Race Equality Schemearchives.dcpa.police.uk/pdfstore/min030605/13.res_suggs.pdf · DEVON AND CORNWALL POLICE AUTHORITY RACE EQUALITY SCHEME 1. INTRODUCTION This is the Race Equality

Race Equality Scheme

2005 – 2008

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DEVON AND CORNWALL POLICE AUTHORITY RACE EQUALITY SCHEME

2002 - 2005

Foreword The Chair’s Foreword will be inserted here at the end of the consultation period on the draft Race Equality Scheme.

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CONTENTS

1. Introduction 4 2. About Devon and Cornwall Police Authority 5 3. How we assess and prioritise the Police Authority’s functions and policies 8 4. How we will assess and consult on the likely impact of proposed policies on the 9

promotion of race equality 5. How we arrange the ongoing monitoring of our policies 10 6. How we will publish the results of assessments, consultation and monitoring 11 7. How we will make sure that the Public have access to the authority’s 11

information and services 8. How we will train Authority members and staff 12 9. Employment monitoring 12 10. Action plan and timetable 13 11. Dealing with complaints 13 12. Consulting and informing staff 14 13. Review of the scheme 14 14. Involving you 15 Contact details 15 APPENDIX A - Summary of Police Authority’s statutory duties and responsibilities APPENDIX B - Police Authority’s policies and strategies APPENDIX C - Template for policy auditing APPENDIX D - Race Relations impact assessment tool APPENDIX E - Police Authority’s RES action plan and timetable APPENDIX F – Self-defined ethnicity classification.

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1. INTRODUCTION This is the Race Equality Scheme for Devon and Cornwall Police Authority. It describes the Authority and the work it does, sets out our values in respect of race equality, and the approach that we will adopt further these values. The production of this scheme is required by law (the Race Relations (Amendment) Act 2000), but we see this work as a natural extension of our commitment to ensuring fairness and equality of opportunity to all members of the community that we serve. The Authority first published a Race Equality Scheme in May 2002; this document revises and builds on that work. 1.1 Background The duty on public authorities to promote race equality arose from the Inquiry Report into the death of Stephen Lawrence, which identified institutional racism in some public organisations. The Government responded by making a commitment to remove the potential for discrimination from the main public services. It amended the Race Relations Act and placed a statutory general duty on most public authorities, including police authorities and forces, to promote race equality. The duty’s aim is to make sure that public authorities build race equality considerations into all aspects of their public services. 1.2 The Legal Framework The Race Relations Act 1976 made it unlawful to discriminate on racial grounds in relation to employment, training and education, the provision of goods, facilities and services, and certain other specified activities. Under Section 71 of the 1976 Act, police authorities had to carry out their functions with due regard to the need to eliminate unlawful racial discrimination, promote equality of opportunity and good relations between persons of different racial groups. The Race Relations (Amendment) Act 2000 strengthened and extended the 1976 Act: • To include all public services and • To make chief police officers and police authorities liable for acts of racial discrimination

committed by police officers, unless it can be shown that reasonable steps were taken to prevent this.

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The General Duty The legislation places a general duty on police authorities and forces to: • Eliminate unlawful racial discrimination • Promote equality of opportunity and • Promote good race relations between people of different racial groups The Specific Duties In order to comply with the general duty, there are two specific duties that we must meet: • To prepare and publish a Race Equality Scheme and • To monitor the authority’s employment procedures and practices This Race Equality Scheme sets out how the Devon and Cornwall Police Authority will meet these duties. 2. ABOUT DEVON AND CORNWALL POLICE AUTHORITY 2.1 Role, Functions and Policies The key role for the Devon and Cornwall Police Authority is to secure the maintenance of an efficient and effective police force for the people of Devon and Cornwall. A detailed summary of the Authority’s statutory duties and responsibilities is attached as Appendix A. The way the Devon and Cornwall Police Authority carries out these duties needs to be audited for relevance to the general duty and any potential impact on any minority groups categorised as either ‘High Risk’, ‘Medium Risk’, or ‘Low Risk’. One of the Authority’s duties is to monitor the performance of Devon and Cornwall Constabulary. The Constabulary has published its own Race Equality Scheme and associated Action Plan and the Authority will monitor how The Constabulary implements its scheme and complies with its race relations duties. We will work to ensure that the functions, policies and practices of both the Authority and the Force conform both to the letter and spirit of the law. Details relating to the scheme and the progress made are included within the Authority’s Policing Plan.

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2.2 Organisational Structure and Committee Process This section sets out how the Authority is made up and how it works. Full details of membership, meeting dates and committees can be found on the authority’s Web-site – www.dcpa.police.uk. Structure Devon and Cornwall Police Authority consists of 19 members drawn from the following groups: • Ten councillors -

4 appointed by Devon County Council 3 appointed by Cornwall County Council 1 appointed by the Council for the Isles of Scilly 1 appointed by Plymouth City Council 1 appointed by Torbay Council

• 3 Lay Justices • 6 independent members who are members of the public appointed following a local selection

process. The full Authority meets five times per year. Meetings are open to the public. Committee Processes The Authority has the following committees and working groups: • Best Value Committee • Diversity Group • Human Resources Committee • Professional Standards and Complaints Monitoring Group • Performance Management and Audit Committee • Planning and Consultation Committee • Resources Committee • Standards Committee • Stop and Search Group • Urgency Committee • Complaints Panel (Senior Police Officers) Because the intention is to ‘mainstream’ race equality issues i.e. make them central to everything we do, each of the Committees will have an ongoing duty to review their own procedures and activities in this respect. In addition, it is proposed that committees will have additional specific responsibilities for monitoring Force and Authority performance. Examples of this would be: Planning and Consultation Committee • Consulting and liasing with local communities • Determining local priorities for policing Best Value Committee • Ensuring that Best Value Reviews include appropriate Race Equality Impact Assessments

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Performance Management and Audit Committee

• Monitoring Force performance against key targets related to the implementation of the Constabulary’s Race Equality Scheme

Professional Standards and Complaints Monitoring Group and Complaints Panel (Senior Police Officers)

• Ensuring that the processes in place for dealing with complaints are fair and accessible to everyone.

Lead Members Each member of the Authority takes a lead role in one or more particular aspects of policing. This is to enable a much more detailed knowledge and involvement than could otherwise be achieved. There are Lead Members for diversity and also training which includes the topics of learning and development. Relationship with the Constabulary Devon and Cornwall Police Authority and Constabulary are separate organisations, each with their own Race Equality Scheme. As described above, the Police Authority has a duty to monitor and review the implementation of the Constabulary’s Scheme and Action Plans. The following table provides a brief summary of how it will fulfil that duty. Regular reports will be presented to the relevant Committee to consider in some detail. Overall monitoring of the scheme will remain the responsibility of the full Authority. Members of the Authority also sit on the Constabulary’s Strategic Boards. These include boards for Human Resources, Diversity and Training. Element of Force Scheme Main monitoring route Overall monitoring of scheme HR committee and Performance Management and

Audit Committee. Report also to be submitted to the Full Authority

Force diversity structures

Human Resources Committee

Policy-making

Human Resources Committee

Stop and Search Performance Management and Audit Committee Recruitment Retention and Progression Human Resources Committee

Complaints and Grievances Professional Standards and Complaints Monitoring

Group Training – see note below Human Resources Committee Consultation strategy Planning and Consultation Committee The Police Authority will report progress against both schemes and the results of consultation in its Annual Policing Plan.

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2.3 Strategic Aims and Objectives Devon and Cornwall Police Authority is committed to the fulfilment of its duties under the Race Relations (Amendment) Act 2000 in the performance of all its functions, duties and powers. It views this as an essential element of delivering the Public Service Agreements “to increase trust and confidence in policing amongst minority ethnic communities”.

Through the development of this Race Equality Scheme the Authority will: • ‘Mainstream’ race equality by making it central to the day to day operation of the police authority • Incorporate race equality aims and objectives into relevant strategies and plans • Work in partnership with the force to ensure an integrated approach to race equality issues • Develop a fuller understanding of the communities the police authority serves • Liase with partner agencies to provide an integrated approach where appropriate • Monitor and scrutinise the force’s approach to race equality. 3. HOW WE ASSESS AND PRIORITISE THE POLICE AUTHORITY’S FUNCTIONS

AND POLICIES In order to meet the general duty the Authority will undertake the following processes: • Identify which of the authority’s functions, policies and practices are relevant to the duty • Prioritise those functions, policies and practices based on their relevance to race equality • Assess whether the functions, policies or practices have an adverse impact on race equality • Consider what changes may need to be made to the functions, policies or practices This includes our responsibilities for Independent Custody Visiting Schemes. The Authority has begun to undertake this work by reviewing and assessing our key functions and policies, a list of the Police Authority’s policies and strategies are included in appendix B. There is further work to do in reviewing and assessing all of our policies and practices, for a template for how this work is carried out see appendix C. 3.1 Assessing the existing functions and policies The Police Authority will be holding workshops for staff and Members to consider basic questions about the Authority’s functions and policies for example: ‘How does this function, policy or practice affect different racial groups in the communities we serve?’ The following questions can then be asked: • Does this function or policy have different effects on different racial groups? • Could there be an adverse impact on any particular group? • Is there any evidence (e.g. complaints, lower levels of satisfaction) that some racial groups are

being differently affected? • Is there any public concern - especially amongst minority ethnic communities - that

functions/policies are discriminatory?

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• Is there an opportunity to promote equality of opportunity and good race relations more effectively?

3.2 Prioritising the Relevant Functions and Policies Having determined which functions and policies are ‘relevant’ to the general duty, these functions will then be prioritised according to their importance, or likely importance, for race equality. This will be achieved by considering the extent to which they have – or could have – an adverse impact on different racial groups and the level of public concern.

3.3 Information and data used In order to carry out these assessments, the information sources and data listed below will be used • Results of consultation exercises – including responses to the draft Race Equality Scheme • Focus groups / meetings • Previous research • Census data 4. HOW WE WILL ASSESS AND CONSULT ON THE LIKELY IMPACT OF PROPOSED POLICIES ON THE PROMOTION OF RACE EQUALITY We also need to undertake assessments of the likely impact of all proposed policies on the promotion of race equality. This includes changes to existing policies (for the Authority’s Race Relations Impact tool, see appendix D). The Commission for Racial Equality has published guidance on this subject, which is available from their website www.cre.gov.uk. The Authority will carry out its impact assessments in accordance with this guidance. The Authority is obliged, in accordance with article 2(2)(a) of the Race Relations Act 1976 (Statutory Duties) Order 2001, to completely review its Race Equality Scheme and its assessment of policies and functions by the 31st May 2008. The Authority will also review its RES and assessments on a three yearly basis in order to meet its legal obligations and to improve confidence in its practices and services. The race equality impact assessment will be carried out in two stages: Stage 1 involves screening policy proposals to see if they are relevant to race equality. All policies will be screened. Stage 2 involves fully assessing policies identified as being relevant to make sure they do not have adverse effects on any racial groups. This involves detailed analysis and assessment of the proposals as they are being developed. It also includes consultation on the proposed policy (or policy options), and publication of a report on the assessment. The flowchart overleaf provides a summary of the process. The arrangements for undertaking the detailed impact assessments will include the involvement of Officers and Members of the Authority, specialist staff from the Constabulary e.g. diversity officers and consultation officers and other relevant organisations.

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Ref: Commission for Racial Equality – Race Equality Impact Assessment: A Step by Step Guide (September 2004) 5. HOW WE ARRANGE THE ONGOING MONITORING OF OUR POLICIES The assessment of a proposed policy outlined above, and our consultations on it, will help us anticipate its likely effects on different racial groups. However the actual impact of the policy will only be apparent once it is in operation. The Authority will therefore monitor relevant policies regularly to understand what is happening in reality.

As previously stated, our aim is to “mainstream” race equality issues and so monitoring will be the responsibility of the policy “owner.” The results of the monitoring will be incorporated into the Authority’s Race Equality Scheme Annual Report.

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Monitoring is a three-stage process: i. Collect and analyse information to highlight any inequalities ii. Investigate the underlying causes iii. Act to remove any adverse impact caused by the policy.

NB At present the Authority does not have sufficient information that determines how people from different ethnic groups view a particular policy. We need to formulate arrangements for collecting and analysing this information as part of our consultation plan. 6. HOW WE WILL PUBLISH THE RESULTS OF ASSESSMENTS, CONSULTATION AND MONITORING Devon and Cornwall Police Authority have a number of existing communications channels that it will use to publish the results of assessment, consultation and monitoring work. The two main routes are the Annual Policing Plan, which incorporates the Police Authority Annual Report, and the Authority Web-site (www.dcpa.police.uk). In addition there are a number of other routes in which results could be fed back and publicised more informally: • Police Authority Liaison Meetings • Meeting with individual groups / organisations • Direct feedback to those supplying information Again, in order to promote mainstreaming of race equality issues, it would be preferable to modify and develop existing routes. This will also assist in setting race equality issues in the context of the wider diversity agenda. Each year a Race Equality Scheme Report will be compiled which sets out progress with activities identified in this scheme, this will include a summary of all assessment, consultation and monitoring reports as well as the review of the action plan. This report will be presented to the Police Authority at the Annual Meeting for approval. It will also be published on the Authority’s website and sent to relevant groups and partners. Please contact the Authority if you would like to be included on the mailing list for this information. 7. HOW WE WILL MAKE SURE THAT THE PUBLIC HAVE ACCESS TO THE AUTHORITY’S INFORMATION AND SERVICES It is very important that all sections of the communities that we serve have access to all the information and services that we provide. All the information that we publish is included in our Publication Scheme and comprehensive and detailed information about the Authority’s work, members, meetings and policies is included on the Web-site. Hard copies of all this information are available on request.

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http://www.dcpa.police.uk/

We do not currently translate all of our documents into different languages on a routine basis but will provide translations on request. We recognise that this may not be sufficient to ensure adequate access for all who need it. In order to improve on this situation the Authority will undertake work to: • Establish what information people in our local communities need or want • Monitor how people use this information — and encourage feedback from local communities on

how they think the police authority could improve communications with the public • Identify and remove any barriers to full access by ensuring that, if required, information is

available in a range of formats, such as: different languages large print Braille audio-tape

• Consider how we can best distribute and publicise this information. This work will be addressed via the Authority’s Strategy for Engaging the Communities of Devon and Cornwall and the results reported in the Race Equality Scheme Annual Report. This is a significant undertaking and may be progressed in partnership with others. 8. HOW WE WILL TRAIN AUTHORITY MEMBERS AND STAFF A training plan will be developed to ensure that all Police Authority members and staff receive appropriate and effective training on the requirements of the Race Relations (Amendment Act) and why it is important for them. The training will also emphasise the need for individuals to demonstrate commitment to the spirit of the Act by the behaviours that they adopt and the willingness to robustly challenge inappropriate behaviour in others. This builds on the training provided in September and December 2003. Training will include all Police Authority members (including independent members of the Standards Committee), staff, independent custody visitors and independent persons who sit on police misconduct panels. Having established a training scheme, it is equally important to monitor and evaluate the training being delivered and to assess how members, staff, and the Police Authority as a whole have benefited from this training. 9. EMPLOYMENT MONITORING The Authority operates a system to monitor, by racial group, our current staff as well as job applicants. Information collected about current staff includes: • Ethnic origin • Current grade/post/position and length of time at that grade length of service • Age • Earnings and benefits • Terms and conditions of employment • Applications for training

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• Applications for promotion • Appraisals. Because of the small number of staff employed in the Authority it is inappropriate to publish all of this information because individuals could be identified. Our current practice is to publish on the Web-site (and in hard copy on request) a breakdown of staff by ethnicity, gender and age. All staff and members are encouraged to provide self classified ethnicity information. Where such information is not provided voluntarily, we will assess the person’s ethnicity in accordance with the Code of Practice supplied by the Commission for Racial Equality and note that the assessment has been made in this way. Monitoring Job Applicants When monitoring job applicants, we ensure that we make a distinction between internal and external applicants. We monitor: • Ethnic origin • Differences in success rates at different stages in the selection process • Reasons for rejection. Monitoring the Composition of the Authority Although not strictly required by the legislation, the Authority monitors the ethnicity of: • Authority members; and • Members of Selection Panels; In addition similar information will be recorded for Independent Custody Visitors starting with the recruitment campaign scheduled for 2005. Selection Panels for Independent members are required to keep a record of applicants for up to four years. As a matter of good practice ethnic monitoring details are included as part of these records. 10. ACTION PLAN AND TIMETABLE For the Police Authority’s Race Equality Scheme action plan and timetable see Appendix E 11. DEALING WITH COMPLAINTS If a person believes that they have been directly affected by a failure of the Devon and Cornwall Police Authority to comply with this Race Equality Scheme, their written complaint should be brought to the attention of the Chief Executive and Clerk to the Authority, who is also the Monitoring Officer. If during the investigation it becomes apparent that an aspect of the Race Equality Scheme has failed to comply with the requirements of the General Duty then the policy will be changed to ensure future compliance. A complaint against a member of the Authority may be a matter for investigation by the Standards Board for England if it relates to an alleged breach of the Code of Conduct adopted by the Authority. Under the provisions of this code, all Members must:

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• Promote equality by not discriminating unlawfully against any person; and • Treat others with respect

If there is a complaint against a senior police officer (Chief Constable, Deputy Chief Constable or Assistant Chief Constable) relating to race equality issues, this will be dealt with via the normal route. The complainant should write to the Chief Executive and Clerk to the Authority who will then arrange for the appropriate action/investigation to be undertaken. 12. CONSULTING AND INFORMING STAFF We will ensure that we consult and inform staff and members throughout the development and implementation of the Police Authority’s Race Equality Scheme. Equally, it is important to make members and staff aware of their own responsibilities under the Race Relations (Amendment) Act. We will consult on and inform staff of: • The arrangements made to meet the general and specific duties • The Police Authority action plan and timetable • How this action plan will be put into practice • Who is responsible for overseeing this process • How staff will be kept regularly informed of further developments and progress • What will be expected of members and staff as a result of the new duties • What training will be provided and who should attend. Every Member and member of staff will receive a copy of the Police Authority’s Race Equality Scheme. 13. REVIEW OF THE SCHEME The Authority will review its Race Equality Scheme annually to: • Assess how we have complied with the duties under the Race Relations (Amendment) Act 2000 • Consider how equality of opportunity and good race relations have been advanced during the

life of the scheme • Think about how we can improve upon what we have already achieved • Look at any areas in which we have not made as much progress as we had hoped and • Consult local communities in order to monitor public perception and satisfaction.

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14. INVOLVING YOU

The Authority would like as much input as possible from local communities on its Race Equality Scheme. We will publish the scheme on the Authority’s website (www.dcpa.police.uk), and distribute it to key partners and interested parties, including representatives of ethnic groups. We will work closely with the Devon and Cornwall Constabulary and other partners on community consultation strategies.

If you would like more information about this or to be involved in a future consultations please see below for contact details. Your involvement would be welcomed.

Devon and Cornwall Police Authority would like to hear any comments you have onthis draft Race Equality Scheme. We would also welcome contact from individuals orgroups who would like to be involved with development and implementation of thescheme. To make comments or request further copies of the scheme, please contact: Mr S G Davey Chief Executive and Clerk Devon and Cornwall Police Authority P O Box 229 EXETER Devon EX2 5YT Telephone : 01392 268333 e-mail: [email protected] Or click on the ‘Contact us’ button on the Police Authority website atwww.dcpa.police.uk A summary of this Race Equality Scheme will be available in a selection of differentlanguages and other formats on request at the above address.

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mailto:[email protected]

APPENDIX A - SUMMARY OF POLICE AUTHORITY STATUTORY DUTIES / RESPONSIBILITIES

Function Act Section To secure the maintenance of an efficient Police Force for its area Police Act 1996 Section 8

To issue a "three-year strategy plan" at the beginning of every three year period which sets out the authority's medium and long term strategies for the policing of that area during that period and submit this to the Secretary of State.

Police Act 1996 Section 8A

To determine local priorities for policing - after consulting local people and the Chief Constable

Police Act 1996 Section 7

To publish an annual policing plan following consultation with the Chief Constable and local people


To report back to local communities at the end of the year on the extent to which the policing/best value performance plan has been met


To appoint and dismiss the Chief Constable, subject to the approval of the Secretary of State


To appoint and dismiss the Deputy Chief Constable, subject to the approval of the Secretary of State


To appoint and dismiss the Assistant Chief Constable, subjects the approval of the Secretary of State


To hold the Police Fund and maintain accounts Police Act 1996 Section 14 (section 40 Local Government Finance Act 1992)

To employ persons to assist the Police Force maintained by the authority or to enable the authority to discharge its duties


To appoint the Clerk to the Authority Police Act 1996 Section 16 To agree the police budget and set the precept Police Act 1996 Section 19 To nominate one or more members of the authority to answer questions on the discharge of the authority's functions at a meeting of a relevant Council when given reasonable notice of this by the Council.


To collaborate with other police authorities to jointly provide equipment, premises, or other material or facilities were appropriate


To determine the charges for the provision of special police services Police Act 1996 Section 25

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Function Act Section

To provide advice and assistance to an international organisation, institution or police body outside the UK, subject to the consent of the Home Secretary


To grant exceptional diligence/ meritorious conduct awards to members of the Police Force on the recommendation of the Chief Officer


To comply with any direction given by the secretary of state on performance targets


To comply with any Codes of Practice issued by the Secretary of State relating to the discharge of Police Authority Functions


To comply with any direction made by the Secretary of State following an adverse report by HMIC


To comply with any direction made by the Secretary of State as to the budget requirement.


To comply with any direction made by the Secretary of State as to action plans and to direct the chief officer of the force to prepare an action plan and submit the plan to the Police Authority for consideration and modification


To comply with any direction made by the Secretary of State to suspend the Chief Constable of a Police Force maintained by the authority from duty


To submit to the Secretary of State a report connected with the discharge of authority functions or policing as may be specified


To comply with any Regulations made by the Secretary of State as to the government administration and conditions of service in Police Forces.


To comment on any HMIC report on the force and any comment made by the Chief Officer about the report and to publish those comments


To have regard to any guidance issued by the Home Secretary on complaints or disciplinary matters.

Police Act 1996 Police Reform Act 2002

Section 87 Section 14

To pay out of the Police Fund any damages or costs awarded against the police in respect of costs or in relation to the settlement of claim


To receive grants from any local Council which falls wholly or partly within the authority, either unconditionally, or subject to conditions with the Chief Officer of Police.


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To accept gifts of money or gifts and loans of other property, including commercial sponsorship of any activity of the authority or force on such terms as appear to it to be appropriate


To borrow a temporary loan or overdraft from a bank or otherwise any sums to meet expenditure before the beginning of its first precepting year.


To make arrangements to obtain the views of local people about the policing of their area and the co-operation of local people in preventing crime


To ensure that the proportion of members of any given party be reflected in the appointment of members to the Police Authority

Police Act 1996 Schedule 2, 4(1)

To appoint a chairman from among its members at an annual general meeting of the Police Authority

Police Act 1996 Schedule 2, 9

To appoint one or more vice chairman from among its members at an annual general meeting of the Police Authority

Police Act 1996 Schedule 2, 9A

To make payments by way of reimbursement of expenses and allowances to its chairman, vice chairman and other members as it may determine

Police Act 1996 Schedule 2, 25A

To co-operate with the responsible authorities in formulating and implementing crime and disorder audits and strategies for each district/unitary in its area

Crime and Disorder Act 1998

Section 5-8

To exercise its functions with due regard to the likely effect of the exercise of those functions on, and the need to do all that it reasonably can to prevent, crime and disorder in its area.


Section 17

To co-operate with the local authority to secure that all youth justice services are available for their area


Section 38

To co-operate with the Youth Justice Board in the carrying out of its functions


Section 41

To issue a "training and development plan" at the beginning of each financial year setting out the proposed arrangements for the carrying out of functions during the year.

Criminal Justice and Police Act 2001

Section 92

To comply with directions of the Secretary of State relating to training and the provision of opportunities for professional development

Criminal Justice and Police Act 2001

Section 98

To comply with the requirements of the Freedom of Information Act Freedom of Information Act 2000

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Function Act Section To comply with an Order of a Minister of the Crown to make provision for or in connection with the transfer to a Police Authority such property, rights or liabilities of a Minister of the Crown and other bodies and person specified in sub-section 3

Greater London Authority Act 1999

Section 408

To promote the formation or extension of a housing association, assist a housing association by subscribing for share or loan capital of the association or make a loan to an unregistered self-build society for the purpose of enabling it to meet expenditure incurred in carrying out its objects

Housing Association Act 1985

Section 58

To follow the specific procedures to gain repossession of land for redevelopment, when the Police Authority is the landlord of the property

Leasehold Reform Act 1967

Section 28

To receive grants from the Secretary of State for certain expenditure particularly targeted at the ethnic minority populations in a community

Local Government Act 1966

Section 11

To use its discretionary power to exclude a member from a meeting whilst a resolution is discussed and voted on


Section 94

To subject itself to provisions and proceedings in relation to meetings concerning the requirements for an annual meeting, powers to call an extraordinary meeting, the procedures for voting and the requirement of keeping minutes


Section 99

To open a Police Authority meeting to the public except to the extent they are excluded from the whole or part of the proceedings


Section 100A

To allow access to the agenda of a meeting and connected reports to members of the public, except to extent access may be excluded


Section 100B

To allow inspection by the general public of minutes and other documents including background papers after meetings until the expiration of six years beginning with dates of the meeting


Section 100C/D

To allow access to inspection of documents relating to committee and sub-committee meetings is the same way as Police Authority meetings


Section 100E

To maintain a register including the names and addressees of members, names of committees on which they sit and any standing orders as to whether they can speak at such meetings. Such list to be open to inspection by the public


Section 100G

To do anything to facilitate the discharge of Police Authority functions


Section 111

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Function Act Section To appoint such officers as necessary for the proper discharge of Police Authority functions


Section 112

To pay a sum not exceeding £5,000 and not being a pension, allowance or gratuity (payable under Superannuating Act 1972) on the death of any person who is or has been an officer, to the officer's personal representatives


Section 119

To accept, hold and administer gifts of property for the purpose of discharging Police Authority functions or for the benefit of the inhabitants of the area in which the Police Authority operate


Section 139

To subscribe to local authority associations if desired Local Government Act 1972

Section 143

To transfer securities on charge of Police Authority area, name etc. Local Government Act 1972

Section 146

To allow any Local Government elector to inspect minutes of Police Authority proceedings


Section 228

To satisfy requirements to store documents ( a photographic copy will generally be sufficient).


Section 229

A public notice required to be given by a Police Authority shall be given by posting the notice in a conspicuous place within the Police Authority area, or in such manner as appears to the Police Authority to be desirable for giving publicity to the notice


Section 231

To follow the specific rules relating to service of documents by a Police Authority


Section 292

To submit to investigation by the Commission for Local Administration where a member of the public has made a written complaint of injustice due to maladministration


Section 25

To follow the Codes of recommended practice as regards publicity issued by the Secretary of State


Section 4

To keep a separate account of expenditure on publicity Local Government Act 1986

Section 5

To only dispose of an interest as mortgagee with the consent of the mortgagor


Section 7

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Function Act Section To exercise its functions in relation to public supply and works contract without reference to matters which are non commercial


Section 17

To secure Best Value i.e. continuous improvement in the way functions are exercised having regard to economy, efficiency and effectiveness


Section 3

To comply with any orders given by the Secretary of State on performance indicators and standards


Section 4

To conduct Best Value reviews of its functions in accordance with any Order made by the Secretary of State


Section 5

To publish an annual policing guide including ministerial priorities, local police objectives and any performance targets set by the authority including the Best Value performance plan


Section 6

To publish any audit report on its Best Value performance plan Local Government Act 1999

Section 9

To pay to the Audit Committee the fee applicable for the inspection. Local Government Act 1999

Section 12

To comply with the directions of the Secretary of State to prepare or amend a performance plan, following specified procedures in relation to a performance plan or carry out a review of the exercise of specified functions


Section 15

To comply with any Regulations made by the Secretary of State about the keeping of accounts


Section 23

To comply with an order of the Secretary of State specifying principles governing the conduct of members of a Police Authority


Section 49

To comply with an order of the Secretary of State to issue a model code as regards to the conduct expected from members of a Police Authority


Section 50

To pass a resolution adopting the code as regards to conduct which is expected of members of a Police Authority and ensure that copies of the code or any revised code are available for inspection by members of the public


Section 51

To establish a standards committee for the purpose of promoting and maintaining high standards of conduct by Police Authority members and assisting members to observe the authority's code of conduct


Section 54

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Function Act Section To appoint one or more sub-committees for the purpose of discharging any of the committee's functions, whether or not to the exclusion of this committee


Section 54A

To borrow money under certain circumstances for any purpose relevant to its function or for the prudent management of financial affairs


Section 1

To determine and keep under review how much money it can afford to borrow


Section 3

To comply with any borrowing limits imposed on a Police Authority by the Secretary of State


Section 4

To comply with Regulations made by the Secretary of State which make provision for the use of capital receipts by a Local Authority


Section 11

To invest for any purpose relevant to its functions under any enactment or for the purpose of the prudent management of its financial affairs


Section 12

To supply the Secretary of State with such information in relation to capital finance as he may request


Section 14

When carrying out its functions in respect of capital expenditure, a Police Authority should comply with any guidance issued or Regulations specified by the Secretary of State


Section 15

To accept a grant from a Minister or the Crown towards expenditure incurred or to be incurred by a Police Authority


Section 31

To designate a Police Authority officer as the "monitoring officer" and provide the officer with such staff as are, in his opinion, sufficient to allow him to perform his duties

Local Government and Housing Act 1969

Section 5

To consider any report of the monitoring officer and prepare a report specifying what action has and will be taken in response to the report

Local Government and Housing Act 1969

Section 5A

To survey land to be acquired under a compulsory purchase order Local Government (Miscellaneous Provisions) Act 1976

Section 15

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To apply to the High Court for the repayment of unclaimed compensation paid into court

Local Government (Miscellaneous Provisions) Act 1976

Section 29

To use the specified procedure for the enforcement of certain covenants arising under deeds to which the Police Authority is a party, and which are executed for the purpose of the carrying out of works on land in the Police Authority's area


Section 33

To follow specific procedures for disposal of property found on land belonging to the Police Authority


Section 41

To comply with any code of practice issued by the Secretary of State in relation to the publication of information about the discharge of functions and other matters (including forecasts)

Local Government, Planning and Land Act 1980

Section 2

To make representations as to why a proposed direction by the Secretary of State to dispose of land should not go ahead


Section 99

To comply with any order of the Secretary of State to dispose of an interest in any land which the Secretary of State feels is not being sufficiently used for the performance of the functions of the Police Authority


Schedule 16

To do such things as appear to it necessary or expedient for enabling adequate use to be made of records under its control

Local Government (Records) Act 1962

Section 1

To acquire by way of purchase or accept by way of gift records which appear to the authority to be of general or local interest. To accept deposit of the same.


Section 2

To contribute as necessary a sum equal to the whole or part of any expenses incurred in relation to acquiring and managing and promoting the use of such records


Section 4

- 24 -

Function Act Section To accept discretionary grants from the Secretary of State if he feels the funds are required for extra expenditure by the Police Authority in any area of special social need.

Local Government Grants (Social Need) Act 1989

Section 1

To access whether premises, equipment or other material or facilities can with advantage be provided jointly for the Authority and the National Criminal Intelligence Service and potentially one or more other Police Authorities, and if appropriate, to enter in an agreement for this purpose

Police Act 997 Section 22 (4)

To ensure it is kept informed of all matters involving the general duties of Police Authorities, Chief Officers and Inspectors and provide the Commission with assistance for the purposes of the carrying out of any investigation by the Commission involving such general duties.

Police Reform Act 2002

Section 15

To receive payment from another Police Force towards the costs of assistance given by the Police Force operating under the Authority

Police Reform Act 2002 Greater London Authority Act 1999

Section 16 Section 32A

To provide information and documents to the Commission in such circumstances and in accordance with such other requirements as may be set out in Regulations made by the Secretary of State


Section 17

To secure access to Police Force premises and documents on behalf of a person nominated by the Commission for the purposes of examination of the efficiency and effectiveness of the arrangements made by the force in question for handling complaints and dealing with conduct matters


Section 18

To provide a complainant with information that will keep him properly informed during the investigation of a complaint


Section 20

To comply with guidance issued by the Commission concerning the exercise or performance of powers or duties relating to the handling of complaints; the means by which recordable conduct matters are dealt with; or the detection or deterrence of misconduct by persons serving with the police


Section 22

To comply with Regulations made by the Secretary of State providing for the procedure to be followed in the case of a complaint against any person.


Section 23

To maintain an effective Independent Custody Visitors Scheme including appointment of Independent Custody Visitors


- 25 -

Function Act Section To handle complaints and conduct matters in respect of a chief officer in such way as set out in Schedule 3, including ensuring that all steps are taken to obtain and preserve evidence relating to the conduct complained of


Schedule 3 (1)

To have due regard to the need to; a) eliminate race discrimination; (b) promote equality of opportunity; and promote good relations between persons of different racial groups

Race Relations (Amendment) Act 2000

Section 2

To grant pensions or other benefits to Police Authority Staff Superannuation (Miscellaneous Provisions) Act 1967

Section 15

To receive notice from the secretary of State of and proposed order affecting a highway or land in the area for which the Police Authority is responsible

Town and Country Planning Act 1990

Section 252

To use Police Authority powers and fulfil Police Authority responsibilities in local planning issues

Town and Country Planning Act 1990

Section 336

To accept payments from the Secretary of State in respect of expenditure in relation to the prevention or selection of road speeding offences

Vehicles (crime) Act 2001

Section 38

- 26 -

- 27 -

APPENDIX B -

POLICIES AND STRATEGIES

Index No

Policy/Procedure/Strategy Name

Meeting Name Meeting Date Minute No

Electronic location Website Comments

1 Joint RiskManagement Strategy

Police Authority

09 July .04 P879 No

2 Property Strategy Police Authority

29 Sept.00 P541 No Replacement strategy due to be approved at PA 03.06.05

3 ProcurementStrategy

Police Authority

16 Feb 01 P556 No

4 Anti Fraud and Corruption Strategy

Police Authority

28 Sept01 P623 No Hard copy not available April 2005

- Service DeliveryMatrix (Best Value)

Police Authority

14 Dec 01 P637 No Superseded by National Guidance issued in 2003

5 Strategy forEngaging the Communities of Devon and Cornwall

Police Authority

21 May 04 P865 Yes A) this work was originally the Consultation strategy P489 (police authority 18.02.00 refers)

6 Medium TermFinancial Strategy

Police Authority

20 Feb 04 P844 No Treasurer suggests that this should not be put on the web as it contains sensitive information

7 TreasuryManagement Policy Statement

Police Authority

17 Jan 95 P20 No

- Best ValueMarketing Strategy

Best Value 18 Jul 02 BV240 No Superseded by National Guidance issued in 2003

- Best Value Best Value 08 Feb 00 BV22 No Superseded by National

- 28 -

Index No




Comparison Strategy

Guidance issued in 2003

- Best ValueCompetition Strategy

Best Value 16 March 00 BV33 No Superseded by National Guidance issued in 2003

- Best ValueChallenge Strategy

Best Value 13 Jan 00 BV11 No Superseded by National Guidance issued in 2003

8 Funding StrategyStatement for Local Government pension Scheme

Resources 28 Jun 04 R347 No

9 Race EqualityScheme

Police Authority

12 Jul .02 Yes Replacement scheme due for Approval at PA 03.06.05

10 Yes Freedom ofInformation Publication Scheme

11 Standing Orders December 1997?

Yes

12 Standing Orders for Tenders and Contracts

2002 Yes

13 FinancialRegulations

July 2002 New filing system/constitution/orders

Yes

14 TreasuryManagement Strategy 05/06

Police authority

8 Feb 05 P1012 New filing system/Authority/reports/ 050218

Yes

15 TreasuryManagement Policy

Police Authority Resources

3 May 2002 18 Apr 2002

P675 R162

No

16 Members Code of Police 03 May 02

- 29 -

Index No




Conduct Authority 17 Anti Discrimination

Code of Conduct July 2000 No

18 Register ofOrganisations, Hospitality and Gifts

Feb 2000 No

19 Local GovernmentPension Scheme Discretionary Payments

08 May 98 No

20 Police PensionScheme & LGPS Internal Dispute Resolution procedures

July 1997 No

21 IndependentCustody Visiting Scheme

12 July 96 Under Review 2005

22 Sponsorship Policy July 1995 No 23 Staff appraisal

Framework

Human Resources

07 April 05 HR/114 New filing system/staff/PA HR policies

24 Harassment &Bullying Policy and Procedure

Human Resources


25 Discipline &Incapability Procedure

Human Resources


26 Policy on Diversity in Employment

Human Resources


27 Grievanceprocedure

Human Resources


- 30 -

Index No




28 SicknessManagement and Ill Health procedure

Human Resources


29 Protocol forMember and Officer Relationships

Human Resources


30 WhisltleblowingPolicy and procedure

Human Resources


- 31 -

APPENDIX C -

INITIAL SCREENING AUDIT FOR POLICE AUTHORITY POLICIES AND FUNCTIONS IN ACCORDANCE WITH RACE RELATIONS DOCUMENT ______________________________________________________ AUDITOR ___________________________________ Date __________________ The following provides a set of questions to be applied by those persons involved in auditing, drafting or amending Police Authority policy, procedures or working practices. The questions are prompts to ensure compliance with the key principles of the Race Relations (Amendment) Act 2000. This completed document must be attached to any policy subjected to this form of review, as this will demonstrate what steps have been taken by the Police Authority to ensure Race Relations Act Amendment) Act 2000 compliance.

ISSUE Question

Response (THIS SECTION SHOULD BE COMPLETED BY THE INDIVIDUAL AUDITING OR

DRAFTING POLICY/PROCEDURE/PRACTICE AND PROVIDES THE EVIDENCE TO SUPPORT ANY CERTIFICATION OF

COMPLIANCE)

Page REFERENCE (cross reference to

section in policy which addresses the issues

raised) Initial Screening for key Human Rights Principles

1. What is the intention of this policy/procedure/working practice?

2. Have the contents of this policy been previously audited for human rights

compliance?

3. Is there any potential interference with an individual’s rights contained in

the policy as set out in the Convention Articles? If yes please provide details and evidence and undertake a full impact assessment by completing the relevant template.

- 32 -

ISSUE Question



COMPLIANCE)



raised) GENERAL DUTY TO PROMOTE RACE EQUALITY BOTH INTERNALLY ANDEXTERNALLY

4. Which if any of the three aspects of the General Duty does the

policy/procedure have links with?

Eliminate racial discrimination Promote equality of opportunity Promote good relations

5. Is there evidence or reason to believe that some racial groups could be

differently affected by the policy/procedure/practice and if so, which groups?

• How much evidence do you have? You should consider existing

performance monitoring data recorded by the force/Police Authority and issues of public interest.

6. Is there any potential for policy/ procedure /working practice to be applied

in a discriminatory manner with respect to race? • How much evidence do you have? You should consider whether there is a

chance for the policy to be applied disproportionately.

- 33 -

ISSUE Question



COMPLIANCE)



raised)

7. Is there any evidence of public concern that the policy/ procedure /working

practice has been or is being generated in a discriminatory way with respect to race?

• How much evidence do you have? You should consider current and

historical media and press interest.

8. Considering the answers to Qs 4-7, is the current policy/ procedure

/working practice or proposed policy/procedure/ working practice relevant to the General Duty to promote race equality? Please circle a level of priority.

None A little (3) Some (2) A lot (1) If None, complete a brief explanation for your reasons. If the policy is assessed as having some relevance, then a Full Race Impact Assessment needs to be completed.

- 34 -

ISSUE Question



COMPLIANCE)



raised)

MONITORING IMPACT OF POLICY

9. Are current recording arrangements and data collection methods sufficient

to allow the policy to be monitored with reference to racial group?

If yes please list what they are, where they are held and when and how they are collected. If no please identify what you think needs to be done to enable this policy to be appropriately monitored.

- 35 -

- 36 -

APPENDIX D –

TEMPLATE FOR CARRYING OUT IMPACT ASSESSMENTS

FULL RACE IMPACT ASSESSMENT TEMPLATE Section /Department

Person Undertaking the Assessment

Date of Assessment

New (Y/N)

Title of Policy, Procedure or Working Practice: 1. Describe the Aims, Objectives and Purpose of the Policy, Procedure or Working Practice: Aims: Objectives: Purpose: 2. Looking back at the initial screening for this policy, procedure or working practice, what are the concerns identified: 3. Summarise the likely impacts: 4. Are there alternative ways to address these impacts? (e.g. Can the organisation achieve the same ends by means other than the policy?) 5. Are there any experts/relevant groups who you can approach to explore their views and obtain further data/information? You may need to liaise with the Diversity Unit. If no, set out your reasons: If yes, please list: Who How will the views of these groups be obtained

(Questionnaire, Meetings, Interviews, telephone, workshop, etc.)

Date contacted or planned

- 37 -

6. Please set out in detail the views and information obtained (continue on a separate sheet if necessary): 7. As a result of this additional information summarise the likely impact (continue on a separate sheet if necessary): 8. As a result of this additional information what recommendations, if any, can you make to address the impact?

- 38 -

9. What Actions/ Tasks can you identify to implement the recommendations? Issue Action/Task Lead Officer Timescales Resource

Implications Comments

10. Who will approve/authorise these? (e.g. May be a Chief Officer/Strategic Group)

11. How will they be monitored? (e.g. Continual Improvement Database)

12. How and where will this be published? (There must be a means to ensure that the consulted groups receive the results of their views). Signed: Date:

- 39 -

APPENDIX E - YEAR ONE (2002 / 03) OBJECTIVE ACTION TARGET

DATE TASKS OWNED BY CURRENT POSITION

1.2 a Audit all Police Authority policy documents to assess relevance to the scheme and prioritise them as ‘High’, ‘Medium’, or ‘Low’ risk

May 2005

Police Authority member of staff responsible for auditing and trained in this skill.

Behind schedule This is a 3 yearly statutory requirement

1.2 b

To identify which of the Authority functions, policies and practice are relevant to the general duty

Review and prioritise any new policies and working practices

Ongoing Need to be identified by relevant committee and audited by Police Authority member of staff responsible for auditing and trained in this skill.

1.3 To impact assess those functions and policies identified as being high priority.

Assess any effects on different racial groups by consultation and analysis

July 2006 Consultation officer Diversity unit

Policy assessment training arranged – on target

1.4 To ensure that Race Equality issues are properly considered throughout the Authority’s activities

Each Committee to review its own procedures and activities

Dec 2005 Police Authority Committees To follow completion of policy review.

1.5 a Identify existing organisations who may facilitate consultation

Nov 2002 Consultation Officer Diversity Unit Planning and Consultation committee

Authority consultation to be carried out in partnership with Force as set out in Force scheme.

1.5 b

To develop effective consultation mechanisms with different racial groups

Develop and agree consultation strategy

Feb 2003 On Target – progress made

OBJECTIVE ACTION TARGET DATE

TASKS OWNED BY CURRENT POSITION

1.5 c Adopt partnership approach to surveys and other consultation exercises

May 2003 This has been achieved with local councils and the Health Authority

1.6 To ensure that all sections of the communities that we serve have access to information about the work of the Authority including the Race Equality Scheme and associated reports

Establish the need to publish information in a range of formats, including different languages, large print, Braille audio-tape

April 2006 Consultation Officer and community engagement practitioners Diversity unit

FOI Publication Scheme prepared. Current proposal is to offer translations as requested rather than publish documents in several different formats. Consultation has revealed the need to publish a simpler version of the RES in the style of an A5 glossy coloured leaflet with useful information made more accessible and easier to understand.

1.7 a Review Force Racial Equality Scheme to establish level of information required

Sept 2005 HR committee and Performance Management and Audit Committee. Full Authority

Reporting mechanisms need to be put in place

1.7 b Agree a reporting protocol with the Force

Dec 2005 Needs updating

1.7 c

To ensure that the Authority has sufficient information to effectively monitor the implementation of the Force Race Equality Scheme

Regularly review and monitor Force performance in this area

Ongoing Authority Steering Group and Committees to monitor in accordance with proposals – needs updating



1.8 a Best Value Panel Review members to review the Project Initiation Documents of all ongoing and future reviews to ensure that this work is addressed

Ongoing as Reviews are undertaken

Best Value Committee

1.8 b

To ensure that every Best Value Review takes account of race equality issues

Panel members to ensure that Best Value Final Reports include appropriate race equality impact assessments

Ongoing as Reviews are undertaken

1.9 a Assess training needs of : • Members (including Selection

Panels) • Staff • Independent Custody Visitors

July 2006 HR committee and Performance Management and Audit Committee. Full Authority Chief Executive and Clerk to the Police Authority

Preparatory work complete; initial training delivered. However, new members will need to be trained. Training needs to be updated following a national training agenda set out by the APA

1.9 b Deliver appropriate awareness and behavioural training for the above groups

Dec 2005

1.9 c

To ensure that Police Authority Members and Staff are aware of the duties of the Race Equality legislation and that they adopt behaviours that demonstrate respect for all ethnic groups

Produce a longer term training plan to ensure that standards of knowledge and behaviour are maintained

May 2006

1.10 a

With the Force, review current policy and practice, including the extent of monitoring

Nov 2005 Included in Force Action Plan

1.10 b

To effectively monitor how the Force deals with complaints, including those that the Force is failing in duties related to its Race Equality Scheme

Ensure that appropriate systems for monitoring, analysis and action, including reporting procedures, are implemented

May 2006 Chief Executive and Clerk to the Police Authority

On target



1.11 a

Place notice on Authority Web-site that scheme is available

31 May 2005 Assistant Chief Executive Complete

1.11 b

Identify most effective routes for supplying this information

March 2005 Consultation Officer Progress made through consultation work carried out

1.11 c

To publicise the availability of the Race Equality Scheme

Include details of scheme and progress in future Annual Reports

Sept 2005 Sept 2006

Police Authority officer responsible for overseeing RES

Publish the results of assessment, consultation and monitoring work

Publish these results in the Annual Policing Plan, which incorporates the Police Authority Annual Report, and the Authority Web-site (www.dcpa.police.uk). Other channels are: Police Authority Liaison Meetings, meeting with individual groups / organisations and direct feedback to those supplying information.

May 2005

Annually thereafter

Police Authority officer responsible for overseeing

RES

1.12 a

Consult with the CRE and stakeholders to develop appropriate performance indicators

Dec 2002 HR committee and Performance Management and Audit Committee. Report also to be submitted to the Full Authority

Not progressed

1.12 b

To develop and monitor the performance indicators needed to monitor progress

Implement a system for monitoring and reporting on performance against the agreed indicators

May 2003

1.13 a

To review the adequacy of the Race Equality Scheme and report on progress against actions

Review Race Equality Scheme Bi-monthly report

HR committee and Performance Management and Audit Committee. Report also to be submitted to the Full Authority

In progress




1.13 b

Report on progress against actions and identify outstanding actions

Bi-monthly report

YEAR 2 (2003 / 04) - as published in scheme

OBJECTIVE ACTION TARGETDATE

TASK OWNED BY COMMENTS

2.1 To report back to the public and other stakeholders on the first year of operation of the Race Equality Scheme

Include a report on the implementation of the Scheme in the annual Best Value Performance Plan and other appropriate communication routes

June 2006 On target

2.2 To monitor those functions and policies identified as being medium priority.

Assess effect on different racial groups by consultation and analysis

July 2007 Police Authority officer responsible for overseeing RES and trained in policy auditing

Adopt partnership approach with Constabulary and other authorities

2.3 a Review the effectiveness of the consultation strategy

Feb 2007 Consultation officer Action to be updated

2.3 b

To ensure that consultation processes are effective and efficient Further develop and extend

partnership approach to surveys and other consultation exercises

Feb 2007 Consultation officer

2.4 To ensure that there is inclusive access to information about the work of the Authority

Provide information in the range of formats, including different languages as identified through preliminary research work in Year 1

April 2007 Police Authority officer responsible for overseeing RES

2.5 a Review the reporting protocol for adequacy

Sept 2006 HR committee and Performance Management and Audit Committee. Report also to be submitted to the Full Authority

Updated scheme will provide details of how this will be carried out

2.5 b

To ensure that the Authority has sufficient information to effectively monitor the implementation of the Force Racial Equality Scheme

Regularly review and monitor Force performance in this area

Ongoing



2.6 To ensure that standards of knowledge and behaviour of Police Authority Members and Staff in relation to the duties of the Race Equality legislation are maintained

Implement term training plan to ensure that: • New members of the Authority,

its staff and custody visitors are trained and

• Existing member and staff knowledge / awareness is regularly updated

May 2007 Will aim to achieve this in ongoing training

YEAR 3



To report back to the public and other stakeholders on the operation of the Race Equality Scheme

Include a report on the implementation of the Scheme in the annual Best Value Performance Plan and other appropriate communication routes

June 2004 Best Value committee

To impact assess those functions and policies identified as being low priority.

Assess effect on different racial groups by consultation and analysis

July 2005 Consultation officer Diversity unit

APPENDIX F -

16+1 Self Defined Ethnic Classification

W1 British W2 Irish White W9 Any other white background M1 White and Black Caribbean M2 White and Black African M3 White and Asian Mixed M9 Any other mixed background A1 Indian A2 Pakistani A3 Bangladeshi

Asian / Asian British

A9 Any other Black background B1 Caribbean B2 African Black / Black

British B3 Any other Black background O1 Chinese Other O9 Any other ethnic background NC Called Away ND Not Given Due to Disorder NU Person Didn’t Understand Ethnicity not stated NG Declined to Give