FOI 714/25
REQUEST
- How many police officers do you have in your organisation that are neurodivergent, can this data be broken down per condition and or rank (i.e. autism, ADHD, dyslexia etc)?
- Do you have data on neurodivergent people who have applied/ been successful or failed the sgt promotion process?
- What is the process in your force for the PC-Sgt promotion.
- What support is offered to autistic/ neurodivergent candidates as part of the PC-Sgt promotion process?
- Does your force have a neurodiversity strategy or policy? Of so could you provide a copy of summary?
- Has the force conducted any reviews or evaluations on how inclusive the pc-sgt promotion process if for autistic/ neurodivergent officers? If yes can you provide a summary/ report?
RESPONSE
We consulted with our Human Resources (HR) department who have provided the following information regarding your request,
Question 1
South Wales Police do not hold the information to answer this part of your request. HR only record under ‘disabled’ at the individuals request. This data is not broken down further by neurodivergent or physical disability.
Question 2
South Wales Police collate and maintain data on neurodivergent people who have applied and either failed or passed the PC-Sgt promotion process.
All information is processed (collected, stored and deleted) in line with GDPR.
Our PROD-EDI-Bronze Dashboard supports us to analyse and track EDI trends and considerations over a number of years specifically relating to promotion board outcomes and help shape future processes in line with continuous improvement. This dashboard is routinely updated after each promotion process.
Question 3
South Wales Police do not formally offer assessment of ability through observation in role. However, depending on the number of vacancies and applicants, use Officers’ PERFORM performance management information as part of a selection process.
PERFORM is completed by Officers’ direct BCU Commander/Department Leader where their direct observations regarding potential, performance and readiness for promotion.
Question setting is undertaken in line with the priority areas and objectives of our delivery plan, guidance from College of Policing, including CVF and also feedback from senior officers and operational leaders.
All scenarios, questions and presentation topics are specifically designed to not disproportionally advantage or disadvantage those with varying roles as part of their career history and is purposefully driven for candidates to demonstrate their diverse operational knowledge.
The Police Federation and other stakeholders are informed of the promotion board date(s) and are welcomed to observe any aspect(s) of the process.
All scenarios, questions and presentation topics are specifically designed to not disproportionally advantage or disadvantage those with varying roles as part of their career history and is purposefully driven for candidates to demonstrate their diverse operational knowledge.
Officers are not made substantive until they have successfully completed NPPF in line with the College of Policing guidelines. The NPPF element of promotion requires candidates to complete a thorough work-based assessment which can evidence capability.
SWP HR Services provide information to officers and staff regarding our flexible working policy and requests for unpaid time away from duties for the purpose of studying.
Question 4
Accommodations and/or reasonable adjustments are offered for officers that might experience impairment through disability, who would be disadvantaged in comparison with their peers in assessment or test formats.
All candidates are sent the attached request form as a standard procedure; this is sent in advance of each promotion process. Please see document entitled ‘Reasonable Adjustments and Accommodations’.
Where appropriate, candidates may be provided with ‘pre-reads’ i.e. a recent report, article or publication that candidates can familiarize themselves with ahead of the process date, which narrows down the topic/subject area.
Question 5
The Equality Impact Assessment (EIA) relating to our Promotion Policy was recently updated to reflect wider organisational data and information. Please see attached document entitled ‘Equality impact assessment’.
In terms of participation in promotion processes there could be barriers for individuals with a disability, either physical or non-physical, which prevent them from fully participating or disadvantages them.
The force has improved awareness and approach to neurodiversity, and has a dedicated staff network to provide support and guidance relating to neurodiverse individuals and/or those who have caring roles outside of work.
All promotion processes include the following (not an exhaustive list):
- Printed copy of interview question(s) in large font to refer to if needed.
- Provision of paper and pen/pencils to make notes.
- Assessors are all required to attend mandatory training relating to Equality Act and Unconscious Bias.
Question 6
As stated in question 5, our Equality Impact Assessment (EIA) relating to our Promotion Policy was recently updated to reflect wider organisational data and information. Furthermore, as stated in question 4, all candidates are offered reasonable adjustments prior to formal invitation to promotion processes; and sent the reasonable adjustments form to complete and return.
Guidance from the Disabled Police Association are currently being reviewed as part of our ongoing commitment to continuously improving promotion processes.
SWP also support and facilitate requests for reasonable adjustments for College of Policing examinations using the appropriate COP reasonable adjustment form.
Further details can be found in our Promotion Policy. Please see attached document entitled ‘Promotions V6.2’.
In relation to the redacted document, the following exemption applies:
Section 40(2) - Personal Information
Section 40(2) is an absolute class based exemption and therefore the authority is not required to consider the public interest in disclosure.
The Data Protection Act covers processing of personal data about a living individual. Personal data means data which relate to a living individual who can be identified-
- from those data, or
- from those data and other information which is in the possession of, or is likely to come into the possession of, the data controller or any other person in respect of the individual.
Information will “relate to” a person if it is about them, linked to them, has some biographical significance for them, is used to inform decisions affecting them, has them as its main focus or impacts on them in any way.
If we disclosed these details, this would provide significant detail which could identify an individual and would breach the first principle of the Data Protection Act 2018.
In accordance with the Act, this letter represents a refusal notice for your request.