formulation and potential plan will be developed which will 
be shared with all involved parties. 

• 

It was identified that ‘there was a shortage of staff in prisons to undertake psychological treatment’  

We wholeheartedly agree that there would be a myriad of benefits to increasing the psychological 
workforce in prisons and in community services. We regularly review the skill mix of our prison 
teams in order to ensure that, within the constraints of the funding available, we employ the right 
combination of staff to deliver effectively on all aspects of our contracts, including psychological 
work.   

MPFT have worked with NHS England to develop a pilot of the Mental Health & Wellbeing 
Practitioner (MHWP) role which is a new role within some Health in Justice services. This role is one 
of the newer psychological professions. MHWPs are trained to provide low intensity psychological 
interventions to people with severe and enduring mental health difficulties.  

Staff have access to an ongoing programme of training which supports our overall Psychological care 
of people in prisons. This includes learning about Cognitive Behavioural Therapy (CBT), Dialectic 
Behaviour Therapy (DBT), Trauma Informed care and working with co- occurring conditions.  

MPFT would welcome the opportunity to employ more psychological practitioners in prisons, 
however given the constraints of our current budgets this is not possible. Close partner relationships 
with individual establishments enable us to take an active part in Health Needs Assessments and, 
where indicated, to work with NHS England to develop business case submissions to request 
additional funding for psychological provision in addition to the actions already taken above.  

Kind regards. 

Yours sincerely, 

Chief Executive Officer 

Together we are making life better 
for our communities 

 
 
 
  
 
 
 
 
 
 
 
 
 Together we are making life better 
for our communities
Response from Ministry of Justice (PDF)
The Right Honourable 

Lord  Chancellor  &  Secretary 
of State for Justice 

The Right Honourable Sir Adrian Fulford PC KC 
HM Judge Coroner 
C/O TLT LLP 
20 Gresham Street 
London EC2V 7JE 

MoJ ref: 

3 September 2024 

Email only: 

Dear Sir Adrian, 

Introduction 

Thank you for your letter of 20 May 2024 sent to my predecessor as Lord Chancellor and 
Secretary  of  State  for  Justice  enclosing  your  Prevention  of  Future  Deaths  (PFD)  report.  
Please also accept my thanks for allowing the Ministry of Justice (MoJ) until 9 September 
2024 to provide our response. 

I take this opportunity to offer my sincere condolences to the families and friends of James 
Furlong,  Joseph  Ritchie-Bennett  and  David  Wails  who  were  tragically  killed  in  Forbury 
Gardens, Reading on 20 June 2020. I am grateful these findings have been brought to my 
attention. I am determined to do all I can to keep the public safe from terrorism and prevent 
similar attacks in the future.  

In your PFD report you identified significant shortcomings in several areas: 

A. the provision of adequate mental healthcare to 
the community; 

 (KS) in both custody and 

B. the assessment and sharing of information and intelligence;  

C. the risk assessment and management of KS through Pathfinder; and  

D. the risk assessment and management of KS through MAPPA.   

In the response that follows, the MoJ’s work to address shortcomings is set out sequentially 
in the same areas, though, as is to be expected, there is some overlap between the issues 
identified in these areas and our response. Supporting documents have been referenced in 
footnotes.  

,  the  Chief 
During  the  inquests  you  heard  PFD  evidence  from: 
,  Executive  Director  of  the  Security  Directorate  of  His 
Probation  Officer; 
Majesty’s Prison and Probation Service (HMPPS); and 
, Head of National 
Security Unit (East and South Central) HMPPS National Security Division (NSD).  It is not 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 intended that  this  response  will  repeat  their PFD  evidence  but  there  will  be  some  limited 
reiteration to provide necessary context. 

A. Mental Health Provision 

1.  Whilst the operational delivery of mental healthcare is for the relevant NHS  trusts, this 
case raises wider concerns about the continuity of healthcare provision between custody 
and  the  community,  the  treatment  and  management  of  offenders  with  personality 
disorders and the support afforded to probation practitioners in working with offenders 
with complex mental health and substance and personality issues.  

2.  Together  with  NHS  England,  the  MoJ  and  the  Government  are  firmly  committed  to 
improving the way health and justice services address the needs of people in prison and 
under  the  supervision  of  probation  services.  This  commitment  is  established  in  the 
National Partnership Agreement on Health and Social Care in England, published on 23 
February 2023 which sets out defined roles for all partners (Department of Health and 
Social Care (DHSC), HMPPS, MOJ, NHS England and the UK Health Security Agency) 
and core objectives for delivering better care.1 

3.  Following the attacks in Forbury Gardens, the Prime Minister at the time commissioned 
an internal Rapid Review of mental health services for people under HMPPS supervision. 
Providing  further  independent  scrutiny,  in  September  2021,  the  Justice  Select 
Committee  published  its  report  on  Mental  Health  in  Prisons  and  a  Joint  Thematic 
Inspection  report  on  these  themes  was  published  by  HM  Inspectorate  of  Probation 
shortly afterwards in November 2021.2 Taken together, these reports called for system-
wide changes. 

4.  The  MoJ,  HMPPS,  the  DHSC  and  NHS  England  have  worked  collaboratively to  drive 
improvements in the areas of concern identified across each of these reports, including: 
ensuring needs are identified early throughout the system; improving data collection and 
information-sharing  across  health  and  justice  agencies;  strengthening  learning  and 
development  for all  staff;  continuing  to  ensure  that  mental health  provision  meets  the 
needs  of  people  in  prison;  and  delivering  greater  continuity  of  care  throughout  the 
pathway and on release.  

5.  We set out key commitments and actions on these issues in our Action Plan, published 
on 4 March 2022 and updated on 27 March 2023.3 This included the following activity: 

i) 

Testing and evaluating a new model within Approved Premises (APs), enabled by 
£2.4  million  funding  over  three  years  up  to  2025.  This  provides  targeted, 
enhanced mental health support to high-risk prison leavers with the most complex 
needs, building a clear bridge into services in the community, as recommended 
in  the  Rapid  Review.  The  initial  formal  evaluation  review  will  be  available  in 
Autumn 2024. 

1 National Partnership Agreement for Health and Social Care (publishing.service.gov.uk) 
2 Mental Health in Prison (parliament.uk), Justice Select Committee, 2021. A joint thematic inspection of the 
criminal justice journey for individuals with mental health needs and disorders (justiceinspectorates.gov.uk), 
HM Inspectorate of Probation, 2021.  
3  An  updated  response  to:  A  Joint  Thematic  Inspection  of  the  Criminal  Justice  Journey  for  Individuals  with 
Mental Health Needs and Disorders, March 2023: Updated plan (publishing.service.gov.uk) 

2 

 
 
 
 
 
 
 
 ii)  Recruiting 47 Health and Justice Partnership Coordinators (HJPC) and 12 Health 
and Justice Partnership Managers (HJPM) roles. 46 HJPCs and 12 HJPMs have 
been  recruited  to  date  and  are  in  post  across  England  and  Wales.  The 
management of these roles sits with the Heads of Community Integration within 
probation. Their purpose is to strengthen the links between substance misuse and 
health services in prisons and the community to support access to treatment. This 
includes  working  through  the  Local  Combatting  Drugs  Partnerships,  to  ensure 
referrals  to  treatment,  consistent  information-sharing  and  the  shaping  of  local 
commissioning to meet the needs of offenders. They also work across probation 
regions  within  Probation  Delivery  units  to  support  and  upskill  probation 
practitioners.  

iii)  Building  confidence  in  information-sharing  through  the  establishment  of  a  joint 
NHS/HMPPS  Information  Sharing  Advisory  Group  (ISAG)  in  2021.  The  ISAG 
provides  guidance  and  advice  on  information-sharing  and  looks  ahead  to  new 
initiatives  and  projects  to  ensure  that  implications  for  information-sharing  are 
considered and issues are addressed. The ISAG has overseen the development 
of  two  guidance  products  for  operational  staff,  with  further  products  in 
development, including a Prison Managers Guide, Probation Guide and a series 
of themed learning bulletins.  

iv)  Developing an Adult Health, Care and Wellbeing Core Capabilities Framework to 
strengthen  learning  and  development  for  MoJ  staff,  working  with  Skills  for 
Justice.4  The  framework  will  describe  the  skills,  knowledge  and  behaviours 
required  for  those  working  with  vulnerable  individuals  in  custody,  detention 
environments or on probation to enable them to recognise individuals who have 
health,  care  and  wellbeing  needs,  identify  the  support that  is available  to  them 
and help them access it. The framework is on track to be published by the end of 
2024.  

6.  Beyond work set out in the Action Plan, we have gone further to strengthen the way we 

support people with mental health needs, including the following activity:  

i)  We have renewed grant funding to the Samaritans, providing total funding of just 
under £2 million between 2022 and 2025. This is primarily for the delivery of the 
Listener Scheme through which selected prisoners are trained to provide support 
to fellow prisoners in emotional distress.  

ii)  The NHS RECONNECT service was launched in some areas in 2019 to improve 
continuity  of  care  and  support  vulnerable  people  leaving  prison  to  access 
community services. It is the largest health and justice commitment in the NHS 
Long  Term  Plan,  with  £20m  of  funding  for  2023/24,  and  is  on  target  for  100% 
rollout across England by April 2025. RECONNECT provides release planning to 
offenders  with  an  identified  health  need  whilst  they  are  still  in  custody,  but 
approaching their release date, and then follows through with support for a period 
of  up  to  six  months  post-release.  The  new  Health  and  Justice  Partnership 

4 Established in 2002, Skills for Justice is the Sector Skills Council for the UK Justice, Community Safety, Fire 
and Rescue, Central and Local Government sectors. Skills for Justice is licensed by the UK Government and 
is a not-for-profit organisation and registered charity.  

3 

 
 
 
 
 
 
 
 Coordinators are working strategically with RECONNECT services to strengthen 
and develop collaborative working and referral pathways.  

iii)  NHS  England  have  also  committed  £3m  for  piloting  Enhanced  RECONNECT 
services  in  four  locations  in  England  during  2023/24.  Enhanced  RECONNECT 
supports offenders with complex needs who are identified as high risk of harm to 
the public to engage with and get the right treatment from community services for 
an extended period of up to a year after release. Offenders are also supported by 
expert care navigators working with health and  probation services. DHSC have 
commissioned the National Institute for Health and Care Research to conduct an 
evaluation of the four pilot sites which is due to end in October 2025, so that a 
decision  can  be  taken  as  to  a  national  rollout  of  Enhanced  RECONNECT.  I 
understand  that  more  information  on  this  is  provided  in  NHS  England’s  PFD 
Response.  

7.  In  December  2023,  NHS  England  and  HMPPS  published  a  refreshed  Offender 
Personality Disorder (OPD) Pathway Strategy for 2023 to 2028.5 The OPD Pathway is a 
set  of  psychologically  informed  services  operating  across  criminal  justice  and  health, 
underpinned  by  a  set  of  principles  and  quality  standards.  Using  evidence-based 
relational and environmental approaches, it aims to reduce risk associated with serious 
reoffending and improve mental health within a high-risk, high-harm cohort likely to meet 
the  clinical  threshold  for  a  diagnosis  of  ‘personality  disorder’.  The  refreshed  OPD 
Pathway  builds  on  the  work  done  in  the  past  decade  pursuant  to  the  original  OPD 
Pathway strategy which was launched in 2011 and then updated in 2015.  

“The  OPD  pathway  was  established  as  an  efficiency  change  program  to  recycle 
existing  resources  and  provide  an  innovative,  jointly  delivered  set  of  services  for 
those with the most complex needs within the criminal justice and health systems. 
This  vision  is  broadly  being  achieved;  however,  the  experience  of  OPD  pathway 
services  to  date,  reflected  through  the  ongoing  commissioning  cycle  and  wider 
feedback gathered during the strategic review, identifies that some highly complex 
individuals,  particularly  among  those  in  custodial  settings,  have difficulties  that  are 
not  yet  being  adequately  addressed.  This  impacts  on  the  public  purse,  poses  an 
ongoing risk to public protection, and has implications for the health and wellbeing of 
those living and working in custodial and community settings. Gaps remain in service 
provision and there is more work to do to enable the vision of a holistic pathway.” 

“The OPD pathway adds significant expertise to the treatment and management of 
high-risk individuals with pervasive psychological difficulties in the criminal justice and 
health  systems.  Collaborative  partnerships,  along  with  effective  signposting  and  a 
commitment to developing coordinated approaches to care, will therefore continue to 
be essential to the success of the OPD pathway as it looks to consolidate its work 
over the next phase of delivery.” 

8.  The strategic ambitions identified in the refreshed strategy include the following which 

appear to be relevant to the issues that arose in the management of KS’s risk: 

A1. Responding to unmet complexity of need. Expand support for those in scope 
who  the  OPD  pathway  has  not  yet  reached,  helping  more  people  become  stable 
enough to progress, while seeking to extend OPD pathway approaches to working 
with complexity across the wider system. 

5 NHS England » The offender personality disorder (OPD) pathway: a joint strategy for 2023 to 2028 

4 

 
 
 
 
 
 
 A2: Pathway consistency and quality. Develop national pathway consistency and 
quality by consolidating existing service provision, addressing regional disparities and 
creating opportunities for progression. 

 A3. Enhancing identification, pathway planning, referrals and access. Improve 
access  to  OPD  pathway  services  across  the  country  by  raising  awareness  of 
services, so that staff, participants and external stakeholders can make well-informed 
decisions about sentence planning and pathway progression. 

A4.  Strengthening  transitional  support.  Develop  service  handovers  to  be 
consistently  managed  and  well  planned  at  times  of  transition  and  improve 
information-sharing  between  OPD  services,  and  with  service  participants  and 
external partners. 

A5. Supporting a whole system approach to complexity, risk and need. Develop 
the  pathway  to  become  more  outward  facing,  providing  consultancy  and  training 
beyond the OPD pathway and strengthening partnerships, to support a whole system 
response to the management of complexity, risk and need. 

9.  The Intensive Intervention and Risk Management Service (IIRMS) provision is part of the 
OPD Pathway. IIRMS expanded rapidly following an increase in funding from 2019.This 
was to ensure that it is available in every region which had not been the case previously. 
This  expansion  has  strengthened  the  way  we  support  prison  leavers  with  personality 
disorders. Local provision will be reviewed against the national IIRMS guidance to ensure 
that  the  service  offer  is  consistent.  This  process  will  provide  assurance  that  people 
subject to probation supervision receive a consistent service irrespective of where they 
live. This work will take place throughout the duration of the current strategy up to 2028. 

B. Information-sharing 

10. In your PFD report you noted that deficiencies in information-sharing between the various 
organisations  involved  in  the  risk  management of  KS  had  contributed  to the  failure to 
provide an adequate response to the risk posed by KS.  Information-sharing processes 
within the specific contexts of MAPPA and Pathfinder are set out in their own respective 
sections.  This  section  describes  the  changes  which  have  been  made  to  improve 
information-sharing between the prison service and the probation service. 

11. Since June 2020 there have been significant developments in the digital offering in both 
prisons and probation. There is greater automated information-sharing between the core 
systems  used  in  prisons  (NOMIS  and  DPS6)  and  NDelius.  All  Offender  Manager  Unit 
staff, including Prison Offender Managers (POMs), now have access to  the Probation 
Services’ electronic record system, NDelius, on a read-only basis.  

12. Manage POM Cases (MPC) is a digital service which sits on DPS and is used to manage 
the  allocation  and  the  responsibility  of  cases  to  POMs  during  an  individual’s  time  in 
custody and transition into the community. MPC determines all allocations in accordance 
with Offender Management in Custody (OMiC) policy. Once sentencing calculations are 
done by the prison, MPC automatically determines whether a case should be managed 
by the POM or Community Offender Manager (COM) responsible for the offender. MPC 

6 DPS (Digital Prison Services) is a suite of newer digital services being developed for use by prison staff and 
prisoners (specific services). 

5 

 
 
 
 
 
 
 
 then  transfers handover dates  onto  NDelius  meaning  both  POM and  COM  can  easily 
see this information.  

13. Contact entries made straight into NDelius will not transfer back onto MPC or DPS so 
there  remains  a  responsibility  for  practitioners  to  communicate  with  one  another 
regarding  key  progress  points  in  an  offender’s  sentence.  However,  other  useful 
information has been extracted from NDelius and made more visible in the screens that 
are used by MPC users in the Offender Management Unit (OMU) who are based in the 
prison. For example, MPC users can now see an individual’s MAPPA level and the last 
OASys (Offender Assessment System, a risk assessment tool used by Probation)  risk 
level on their screens, so they do not have to access NDelius or OASys to check this. 

14. A specific subset of  case notes written up by prison staff in NOMIS are transferred to 
NDelius  and  displayed  in  the  NDelius  contact  log.  This  automatic  transfer  occurs  for 
entries which relate to the following recorded activities, regardless of who has made the 
entry: 

Person released from institution. 
Person transferred. 
General observations. 
Alerts active. 
Alerts inactive. 
All OMiC events. 
All OMiC OPD events 

i) 
ii) 
iii) 
iv) 
v) 
vi) 
vii) 
viii)  Keyworking events. 

15. Other new services are being developed to share information across systems to make 
sure that HMPPS staff have the information that they need. Whilst some of these services 
are still in development, several have been launched since 2020, including in particular 
the Pathfinder IT service which supports the management of terrorism-related nominals 
across the prison and probation services. Pathfinder IT is addressed in more detail at 
paragraphs 30 to 32 below. 

16. A project to replace the Mercury Intelligence System with the Intelligence Management 
Service (IMS) is underway, with the roll-out of the new live system planned for Spring 
2025. IMS will enable, for the first time, some probation staff to have direct access to 
intelligence  held  by  the  prisons.  This  is  in  contrast  to  Mercury,  which,  for  contractual 
reasons, only prison staff were permitted to use. Probation staff access to IMS will be for 
POMs  in  the  first  instance,  though  the  potential  for  probation  staff  working  in  the 
community  to  have  access  will  also  be  explored.  In  addition,  IMS  is  a  modern  digital 
system which is much faster than Mercury and has a user interface that is much more 
intuitive as it is based on the Government Digital Service standards originally devised for 
public-facing services. We will be able to deliver improvements to IMS more quickly and 
easily and ensure that we provide the right data at the right time to enable robust decision 
making. 

17. Information from IMS will be disseminated to HMPPS staff  and partner agencies more 
effectively. Probation staff will be able to identify intelligence that is useful to inform risk 
assessment and management and formally request that it is released to them from the 
prison’s security department. Sharing information with partners will be the same as it is 
now with Mercury but with more controls and audits in place to monitor it. 

6 

 
 
 
 
 
 18. IMS will assist with the dissemination of information from the POM to the COM. In the 
initial release of IMS, it will be the responsibility of the POM to identify the material of use 
to the COM and request it from the prison’s security department. The security department 
will provide a usable form of words to be passed to the COM with the form of words being 
dictated by the sensitivity of the intelligence. Ultimately, it is intended that COMs will have 
direct access to IMS. However, given the size of the HMPPS workforce this is a large 
undertaking which will require time to achieve.  

19.  Whilst  the  Mercury  system  is  still  operational,  there  is  also  a  plan  to  publish  specific 
guidance to ensure that all prison staff are aware that Mercury Intelligence Records need 
to be linked to a nominal’s record, even if the subject is no longer in custody. This will be 
published  by  Autumn  2024.  The  working  assumption  is  that  intelligence  on  former 
prisoners is linked to their records, and it is the case that the vast majority of information 
is  correctly  linked.  However,  this  requirement  is  not  formally  stated  anywhere  within 
HMPPS training or processes. This new guidance will address this lacuna.    

20. The  Assessment  Care  in  Custody  Teamwork  (ACCT)7  process  is  still  largely  paper-
based  although  the  fact  that  an  offender  is  being  monitored  on  an  ACCT  should  be 
recorded in NOMIS, which will automatically send an alert through onto NDelius.  

C. Pathfinder 

21. In  your  PFD  report  you  identified  numerous  shortcomings  in  the  operation  and 
effectiveness of the Pathfinder process in KS’s case, including failures to arrange a pre-
release  Pathfinder review,  failures  by  Pathfinder to  secure  the engagement  of  Mental 
Health services and failures to ensure that a complete intelligence picture was available 
to  those  who  were  tasked  with  the  management  of  KS’s  risk  within  the  prison  and 
probation services and amongst policing partners. The MoJ recognises that KS’s case 
raises  concerns  that  systemic  problems  within  Pathfinder  could  present  risks  that 
offenders’ extremism risks are not identified and responded to appropriately.  

22. This  response  on  Pathfinder  seeks  to  detail  the  steps  MoJ  has  taken  to  address  the 
failures in the Pathfinder process which  you  identified; the further changes which the 
MoJ  has  identified  and    implemented  to  improve  the  Pathfinder  process;  to  provide 
assurances to you  that improvements are being effectively implemented by MoJ; and 
future changes which the MoJ is intending to make as part of a process of continuous 
ongoing improvement to Pathfinder.   

Failure to arrange a pre-release Pathfinder Meeting  

23. In  March  2021,  the  Dormant  Review  Standard  Operating  Procedure  (DR  SOP)  was 
introduced. This provided detailed guidance as to when and how to complete a review 
of a dormant Pathfinder case, and who should do it. Previously, staff were reliant on the 
very  limited  detail  about  the  Dormant  Review  requirement  that  was  included  in  the 
Managing  Extremism  Policy  Framework  (Annex  C  of  Managing  Extremism  Amongst 
Offenders in Custody and Annex L of Managing Extremism Amongst Offenders in the 
Community).  The  Dormant  Review  process  ensures  that  those  who  have  previously 

7 ACCT is the Prison Service system for identifying and managing prisoners at risk of suicide and self-harm. 

7 

 
 
 
 
 
 
 
 presented a terrorist risk are reviewed before a significant change of circumstances, such 
as release from custody.  

24. All Pathfinder nominals, save for those previously assessed and managed at the lowest 
risk level, must be classified as ‘Dormant Review’ when the decision is taken to remove 
their  ‘active’  Pathfinder  status.  Following  the  Dormant  Review  process  set  out  below, 
nominals  will  be  classed  as  dormant  where  they  have  been  assessed  as  no  longer 
presenting with an engagement or susceptibility to terrorism. The Prison Prevent Lead 
(PPL) or CT Specialist Probation Practitioner (CTSPP) is notified, via the Pathfinder IT 
system, of the prisoner’s release date and will seek information regarding  the prisoner 
three months prior to release. Once this notification of an impending release has been 
received, there will be a review which commences with alerting all the agencies engaged 
with Pathfinder of the prisoner’s imminent release. If all are satisfied that the threat and 
risk are mitigated, then the prisoner will be made ‘dormant’, and this will be recorded on 
the  Pathfinder  system.  (Once  a  case  has  been  made  ‘dormant’  in  custody  prior  to 
release, the offender will only be discussed at Community Pathfinder meetings if new 
concerns arise that lead to a new referral being made to Community Pathfinder.)  If not 
made  ‘dormant’,  then  they  are  made  ‘active’  and  will  transfer  into  the  community  as 
‘active’ on Pathfinder. This process ensures that this is a multi-agency decision. 

25. Dormant  Review  cases  are  now  discussed  at  every  Prison  Pathfinder  meeting  as  a 
standing item on the Pathfinder meeting agenda. Any Pathfinder prisoners classified as 
‘Dormant Review’ who either (1) have been a Dormant Review case for 3 months or (2) 
are approaching a significant change in their custodial status will be considered by  the 
Pathfinder committee and made an ‘active’ case again if any risk is identified.  

26. The  change  to  the  Pathfinder  Dormant  Review  process  described  under  scenario  (1) 
above, ensures that cases which have remained ‘dormant’ are still regularly discussed 
and  assessed  for  any  changes  in  risk.  Therefore,  all  Dormant  Review  cases  are 
considered  on  an  ongoing  basis.  In  respect  of  scenario  (2)  above,  a  case  will  be 
discussed in more depth if the offender that is subject to Dormant Review is approaching 
a significant milestone, such as if the offender is due for parole, to be released or re-
categorised.  If  no  risks  are  identified  at  the  last  Prison  Pathfinder  meeting  prior  to 
release, an offender’s case will be made ‘dormant’.  

27. A member of the Probation Counter-Terrorism Team (PCTT) will not always attend the 
Prison Pathfinder Dormant Review meeting in person.  However, the PCTT are always 
consulted  for  their  view  on  the  Dormant  Review  cases  by  the  Regional  Counter-
Terrorism Team (RCTT) and any view they have will be fed in via a PCTT representative 
or the PPL on behalf of the network. 

28. Two  dedicated  audits have taken  place  since  the  introduction of  the  Dormant  Review 
SOP to test compliance and the quality of application. In the period 1 March 2021 to 31 
August 2022, 455 cases were screened. It was found that only 10 had a requirement for 
a review in the last three months of custody to decide whether to make them ‘active’ or 
‘dormant’. Six of these cases were dealt with in accordance with the SOP, three followed 
the  SOP  for  the  most  part  with  minor  areas  of  non-compliance  with  the  procedure 
identified  and  one  case  had  been  overlooked  for  technical  reasons  which  were 
subsequently addressed. In the period 1 March 2024 to 25 June 2024, 572 cases were 
screened. 23 cases had a requirement for a review in the last three months of custody 
to  decide  whether  the  cases  should  be  made  ‘active’  or  ‘dormant’.  20  of  these  cases 
were reviewed in accordance with the requirements of the SOP. For the remaining three, 
the  process  was  followed  in  the  sense  that  the  risks  of  the  individuals  were  properly 

8 

 
 
 
 
 
 reviewed, however the three cases were each made ‘dormant’ at the three month point 
rather than the last Pathfinder meeting prior to release.   

29. In  order  to  provide  assurances  that  the  expectations  of  Pathfinder  in  the  pre-release 
period  are  maintained  to  a  high  standard,  it  is  now  the  responsibility  of  the  Regional 
Pathfinder  Chairs  to  assure  themselves  that  the  appropriate  identification  and 
management  of  Dormant  Review  cases  is  undertaken  in  the  pre-release  window. 
Assurance processes to ensure that standards are maintained in the  Dormant Review 
process  will  also  be  included  as  part  of  the  updated  community  and  local  custody 
Pathfinder SOPs. 

Pathfinder IT 

30. The Dormant Review process is supported by Pathfinder IT (PFIT), which was created 
in 2020. PFIT is a centralised case management system which enables professionals 
across  HMPPS  staff  to  manage  the  CT  Cohort,  which  encompasses  Terrorist  and 
Terrorist-Risk nominals across both the Custody and Community arena. It is accessible 
by Joint Extremism Unit (JEXU) Prison and Probation networks, JEXU HQ and various 
external partners (e.g. Joint Counter Terrorism Prisons and Probation Hub (JCTPPH) & 
CT Policing). 

31. PFIT draws live data from primary frontline case management systems across HMPPS, 
specifically  NDelius  and  NOMIS.  This  is to ensure that  key dates, e.g.  the  Calculated 
Release Date, are accurate and aligned consistently with wider HMPPS data platforms. 
Should a frontline prison or probation team amend any of these dates e.g. if a sentence 
is  recalculated,  the  amended  date  will  automatically  be  updated  within  PFIT  once  a 
change has been recorded within either NOMIS or  NDelius. This means that in cases 
such as KS’s, the PPL and the Regional Counter Terrorism Lead would automatically 
become aware from the data recorded via PFIT that a prisoner’s release was impending, 
either when a prisoner enters the final three months of their sentence or if their release 
date  is brought  forwards.  This enables  the  RCTT to  ensure  that  the  Dormant  Review 
case is considered ahead of the prisoner’s early release to ensure risk is fully assessed. 
This flag prompts further discussion and consideration at Prison Pathfinder meetings. 

32. Furthermore, PFIT has an integrated notification feature which ensures that an alert is 
automatically generated and sent to relevant users (determined as those users who have 
the  nominal listed  within  their  caseload) to make them aware  of any  change  to a  key 
date.  

New Pathfinder tools – guidance and assurance   

33. In  October  2022,  the  Pathfinder  Guidance  Framework  (PGF)  Operational  Delivery 
Guidance  was  issued.  The  PGF  assesses  susceptibility  to  extremism  and  what  is 
required by way of interventions to address this. It has been designed to help document, 
structure  and  support  decision  making  and  the  case  management  of  terrorist  risk 
offenders. It should be completed alongside the Controls and Interventions Matrix (CIM). 
It should be used by CT Specialists to guide consideration of the extremism concerns 
and to help direct further actions and interventions. It was issued to trained assessors, 
supervisors and staff involved in the management of terrorist risk cases across HMPPS. 
The PGF is an assessment tool which must be completed for all terrorist risk offenders 
who  have  been  made  an  active  case  of  concern  at  Pathfinder.  It  must  be  completed 
within 8 weeks of the offender being made ‘active’. It informs CT specialists in providing 
advice and guidance to those outside the CT network. The PGF  assessment can only 

9 

 
 
 
 
 
 be  completed  by  staff  who  have  attended  a  full  day  training  event  and  successfully 
completed  the  post  training  assessment.  The  PGF  replaced  the  Extremism  Risk 
Screening (ERS) which was used in KS’s case.  

34. The  Counter Terrorism  Quality  Development  Tools (CTQDTs),  first launched  in  2021, 
have been developed in collaboration with the Improvement Support Group (ISG), OMiC 
Team,  Probation  Service  NSD  and  JEXU’s  Prison  and  Probation  CT  Operational 
Network of specialist staff. The Tools, deployed by regional CT Leads, have two main 
aims:  

a.  Quality  Development  –  Providing  Regional  CT  Teams  and  Prison  &  Probation 
Practitioners with feedback to improve quality standards in operational delivery, 
including sharing notable positive practice.  

b.  First Line Assurance – Providing Regional CT Leads with a mechanism to ensure 
that CT delivery meets a minimum standard and address any shortfalls which are 
identified. This allows Regional CT Leads to build capability and confidence within 
their respective teams.  

Additionally, national themes and trends are analysed, and presented to senior leaders 
to address any wider or systemic gaps (e.g., where guidance may need updating). 

 Failures by Pathfinder to secure mental health engagement  

35. Terrorist and terrorist-risk offenders commonly have multiple, complex needs and face 
difficulties  in  accessing  services.  As  healthcare  does not allocate treatment  based  on 
national  security  risk  but  rather  on  clinical  need,  terrorist  and  terrorist-risk  offenders 
cannot  be  auto-prioritised.  To  date,  HMPPS  has  limited  levers  to  use  to  secure 
healthcare attendance at Pathfinder and escalate issues where mental health services 
are lacking.  

36. In  June  2022,  HMPPS  and  NHS  England  jointly  issued  guidance  for  healthcare  staff 
entitled  “Increasing  the  Engagement  of  Prison  Integrated  Healthcare  Teams  in 
Pathfinder”. This followed a JEXU Review of mental health provision after the attacks in 
Forbury  Gardens.  The  review  identified  the  need  to  improve  the  engagement  of 
healthcare  teams  in  Pathfinder.  The  aim  of  this  guidance  has  been  to  encourage 
healthcare  attendance  at  case  management  meetings  in  custody,  and  in  turn  to  help 
ensure  mental  health  information  is  being  used  to  inform  the  assessment  and 
management of terrorist risk. Follow-up surveys on the implementation of this guidance 
show  an  increase  of  21  percentage  points  in  healthcare’s  attendance  at  Pathfinder 
meetings from 59% in the first half of 2022 to 80% in the second half of 2022. The surveys 
were  not  mandatory  but  provide  an  indicative  representation.  HMPPS  have  been 
informed by the NHS that they have sent out this guidance to all mental health providers 
involved in Pathfinder.    

37. To better support probation teams in navigating the barriers that operational staff  face 
when  accessing  mental  health  and  complex  needs  services  for  this  offender  cohort, 
JEXU has issued further guidance setting out the different national provisions available 
for  terrorist  and  terrorist-risk  individuals  with  suspected  or  diagnosed  mental  health 
needs once they have been released into the community. This includes information on 
services  that  can  support  in  cases  where  offenders  do  not  engage  with  the  services 
available to them. JEXU has also developed specific training on the interaction between 
mental health issues and terrorism risk, with the purpose of supporting those involved in 

10 

 
 
 
 
 
 case management (specifically Pathfinder partners) and healthcare colleagues in better 
understanding this interaction. 

38. As part of ongoing continuous improvement activities, HMPPS is taking steps to improve 
how  Pathfinder  is  delivered  including  re-defining  the  roles  and  responsibilities  of 
Pathfinder partners. These include links that have been established between Pathfinder 
forums and the Counter Terrorism Clinical Consultancy Service (CTCCS) which replaced 
Vulnerability Support Hubs in April 2024. CTCCS are embedded multi-disciplinary mental 
health teams that work with individuals who are deemed susceptible to radicalisation and 
who also present as having mental health issues.  

Failures by Pathfinder concerning Information-sharing  

39. In April 2021, the JCTPPH, a new national body with co-located staff from CT Policing, 
HMPPS and MI5 became operational. The core function of the JCTPPH is co-ordinating 
quicker and better information and intelligence exchange between operational partners. 
The  JCTPPH  provides  a  range  of  new  capabilities  and  services  that  enable  more 
effective  management  of  individuals  of  national  security  concern  in  prison  or  under 
probation  supervision  in  the  community.  The  JCTPPH is focussed around  placing the 
right  intelligence,  appropriately  protected,  into  the  right  forums  to  ensure  the  most 
effective  risk  management  decisions  are  made.  Working  with  partners,  the  JCTPPH 
ensures  there  is  a  shared  understanding  of  who  poses  a  risk,  and  why,  to  enable 
management  of  these  individuals  through  multi-agency  partnerships  and  engagement 
with the appropriate statutory bodies and functions.  

40. Since  2020,  HMPPS  have  also  enhanced  our  ability  to  access  intelligence  and 
information from partners through improvements to regional Pathfinder, which provides 
a  multi-agency  working  environment  for HMPPS,  CT Policing  and  partners to  discuss 
cases,  make  decisions,  plan  releases  and  share  information  pertaining  to  CT  case 
management.  Pathfinder  meetings  are  held  regularly  and  there  is  a  requirement  for 
minutes to be taken and shared with partners to ensure decisions made are recorded 
and actions required are documented.   

Pathfinder conclusion  

41. As part of ongoing continuous improvement activities, HMPPS and partners are planning 
to make further improvements to Pathfinder. These reforms will build on the established 
foundations  of  multi-agency,  CT-specialist  case  management  processes  already 
operating  in  the  prison  and  probation  sector,  developing  these  further  to  improve  our 
ability  to  make  agile,  informed  decisions  around  CT  case  management,  by  creating 
timely, secure access to the right information and intelligence, at the right time, by the 
right people.  

42. Amongst  those  planned  improvements  are  the  following:  HMPPS  will  review  the 
thresholds for referring and adopting cases to Pathfinder and will review the appropriate 
risk  levels  for  each  threshold;  HMPPS  will  also  ensure  that  there  is  a  consistent  and 
aligned understanding of terrorist risk that is shared by Pathfinder partners; HMPPS will 
strengthen its ability to respond to risk by setting up a new National Pathfinder process, 
which  will  provide  senior  oversight  and  additional  assurance  on  case  management. 
National Pathfinder will, among other things, be a forum for escalating issues affecting 
case  management  or  risks  where  national  support  may  be  required,  as  well  as 
overseeing high risk cases.  

11 

 
 
 
 
 
 D. Multi-Agency Public Protection Arrangements (MAPPA) 

43. In  your  PFD  report  you  identified  numerous  shortcomings  in  the  operation  and 
effectiveness of MAPPA in KS’s case. Your report encouraged the MoJ and the Chief 
Constable of Thames Valley Police to work together to remedy these deficiencies. The 
problems you identified included the ineffectiveness of MAPPA in formulating a complete 
picture of the risk posed by KS and the corresponding failure of MAPPA to effectively 
disseminate  intelligence  between  organisations.  Your  report  noted  that  if  these 
intelligence  failures  had  not  taken  place,  it  was  possible  that  MAPPA  could  have 
upgraded  KS  to  ‘very high  risk’ and  designated  him  a  Critical  Public Protection  Case, 
resulting in his management at MAPPA Level 3. Such a change could have impacted 
KS’ licence conditions, the availability of Approved Premises and the speed of a recall of 
KS. Further, you identified the erroneous assignment of KS to a non-existent MAPPA 
risk level, errors in the information considered by MAPPA about available mental health 
treatment options, misconceptions in meetings about how KS’ mental health conditions 
impacted his risk, an incorrect decision to remove KS from the MAPPA agenda and a 
failure to regularly secure the engagement of key stakeholders. The MoJ recognises its 
part in these failures and the risks which would arise in the future if these issues are not 
properly addressed.   

Thames Valley MAPPA 

44. Thames Valley MAPPA drafted an action plan in response to the MAPPA Serious Case 
Review of 5 October 2021 (MAPPA SCR). The October 2023 updated action plan was 
’ PFD witness statement. The main actions taken as 
exhibited to 
a result of this post-MAPPA SCR action plan were set out in the PFD witness statements 
. An updated version of this action plan (‘TVP 
of 
Local  Action  Plan’),  now  addresses  points  arising  from  your  PFD  report.  There  is  an 
element of crossover in findings between the MAPPA SCR and your PFD report. This 
local  action  plan  shows  when  recommendations  from  the  MAPPA  SCR  have  been 
progressed if they are relevant to your findings and issues raised in your PFD report. 

 and of 

45. The actions identified in the TVP Local Action Plan which are new and are therefore not 
described in either of the witness statements of 
 are 
summarised below. Training and reminders about the correct MAPPA processes have 
been provided to probation practitioners as follows: 

 or 

i) 

ii) 

iii) 

Training  on  identifying  cases  that  would  benefit  from  MAPPA  management 
was provided to probation case administrators on 1 May 2024.  

The  MAPPA  Chairs  Compendium  of  Learning  has  been  amended  to 
emphasise the need for chairs to indicate what circumstances might lead to a 
case needing to be re-referred into MAPPA Level 2/3.  

The  Head  of  Public  Protection  has  reminded  probation  practitioners  of  their 
responsibility to ensure that any case that is outside MAPPA or is at Level 1 
and needs to be heard in a meeting must have a new referral submitted to the 
thresholding panel.  This has been included in the Compendium of Learning 
referenced above.  

12

 
 
 
 
 
 iv) 

The  Head  of  Public  Protection  has  reminded  probation  practitioners  (as  the 
lead  for  most  MAPPA  cases)  of  their  responsibility  to  ensure  the  MAPPA 
administrator  is  aware  of  who  to  invite  to  meetings,  not  just  at  the  point  of 
referral  but  throughout  the  MAPPA  management  of  the  offender.  This  has 
been included in guidance documents and ongoing training for Chairs. 

46. As described at paragraph 56(ii) of 

’ PFD witness statement there 
is  now  an  escalation  process  to  monitor  and  address  non-attendance  at  MAPPA 
meetings.  The  MAPPA  Coordinator and the  Strategic Management  Board  continue  to 
maintain a list of escalation points so that the attendance and meaningful participation of 
agencies at MAPPA is pursued.  

47. Local  Strategic  Management  Boards  (SMBs)  are  responsible  for  delivering  MAPPA 
within their respective Criminal Justice areas. These boards provide governance and are 
required to have quality assurance processes in place. Thames Valley MAPPA SMB has 
implemented quality assurance of the MAPPA process. This has included audits on 18 
March 2024 and 15 April 2024 for referrals rejected by the thresholding panel and audit 
of  MAPPA  Minutes  on  19  February  2024  for  the  management  of  MAPPA  Level  2/3 
meetings.  These  aspects  were  specifically chosen  as  they  had been  identified  as not 
working well by the author of the MAPPA SCR. 

48. In  the  first  audit,  12  cases  were  selected  at  random  and  the  thresholding  of  referring 
cases to MAPPA Level 2 was analysed. In 11 cases the auditors agreed with the referral 
decision, with them disagreeing with the referral in one case only. The robust approach 
taken by the audit team has identified clear goals for improvement in several areas of 
the  MAPPA  process.  Audit  reports  are  presented  to  the  MAPPA  SMB  to  identify  any 
actions. Learning from the audit around presenting risk information, risk assessment and 
the identification of how MAPPA will add value to the risk management of the case will 
now be disseminated within the Thames Valley area. This will be done via the Thames 
Valley MAPPA SMB Quality and Monitoring Sub-group and the MAPPA Chairs Forum.   

49. In  the  second  audit,  six  cases  were  selected  at  random  and  the  meeting  minutes 
analysed. The record of the audit outcome meeting on 19 February 2024 identified some 
areas  of  improvement  especially  in  respect  of  the  attendance  of  other  agencies.  In 
response a detailed action plan was drawn up and this set out steps such as refresher 
training for MAPPA Chairs, the escalation processes to be invoked, and reminders to 
agencies to attend. 

Assessing Intelligence in its entirety 

50. In your factual findings you identified that there was an incomplete intelligence picture 
for KS. This included prison intelligence which did not reach KS’s COM. The National 
Intelligence  Unit  (NIU)  within  HMPPS  has  reviewed  the  way  prisons  share  security 
information  and  intelligence  within  MAPPA,  specifically  when  contributing  to  MAPPA 
level 2 and 3 meetings.  

51. In  consultation  with  the  national  MAPPA  team,  the  NIU  have  produced  additional 
guidance  for  prison  security  departments  to  improve  the  quality  of  the  intelligence 
assessment which forms part of the information-sharing report (MAPPA F) which prisons 
complete for each level 2/3 pre-release MAPPA meeting. The guidance includes a new 
template  to  structure  the  intelligence  assessment  and  instructions  on  the  process  to 

13

 
 
 
 
 follow.  This  has  been  designed  to  ensure  that  the  intelligence  provided  by  prisons  to 
MAPPA panels is comprehensive. 

52. In addition to providing relevant intelligence, it is now required that prisons will attend all 
pre-release MAPPA Level 2/3 meetings. At a national level, their attendance is monitored 
by  the  Responsible  Authority  National  Steering  Group  (RANSG),  which  a  senior 
representative from the Prison Service attends. The data shows that, nationally, prison 
attendance at MAPPA Level 2/3 meetings is consistently high. Where there is a dip in a 
particular  area  the  RANSG  will  commission  localised  work  to  improve  attendance.  At 
present prison attendance at Level 2/3 meetings stands at over 93% against a target of 
90%. 

Addressing Risk 

53.  The  quality  of  how  MAPPA  meetings  are  managed  is  monitored  using  the  Quality 
Improvement Tool which was launched in April 2023. The National MAPPA team is now 
assessing the data collected in the last year. Initial findings from the Quality Improvement 
toolkit show that overall, the management of cases is meeting the set criteria including 
the quality of chairing and the quality of minutes. There are some areas for improvement 
and the National MAPPA Team will address these in the coming months. The National 
MAPPA  team  will  continue  to  use  the  findings  from  the  Quality  Improvement  Tool  to 
address deficiencies and highlight where areas are doing well.   

54. In  addition,  MAPPA  are  subject  to  independent  scrutiny  by  the  three  Criminal  Justice 
Inspectorates.  The  joint  thematic  inspection  of  MAPPA  was  published  in  20228.  This 
concluded “that for cases managed at Levels 2 and 3, MAPPA largely achieves its aim 
of managing the risks that violent and sexual offenders pose to the public”, but that “for 
Level 1 cases, further improvements are needed”.   

55. There has also been an independent review of MAPPA by Jonathan Hall,9 as a result of 
which a discrete new MAPPA category, Category 4 was created. This was to ensure that 
all offenders convicted of terrorism offences are automatically referred to and managed 
under MAPPA and to enable offenders who are assessed as presenting a terrorism risk 
to be managed under MAPPA, even where they have not been convicted of terrorism 
offences.  We  also  introduced  amendments  to  part  13  of  the  Criminal  and  Justice  Act 
200310  to  put  beyond  doubt  Duty  to  Co-operate  (DTC)  agencies’  powers  to  share 
information  under  MAPPA  and  extended  these  powers  to  cover  any  agency  the 
Responsible Authority considers may contribute to the assessment and management of 
the risks presented by MAPPA offenders, for example GPs. 

56. In July 2023 there was a joint inspection of the management of terrorist offenders11 which 
stated that it was evident that many of Jonathan Hall KC’s recommendations from his 
2020  review  of  the  management  of  terrorist  offenders  through  MAPPA  have  been 
implemented.   

8 Criminal Justice Joint Inspection of MAPPA by HM Chief Inspectors of Probation, Prisons and Constabulary 
July 2022   
9  Independent Review of Statutory Multi-Agency Public Protection Arrangements May 2020 by Jonathan 
Hall KC 
10 https://www.legislation.gov.uk/ukpga/2003/44/part/13  
11 Counter Terrorism Joint Inspection – National Security Division and multi-agency arrangement for the 
management of terrorist offenders in the wake of terror attacks – July 2023 

14 

 
 
 
 
 
 
 Conclusion 

57. Finally, I wish to thank you for the care and consideration with which you and your legal 
team conducted these inquests. Your factual findings and PFD report identify extensive 
learning points for the MoJ. Whilst much of the improvement work was already in train, 
the need for greater scrutiny of some key issues and further important improvements has 
been identified as a direct result of these inquests. I hope that these will provide some 
reassurance to you and to the  families and friends of James Furlong, Joseph Ritchie-
Bennett and David Wails. 

Yours sincerely, 

LORD CHANCELLOR AND SECRETARY OF STATE FOR JUSTICE 

15
Response from NHS England (PDF)
Sir Adrian Fulford PC 
Nominated Judge Coroner 
c/o TLT LLP  
20 Gresham Street 
London 
EC2V 7JE 

National Medical Director  
NHS England  
Wellington House 
133-155 Waterloo Road  
London 
SE1 8UG 

Dear Sir Adrian 

Re: Regulation 28 Report to Prevent Future Deaths – James Furlong, Joseph 
Ritchie-Bennett and David Wails who died on 20 June 2020 in the Forbury 
Gardens terror attack  

Thank you for your Report to Prevent Future Deaths (hereafter “Report”) dated 20 May 
2024  concerning  the  deaths  of  James  Furlong,  Joseph  Ritchie-Bennett  and  David 
Wails on 20 June 2020. In advance of responding to the specific concerns raised in 
your Report, I would like to express my deep condolences to  the families and loved 
ones of James, Joseph and David. NHS England are keen to assure the families and 
the  Coroner  that  the  concerns  raised  in  your  Report  about  the  prior  care  of  the 
perpetrator of the attack have been listened to and reflected upon.   

My  response  focuses  on  those  concerns  that  fall  under  the  remit  of  NHS  England, 
namely those summarised at paragraphs 43-45 of your Report, regarding secondary 
healthcare  service  arrangements  and  resourcing  within  prison  establishments.  In 
particular you have raised that the evidence at the Inquests made clear that there were 
wider issues with the shortage of staff in prisons to provide psychological treatment, 
and with the processes to prioritise and track prisoners on the waiting list to ensure 
that they were seen. 

I  have  not  specifically  addressed  your  concerns  relating  to  the  deficiencies  of 
Pathfinder  (set  out  at  paragraphs  18  and  25-30  of  your  Report),  as  these  are  best 
addressed by the Secretary of State for Justice, who has responsibility for the service, 
along with Thames Valley Police. It is, however, acknowledged that NHS England and 
HMPPS  jointly  issued  Guidance  entitled  “Increasing  the  Engagement  of  Prison 
Integrated  Healthcare  Teams  in  Pathfinder”  in  June  2022,  following  the  Forbury 
Gardens attack and the review conducted by the Joint Extremism Unit (JEXU) on the 
mental health provision. 

In response to your concerns directed to NHS England, I provide you with details about 
NHS England’s work below.  

Mental health pathways programme of work 

The NHS England Mental Health Programme has recently embarked on new work to 
review the current service provision for adult individuals in contact with the criminal 
justice system. This has focused on the changes required to provide sustainable and 

                                                                                                                       
 
 
 
 
 
 
  
  
 
 
 
 
 
 ongoing  consistency  of  service  provision,  for  those  adults  who  need  care  and 
treatment for mental ill health, and associated disorders.  

To  enable  these  changes,  a  Mental  Health  Criminal  Justice  Pathway  is  in 
development.  This  Pathway  is  overseen  by  a  ‘Health  and  Justice  Mental  Health 
Pathway Expert Working Group’ and this work aims to:  

•  Ensure,  from  a  patient  perspective,  that  the  Pathway  is  robust,  seamless, 

individualised, and responsive to a person’s needs and requirements.  

•  Provide  people  with  mental  health  concerns  timely,  consistent,  high-quality 
advice,  treatment,  and  support  that  is  effectively  communicated  across  all 
services.  

•  Reduce  reoffending  and  improve  health  outcomes  by  addressing  underlying 

mental health issues at the earliest opportunity.  

•  Strengthen  pre-sentence  community-based  health  options  by  working  in 

partnership with health and justice agencies.  

•  Reduce the number of people with mental health issues who are remanded or 
sentenced to custody, ensuring they receive appropriate care and treatment in 
the right settings at the earliest opportunity. 

•  Work  with  partners  to  make  available  appropriate  healthcare  alternatives,  in 
place of remand in custody and short custodial sentences, for those with mental 
health issues.  

•  Reduce the number of people being sent to custody with mental health issues, 
resulting  in  a  reduction  of  individuals  requiring  transfer  to  hospital  under  the 
Mental Health Act 1983. 

Psychology provision/equivalence 

The Service Specification for Integrated Mental Health Service for Prisons in England 
(2018) states that there should be access to suitable, evidence-based psychological / 
psychosocial and clinical interventions. Importantly, services are required to ensure all 
patients have a diagnosis and clinical formulation, and should provide evidence-based 
psychological interventions adapted to patients’ needs. Patients within secure settings 
should receive an equivalent level of healthcare to patients in the community (in terms 
of the range of interventions and services available, quality and standards).  

The service specification requires that patients have a robust discharge plan to enable 
continuity of care in the community. Where patients exit a service due to  a transfer 
from  custody,  extensive  and  timely  multi-disciplinary  planning  is  required  and 
expected. Similarly, where a patient is transferred to another prison, a comprehensive 
handover is expected to be actioned and coordinated.  

 
 
 
 
 
 
 
 
 
 
 
 
 I  would  also  like  to  highlight  the  work  of  NHS  England’s  RECONNECT  and  the 
enhanced  RECONNECT  ‘care  after  custody’  services.  RECONNECT  seeks  to 
improve the continuity of care of people leaving prison by working with them before 
they  leave  and  supporting  their  transition  to  community-based  services,  thereby 
safeguarding any health gains made whilst detained.  

RECONNECT is not a service providing clinical interventions. What it offers is liaison, 
advocacy, signposting, and support to those leaving prison, to aid engagement  with 
community-based  health  and  support  services.  It  provides  support  and  release 
planning for up to 12 weeks prior to release (or as soon as the person is referred) and 
will work with them for up to 6 months post release date, or when all health care needs 
are met, whichever comes soonest.  

Enhanced  RECONNECT  (ER),  which  is  a  trauma  informed  service  working  with 
people  from  6  months  prior  to  release  until  12  months  post  release,  builds  on  the 
RECONNECT  service  as  an  enhanced  pathway  of  care,  and  is  NHS  England’s 
response  to  the  management  of  individuals  identified  as  a  high  risk  of  harm  to  the 
public and who have complex health needs. The enhanced service is a pilot scheme 
currently operating in  the  North East,  North West  and South  West  of  England.  The 
service  works  collaboratively  with  partners  (including  from  other  services  and 
organisations)  to  support  any  high-risk  individual  with  complex  health  needs,  which 
may impact on their risk of reoffending.  

Additionally,  since  the  tragic  events  of  20  June  2020,  NHS  England’s  South  East 
region  has  re-procured  mental  health  services  at  HMP  Bullingdon  and  HMP 
Huntercombe. These services are now provided by Oxford Health NHS Foundation 
Trust (OHFT) at both sites.  

Further to the above, there is an integrated model of mental health care across both 
primary  and  secondary  care  mental  health  services,  with  access  to  the  Health  and 
Justice  Information  Services  (HJIS)  records,  along  with  community  mental  health 
records, to better support continuity of care and information sharing.  

The provision of psychological therapies is still commissioned, although recruitment 
challenges mean there is a longer wait for initial assessment for psychological therapy 
than is ideal at present. Prison mental health teams do maintain a 5 day wait for routine 
mental health referrals, however, increasing the availability and accessibility of talking 
therapies is a priority.  

OHFT  and  NHS  England’s  South  East  Region  continue  to  prioritise  increasing  the 
availability  of  access  to  evidence  based  talking  therapies  at  the  prisons,  whilst 
developing a more sustainable workforce to deliver the interventions.    

It is also positive that clinical information sharing between prisons when a prisoner is 
transferred  is  much more robust  in  2024 than it  was  in  2020. Patient information  is 
now routinely shared on a digital Prisoner Escort Record (PER) and via HJIS notes, 
and the transfer of clinical information between prisons and community providers is 
locally audited on an annual basis alongside other performance indicators.  

Community Mental Health Services 

 
 
 
 
 
  
  
 
 Additionally, as part of its NHS Long Term Plan commitments to improve mental health 
care, NHS England has increased the investment in adult and older adult community 
mental health services by £1 billion per year since 2019/20. This additional funding 
has meant that over 370,000 people were able to access transformed models of care 
in  2023/24. These  new  models,  as  described  in  the  Community  Mental  Health 
Framework (September 2019), are aimed at ensuring that adults and older adults with 
severe mental health problems are better able to access a high quality of care that 
meets their clinical and social needs, and that care is easily 'stepped up' or 'stepped 
down' depending on their needs.  

However, NHS England recognises that further national work is needed to ensure that 
people with severe mental illness, who pose a risk of harm to others when unwell, are 
properly supported and can access appropriate care to avoid relapses in their mental 
health. NHS England has therefore asked all Integrated Care Boards to review their 
community services by September 2024, to ensure that they have clear policies and 
practices  in  place  for  patients  with  serious  mental  illness,  who  require  intensive 
community treatment and follow-up, but where engagement is a challenge. To support 
system reviews, NHS England has convened an expert advisory group to advise on 
the development of national guidance, setting out the key principles in this area that 
should be reflected in local policies and practices. 

Trust Provision  

We  note  that  you  have  also  addressed  your  Report  to  Berkshire  Healthcare  NHS 
Foundation Trust (BHFT), who are the appropriate organisation to respond to many of 
the concerns raised about the quality of care previously delivered to the perpetrator of 
the terrorist attack. We also note that Midlands Partnership University NHS Foundation 
Trust (MPFT) are required to respond to you, demonstrating that they are continuing 
to  make  appropriate  changes  to  the  services  they  provide  to  other  prison 
establishments. We have ensured that all regions where MPFT has a prison provision 
footprint (as this extends outside of the Midlands region) are  aware of the concerns 
raised in your Report.  

My regional colleagues in the South East have also been asked to engage with BHFT 
on the concerns raised, and with OHFT who, as set out above, are now providing the 
secondary  mental health  services to  HMPs’ Bullingdon and  Huntercombe.  We note 
that OHFT are required to provide assurance of current practices at these two prisons, 
including the current position on the level of available psychological services against 
the background of the previous failure by MPFT to provide these to the perpetrator of 
the attack whilst he was in prison. We will carefully consider the Trusts’ responses, 
once sighted on these.  

I  would  also  like  to  provide  further  assurances  on  the  national  NHS  England  work 
taking place around the Reports to Prevent Future Deaths. All reports received are 
discussed  by  the  Regulation  28  Working  Group,  comprising  Regional  Medical 
Directors  and  other  clinical  and  quality  colleagues  from  across  the  regions.  This 
ensures that key learnings and insights are shared across the NHS at both a national 
and regional level and helps us to pay close attention to any emerging trends that may 
require further review and action.   

 
 
 
 
 
  
 Thank you for bringing these important patient safety issues to my attention and please 
do not hesitate to contact me should you need any further information.  

Yours sincerely,  

National Medical Director
Response from Oxford Health (PDF)
Private & Confidential 
The Right Honourable Lord Justice Fulford 
Royal Courts of Justice  
Strand  
London  
WC2A 2LL 

Chief Executive’s Office 
Trust Headquarters   

Littlemore Mental Health Centre 
Sandford Road 
Littlemore 
Oxford 
OX4 4XN 

9 July 2024 

Dear Judge Fulford, 

The Forbury Gardens Inquests  
Report on Action to Prevent Future Deaths 
Response of Oxford Health NHS Foundation Trust 

Thank you for your letter of 20 May 2024. I write to respond to your concerns. 

Paragraph  45  of  your report is  directed  at  Oxford  Health  NHS  Foundation  Trust  (“OHFT”).   
My  colleague 
,  Forensic  Service  Manager,  provided  a  statement  to  the 
inquests in which she explained that OHFT has held the contract for provision of integrated 
mental health services into Bullingdon and Huntercombe prisons since October 2022.   The 
contract that OHFT signed to provide integrated mental health services is between OHFT and 
a  company  called  Practice  Plus  Group,  rather  than  direct  between  OHFT  and  the  Prison 
Service. Practice Plus Group holds the contract with the Prison Service for overall provision 
of medical care into the prison. 

Paragraph 45 records – 

As  regards  MPFT,  they  no  longer  provide  secondary  healthcare  services  in  HMP 
Bullingdon and Huntercombe. Therefore, this Report (in this context) is directed primarily 
at OHFT; nonetheless it will be provided to MPFT who continue to provide services in 
other prison establishments. I have also directed that it is sent to NHS England so that 
appropriate  national  action  in  this  area  can  be  considered. 
,  service 
manager for OHFT, was specifically asked to address the “tracking” of prisoners as they 
moved  between  prisons.  It  became  clear  during  the  evidence  that  there  were  wider 
issues with the shortage of staff in prisons to provide psychological treatment and with 
the processes to prioritise and track prisoners on the waiting list to ensure that they were 
seen (regardless of whether they transferred or not). As a result, and without criticism 
of  her  statement, 
  does  not  address  the  current  position  on  the  level  of 
psychological  services  at  HMP  Bullingdon  and  HMP  Huntercombe  against  the 
background of the previous failure by MPFT to provide these to KS at any stage whilst 
he was in prison. I suggest that for a prisoner demonstrating KS’s risk factors, he should 
have been offered, within the limits of available resources, the opportunity to participate 
in long term psychology sessions. I request that this issue is addressed by OHFT in its 
response to this Report, in order to prevent future deaths.  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 OHFT currently provide psychological services for HMP Bullingdon and HMP Huntercombe 
as part of the integrated mental health team. The evidence based psychological interventions 
are delivered based on clinical need and sentence length, in line with the NHS Stepped Care 
Model and National Institute of Clinical Excellence guidance. These include psychotherapy, 
cognitive  behavioural 
focussed-CBT,  and  eye  movement 
trauma 
desensitisation and re-processing. 

therapy 

[CBT], 

Any staff who work within the prison can make referrals into the mental health team, as well 
as  self-referrals from any prisoners  themselves.  All  referrals made  to  the  team  will  have a 
face-to-face  triage  appointment.    A  multidisciplinary  team  (MDT)  discussion  follows  each 
referral. If the MDT identifies a need for psychology that person will receive a full assessment 
through which their needs and treatment pathway will be determined. Anyone who is waiting 
to start psychological treatment will be placed on an electronic waiting list on SystmOne, and 
assigned a mental health nurse who will meet with that person monthly until their appropriate 
psychological  treatment  has  commenced.  Mental  health  nurses  also  deliver  emotional 
management and coping skills groups, which can be offered during the waiting period. The 
waiting list is managed by the psychology staff, and when a prisoner is discharged after they 
finish their treatment, the next person on the waiting list will then be offered a place to start 
their treatment. The waiting list is determined on a first come first served basis.  The exception 
to that is when a prisoner is a veteran of HM Forces, which is standard practice across all 
prisons. 

If a prisoner has commenced a psychological treatment, they would be placed on a medical 
hold  to  prevent  a  transfer to another  prison.  That  is  so  they  can  finish  their treatment.  If  a 
prisoner is transferred elsewhere whilst waiting to start psychology, the receiving prison would 
be informed that the prisoner in question was on the waiting list through detailed handovers, 
and both oral and email confirmation. Standard process would be for the prisoner to then be 
placed on the waiting list (for psychology) at the receiving prison. The prisoner would then be 
seen by the receiving prison’s psychologist for a triage assessment, subject to the receiving 
prison having a psychology provision. Timescales vary at establishments based on demand. 

At HMP Bullingdon the current staffing model is a 0.8 whole time equivalent (WTE) band 7 
psychotherapist,  a  0.3  WTE  band  8a  forensic  psychologist,  and  two  band  5  psychological 
wellbeing practitioners who are currently due to start in the service in July 2024. In the past 
12 months there have been 116 referrals for psychology, 17 patients are engaged in therapy 
currently, and  34 patients  waiting.  The  average  waiting  time  is  around  14  weeks. We  also 
have a Consultant Forensic Psychologist who oversees the governance of the psychological 
therapies  pathways  within  the  mental  health  teams,  including  managing  caseloads  of  the 
psychologists and psychological therapists. 

At HMP Huntercombe the current staffing model is one WTE band 4 assistant psychologist 
and 0.3 WTE band 8a psychologist.  The service has not been able to fill these posts and a 
business  case  was  submitted  by  the  service  to  commissioners  that  proposed  three 
alternatives to the staffing model. The purpose of the business case is to give us the best 
chance  to  recruit  into  posts,  to  increase  the  provision  for  psychology  and  to  expand  the 
service which can be offered. The business case has been submitted and we hope to receive 
a  decision  in  July  2024.  There  are  high  levels  of  trauma  within  the  establishment  and  the 
focus will be to treat the trauma and any associated symptoms. 

2 

 
 
 
 
 
 
 
 
 
 In terms of actions that it will be helpful for the Trust to consider, the service will consider if 
they should introduce guidance for psychological therapy staff about what to record when an 
individual declines treatment in the prison pathway, to include guidance that declined offers 
of treatment are always considered in caseload management supervision. 

I hope that this response provides you with the information that you require, but of course 
please do not hesitate to contact me if OHFT can assist further.  

Yours sincerely, 

Interim Chief Executive 

3
Response from Thames Valley Police (PDF)
Jason Hogg 
Chief Constable 

Thames Valley Police HQ 
Oxford Road 
Kidlington 
OX5 2NX 

www.thamesvalley.police.uk 

15 July 2024

The Rt Hon Sir Adrian Fulford PC KC 
The Inquest Legal Team 
20 Gresham Street 
London 
EC2V 7JE 

Dear Sir Adrian 

Preventing Future Deaths response of the Chief Constable of Thames Valley Police  

I  write  in  response  to  your  report  under  regulation  28  of  the  Coroners  (Investigations) 
Regulations  2013  dated  20  May  2024  (the  PFD  report),  for  which  I  am  grateful.  This  is  a 
consolidated response which addresses the position both of Thames Valley Police (TVP) as 
the local force for which I am the chief officer, and of Counter Terrorism Policing South-East 
(CTPSE),  which  is  one  of  the  regional  collaborations  within  the  Counter Terrorism  Policing 
(CTP) network and for which I am the lead chief officer. 

The inquests into the deaths of James Furlong, Joseph Ritchie-Bennett and David Wails which 
you heard between January and April 2024 shone a light on many procedures and practices 
within both TVP and CTPSE. TVP and CTPSE have taken the time to consider your findings 
of  fact  and  the  PFD  report  in  detail.  On  behalf  of  TVP  and  CTPSE,  I  wholly  accept  your 
findings.  They  were  not  easy  reading:  it  is clear that  some of  the  service  provided  by  both 
CTPSE and TVP fell short – sometimes far short – of expectations. 

I am grateful for the opportunity to set out, in response to your concerns in the PFD report, the 
action that has been taken to date to address the  risk of future fatalities, and the action that 
will be taken in future. 

In  this  response,  I  address  the  following  topics  raised  in  the  PFD  report  for  which  you 
requested a response by CTPSE or TVP: 

  The maintenance and dissemination of an adequate intelligence picture by CTPSE; 
  Prevent 
  MAPPA 
  Operation Plato 
  Support for the Force Incident Manager (FIM) 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 While I address these topics separately below, I recognise the substantial overlap between 
them, and between those areas for which I, as Chief Constable, am  responsible, and other 
linked areas such as Pathfinder which are the responsibility of HM Prison & Probation Service 
(HMPPS), or national policy on Prevent which falls under the Secretary of State for the Home 
Department. I ought also to note that CTPSE forms part of a wider network, with national policy 
and guidance set by Counter Terrorism Policing Headquarters (CTPHQ), which is led by the 
Commissioner  of  Police  of  the  Metropolis.  As  well  as  taking  action  as  regards  CTPSE’s 
activity,  CTPSE  both  implements  CTPHQ’s  policy  and  guidance  and  contributes  to  action 
being taken as part of national-level projects under CTPHQ’s auspices. 

 of TVP and CTPSE and 

 of 
As you note in the PFD report, 
CTPHQ, in their written and oral evidence (particularly their statements dated 10 November 
2023 and 17 November 2023 respectively), set out many and various steps which have been 
taken since 2020 to address a number of the issues that became apparent as a result of this 
attack. I do not wish simply to repeat information of which you are already aware, and so ask 
that this response be read in conjunction with the evidence you have already received from 
them. 

The maintenance and dissemination of an adequate intelligence picture by CTPSE 

The headline point as regards CTPSE’s management of intelligence is that a comprehensive 
review of CTPSE’s Fixed Intelligence Management Unit (FIMU) began in March 2024, and will 

be completed by the end of the year. CTPSE initiated this review (the CTPSE FIMU review) 
in  response  to  the  issues  canvassed  in  these  Inquests.  It  is  being  carried  out  by  CTPSE’s 
Head of Intelligence, an officer of Detective Superintendent rank.  

For context, most of the general intelligence analysis and dissemination within CTPSE takes 
place within the FIMU. The exceptions are work on specific operations and work on reactive 
operations (such as following the Forbury Gardens attack).  

As well as being a response to these Inquests, the CTPSE FIMU review also reflects national 
work  undertaken  by  the  CTP  Intelligence  Capability  Board  (ICB),  a  national  oversight 
mechanism for intelligence capability run by CTPHQ. In February 2024 a paper was presented 
to the ICB which identified growing demand on FIMUs across the country, and the need for 
them  to  remain focused  on  their  core  role  of  identification  and  assessment  of terrorist  risk. 
Those issues are relevant to the concerns you have raised about how CTPSE can maintain 
and  disseminate  an  adequate  intelligence  picture,  and  so  the  CTPSE  FIMU  review  will 
examine them as well as address concerns arising specifically from the Inquests. In the event 
that  there  are  any  national  recommendations  or  direction  from  the  ICB,  these  will  be 
incorporated into the CTPSE FIMU review. 

The  CTPSE  FIMU  review  will  cover  a  number  of  key  themes,  with  an  overarching  aim  of 
ensuring that the assessment, analysis, and dissemination of intelligence about terrorist risk 
by the CTPSE FIMU is properly resourced, trained, delivered and monitored. 

2 

 
 
 
 
 
 
 
 
 
 
 First, the CTPSE FIMU review will consider the training which FIMU assessors receive. They 
are required to undertake nationally mandated training to ensure that their work is compliant 
with  the  National  Standards  of  Intelligence  Management  (NSIM).  Compliance  with  this 
requirement is good, with 97.5% of staff in roles where this is a requirement having undergone 
this training. However, there has been feedback that this training focuses on the mechanics of 
assessment  and  does  not  adequately  provide  an  understanding  of  the  broad  underpinning 
principles  for  why  actions  are  undertaken.  CTPSE  has  raised  this  with  the  CTPHQ 
Organisational Development Unit (who manage this national course) to ensure that the course 
remains fit for purpose and incorporates the learning from your findings in this case. 

Nationally, the ICB is also reviewing the training and professional standards of certain roles 
within Intelligence functions, under the leadership of the Head of Intelligence of another CTP 
region. CTPSE have representation on that group and will ensure that the learning from your 
findings in this case is reflected in that national review. 

Second,  your  findings  highlighted  the  importance  of  clear  and  timely  communications 
between local police forces and CTPSE. I acknowledge that, as far as possible, information 
sharing needs to be based more consistently on an approach of ‘dare to share’, rather than 
‘need to know’. This can be challenging, particularly where intelligence is sensitive, requiring 
‘action on’ permissions or agreed forms of words. Nevertheless, the culture must be one that 
pushes the boundaries where necessary to facilitate the management of risk. CTPSE and the 
joint Contact Management Department of TVP and Hampshire & Isle of Wight Constabulary 
have met to discuss how the passage of information between CTPSE and local forces can be 
enhanced. 

One result of these meetings is that CTPSE and the Contact Management Department are to 
develop  training  for  call  handlers  to  build  awareness  around  the  role,  capabilities  and 
limitations of CTPSE, including in how to ask CTPSE effective questions about any information 
shared. There will also be new training for those within the FIMU who take calls from Contact 
Management. 

While the CTPSE FIMU review will determine the detail, one potential option is to incorporate 
a template that can be added to force command and control systems (Contact Management 
Platform – CMP in TVP’s case). This template would contain basic details such as what was 
known,  what  was  shared,  what  was  not  shared  and  why,  which  is  intended  to  assist  in 
providing the clarity needed. This model will, of course, need to be replicated across all the 
forces that CTPSE serve, and I intend that this work will be carried out at pace. 

I would like to emphasise that since 2020, we have already  seen a marked improvement in 
information  recorded  within  CMP  logs  by  CTPSE,  and  an  even  greater  improvement  in 
recording information and clarifying ownership of work/risk on Niche. This will be the subject 
of future supervisory audits, a point I will return to below. 

The CTPSE FIMU review will also consider how to approach issues of mental health where 
it  intersects  with  extremism.  CTPSE’s  FIMU  assessors  have  all  attended  awareness 
sessions for the newly established CTPHQ Clinical Consultancy Service (a national CTPHQ 

3 

 
 
 
 
 
 
 
 
 programme that has replaced the Vulnerability Support Hub about which I know  you heard 
evidence), and  are being  actively  encouraged  to  refer suitable  cases  where  needed.  Much 
work has  been undertaken  in  this  area  to  reinforce  the  concept  that  extremism  and  mental 
health  are  not  mutually  exclusive.  CTP  casework  (and  by  definition  FIMU  assessments) 
regularly involves cases where both are present. Checking that assessors are not delineating 
the two will continue through the supervisory frameworks being put in place. 

I would add that I recognise that, prior to 2020, FIMUs had a tendency to require evidence of 
defined ideologies and specific group affiliations (ISIS/Al Qaeda, etc.). In recent years, FIMU 
assessors  and  supervisors  have  become  more  aware  of  the  terrorist  risk  arising  from  or 
contributed to by individual psychologies, including mental health, or ideology, rather than links 
to groups. This change in emphasis reflects the network-wide dissemination of CTP learning 
from  the  various  terrorist  attacks  in  2017-2020,  as  well  as  the  changing  threat  which  we 
continue to  confront. As  compared  with  2020,  I  am  confident  that the  FIMU  do  not  dismiss 
threats based on mixed/unclear ideologies or mental health, and do not regard mental health 
as a mitigating factor for someone becoming a terrorist or holding an extremist ideology. 

The  CTPSE  FIMU  review  will  also  consider  how  the  FIMU  handles  the  totality  of  an 
intelligence picture. As 
 accepted in his evidence before you, simply adding a 
new  piece  of  intelligence  to  a  previous  assessment  is not  an  effective  way  to  consider  the 
entirety of risk. CTPSE’s intention is to free up capacity among assessors to enhance their 

ability  to  review  all  relevant  intelligence  when  considering  a  case.  This  may  represent 
something of a culture change which will need to be reinforced through supervisory processes. 
The demand that this creates will also need to be carefully monitored. There will inevitably be 
a balance between speed and complete totality of assessment. 

Inevitably,  IT  systems  such  as  the  National  Common  Intelligence  Application  (NCIA),  the 
platform  used  by  CTP  nationwide,  have  a  role  to  play  in  how  this  change  of  culture  is 
embedded. Whilst NCIA was transformational in bringing all CTP intelligence nationally onto 
a  single  system,  it  does  have  limitations  as  regards  searching  and  accessing  information, 
some of which I know were apparent in the evidence you heard. There are also issues around 
different access control levels for different kinds of users, which the CTPSE FIMU review will 
consider. Nationally, CTP is already undertaking a significant project to replace NCIA with a 
new IT platform for intelligence handling. This is expected to be introduced in 2026/27. It will 
provide  FIMU  intelligence  assessors  (and  all  those  in  CTP  requiring  access)  with  a  more 
intuitive, accessible and user-friendly platform to accelerate and improve assessment of often 
complex and detailed intelligence. This will address the concern that it is in some situations 
difficult to get a meaningful summary out of NCIA at pace. This work will also help to address 
concerns around the sharing of adequate relevant information with partner agencies, including 
HMPPS and MI5, to assist them in carrying out their functions. 

The CTPSE FIMU review will also consider  the level of knowledge of staff in relation to 
proscribed groups, and how this can be enhanced. Currently, when a group is proscribed, 
communications are issued centrally from CTPHQ. Those staff in post at that time therefore 
receive an update, but this does not help individuals who join after the point of proscription. 
Present thinking is that having more concise guides available could help understanding in this 

4 

 
 
 
 
 
 
 area. This links to the culture change I described above, which encourages assessors to take 
a holistic approach to the assessment of intelligence. 

Additionally, CTPSE intends within the next four weeks to open discussions with CTPHQ as 
to how a dedicated database which provides easy, instant access to information on proscribed 
organisations  around  the  world  to  inform  assessments  might  be  made  available.  Such 
databases are available to some of CTP’s partner agencies, which it is hoped will provide a 

model for this development. 

The deputy Senior Investigating Officer (SIO) for the original Forbury Gardens investigation 
(who  was  also  the  SIO for Operation  Cropland,  CTPSE/TVP’s response  to  these  Inquests) 

has, on behalf of CTPHQ, created a learning video presentation on the case which will soon 
be available online to all staff in the CTP network. The CTPSE FIMU review will also consider 
how the FIMU can better identify indicators of an imminent attack. Since 2021, CTPSE has 
utilised a set of indicators from the learning from previous attacks, and they are used by FIMU 
staff.  They  are  also  used  nationally,  and  the  SIO  for  Operation  Cropland  through  CTPHQ 
delivers training nationally using previous cases, including Reading, to increase awareness of 
these indicators. These indicators are based on a more general approach to using behavioural 
science  and  academic  support  to  increase  understanding  of  1)  what  indicates  someone  is 
mobilising towards violence and 2) what factors make someone more likely to be violent to 
assist case prioritisation. The idea is to move away from a model that simply identifies explicit 
threats, to a more holistic approach to the threat.  

CTPSE have also piloted the Self-Initiated Terrorist oversight group, which is now led by a 
Detective Inspector. The point of it is to consider cases such as KS that fall below the threshold 
for  coverage  or  intervention  by  MI5,  to  make  sure  they  are  being  addressed  correctly,  to 
ensure that they sit in the right space for intervention, the cases are escalated quickly where 
necessary, and to provide staff with a further support in their risk assessment decision making. 
This approach is being rolled out in other parts of the country but it is most developed in the 
South East as a direct result of the Forbury Gardens attack. 

The CTPSE FIMU review will also examine how actions are monitored and tracked within 
the FIMU, and how supervisory reviews take place. I am aware that the evidence heard at 
the Inquests indicated that actions set by or for the CTPSE FIMU were not consistently tracked 
or followed through. At the end of  2021, ‘Management Logs’ (MLs) were introduced to CTP 
FIMUs nationally to provide an easier way for FIMU assessors and supervisors to manage the 
intelligence development space. ‘Open actions’ on NCIA can now easily be searched for and 

managed  accordingly.  Supervisors  carry  out  weekly  checks  to  review  and,  if  necessary, 
reallocate actions. FIMU assessors can add auditable entries to the MLs to demonstrate efforts 
made to complete enquiries. Whilst there is already a high degree of confidence in MLs, the 
new  intelligence  handling  IT  system  referred  to  above  should  improve  this  process  even 
further. 

Across  CTP,  supervisory  reviews  are  now  carried  out  on  a  set  percentage  of  FIMU 
assessments. It is not possible to review all assessments due to the volume, so a ‘dip checking’ 

5 

 
 
 
 
 
 
 
 regime is in place. National standards now stipulate that 5% of all records are checked but this 
is subject to review, and is likely to be increased. The checking regime within CTPSE will also 
be  strengthened  to  include  more  qualitative  assessments,  such  as  whether  the  totality  of 
intelligence has been assessed and checking the quality of decisions made. Where areas for 
improvements are identified these will be fed back, either individually or to the entire team. 
The emphasis will be on continuous learning as opposed to blame and on creating an open 
culture of reflective practice excellence in decision making.  

The key points learnt from the supervisory framework will be incorporated into regular quarterly 
reporting  cycles.  This  will  complement  the  current  CTP  Intelligence  Capability  Assurance 
Report  reporting  process  that  looks  at  metrics  measurable  from  the  NCIA  database  and  is 
examined  at  the  ICB.  The  local  review  process  will  add  qualitative  learning  that  helps  to 
improve decision making as well as ensuring that supervisors are compliant. This qualitative 
learning will then be disseminated to the ICB to ensure that any applicable lessons are learnt 
across the whole CTP network. 

Closely  linked  to  the  supervisory  review  framework  will  be  a  reassessment  of  the 
measurement  of  demand  and  performance  in  the  FIMU.  Currently,  performance  reporting 
largely focuses on volumes of intelligence documents assessed, their measurable outcomes, 
and timeliness. While these are important metrics, the scope of performance reporting requires 
expansion  to  cover  overall  FIMU  demand  and  a  qualitative  assessment  of  the  work  being 
undertaken. The CTPSE FIMU review will consider whether there are further steps, in addition 
to those described above, that can be taken in this regard. 

I would also like to draw to your attention  the increased sharing of information between 
CTPSE’s Intelligence function and its Nominal Management Team (NMT), which forms 
part  of  its  Interventions  function.  Both  the  CT  Nominal  Management  (CTNM)  Manual  of 
Guidance and the national Prevent process require compliance with the National Standards 
of Intelligence Management (NSIM) which requires submission of intelligence back into FIMUs 
as  part  of  the  intelligence  cycle.  This  ensures  visibility  of  individuals  subject  to  Prevent  or 
CTNM within the intelligence space.  

There are still challenges as regards the sharing of intelligence between FIMUs and CTNM 
nationally  due  to  the  lack  of  a  single  national  CTP  case  management  system  which  has 
resulted  in  a  variety  of  methods  of  recording  across  the  country.  The  Home  Office  owned 
Violent  Sex  Offender Register  (ViSOR)  provides  a  partial  solution  as  a  national  system  for 
recording cases shared with HMPPS. However this system is significantly outdated, not initially 
designed for CT use, and has access requirements which are not compatible with the majority 
of the CTP estate. To address this challenge, CTP will be the first adopters of the new Multi-
Agency Public Protection System (MAPPS), a replacement for ViSOR, which is expected to 
be delivered in 2025/26. MAPPS has been designed from commissioning for use in terrorism 
cases and has modern access requirements compatible with the CTP estate. 

There is also a well-defined CTPSE process which ensures that FIMU have visibility into all 
individuals on NCIA who are within the CTNM cohort. In summary, this process ensures that 
each new instance of intelligence or enquiry relating to a CTNM subject is drawn immediately 

6 

 
 
 
 
 
 
 
 to the attention of CTNM officers. Where necessary, this results in case conferences but either 
way ensures decision making between FIMUs and CTNM is well coordinated and jointly made. 
This process has been tested recently with FIMU being alerted to concerns around a CTNM 
cohort  member,  swiftly  gaining  access  to  the  nominal’s  CTNM  record,  and  putting  in  place 
appropriate  management  plans.  This  all  occurred  out  of  hours  and  no  problems  were 
encountered with accessing the information.  

FIMU are also responsible for setting up the flags and markers required for such nominals, 
plus their closure. 

FIMUs  also  have  visibility  of  the  Prevent  cohort  as  they  have  access  to  the  Prevent  Case 
Management  Tracker  Enhanced  system.  All  Prevent  staff  are  aware  of  the  necessity  and 
process for submitting intelligence. Regular monthly meetings between FIMU managers and 
Prevent managers have enhanced CTPSE processes in this area. 

After the CTPSE FIMU review has concluded, CTPSE will ask CTPHQ for a  peer review of 
CTPSE FIMU to provide external scrutiny and reassurance of effective working. 
As I hope is clear from the above, this CTPSE FIMU review is intended to be a wide-ranging 
and thorough review that covers not only the matters you have raised in the PFD report, but 
also builds on previous and ongoing work within both CTPSE and nationally. I can assure you 
that  the  entire  chain  of  command  within  CTPSE,  from  myself  down,  is  committed  to 
implementing any necessary or desirable changes that the CTPSE FIMU review identifies.  

Prevent 

I acknowledge the concerns you set out regarding Prevent at §§19-21 of your regulation 28 
report. The changes made or planned to the FIMU described above clearly interlock with these 
concerns: for example,  ensuring  that  there  is  an assessment  of  the  totality  of  the  available 
evidence of sufficient quality, made available by the FIMU to Prevent staff to ensure that they 
can make a properly considered assessment of risk. This should ensure that Prevent staff, in 
future,  would  be  aware  of  an  individual’s  links  to  proscribed  organisations  or other terrorist 
offenders, where this information is known by CTPSE. To support this, CTPSE has begun to 
implement access to NCIA (and the associated requirement for Developed Vetting) for some 
Prevent  staff.  The  Prevent  Gateway  Team  within  CTPSE  has  also,  since  2019,  been  co-
located with the FIMU. 

To address the weaknesses in training in Prevent, it is now a requirement that all CTP Prevent 
staff undergo  a  CTPHQ-accredited  training  pathway.  This  training  aims  to  build  on existing 
policing expertise, whilst providing additional knowledge, skills, and awareness for the CTP 
context. The National Interventions Foundation Programme (NIFP) has four online modules, 
one  day  face-to-face  on  the  assessment  framework  and  one  day  face-to-face  on 
welfare/disguised compliance. An interactive exercise will be included in the NIFP but is still 
under development at the time of writing. While the NIFP and its training courses are signed 
off/accredited  by  CTPHQ,  there  is no  official external accreditation  for the  content  of those 
courses. 

7 

 
 
 
 
 
 
 
 
 
 In relation to supervision and selection, within CTPSE both Prevent supervisors (generally 
at Sergeant rank) and managers (at Inspector and Chief Inspector rank) are now required to 
be (at least) PIP2 Detectives. This is a change from the previous position, where this was not 
a requirement for supervisors. This new requirement has two key impacts. First, it ensures a 
high level of investigative competence and leadership within the team at both supervisory and 
management levels. Second, it means that all CTPSE recruitment into Prevent is undertaken 
by accredited detectives, with the requisite experience and an investigative mind-set. While 
Prevent  staff  below  supervisory/management  level  are  not  required  to  be  accredited 
detectives, those selecting and recruiting them are. That helps to ensure that our selection 
process for these roles is rigorous, prioritising experienced individuals with the right attitude 
and approach, who can effectively manage complex cases. 

To help put this into context, in 2021 the number of Prevent supervisors in the Reading and 
Berkshire area increased from one to two, as I understand you heard in the Inquests. At the 
time, neither was an accredited detective: they have both since been sponsored by CTPSE to 
complete  their  PIP2  accreditation.  The  most  recent  supervisory  appointment  to  CTPSE’s 
Prevent department was an experienced Detective Sergeant with a background of working in 
Public Protection. 

Additionally,  both  current  Prevent  Detective  Inspectors  within  CTPSE  have  completed  the 
Management  of  Serious  Crime  Investigation  Development  Programme.  They  have  a 
background  in  intelligence,  and  keep  this  skillset  current  by  supporting  the  on-call  rota  for 
CTPSE’s Intelligence department. 

Furthermore, we have re-posted managers across our departments – Nominal Management, 
Prevent, and Intelligence – over recent years. A Detective Chief Inspector from Prevent has 
moved  into  the  Nominal  Management  Team;  a  Detective  Inspector  from  Intelligence  has 
moved to Prevent (as alluded to above); and a Detective Inspector from Prevent has moved 
the  other way,  into  Intelligence.  This deliberate  approach fosters the  transfer of  knowledge 
and reduces the risk of silos, thereby enhancing overall efficiency and cohesion. 

This comprehensive approach ensures that all Prevent officers are well-versed in the latest 
methodologies and best practices in risk management. Continuous professional development 
(CPD)  events  are  also  accessible  and  mandated  for  all  staff,  ensuring  that  they  remain 
updated  with  evolving  strategies  and  maintain  high  standards  of  professional  competency. 
These CPD events provide ongoing learning opportunities that reinforce and expand on the 
foundational training, ensuring that staff are continuously improving their skills and knowledge 
base. 

There has also been substantial recent and ongoing work on structured assessments within 
Prevent. Following a recommendation from the Independent Review of Prevent, CTPHQ and 
the  Home  Office’s  Homeland  Security  Group  (HSG)  have  been  working  with  HMPPS  to 
develop  an  upgraded  version  of  the  current  Prevent  risk  assessment  tools.  HMPPS  were 
commissioned to develop the new tool to harness the best practice from the success of their 
well-known  ERG22  CT  risk  assessment.  The  new  tool  has  been  informed  by  up-to-date 

8 

 
 
 
 
 
 
 
 
 research and plans for ongoing evaluation and improvement. It consolidates two previous tools 
into one for a more streamlined user friendly and time efficient process. It directs the focus of 
the  assessment  to  early  closure  of  referrals  that  have  no  terrorism/extremism  relevance 
allowing  resources to be focused on those susceptible to becoming terrorists or supporting 
terrorism. 

This new methodology was piloted in two regions (not including CTPSE) between November 
2023 and May 2024. Feedback indicates that it has been well received with staff commenting 
that it has assisted with justification and reinforcement of decisions around whether to progress 
a case or not. It has improved confidence in closing cases with no terrorism/extremism risk 
and  prevented  wasted  time. It  has  focused  practitioners  to  make  decisions  based  on  facts 
rather than preconceptions. It has been peer reviewed by two academic experts, and has had 
oversight from the Correctional Services Advice and Accreditation Panel who recently signed 
off on national roll out. The CTP network is currently in the training stages for adoption of this 
new methodology and are hopeful that it will be launched nationally in September 2024. 

The  requirement  to  embed  professional  curiosity  more  consistently  when  dealing  with 
potential terrorists is a theme within both Intelligence and Prevent. This is particularly relevant 
to  the  phenomenon  that  is  often  called  ‘Disguised  Compliance’  but  is  increasingly  being 
referred to by CTP as ‘Sincerity of Change’. Training in this area forms part of the initial Prevent 
‘Conversations’  module,  which  is  delivered  for  Prevent  staff  by  CTPHQ  (see  above). 

Additionally, CTPHQ ODU (Operational Development Unit) have recently released a new face-
to-face  training  package  entitled  ‘Interventions Welfare Training’,  which  specifically  focuses 
on Sincerity of Change. All CTPSE Prevent and Nominal Management Team (NMT) staff will 
be completing this training in 2024, and a request has been made to CTPHQ ODU for further 
sessions  to  include  FIMU  and  SERPIT  (South  East  Region  Prison  Intelligence  Team) 
personnel. 

You have raised a concern about how CTPSE handles repeat Prevent referrals in light of the 
fact that KS was referred to Prevent on four separate occasions between 2017 and 2019. CTP 
Prevent policy has now been amended to provide additional scrutiny to the cumulative impact 
of  repeat  referrals  related  to  the  same  subject,  even  if  the  subject  had  been  closed  from 
Prevent previously at an early juncture without management or interventions. In such cases, 
Counter Terrorism Case Officers (CTCOs) and their supervisors are now required to obtain 
the authorisation from a senior officer (Inspector or above) before closing a ‘repeat referral’ 
from the case management system. This change is intended to bring added assurance that, 
in cases where CTP has been notified of a radicalisation risk more than once, greater scrutiny 
is  afforded  to  the  case  circumstances  and  decision  making  within  it.  The  improvements  to 
supervision  and  scrutiny  within  Prevent,  set  out  above,  of  course  also  contribute  to  the 
effectiveness of this process. 

To  further  enhance  support  for  repeat  referrals,  CTPHQ  has  established  a  case  review 
process for cases  where  an  individual referred  to  Prevent  goes  on  to  commit or attempt  to 
commit high harm offences to establish if all opportunities to protect the public, and safeguard 
individuals were maximised. 

9 

 
 
 
 
 
 
 
 The  focus  of  CTPHQ’s  process  is  primarily  concerned  with  risk  identification  and 
organisational learning, not on finding fault nor apportioning blame. Where failings of duty or 
misconduct  are  identified,  these  are  brought  to  the  attention  of  the  Regional  Prevent  Co-
ordinator for their consideration and progression. 

MAPPA 

In addressing your concerns around MAPPA, I hope it will be helpful to outline the position 
regarding terrorist and terrorist risk offenders, who now fall under Counter Terrorist MAPPA 
(CT MAPPA), and also regarding non-CT MAPPA offenders. 

I should state at this juncture that I am also confident that the changes to intelligence handling 
and assessment by CTPSE set out above mean that an individual such as KS would now and 
in future be appropriately identified as being a terrorist risk offender, and so would be subject 
to the CT MAPPA process. 

In relation to CT MAPPA offenders, following the 2022 report of the Independent Review of 
) into MAPPA, a new category for such offenders was 
Terrorism Legislation (
created by the Crime, Sentencing & Courts Act 2022. Very considerable work, under Project 
Semper, has been undertaken to ensure that the new CT MAPPA process is effective. It is 
also  linked  to  the  ongoing  development  of  the  CT  Nominal  Management  capacity,  and  the 
joinder, through Project Eleos, of CTP’s national Nominal Management and Prevent functions 
into a single Interventions Capability. 

The  CT  MAPPA  process  ensures  that  there  is  a  forum  where  intelligence  can  be  shared 
appropriately,  with  input  from  the  right  subject  matter  experts  including  from  CTPSE  and 
HMPPS’ National Security Division. Attendance at CT MAPPA meetings from a member of 

the  CT  Nominal  Management  team  is  mandatory.  There  is  also  a  route  for  sensitive 
information to be shared with MAPPA chairs, via the Joint CT Prison & Probation Hub. 

MAPPA training is covered in the CTNM foundation course, with additional specific training for 
MAPPA chairs. Additionally all staff within the CTP network now  have access to a MAPPA 
awareness video, accessible to all training managers to share across their portfolios and as 
well as regional Training and Development Coordinators to share across their regions. This 
will be made mandatory for all CTPSE staff. 

I  know  that  these  changes  were  covered  extensively  in 

’s  and 

’s evidence to you. By way of an update, in 2024 CTPSE appointed a Detective Chief 

Inspector  into  a  newly  created  role  to  lead  its  NMT  and  fulfil  the  role  of  Lead  Responsible 
Officer for CT Nominal Management. This involves co-chairing MAPPA Category 4 Level 3 
meetings. Category 4 Level 2 meetings are chaired by a CTPSE Detective Inspector, and the 
number of individuals carrying out this role has been increased to provide additional resilience. 
All MAPPA chairs or co-chairs have undergone the national training required for the role, which 
includes training on when MAPPA referrals can be closed. 

As regards  non-CT MAPPA,  within the TVP force area this falls to TVP as the local force, 

10 

 
 
 
 
 
 
 
 
 
 
 rather than to CTPSE. There are national policies and guidance in respect of which I anticipate 
 also covered the changes 
the Secretary of State for Justice will respond to you. 
since 2020 in his witness statement at paragraphs 19-34, but I hope it will assist if I provide 
some additional detail on the action that has been taken. 

In 2022, TVP created a dedicated Management of Sexual or Violent Offenders (MOSOVO) 
department  to  ensure  there  was  structured  and  consistent  management  of  Registered  Sex 
Offenders (RSOs), as well as those being managed under Category 2 or 3 (violent offenders) 
of  MAPPA.  MOSOVO  received  an  uplift  of  staff  which  created  an  additional  Detective 
Inspector, one Detective Sergeant and four Constable posts. The sole role for these constable 
posts is to focus on Category 2 and 3 offenders. These staff are referred to as MAPPA officers. 
In addition to this uplift to TVP’s MAPPA capacity, a further four constable posts have been 

created for officers are specially trained in digital capability who can, for example, assist with 
searching for individuals who may be ‘wanted’. 
Most of TVP’s MAPPA work relates to the management of RSOs, of whom there are more 

than  1,000  in  the  TVP  area.  These  fall  within  Category  1  of  MAPPA.  The  overwhelming 
majority of them are managed at Level 1. 

There  are  currently  90  Category  2  or  3  offenders managed  within  the  Thames  Valley  area 
(although eighteen of those live outside of TVP). Of the 90, 66 are Level 2 and 24 are Level 
3. All bar two of the 90 are Probation-led, with TVP providing Probation with support in risk 
management. 

The MAPPA officers, alongside appropriate supervisors (Detective Sergeant for Level 2, and 
Detective Inspector for Level 3) represent TVP at all Level 2 and Level 3 MAPPA meetings for 
Category 2 or 3 offenders. They work with Probation and other partners in supporting the risk 
management  of  that  individual,  including  preparing  trigger  plans;  advising  on  tactics  and 
options available; engaging with and briefing the local police area; identifying cases/individuals 
that are suitable for MAPPA or should be considered for escalation to a higher MAPPA level. 
If an individual is police-led, then they will always be Category 3 and it is now well-understood 
that they therefore will always be at least under Level 2 MAPPA management. This will ensure 
there  are  regular  MAPPA  meetings  with  an  appropriate  Chair  and  multi-agency  panel  risk 
management. 

In terms of oversight, supervising Sergeants direct the work of the MAPPA officers through 
review  meetings,  and  there  are  weekly  meetings  between  Detective  Inspectors  and 
supervisors, and a monthly review by the Detective Chief Inspector for offender management. 
There is then a reporting and governance chain through the Head of Public Protection and 
Safeguarding (a Detective Chief Superintendent) to the ACC for Crime. This governance and 
supervision  structure  is  supported  by  a  data  dashboard,  the  Managed  Offender  Review 
Framework  (MORF)  that  enables  a  current  and  accurate  assessment  of  performance,  the 
identification and escalation of individuals where additional intervention is required, and focus 
on  areas  of  challenge  that  need  to  be  prioritised.  This  has  facilitated  a  much  stronger 
organisational  grip  on  TVP’s  management  of  sexual  or  violent  offenders.  For example,  the 

MORF is used to prompt risk level reviews for those managed by TVP at MAPPA Level 1. This 
framework enables a current and accurate assessment of performance and demand of not 

11 

 
 
 
 
 
 
 only  the  management  of  Registered  Sex  Offenders  in  Category  1,  but  also  those  being 
managed  under  Category  2  or  3.  In  addition  to  the  MORF,  there  is  a  weekly  management 
meeting, whereby any new information or intelligence received by TVP in the previous week 
is assessed. This is in addition to the ‘notify if’ flags that are applied to all Category 2 or 3 

offenders, which I address below. 

In  May  2023,  HM  Inspectorate  of  Constabulary  and  Fire  &  Rescue  Services  (HMICFRS) 
conducted a National Child Protection Inspection for the Thames Valley area. The subsequent 
report  commented  that  in  ‘Cases  assessed  involving  sex  offender  management  in  which 
children have been assessed as at risk from the person being managed’ there was ‘very good 

liaison and information exchange with the probation service, including holding joint police and 
probation meetings with the registered sex offender’ (pages 14 & 15). It also concluded on 
page 45 that: 

‘The  quality  of  work  with  partner  organisations  to  reduce  risk  from  registered  sex 
offenders is good. […] In our case audits we found very good liaison and information 

exchange with probation officers from the National Probation Service, who manage 
offenders subject to court-imposed licence restrictions.’ 

While this aspect of the inspection predominantly focused on TVP’s management of RSOs 

managed in Category 1, Category 2 and 3 MAPPA cases make use of the same information 
sharing processes with Probation and other partner organisations. 

You have already referred in the PFD report to changes such as notification flags on Niche to 
provide MAPPA with relevant information. I would like to expand on this change since 2019-
2020. The automatic ‘notify if’ marker for managed offenders notifies officers dealing with an 

individual that they are a managed offender, and directs them to the MOSOVO team, but also 
provides a notification to the MOSOVO offender manager whenever new information is added 
about that individual. It therefore provides assurance in two ways, to help MOSOVO offender 
managers to promptly make any necessary re-assessment threat, harm and risk, and to assist 
them in recording and sharing that information appropriately. 

While I acknowledge that there is always scope for better joint working, and close liaison with 
HMPPS as regards both CT MAPPA and non-CT MAPPA, I am confident that the position as 
regards MAPPA in the TVP force area is far better than it was in 2019-2020. 

Operation Plato and Force Incident Managers 

You have also raised concerns over the declaration of Operation Plato, and the demands on 
Force Incident Managers (FIMs). Both of these matters fall primarily to TVP, as the local force. 

The  current  version  of  the  Operation  Plato  guidance  is  clear  that  a  Tactical  Firearms 
Commander (TFC) based in a force control room is responsible for the formal declaration of 
Operation Plato. 

All FIMs are accredited Initial Tactical Firearms Commanders (ITFC) both occupationally and 

12 

 
 
 
 
 
 
 
 
 
 
 
 operationally. Prior to commencing the role, any officer who wishes to become a FIM must 
attend  and  pass  a  national  ITFC  course.  This  is  a  residential  course  consisting  of  both 
classroom  learning  and  scenario-based  assessments.  One  of  the  scenarios  covers  the 
declaration of Operation Plato and how to respond to a rapidly unfolding Marauding Terrorist 
Attack (MTA). If the course is successfully passed, then the FIM is considered occupationally 
competent. 

Once in role the FIM undergoes a period of mentoring, which on average is 3 months. They 
are allocated a mentor, who  will ensure the FIM reaches operational competency. This not 
only covers firearms command but any other incidents/tasks that the FIM would be responsible 
for  during  their  duty.  FIMs  are  required  to  present  evidence  in  a  portfolio  to  show  their 
operational competence. This evidence is reviewed and signed off by the Superintendent for 
firearms and Assistant Chief Constable for the Joint Operations Unit. To maintain operational 
competence  all  FIMs  are  required  to  attend  two  command-training  days  per  year.  For  the 
2023-24  training  year  one  of  the  training  packages  was  a  table-top  exercise  based  on  an 
Operation  Plato  scenario  at  Blenheim  Palace,  Oxfordshire.  The  training  was  attended  by 
Police, Fire and Ambulance service. It covered Joint Operating Principles for the Emergency 
Services and was structured around a series of paper feeds detailing an MTA. The issue of 
identifying an Operation Plato incident and the declaration of Operation Plato were specifically 
covered within this training package. 

Every FIM must attend an ITFC reaccreditation course every five years. This must be passed 
to maintain competence. This course covers the declaration of Operation Plato and includes 
a MTA scenario in the final assessment.  

In  October  2023  all  FIMs  attended  multi-agency  training  in  response  of  the  release  of  an 
updated Operation Plato policy. A training package is being developed to capture any new 
FIMs who have joined since this training. 

Following the internal reviews of the response to the deaths that were the subject of these 
inquests,  and  the  national  learning  from  the  Manchester  Arena  Inquiry,  a  number  of 
amendments have been made to the TVP Operation Plato plan. You have referred to some of 
these  in  your  report,  but  they  include  setting  out  clearly  that  only  the  FIM  (as  an  ITFC)  or 
another TFC could call Operation Plato, revisions to where the Plato control room would be 
situated  (so  that  it  corresponded  to  where  the  FIM  was  based,  rather  than  being  a  pre-set 
location), the implementation of a ‘hot line’ to the Strategic Firearms Commander, the creation 

of Bronze Supervisor and FIM staff officer roles once Plato is declared, the allocation of an 
additional  assistant  to  the  FIM,  and  the  implementation  of  the  Emergency  Services  Inter 
Control Talkgroup. Each of these is intended to contribute to relieving the pressure on a FIM 
as and when Operation Plato is called. 

I agree with your view that these arrangements need to be stress-tested, and am pleased to 
say  that  this  is  well  in  hand.  On  24  April  2024  TVP,  in  conjunction  with  other  agencies, 
undertook  Exercise  Pinnacle  at  Legoland  Windsor  in  conjunction  with  a  variety  of  other 
agencies. This tested the initial operational response to an MTA with a specific focus on the 
Operation Plato plan and control room communications in the immediate stages of such an 

13 

 
 
 
 
 
 
 
 incident. As well as the operational staff on the ground, over 100 volunteers were employed 
to act as members of the public suffering from various injuries. 

Exercise Pinnacle included the setting up of a dedicated Control Room, with the aim of stress 
testing the initial actions of the TVP Plato plan. This focused on the communication element 
with the aim of testing the effectiveness of the information flow and joint emergency service 
working.  

The scenario was initially led by Fire and Rescue as an emergency response to a report of a 
fire  at  the  entrance  to  Legoland.  It  then  developed  into  an  MTA,  with  reports  of  subjects 
attacking members of the public with bladed weapons. This triggered an unarmed, and then 
armed, response based on information provided to the Control Room. 

Twenty-four pre-written calls were introduced at specific points during the operation, with the 
purpose of testing the communication flow of information from call to FIM to operational staff 
on the ground. Initial informal feedback has acknowledged the effectiveness of the Plato plan 
and that it appears fit for purpose. 

A  formal  multi-agency  debrief  from  this  exercise  took  place  on  18th  June  2024,  and  the 
learning  from  it  will  be  incorporated  into  further  revisions  to  the  Plato  policy,  which  will  be 
tested again in future in the same manner.  

Publication 

I  acknowledge  that  this  response  will  be  sent  to  the  Chief  Coroner  and  other  Interested 
Persons, and that you may send it to any other person who you believe may find it useful or 
of interest. I have no representations to make regarding publication of this response. 

Conclusion 

I would like to again express my gratitude for the opportunity to respond to your PFD report, 
and for  the  care and attention  which  you brought to the  inquests. TVP  and  CTPSE  remain 
committed to a close relationship with the families of Joseph Ritchie-Bennett, David Wails and 
James Furlong, who have made clear their wish to be kept up to date on the changes and 
reforms we are implementing as a result of the Inquests. In the same spirit, I would be very 
happy to meet with you to discuss any of the matters covered in your findings, the PFD report, 
or this response, if you would find that helpful at all. 

Yours sincerely, 

Chief Constable 

14
Response from The Home Office (PDF)
SIR ADRIAN FULFORD PC 

By email only 

Home Secretary 

2 Marsham Street 
London SW1P 4DF 

9 September 2024 

FORBURY GARDENS REGULATION 28 REPORT TO PREVENT FUTURE DEATHS 
RESPONSE OF THE SECRETARY OF STATE FOR THE HOME DEPARTMENT 

Thank  you  for  all  the  diligent  work  you  and  your  legal  team  have  undertaken  during  the 
inquests arising from the deaths of James Furlong, Joseph Ritchie-Bennett and David Wails 
in the Forbury Gardens terror attack of 20 June 2020. Before responding to your letter of 20 
May 2024, I would like to express my deepest condolences to the families and loved ones 
of  James,  Joseph  and  David,  as  well as my  thoughts  to  all those  impacted  by  this tragic 
incident. It is crucial that we do everything within our power to prevent this from happening 
again. 

I am grateful for your recognition in the Regulation 28 Report to Prevent Future Deaths (the 
Report) that the Home Office has made several improvements since this tragic incident. I 
fully  accept  and  support your  conclusion  that  there must  be  effective monitoring  of  these 
improvements to ensure they meet their  purpose and I address the relevant measures in 
this regard below.  

I  would  like  to  acknowledge  that  the  events  described  cover  a  period  under  a  previous 
government and reiterate my commitment as Home Secretary to treat the failures with the 
utmost  seriousness.  I  will  be  overseeing  the  proper  implementation  of  recommendations 
and any new commitments made.  

Prevent 

The  Home  Office,  along  with  our  partners,  continuously  drives  improvements  to  our 
capabilities to strengthen our approach to supporting those vulnerable to being drawn into 
terrorism. We do this through regularly reviewing elements of the Prevent system, both at 
an  operational  and  strategic  level.  As  I  will  detail  further  in  my  response,  this  includes 
conducting process reviews, case assurance and producing annual statistics to inform and 
improve  policy  and  strategy.  We  also  commit  to  implementing  improvements  from  the 
independent  evaluation  of  the  Home  Office  Channel  programme,  which  is  currently 
underway and expected to report in 2025/20261. As Michael Stewart, Director of Prevent, 

1 As stated in Michael Stewart’s witness statement, evaluation of the Prevent system is a priority. We are 
evaluating Channel’s effectiveness to understand its impact on counter-terrorism outcomes and risk. The 
core objective is to fill these evidence gaps by consolidating best practice in preventing or countering violent 
extremism (‘P/CVE’), evaluation, and trialling innovative approaches to significantly build the evidence base 
and to shape government responses to the threat of violent extremism. This will be an independent 
evaluation, conducted by Ipsos and University College London. This is a significant piece of work and will be 
the first of its kind in this field.  

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 said in his evidence, we know that no programme of this type can offer a complete guarantee 
of success, however, we must do everything we can to ensure we are working to the best 
of our ability to stop such terrible attacks occurring in future. Any failure must be treated with 
the utmost seriousness.  

The Home Office is also keeping the Joint Enhanced Casework Team’s (JECT) operations 
under close review and is continuing to develop and improve its processes. This includes 
oversight  of  JECT  to  ensure  that  the  range  of  interventions  available  are  effectively 
managing  individual  cases.  Oversight  is  through  the  CONTEST  Board  which  is  a  senior 
officials board that meets monthly to monitor the implementation of CONTEST and ensures 
that we maintain collective decision-making and effective co-ordination across government. 
It  brings  together  senior  operational  and  policy  leaders  from  each  of  the  government 
departments  included  in  CONTEST,  Counter  Terrorism  Policing  Headquarters  (CTPHQ) 
and the security and intelligence agencies. As well as being part of regular discussions in 
the monthly CONTEST board structure, every six months JECT’s performance is considered 
as one part of CONTEST’s wider performance review. 

The failure to maintain and disseminate an adequate intelligence picture: Prevent2  

The Home Office's Prevent directorate provides the strategic direction for Prevent, including 
Prevent  relevant  training  to  non-police  Prevent  statutory  partners  within  local  authorities. 
The  police  are  responsible  for  managing  the  terrorism  risk  of  individuals  throughout  all 
stages of the Prevent pathway, as well as the policy, assessment tools, and training of police 
officers and staff conducting these assessments. As all of KS’s referrals were closed at the 
initial assessment stage by  Counter Terrorism Policing  Prevent officers, the Home Office 
Channel  programme  did  not  manage  the  case.  Therefore,  effective  monitoring  of  the 
operational Prevent issues raised in the Report is best addressed by CTPHQ.  

However, as part of the Home Office’s efforts to improve the Prevent system, we are working 
with partners including CTPHQ on multiple projects. These aim to better manage risk and 
improve the quality of our data, to further enable robust monitoring of the effectiveness of 
Prevent.  I  have  set  out  the  developments  and  monitoring  in  place  for  the  three  areas  of 
concern identified in the Report for Prevent, which are within the Home Office’s remit. 

a)  Overall failure to revisit and review the overall intelligence and risk assessment 

picture in light of newly acquired information  

I  understand  that  the  Home  Office  and  CTPHQ  launched  a  new  joint  Prevent  case 
management system in May 2024. In developing this system, I am told we have ensured 
that  when  a  new  Prevent  referral  is  registered,  any  previous  referrals  are  automatically 
flagged to ensure this information is fully considered during the initial assessment stage and 
throughout  the  individual’s  Prevent  pathway.  I  am  concerned  about  the  specific  issue  of 
repeat Prevent referrals falling below the threshold and am committed to look closely at this. 
This new case management system also provides CTPHQ and the Home Office access to 
data trends, which allows for consideration of any outliers in decision making. These outliers 
can be flagged for potential further action. This includes additional training for the Counter 
Terrorism Case Officers (CTCOs)3, who undertake the assessment of Prevent referrals, or 
the Channel panel, or further investment in the local area if the threat has increased.   

2 Responding particularly to paragraphs 18-21 of Judge Coroner’s Report of 20 May 2024. 
3 CTCOs are responsible for managing referrals and cases through the Channel process (including ensuring 
case information is kept up to date on the case management system), reviewing and amending the Prevent 
assessment framework, assessing any escalating risk, and transferring cases to police led partnership/Pursue 
where appropriate. 

2 

 
 
 
 
 
 
 
 
 As  I  understand  Chief  Constable 
  will  also  be  addressing  in  Thames  Valley 
Police’s response  to  you  from  the  operational perspective,  the  Home  Office  and  CTPHQ 
have also worked with the national CT Assessment and Rehabilitation Centre (CT-ARC)4 to 
develop a new Prevent  assessment framework (PAF). I understand that this replaces the 
Vulnerability assessment framework and is designed to ensure that the triaging of referrals 
into Prevent is consistent, rigorous, and proportionate. I am told the PAF, which has been 
independently endorsed, will ensure that thresholds and decision-making are implemented 
consistently across all ideological threats by creating a framework that is easily understood, 
easily completed, and supports CTCOs in their decision making. It covers referral details, 
indicators  of  concern,  a  susceptibility  assessment,  engagement  factors,  intent  factors, 
capability factors, protective and risk mitigating factors, and support planning. The PAF also 
captures  repeat  referrals  to  ensure  consideration  is given  to  cumulative  risk,  which  is an 
issue  I  am  concerned  about.  I  understand  that  this new tool  is  more  reflective  of  current 
research and understanding of those vulnerable to being drawn into terrorism; it will identify 
referrals suitable for Prevent and the Channel process earlier and more accurately; and it 
will improve the quality and effectiveness of risk assessments of referrals adopted as cases.  

The PAF is being rolled out in Autumn of 2024 to all regions. Prior to using it, CTCOs must 
attend an assessed training day to become familiar with the PAF, how to complete it, how it 
fits into current processes, and to practise completing it. During the training day there are 
three  assessment  points  where  attendees will  be  assessed  as  either ‘Ready’ or ‘Not  Yet 
Ready’ to complete a PAF for live cases. If awarded ‘Not Ready’, attendees will be provided 
a further opportunity to complete the task training. 

I understand that the PAF has been piloted since  November 2023 in the South-West and 
Eastern regions. During this pilot stage, as well as receiving feedback on the PAF, I am told 
that CT-ARC have been quality assuring the PAF process monthly to assess the quality of 
use and completion by looking at how integrity to the guidance is upheld. We will continue 
to  monitor  the  PAF  with  CT-ARC  and  CTPHQ  to  ensure  it  is  robust,  efficient,  evidence-
informed,  operationally  viable  and  well-integrated  into  the  current  system.  Details  of  how 
longer-term quality assurance will be conducted will be finalised in August ahead of national 
PAF rollout later in autumn. However, this will include continuous and regular review of PAF 
use, as well as a longer-term evaluation. As the PAF is embedded into the Prevent pathway 
it will also feature within existing Home Office quality assurance systems, specifically quality 
assuring the PAF’s operational application by Channel panels in the assessment of risk and 
provision of support. 

b)  Failure  by  Prevent  to  correctly  assess  risk,  by  over  emphasising  mental  health 

difficulties 

Improving the quality of Prevent referrals 

4 The CT Assessment and Rehabilitation Centre (CT-ARC) is a national HM Prison & Probation Service 
(HMPPS) body comprising a network of specialist psychologists, probation officers, and other staff who focus 
on standards for risk assessment, risk reduction and rehabilitation. 

3 

 
 
 
 
 
 
 
 
 In 2023 the Home Office updated the Prevent duty guidance (England and Wales)5 and the 
Channel  duty  guidance6.  My  understanding  is  that  this  is  to  better  enable  those  sectors 
subject to the Prevent duty (such as local authorities, police, health, education, and prisons 
and probation) as well as those working on Channel panels, to be effective at understanding 
and mitigating terrorism risk, and to have structures in place that identify and support people 
vulnerable  to  radicalisation.  The  new  guidance  provides  clearer  advice  on  how  to 
understand  and  manage  risk,  including  by  ensuring  comprehensive  training  and  risk 
assessments take place. It also introduces new tools for frontline practitioners to ensure that 
those  meeting  the  Prevent  threshold  are  progressed  for  Prevent  specific  support,  with  a 
focus  on  ideology  as  a  determinant  of  Prevent  thresholds.  I  outline  relevant  training 
packages on ideology later under the subheading of training. 

Our updated  guidance  advises  front-line  staff  to  use the  national Prevent  referral form  to 
submit their initial concerns. This single Prevent national referral form, while not mandatory, 
has been provided to all partners to promote consistency. I have been told that it has been 
designed  to  be  completed  by  front-line  staff  who  may  not  have  specialist  knowledge  of 
radicalisation.  It  requests  information  around  ideologies,  behaviours  and  relevant factors, 
encouraging the person submitting the referral to provide as much relevant information as 
possible.  This  is  to  ensure  specialist  officers  can  make  an  effective  assessment  of  risk, 
including  in  the  PAF,  and  improve  data  recording.  We  have  also  updated  the  GOV.UK 
Prevent page7 to make clear that referrals should be made where there is a genuine concern 
of radicalisation, and that ideology should be a critical consideration.  

We are using Prevent referral data (from the new case management system) and training 
data to identify where the quality of referrals is lower, or not in line with the risk in that area 
or sector. This has enabled us to better target Prevent outreach and training to improve the 
quality  of  referrals.  Alongside  this,  a  refreshed  list  of  ideology  categories  has  also  been 
created for use in the new case management system, which will be accompanied by updated 
training and guidance for case officers to ensure accurate recording of data and evidence 
about ideology. We will review the ideology categories on an annual basis to ensure they 
are reflective of the wider ideological picture and routinely monitor Prevent data, carrying 
out  dip  sampling  to  provide  assurance  that  there  are  no  disparities  in  decision-making 
throughout the Prevent pathway. 

Improving mental health management within Prevent cases 

The relevance mental ill-health conditions play in the threat varies by case. Mental ill-health 
can contribute to the radicalisation of some individuals, acting as a risk factor, while in other 
cases it may act as an inhibitor.8 The majority of Prevent practitioners are not mental health 
professionals  and  anecdotal evidence  from  those  practitioners indicates  that  they  remain 
concerned  about  the  incidence  of  diagnosed  and  undiagnosed  mental  health  conditions 
within Prevent casework. That is why it is essential that there is multi-agency involvement in 
the Channel process so that Channel panels can pull on the professional expertise of mental 
health practitioners when progressing cases. This includes advice on the type of activities 

5 England and Wales: https://www.gov.uk/government/publications/prevent-duty-guidance.  Statutory 
guidance for Scotland was issued on 7 May 2024 under Section 29 of the Counter-Terrorism and Security 
Act 2015: https://www.gov.uk/government/publications/prevent-duty-guidance-for-specified-authorities-in-
scotland.    
6 The Channel duty guidance for England and Wales: https://www.gov.uk/government/publications/channel-
and-prevent-multi-agency-panel-pmap-guidance. 
7 https://www.gov.uk/guidance/get-help-if-youre-worried-about-someone-being-radicalised.  
8 See p. 15, paragraph 27 of CONTEST 2023: https://www.gov.uk/government/publications/counter-terrorism-
strategy-contest-2023. 

4 

 
 
 
 
 
 
 that should be included  in a support package9, as well as attending panels to provide an 
update on the progress of support given.  

The Clinical Consultancy Service (CCS)10 can also be drawn on to provide Prevent officers 
with  advice,  guidance  and  options  to  help  manage  the  individuals  in  their  casework  with 
mental  health  needs.  Through  this  service  Prevent  officers  are  given  access  to  a  multi-
disciplinary team, including NHS mental health nurses, psychologists and psychiatrists. The 
Home Office are part of the oversight board of the CCS to monitor its effectiveness in helping 
to reduce the risk of those individuals vulnerable to being drawn into terrorism. 

The PAF is used by Channel to guide decisions about whether someone needs support to 
address  their  radicalisation  risk,  and  the  nature  of  support  that  they  need.  PAF  training 
makes  clear  that  mental  health  concerns  can  be  a  potential  indicator  of  concern  or  a 
safeguarding factor, directing that any mental health support being received may form part 
of the information gathering process on an individual who has been referred. Mental health 
and complex needs are also considered as potential engagement factors, so consideration 
must be given as to whether the existence of any mental health difficulties could contribute 
to  make  an  individual  more  vulnerable  to  engaging  with  an  extremist  group,  cause  or 
ideology. 

As a challenging area for research, we recognise the importance of ensuring that Prevent 
practitioners  have  up  to  date  guidance  which  assists  them  in  understanding  how  best  to 
understand the relevance of mental health for an individual. The latest  
Channel  duty  guidance  reinforces  that  having  mental  health  issues  does  not  exclude  a 
person from being suitable for Prevent. Rather, any relevant mental health issue is one of 
several factors which should guide decisions about whether the individual needs support to 
address their risk of radicalisation, and the kind of support that they need. Several of the 
case studies within the guidance have mental health elements to illustrate this. The Home 
Office will continue in its guidance to be clear that for Prevent, cases should not be presented 
as a binary choice between mental health interventions or counter-terrorism ones. We keep 
our operational policy approach to Prevent under constant review, and we will continue to 
look  at  mental  health  issues  and  neurodiversity  as  part  of  this,  to  identify  areas  we  can 
strengthen. 

To further this point, we have written to all Channel Chairs to raise awareness of the concern 
in  the  report  that  KS’s  risk  assessment  was  incorrectly  focused  on  his  mental  health 
difficulties, and to reinforce that the purpose of Channel is both to safeguard individuals and 
to manage the potential terrorist risk they may pose. Therefore, the existence of or need for 
wraparound mental health support for an individual does not negate the need for the person 
to receive Prevent support. We also reminded Channel Chairs that the CCS is available to 
provide Prevent officers with advice, guidance and options to help manage the individuals 
in their casework with mental health needs.  

c)  Failures of training, supervision and selection  

Training 

9 See paragraph 157 of the Channel duty guidance 2024 for examples on the type of support which could be 
offered: https://www.gov.uk/government/publications/channel-and-prevent-multi-agency-panel-pmap-
guidance  
10  The  Clinical  Consultancy  Service  (CCS)  was  launched  by  CTPHQ  on  2  April  2024,  (building  on  the 
Vulnerability Support Hub pilots which you heard from several witnesses on) to provide access to a nationally 
consistent service. 

5 

 
 
 
 
 
 
 
 
 
 The Home Office Prevent directorate is one small part of the Prevent system, which operates 
at  a  mainly  strategic  level.  The  successful  delivery  of  Prevent  is  dependent  on  the 
engagement of national, regional and local partners across multiple sectors, including the 
community and voluntary sector. Public sector frontline staff have been identified as a key 
group that can make an important contribution to identifying and referring people who may 
be at risk of radicalisation. Likewise, the success of the Channel programme is dependent 
on the co-operation and co-ordinated activity of partners so that a wide network of support 
is brought together to reduce a person’s terrorism or radicalisation risk. 

Prevent staff in the Home Office 

In July 2023, I am told, we created and started implementing a Prevent Professionalisation 
Plan to upskill Home Office officials working on Prevent through compulsory training and a 
new induction programme. All directorate staff were mandated to complete the Prevent duty 
training (both the awareness course and the referral course, which are part of the e-learning 
package referred to below)11 by end of September 2023. All directorate staff must retake the 
awareness and referral courses every two years and complete the refresher course in the 
year between. All new starters must complete the awareness and referrals courses within 
three  months  of  starting  in  role,  as  part  of  their  wider  Prevent  induction.  In  addition,  a 
specialist  ideology  training  package  was  developed  by  the  Commission  for  Countering 
Extremism  (CCE),  which  provides  the  government  with  impartial  and  expert  advice  on 
terrorism  and  extremism  matters.  I  understand  that  this  was  rolled  out  as  face-to-face 
training  for  Prevent  directorate  staff  by  the  CCE  in  March  and  April  2024,  training 
approximately 88% of the directorate in post at the time. Future training requirements will be 
kept under review. 

Frontline staff subject to the Prevent duty 

I have been told that the Prevent duty e-learning training package was updated in August 
2023. Each of the four courses12 has specific learning outcomes to support awareness of 
Prevent and radicalisation; making a referral; and the Channel programme. Following this 
refresh, we monitor training uptake monthly and publish monthly performance data13. Over 
1.4 million people have completed the training since it went live in August 2022. The current 
process provides learners with a certificate at the end of the training which they keep for 
their own records and to use as evidence for completion of training. I have been told that 
some sectors have created a Prevent learning goal/objective on their internal performance 
or training systems, which requires completion of the Home Office e-learning, particularly 
for front line staff. Staff upload a copy of the learning completion certificate to the platform 
to demonstrate it has been completed. This has aided supervisors at a local level to have 
consistent  oversight  of  training. The  published  monthly  regional  performance  data14, 
provides an insight into the extent of training delivery at a regional level. Whilst this would 
not be suitable for individual local authorities to monitor training, it does provide insight into 
training uptake across different regions.  

A new face-to-face training package to raise awareness of Prevent has also been developed 
and is being implemented. This is designed to help attendees understand what may make 
people vulnerable to radicalisation and understand more about the local context.  This will 
enable specialist trainers to have more detailed discussions, including on how to make high 
quality  referrals that  are  relevant  to  Prevent.  It  also  enables  training  to  be  tailored  to  the 

11 https://www.gov.uk/guidance/prevent-duty-training. 
12 https://www.gov.uk/guidance/prevent-duty-training. 
13 https://www.support-people-susceptible-to-radicalisation.service.gov.uk/service-performance.  
14 https://www.support-people-susceptible-to-radicalisation.service.gov.uk/service-performance.  

6 

 
 
 
 
 
 
 
 specific sector, location or role. During the pilot waves we are testing the service with existing 
trainers, and new Prevent training leads across England, Scotland and Wales. I understand 
the pilots have been running since 20 May 2024, and are being run nationally across health, 
local authority and education sectors with the final pilot in early September. We are piloting 
this  service  until  late  autumn,  with  wider  rollout  to  follow  once  any  final  changes  and 
improvements have been made based on user feedback.  

We are also developing a new ideology training course to include as part of our face-to-face 
and  e-learning  training  packages.  The  course  has  been  developed  with  experts from  the 
CCE and other subject matter experts within the Home Office. The ideology course includes 
modules on Islamist ideology, Extreme Right-Wing ideology, antisemitism and other types 
of  concern.  It  is  being  developed  to  support  frontline  staff  under  the  Prevent  duty  to 
understand  the  ideological  nature  of  terrorism  and  to  enable  them  to  make  an  informed 
referral where the ideology present is identified and known. This will provide learners with a 
basic understanding of extremist ideology and radicalisation. The training will outline factors 
to consider when making a referral, such as the importance of ideology, common narratives, 
and  a  reflection  of  the  current  threat  picture.  This  increased  understanding  will  support 
sectors  in  making  more  appropriate  and  relevant  Prevent  referrals  that  can  progress  to 
Channel. The ideology training course will be available across the education, health, police 
and  local  authority  sectors in  England,  Scotland, and  Wales.  The intention  is for suitable 
trainers from each of these sectors to deliver in-person or virtual sessions, with the training 
package available on our online platform for registered trainers to access and deliver. I have 
been  told  that  user  research  sessions  were  delivered  with  trainers  across  four  identified 
sectors  for  police,  education,  local  authority  and  health  during  January  to  early  February 
2024. The training modules were allocated to regions in accordance with the risk and threat 
in the area to ensure it was relevant to the local audience. Sessions were delivered in both 
virtual  and  in-person  settings  to  gather  feedback  and  understand  the  impact  of  different 
methods.  Final iterations  were made  in  response  to  feedback  from  learners and  trainers. 
The training will be piloted and rolled out alongside the face-to-face training package in late 
autumn. 

Channel panel members 

Alongside sector specific training, Channel panel members and partners should complete 
the previously mentioned Prevent duty training courses. The Channel course of the Prevent 
e-learning package has tailored content for Channel chairs and for those who are new to 
attending Channel panels. Channel chairs and deputy chairs are also required to complete 
mandatory  ‘delivering  Channel  locally’  training  within  six  months  of  starting  these  roles, 
which is centred on building understanding of the Channel duty guidance requirements and 
standards. The Home Office has also commissioned a range of additional training (including 
training on different ideologies, the online threat picture and neurodivergence)  to meet the 
needs of Channel chairs, deputy chairs and panel members in fulfilling the requirements set 
out within this guidance and to understand the national risk and threat picture.  

Supervision and assurance 

Identifying  and  supporting  those  vulnerable  to  radicalisation  helps  to  keep  us  safe  and 
specified authorities play a vital and valued role in this. The Prevent duty guidance sets out 
best practice and expectations for each sector and, by following it, specified authorities will 
be well placed to comply with the duty, underpinned by the Counter-Terrorism and Security 
Act  2015  (CTSA  2015). The  guidance  details  at  Section  4  the  monitoring  and  assurance 
arrangements  for  each  sector  subject  to  the  Prevent  duty.  There  are  a  range  of  existing 

7 

 
 
 
 
 
 
 powers  available  to  encourage  compliance15.  However,  where  a  specified  body  is  not 
complying with the duty, the Secretary of State may use the power of direction under Section 
30 of the CTSA 2015 to give directions. These directions may be enforced by court order.   

I  have  been  told  that  in  support  of  our  role  in  supervising  local  delivery,  in  2021  we 
established  an  expert  network  of  region-based  Home  Office  Prevent  Advisers  who  work 
together  with  partners  across  England,  Scotland  and  Wales  to  raise  Prevent  delivery 
standards  and  hold  local  authorities  to  account.  Prevent  Advisers  also  deliver  an  annual 
assurance exercise, which assesses the extent to which local authorities are meeting the 
Prevent duty. As part of the Prevent duty guidance refresh in 2023, I understand that the 
Home  Office  updated  its  assurance  process  to  help  ensure  that  local  authorities  are 
delivering their statutory Prevent duty in line with the  Prevent duty guidance. The Prevent 
duty  toolkit  for  local  authorities16  outlines  eight  benchmarks  that  Prevent  delivery  is 
measured against and includes suggested examples of good and best practice. The Home 
Office  has  worked  with  all  local  authorities  in  England  and  Wales  to  complete  a  Prevent 
assurance exercise for FY23/24 against seven of the eight Prevent duty benchmarks17. This 
is the third year that we have assessed local authorities in this way. This exercise provides 
the  Home  Office  with  assurances  that  the  Prevent  duty  is  being  met  in  proportion  to  the 
threat and risk in each area. It also helps to understand where there are gaps in Prevent 
delivery, to identify and share good practice, and to improve performance and standards, 
which often involves direct support from the Home Office. 

Following  the  introduction  of  the  Channel Quality  Assurance  Framework in  2021,  we  are 
introducing an improved and strengthened quality assurance process. This includes routine 
assessment of Channel panel performance and case management. We will also utilise the 
data  trends  drawn  from  the  new  case  management  system  to  identify  areas  (regional  or 
thematic) to provide additional case assurance and direct improvements where needed. We 
will  use  this  quality  assurance  process  and  performance  monitoring  to  further  drive-up 
standards of delivery. I have been informed that this process started in April 2024 and initial 
results are expected to be shared with Channel panels in April 2025. 

Where serious case reviews, safeguarding adult reviews or domestic homicide reviews are 
triggered due to a serious incident or a death involving a person supported through Channel, 
input from local Prevent practitioners (including the Channel chair and CTPHQ) should be 
sought  to  support  the  identification  of  practice  improvements  and  shared  learning.  The 
Home  Office  is  currently  working  with  relevant  partners  to  raise  awareness  of  this  new 
process  to  ensure  that  the  Home  Office  is  notified  in  these  instances.  Report  findings 
detailing  recommendations  and  any  identified  learning  should  also  be  forwarded.  Where 
terrorism offences or incidents of serious violence are committed by people with a Prevent 
history and a statutory review process is not triggered, a Prevent learning review may be 
undertaken  to  identify  national  learning  and  drive  system  improvement.  Where  these 
instances are assessed as high harm by the Home Office, Prevent learning reviews may run 
in tandem with statutory review processes. The focus of a Prevent learning review is not to 
apportion blame, but to use reviews to identify good practice and where improvements are 

15 For example, for local authorities: if there are concerns about compliance, the Home Office may consider 
the appropriateness of using existing mechanisms such as appointing an inspector, requiring the local 
authority to undertake specific actions, requesting an inquiry, or issuing a direction. Powers under the Local 
Government Act 1999 or the Local Government and Elections (Wales) Act 2021 may be used. 
16 https://www.gov.uk/government/publications/prevent-duty-toolkit-for-local-authorities. 
17 An assurance of the eighth benchmark, Channel, was not completed, as this is subject to a separate 
process (i.e., the Channel Annual Assurance Statement).  

8 

 
 
 
 
 
 needed,  which  can  inform  and  strengthen  Prevent  legislation,  policy  or  practice  at  the 
national level.   

A new independent Standards and Compliance Unit (StaCU) was established in February 
2024 by the CCE. This provides a clear route for both the public and practitioners to raise 
concerns about Prevent activity and delivery18. The unit triages complaints to the relevant 
body  for  investigation  and  ensures  these  complaints  are  handled  promptly,  fairly  and 
transparently. The unit monitors data trends and any trends are reported into the Prevent 
Ministerial  Oversight  Board19  (PMOB),  where  Ministers  can  instruct  investigations  into 
specified authorities  where  there  is concern  over  a  failure  to  discharge  the  Prevent  duty. 
Prevent senior management will also consider the findings of StaCU outside of the PMOB 
meeting cycle. This acts as a quality assurance mechanism for the Prevent system to ensure 
any systemic issues are resolved quickly and that Prevent continuously improves. 

Selection of support providers 

Multi-agency involvement in the Channel process is essential to ensure that people at risk 
of  radicalisation  have  access  to  a  wide  range  of  support,  from  specialist  services  to 
diversionary activities.  As mentioned above,  Channel panels can pull on the professional 
expertise  of  mental  health  practitioners  when  progressing  cases.  It  also  ensures  the  full 
range of information is accessible to the panel, so that ideological drivers, risk, vulnerabilities 
and support needs can be fully assessed. Therefore, the Channel panel chair is responsible 
for  inviting  the  appropriate  representatives  to  each  meeting  as  panel  members  and  for 
establishing  effective  relationships  across  partners  of  the  panel  to  ensure  effective  co-
operation, information sharing, attendance at panel meetings and delivery of support. 

Where  a  Channel  panel  identifies  that  an  individual  would  benefit  from  an  Intervention 
Provider (IP), the Channel  case officer20 is responsible for arranging the provision of that 
service.  IPs  are  vital  to  Prevent  and  work  directly  with  Channel  and  Desistance  and 
Disengagement  Programme  participants  to  help  reduce  their  risk,  often  challenging  and 
supporting individuals with a wide range of complex needs. IPs are experienced in assessing 
ideological  drivers,  possess  an  expert  understanding  of  radicalising  extremist  narratives, 
can counter these narratives, and receive comprehensive  Home Office training to support 
their work. When commissioning an IP the priority will always be to match the specific IP 
skillsets to the requirements of the person receiving support, and so Channel case officers 
will present three potential IPs to the panel wherever possible.  

IPs work on a one-to-one basis with people who are vulnerable and potentially dangerous, 
and they are therefore subject to a rigorous recruitment process and must receive ministerial 
approval to  work on  the  programme.  Strengthened due  diligence processes for IPs  have 
been in place since July 2020. Continued professional development and professionalisation 
of the network of IPs is essential. A comprehensive IP training programme (called the IP 
Professionalisation  Programme)  was  introduced  in  2019  in  support  of  their  roles,  which 
includes a range of mandatory skills-based courses to improve consistency in delivery, and 
to increase their knowledge and understanding of key themes. A monthly operational update 
ensures IPs are regularly provided with a contemporaneous picture of online activism. This 

18 Complaints about how the Prevent duty has been applied, including any problems with Prevent training, 
can be made online: https://www.gov.uk/guidance/make-a-complaint-about-prevent. 
19 The Prevent Ministerial Oversight Board is chaired by the Security Minister and convenes bi-annually. The 
PMOB increases oversight of Prevent, enables a truly cross-government approach to Prevent and is a clear 
decision-making forum. 
20 Any reference to the Channel case officer refers to either the police CTCO or the Home Office-funded 
Channel co-ordinator, employed by the local authority. 
9 

 
 
 
 
 
 
 
 is intended  to  assist IPs  in  maintaining  their  understanding of  how their  referrals may  be 
using social media applications to connect with extremists, as well as their appreciation of 
the extremist content found on these platforms. 

Immigration Status/Deportation Issues21  

Immigration  Enforcement  is  committed  to  continuous  learning  and  improvement.  It  is  a 
cause  of  utmost  concern  to me  that,  although  you  concluded the failings  identified  within 
Immigration Enforcement did not contribute directly to the deaths of James Furlong, Joseph 
Ritchie-Bennett and David Wails, you found that ‘in different circumstances [they] could have 
been of real significance’.  

Your Prevention of Future Deaths Report recognises the significant systemic changes within 
the Home Office since KS’s case was handled by Immigration Enforcement, including the 
reintroduction of exit checks, the new workflow management system (Define), improvements 
to the Voluntary Returns Service and the introduction of the Detention Gatekeeper. These 
 to the 
wide-ranging improvements were set out in the witness statements of 
inquest. 

I  elaborate  in  this  response  on  the  changes  outlined  by 
  in  relation  to  Foreign 
National Offenders Returns Command  (FNORC) staff training; subsequent developments 
since the inquest; and, I outline the assurance review which is now underway to evaluate 
the impact and sufficiency of the full breadth of changes which have taken place since KS's 
Enforcement. 
in 
case 

Immigration 

handled 

was 

The training requirements of Foreign National Offenders Returns Command staff 

The FNORC People Strategy and the FNORC Learning & Development Strategy set out the 
command’s high-level approach to training and staff development. The strategies were last 
refreshed in November 2022 and will be next revisited in November 2024. Under the current 
’s  witness  statement  of  15 
strategies,  which  were  briefly  touched  upon  in 
November  2023  (paragraph  6),  the  command’s  learning  needs  are  met  by  a  14-person 
operational training team.  

For  new  entrants,  the  training  team  delivers  intensive  initial  casework  training,  initial 
administrative officer training and early in-role support. For existing staff, the team provides 
ongoing  professional development.  This  includes  refresher training,  offered  several times 
annually, for any staff who are changing role or who are returning to work after a significant 
period  of  absence.  The  training  team  also  provides  role-specific  training,  such  as  line-
manager  training,  to  meet  demand,  and  targeted  topical  training  where  further  learning 
needs  are  identified  or  where  legislative,  policy  or  process  changes  necessitate  staff 
updates.  The  team  also  ensures  staff  are  compliant  with  their  mandatory  learning 
requirements,  including  participation  in  courses  introduced  in  response  to  the  Windrush 
Lessons Learnt review. 

Since  June  2023,  I  am  told  that  the  training  team  has  included  an  innovative  ‘mobile 
mentoring’ unit of geographically mobile staff with significant casework experience, deployed 
to  provide  consistent,  face-to-face  support  to  new  caseworkers.  I  understand  that  the 
approach was initially piloted between June 2023 and March 2024 to meet the needs of a 
large intake of new staff. During this period, 237 staff received mentoring support, and the 
pilot was subject to an internal evaluation in March 2024.  

21 Responding to paragraphs 47-51 of Judge Coroner’s report of 20 May 2024. 

10 

 
 
 
 
 
 
 
 
 
 
 Following the internal evaluation, I am informed that Senior Civil Servant (SCS) approval 
was given on 1 April 2024 for the mobile mentoring unit’s work to be made permanent and 
to transition from being solely for new starters to include all staff, in line with business needs. 
The mentors’ remit now includes embedding and refreshing the skills of existing staff through 
a  coaching-centred  approach  on  live  cases,  based  on  thematic  training  needs  identified 
through staff feedback and quality assurance. Current areas of focus include the duties of 
administrative  grade  staff,  casework  decision-making  and  the  writing  of  release  referrals. 
The unit remains flexible to shape its future offer to meet staff and business needs. 

The current focus of the wider training team is the expansion of its learning and development 
support to non-traditional or non-casework functions within FNORC. This started with the 
design,  in  July  2024,  of  a  casework  overview  package  for  staff  working  in  the  Electronic 
Monitoring  (EM)  Hub,  to  complement  their  existing  functional  training  and  ensure  their 
understanding  of  the  wider  FNORC  processes  within  which  their  work  sits.  The  training 
package will be trialled in August and September 2024 before being made available to all 
relevant EM Hub staff. The training team will focus next on analysing and responding to the 
training needs of the Intake & Triage team (scheduled for Autumn 2024) and then those of 
the Criminality Assessment and Returns Unit (late 2024/early 2025). 

In  addition,  since  May  2024,  I  am  told  that  an  improved  supervision  offer  has  been 
introduced within FNORC and will be fully implemented across all sites by the end of 2024. 
The  role  of  the  Senior  Caseworker  (a  Higher  Executive  Officer  grade  post)  has  been 
refocused  on  coaching  and  support,  with  the  aim  of  maximising  staff  productivity, 
consistency and quality. There is a particular emphasis on reviewing staff work, both through 
the  formal  quality  assurance  framework  and  through  informal  responses  to  queries, 
technical  expertise.  Senior 
providing  constructive 
caseworkers also participate in a benchmarking cycle to review and grade the work of each 
casework decision maker on a quarterly basis and work with the individual’s line manager 
to address their development needs. These activities are underpinned by a newly produced 
Development Framework and Skills Matrix to help the Senior Caseworker identify and record 
staff learning and development needs, and where trends appear across units, they take a 
role in collaborating with other units, including the learning and development team, to ensure 
that these needs are addressed. 

feedback  and  building 

teams’ 

Assurance review 

In  response  to  the  Regulation  28  Report  to  Prevent  Future  Deaths,  FNORC  has 
commissioned an assurance review of the reforms introduced since KS' case was handled 
by the department and which were outlined by 

 at the inquest. 

The  assurance  review  was  commissioned  in  June  2024  and  is  being  conducted  by  the 
Immigration Enforcement Assurance, Integrity, Risk and Resilience (IE AIRR) Team.  

IE AIRR sits in the Strategic Services and Transformation directorate within Home Office 
Immigration  Enforcement.  The  assurance  team  offers  bespoke,  independent  assurance 
reviews across teams in Immigration Enforcement to interrogate best practice and highlight 
areas of risk. As part of any final report issued by IE AIRR, actionable recommendations will 
be made in much the same way as external review bodies such as the Independent Chief 
Inspector of Borders and Immigration (ICIBI). 

Assurance managers within IE AIRR are specialist trained staff and are accredited by the 
Institute of Internal Audit and Assurance. The postholder within the team with responsibility 

11 

 
 
 
 
 
 
 
 
  
 for  recommendations  also  holds  the  internal  auditors’  qualification  from  the  Chartered 
Institute of Internal Auditors. 

The review will be overseen by 
 as the Senior Responsible Officer given her insight 
into the issues which concerned the inquest. The terms of reference and problem definition 
statement for the review have been agreed at Senior Civil Servant level and set out that the 
review will address the following questions: 

1.  Are adequate systems in place to ensure that all appropriate information is 
before the relevant Grade 7 when considering discontinuance of impending 
prosecutions? 

2.  Have  the  relevant  Grade  7s  received  appropriate  training  to  assess  the 
prospects  of removal  when considering  the  discontinuance  of  impending 
prosecutions? 

3.  Has  the  implementation  &  reintroduction  of  new  systems,  including  exit 
checks, workflow management tools, the triage system – ‘Define’, changes 
to  the  Voluntary  Returns  Scheme  (VRS)  &  the  detention  gatekeeper 
addressed the issues raised by Judge Coroner? 

4.  Have the training requirements of FNORC staff been adequately met? 

The review will provide an independent assessment of the changes made by FNORC and 
whether they are sufficient to mitigate a recurrence of the failures noted by 
 at the 
inquest  and  reflected  in  your factual findings.  If  appropriate, the  review  will  also  highlight 
where further improvements can be made.   

To  assess  the  effectiveness  of  the  introduction,  re-introduction  and/or  improvement  of 
systems and processes made by FNORC, IE AIRR is assessing the controls that have been 
implemented.  Methods  include  ‘dip  sampling’  (a  random  review  of  a  sample)  of  FNORC 
cases to evaluate whether the systems are being correctly implemented, staff observation, 
and staff and stakeholder engagement. The latter is being used in particular in response to 
the fourth research question, to assess caseworkers’ self-assessment of training received, 
their understanding of their role and any concerns they may have. 

The  fieldwork  for  the  assurance  review  is  currently  underway  and  is  due  to  report  by  11 
October 2024. The report will detail key findings in response to the questions outlined in the 
problem  definition  statement  and  will  make  recommendations  where  there  is  scope  for 
further improvement. Both will be backed by relevant data and guidance extracts.  

Prior to final sign off, the assurance report will go through several levels of quality assurance 
and  governance  to  ensure  accuracy  before  the  findings  and  recommendations  are 
presented to 
. Once agreed, the recommendations will be logged on both the local 
FNORC  recommendation  register  and  the  central  IE  recommendation  register.  Progress 
against  the  recommendations  will  be  monitored on a  regular basis by  IE  AIRR to ensure 
timely 
the  proper 
I  am  also  personally  committed 
implementation  of  any  recommendations  that  will  be  made  following  completion  of  the 
review.     

implementation. 

to  ensuring 

Discontinuance of Proceedings  

12 

 
 
 
 
 
 
 
 
 
 
 
 
 
 ’s witness statement of 15 November 2023 (paragraphs 13-22) 
I understand that 
also outlined the significant changes made to the processes by which the discontinuance of 
an impending  prosecution can be requested. Most notably, junior FNORC casework staff 
can only request updates from the  police and Crown Prosecution Service, as opposed to 
requesting discontinuance.  Precautions have been designed into the process so that Grade 
7 authority to request discontinuance of the prosecution must be sought and recorded in all 
cases, through amended documentation. These changes minimise risks of an inappropriate 
discontinuance request being made, or of the omission of the required authorisation. These 
changes  are  supported  by  improved  recording  via  the  Atlas  casework  system,  to  which 
FNORC fully transitioned on 19 October 2022 (i.e., the date on which FNORC ceased use 
of the legacy casework system).   

The implementation and sufficiency of these changes form part of the IE AIRR assurance 
exercise and are the focus of two of the four questions which the review  
seeks to address:  

1.  Are adequate systems in place to ensure that all appropriate information is 
before the relevant Grade 7 when considering discontinuance of impending 
prosecutions? 

2.  Have  the  relevant  Grade  7s  received  appropriate  training  to  assess  the 
prospects  of removal  when considering  the  discontinuance  of  impending 
prosecutions? 

In addition to the general methodology outlined above for the assurance review, the review 
manager is conducting focused activity to assure the training, process and risks associated 
with the discontinuance of impending prosecutions. This includes interviewing the Grade 7s 
who have received the relevant training to assess their understanding, and analysing the 
process,  particularly  the  origin  of  the  required  information  and  how  it  is  received.  To 
understand  pressures  that  risk  compromising  the  process  being  operationalised  as 
intended,  Grade  7s  will  also  be  interviewed  about  their  expected  levels  of  work  and 
conflicting priorities.  

Conclusion 

I hope that my response to your Report has provided reassurance that the Home Office has 
fully considered your findings and concerns and that we intend to do all we can to prevent 
such  tragic  loss  of  lives  in  the  future.  This  is  both  through  ensuring  our  immigration 
processes  are  fit  for  purpose,  and  that  we  intervene  early  to  stop  people  from  becoming 
terrorists  or  supporting  terrorism.  I  am  committed  to  treat  any  failures  with  the  utmost 
seriousness  and  oversee 
recommendations  and 
commitments.  I  will  be  extending  an  invitation  to  the  families  of  James  Furlong,  Joseph 
Ritchie-Bennett and David Wails, should they wish to discuss the findings in relation to the 
Home Office or my response.  

implementation  of 

the  proper 

Home Secretary 

13

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