POLICE CRIME COMMISSIONER FOR GLOUCESTERSHIRE & GLOUCESTERSHIRE CONSTABULARY Risk Management Framework Title: Authors: Management of Risk for the Force Planning & Governance Services Unit, BID Date prepared: RMF Version 2.9 revised 15 Nov 2012 30 September 2010 1 Statement The Risk Management Policy for the Police and Crime Commissioner for Gloucestershire and Gloucestershire Constabulary (the Commissioner and Constabulary) is to adopt recognised best practice in the identification, evaluation and cost effective control of risks and opportunities to ensure that they are managed at acceptable levels. We use a definition of risk, which is ‘An uncertain event or set of events which, should it occur, will have an effect on the achievement of objectives’ 1. Good risk management will support and enhance the decision making process, increasing the likelihood of the Commissioner and Constabulary meeting their objectives and enable them to respond quickly to new threats and opportunities. Aims This framework aims to ensure there is a planned and systematic approach to identifying, evaluating and managing risks threats and opportunities facing the Commissioner and Constabulary. The framework is underpinned by procedures that detail the responsibilities, process and structure for delivering effective risk management. Objectives The primary objective of the risk management process is to manage threats in a way that reduces the likelihood of them occurring and minimises their impact should they materialise. Associated objectives are to: Integrate risk management into planning and performance frameworks Ensure the Commissioner and Constabulary operate under sound principles of Corporate Governance Improve strategic, operational and financial management Prevent or reduce events that could damage reputation and public confidence Improve service delivery and value for money Application & Communication All officers and employees must be made aware of the importance of risk management and their role in promoting better risk management. In order to 1 As defined by the OGC Management Of Risk: Guidance for Practitioners RMF Version 2.9 revised 15 Nov 2012 2 achieve this, a communication strategy will be developed by the risk management. This strategy will ensure that: The Commissioner’s and Constabulary’s Strategy & Framework on Risk Management is disseminated throughout both organisations. Risk-related information is communicated to the appropriate recipient. Any risk of breakdown in communication, leading to inaccurate/out of date risk management information and potentially greater exposure, is minimised. Outcomes The adoption of this framework will have the following implications for the Constabulary within several specified areas: The Police Crime Commissioner (via their Audit Committee) and the Constabulary (via the RRG) will identify what level of risk it will tolerate. This is the appetite for risk. Police Officers and Staff will be encouraged to raise potential risks that may concern them. The Commissioner and Constabulary will adopt a Standard Operating Procedure for Risk Management. An embedded culture where everyone is aware of the Commissioner and Constabulary’s approach to risk and their responsibilities in relation to it We will do this by: A formal initial and periodic evaluation of organisational risks using a standard corporate methodology. The development of appropriate control strategies and ongoing monitoring of progress and impact. RMF Version 2.9 revised 15 Nov 2012 3 Table of Contents Risk Management Framework ...................................................................... 1 Statement ..................................................................................................... 2 Aims .............................................................................................................. 2 Objectives ..................................................................................................... 2 Application & Communication ....................................................................... 2 Outcomes ..................................................................................................... 3 Context ......................................................................................................... 5 Approach ...................................................................................................... 5 Structure ....................................................................................................... 6 Responsibilities ............................................................................................. 6 Business Continuity Management................................................................. 6 Appendix 1 – The Risk Management Process .............................................. 8 Appendix 2 – Risk Management Structure .................................................. 16 Appendix 3 – Roles & Responsibilities........................................................ 17 Appendix 4 – Risk Register ......................................................................... 18 Terminology ................................................................................................ 18 RMF Version 2.9 revised 15 Nov 2012 4 Context Gloucestershire Constabulary delivers a range of essential services to a countywide population in excess of 575,000 people, as well as supporting a number of sites of strategic national importance. Inevitably through its day-today business it will encounter varying degrees of risk. The purpose of this document is to illustrate the processes required to implement effective management of risk - whether it is a threat or an opportunity. Risk Management is the systematic application of principles, approach and processes to the tasks of identifying and assessing risks, and then planning and implementing risk responses. This provides a disciplined environment for proactive decision-making. Health & Safety and Operational Policing Risks will be managed through already established structures and reporting practices and therefore will not be included in the Risk Management Process, except in circumstances where it is considered to have such an effect on the organisation that it becomes a strategic risk. Approach There is a two-tiered approach to managing risk within Gloucestershire Police Service. Risks will be managed at a Corporate and Business area/Local Policing Area, with the focus on the achievement of objectives, not the process itself. The Constabulary will focus on two areas of risk: Strategic Risk: Key significant risks that will have an impact across the whole Constabulary with a need for regular strategic management input and/or require a Constabulary wide response in terms of mitigation. Business area/LPA Risk: Key risks that will have an impact in one or more LPA or Business area achieving their objectives. Any identified high risk from Local Policing Area/Business area Risk Registers can be escalated to the Strategic Risk Register through the Risk Review Group, when appropriate. The Police and Crime Commissioner will focus on the Strategic risks as defined above. The four stages to the Risk Management Process are described below. Identification- Identify potential risk Threats/Opportunities which may affect the Commissioner’s or Constabulary’s ability to achieve its objectives. RMF Version 2.9 revised 15 Nov 2012 5 Assessment- Analyse the potential risk, and score it in terms of the potential likelihood and impact of occurrence. Addressing- Review current management controls and develop strategies for managing the risk. Reviewing and Reporting – Evaluating the actions implemented and monitoring them as to their effectiveness. Appendix 1 outlines the risk management process for the Commissioner and Constabulary in more detail. Structure Together the Commissioner and Constabulary have implemented a risk management structure to effectively manage strategic risks in order to ensure it operates under sound principles of Corporate Governance. Appendix 2 outlines a graphical representation of the risk management structure within Gloucestershire Constabulary & the standard operating procedure. Responsibilities All members, employees and partner organisations must understand the nature of risk and accept responsibility for managing those risks associated with their area of activity. Appendix 3 outlines the roles & responsibilities for managing risk within the Constabulary. Business Continuity Management For the Gloucestershire Police and Crime Commissioner and Constabulary, Business Continuity Management is ‘the means by which the organisations plan to maintain their business in the event of adverse impact to essential activities and critical functions of our business’. Business Continuity Management is part of the Commissioner and Constabulary’s overall risk management framework and can be used to mitigate risks. A risk based assessment of any 'essential activity' should be undertaken in order to evaluate the risk of the activity being ceased or curtailed. The risk assessment can then be used by individual LPA’s/Business areas as necessary to escalate any ceased or curtailed essential activities that are becoming a priority or threat. Business area and LPA Business Continuity Plans identify activities which are identified as ‘business as usual’, ‘essential’ and ‘critical’ - supported through Business Impact Analysis – the Constabulary uses this as a system to categorise and prioritise. This process links with the Constabulary’s Risk Management Framework underpinned by Business area/LPA Risk Registers. RMF Version 2.9 revised 15 Nov 2012 6 The Business Continuity Plan can be viewed on the intranet, using the link below or accessed through Business Improvements Intranet site under the Planning & Governance Unit section. Business Continuity Plan RMF Version 2.9 revised 15 Nov 2012 7 Appendix 1 – The Risk Management Process Risk Definition ‘An uncertain event or set of events which, should it occur, will have an effect on the achievement of objectives’ The role of risk management is to ensure that the Commissioner and Constabulary make better decisions through a good understanding of the risks and their likely impact through a disciplined environment. The risk management process looks at what can prevent the Commissioner and Constabulary from achieving their objectives, through identifying what could go wrong and the actions that can be taken to prevent this from happening or taking full advantage of emerging opportunities. The Risk Management Framework provides a standardised approach on how risk is managed by the Commissioner and Constabulary through a four step approach The risk management process can only commence after the objectives for the Commissioner, Constabulary & business area have been set and understood. The diagram below demonstrates the fours steps to the risk management process, which should align to the Corporate/Business area objectives. The risk management process is a cyclical cycle that continues throughout the year, on a quarterly basis. RMF Version 2.9 revised 15 Nov 2012 8 What are the 7 key risk management standards? The following standards have been identified to help you successfully integrate risk management into your business area. The seven standards are: Standard 1 Clarify your outcomes/objectives Within the context of the Commissioner and Constabulary there are established strategic objectives to help deliver the priorities in the Police and Crime Plan. Therefore objectives must exist before we can identify potential events affecting their achievement (both positive and negative). Standard one is straight forward, link these objectives with what our organisation is aiming to achieve Standard 2 Identifying the risks Once the objectives have been identified, the next standard is to identify the key risks that can hinder, or opportunities that can enhance the achievement of the objective. When objectives have been changed or recently set any existing identified risks should be reviewed and updated as to there relevance. The use of categories can be used to make it easier when identifying risks, a definition of each of the categories is provided to clarify what they mean and the type of risk it can be. (See page 11 for the categories definition) Standard 3 Assessing/Evaluating the risks Once all the possible key risks and/or opportunities have identified, it is then necessary to analyse and evaluate the risks so that you may distinguish minor acceptable risks from major risks. This process means determining the likelihood of the risk happening and the impact the risk will have on the achievement of the objectives, should the risk occur. To assess the risks adequately and consistently, we should give each risk a score or risk rating which is calculated by multiplying the likelihood score by the potential impact score this can be achieved by using the 5x5 Risk Matrix and scoring methodology. (See page 13 for scoring methodology) The first assessment should be undertaken on the ‘Inherent Risk’ i.e. the risk before any controls have been put into place. This is to ensure that all significant risks are highlighted and assurance can be provided that these risks are being managed. If you only assess the risk after controls have been RMF Version 2.9 revised 15 Nov 2012 9 put in place (Residual Risk) then you are assuming that the controls will always be there. Standard 4 What controls are already in place? The fourth standard is to document the key controls, systems and processes i.e. the policies/actions/measures that you currently have in place to manage the inherent risks identified. This process also evidences control. Standard 5 Re-assess the risk The fifth standard is to assess your risks after your existing controls have been evaluated. This will give you a Residual Risk score and overall risk rating level. Standard 6 Are there any further actions required? The sixth standard is to determine if any actions are required to reduce further the risks identified and nominate a risk owner who will take responsibility to ensure that these actions are addressed. (It may be that no further actions are required as the risk is acceptable subject to the current control measures remaining in force and valid). A summary of the type of action you should consider when addressing a risk is set out below: Terminate Accept the risk, use this option where the cost of acting on the risk is too high compared to the perceived benefits or the ability to deal with a risk is limited. Any Residual Risks considered low impact and/or likelihood will usually be tolerated, however, the risk should be monitored in case the situation changes (Increased impact/likelihood). By terminating the risky activity or partnership this might lead to other risks or disadvantages, especially where you provide a statutory service, so use this control with caution. Transfer This option is usually used through insurance policies or third party arrangements (Partnership working), however, the reputation of the Commissioner or Constabulary could still be affected if the risk is realised. Tolerate Accept the risk, use this option where the cost of acting on the risk is too high compared to the perceived benefits or the ability to deal with a risk is limited. Treat Aims to (1) Reduce the likelihood of the risk, by performing some form of control, &/or (2) Reduce the impact of the risk should it occur. RMF Version 2.9 revised 15 Nov 2012 10 Treating the risk may not eradicate it completely but reduce it to a more manageable level. What do I do if I want to accept one or more of the risks? Risk tolerance Before deciding what action to take to further mitigate risks consideration should be given to the amount of risk you are prepared to accept/tolerate, bearing in mind there will always be competing risks, for example financial risk via environmental risk or reputation risk. This will vary according to the importance of achieving particular objectives/benefits and what the impact the realisation of the risk will have on those outcomes. The risk matrix and scoring methodology detailed within standard 3 should be used to identify the likelihood and impact the risk may have on the objectives and applied to all proposed options. Standard 7 Risk Monitoring The final standard is to ensure that the objective/risk is monitored and reported on a quarterly basis to Risk Management upon request. Depending upon the complexity of the risk it would be good practice to have the risk register as a standing agenda item at your monthly Business Area/LPA meetings to be able to discuss/ close down risks when they no longer pose a threat or to add new risks and opportunities in the light of new information. RMF Version 2.9 revised 15 Nov 2012 11 Categories of Risk Category Definitions Political Those associated with the organisations’ ability to deliver either central government policy or meet the Commissioner’s Police and Crime Plan commitments Economic Those associated with the ability of the organisation to meet its financial commitments. There may be external (e.g. interest rates, exchange rates, and inflation) or internal (e.g. budgetary pressures, adequacy of insurance cover, consequences of proposed investment decisions). Social Those associated with the effects of any changes in socio-demographic trends, and the organisations’ ability to deliver its objectives. Technological Those associated with the capacity of the organisation to deal with the pace/scale of technological change, or its ability to use technology to address changing demands. This would also include the organisations’ reliance on operational equipment (e.g. IS or equipment and machinery). Environmental RMF Version 2.9 revised 15 Nov 2012 12 Those relating to the environmental consequences (including climate change) of progressing the organisations’ strategic objectives (e.g. emissions) or the impacts of ongoing operations (e.g. pollution, noise, energy efficiency). Legal Those related to possible breaches of legislation, or compliance with laws and regulations designed to reduce hazards (e.g.-Health and Safety at Work Act). Organisational Anything which would affect the ability of the organisation to achieve its objectives. Risk associated with the organisations’ reputation and the public perception of the organisation’s efficiency and effectiveness. Risks associated with the particular nature of each profession and the people who deliver those services (e.g. 999 calls, Public Protection Bureau etc.) Insuring Your Risks Risk Management and Insurance Services also have a critical role to play in helping each service strike a balance between self-insurance and external insurance. Regardless of the balance chosen, effective risk management will help to reduce the direct costs of self-insurance, the indirect (hidden) costs (e.g. management and administration time, negative impact on our reputation, service disruption, client/service user dissatisfaction etc), associated with ‘clearing up the aftermath of an event that has happened’ and minimise the premiums paid for external cover. Did you know? That only 20-25% of risks are insurable? The other 75-80% of risks need to be managed by us!! RMF Version 2.9 revised 15 Nov 2012 13 Whilst the above highlights that insurance is one way of controlling risks. It should be stressed that there are lots of other things that we can do to control our risks; we do not want to depend on insurance. As can be demonstrated above, effective risk management activities and arrangements are essential to control the 75-80% of risks that are NOT INSURABLE!! Risk Assessment Having identified the risks, the next stage is to assess both the likelihood of the risk event occurring and the impact of the risk if it is realised. Each risk must be evaluated to decide whether the level of risk is acceptable, i.e. you are happy to tolerate that level of risk exposure or not. Risk Appetite & Tolerance Risk Appetite is the position the Commissioner and Constabulary will take towards risk taking, which will also decide the amount of risk considered acceptable. The Risk Review Group is responsible for defining the levels of appetite through performance improvement review methods to achieve the Constabulary’s overall Purpose and Mission. Risk Scoring Risks need to be assessed both in terms of their likelihood and impact. When assessing the level of likelihood and impact, the Commissioner and Constabulary will use a number rating system of 1 – 5 (1 = Low, 5 = High) to summarise the measurement of descriptive information. There are two stages when assessing the risk, the initial stage is to assess the pure risk when no controls or mitigation have been considered, this is called the ‘Inherent Risk’ score. The second stage is to produce the ‘Residual Risk’ score, which is the score of a risk when all the controls or mitigation have been considered. A risk score is calculated by multiplying the Likelihood score by the Impact score Both the Likelihood & Impact tables can be viewed using the link below: Scoring a Risk Risk Opportunities Risk Management includes the identification of beneficial opportunities through risk awareness. If risk opportunities occur, they will be assessed using the processes and procedures set down in the Risk Management Framework RMF Version 2.9 revised 15 Nov 2012 14 Review & Reporting Risk At a corporate level there are lead “Risk Owners” usually members of the Chief Officers Group who have ultimate responsibility for the Strategic Risk Register (SRR). Below them the ”Risk Leads” are responsible for reporting on mitigation progress, blockages or developments and further actions relating to the risk. The SRR will be reported to the Chief Constable’s Executive Board and the Audit Committee on a quarterly basis though if needed’ there will be an “exception” report produced to highlight any major changes/ increases in the risk status in the interim periods. At a Business area/Local Policing Area, managers are required to ensure that risks associated to priorities are reported quarterly through the business planning template, Risk Management will provide quality assurance checks on the risks. If a new risk needs to be agreed the manager responsible should complete a “risk form” this form should be forwarded/e-mailed to the relevant senior manager for agreement. Select the attached link for the Risk Form template. Escalation of Risks If an operational level risk needs to be escalated to the Strategic Risk Register it is agreed by the Risk Review Group members before it is reported by Exception to either the Chief Officer Executive Board or the Chief Officer Group. Risk updates are provided to the Change Management Board and the Service Improvement Board as and when required. In which case the risk will be reported to the Commissioner and Chief Officers to make an informed decision about the further action required. Risk Management Intranet Site Internal Control Our internal control measure is to provide reasonable assurance through the identification of objectives/priorities and associated risks in the business planning process within the Commissioner’s office and Constabulary. RMF Version 2.9 revised 15 Nov 2012 15 Appendix 2 – Risk Management Structure The Gloucestershire Police and Crime Commissioner and Constabulary have implemented a risk management process to manage effectively the business risks in order to ensure it operates under sound principles of Corporate Governance. A structural diagram for managing risk and key reporting responsibilities for the organisations can be accessed using the link below: Management of risk structure & reporting RMF Version 2.9 revised 15 Nov 2012 16 Appendix 3 – Roles & Responsibilities Roles and Responsibilities Within the Commissioner’s office and Constabulary the following key roles and responsibilities have been identified as part of the standard operating procedures. All Staff All staff are responsible for identifying and managing risk once they have been provided with the necessary training and skills. It’s not the sole domain of managers or management groups. Portfolio Holders and LPA/Business area Heads It is the responsibility of the Portfolio Holders and Business area managers to produce their own risk register. Any risk that needs to be escalated to the Strategic Risk Register should be reported to the Risk Management who will submit a quarterly “Risk Report” to the Risk Review Group. Risk Owners/Risk Leads Each identified strategic risk will have a named risk owner, that is, a person with responsibility for ensuring that each of the proposed responses to risk are implemented The Risk Lead is responsible for monitoring the overall progress, tackling the risk and providing report updates on the risk controls and status. Specific roles & responsibilities for the management of risk can be accessed using the attached link: RM Roles & Responsibilities RMF Version 2.9 revised 15 Nov 2012 17 Appendix 4 – Risk Register Risk Management maintains the risk register template. A generic version is issued to each Portfolio Holder/LPA/Business area managers for them to complete and maintain. It is their responsibility to maintain these registers and provide updates to Risk Management following the timetable within the Standard Operating Procedure. Each risk register should be constructed using the corporate template; the latest version & guidance can be obtained from the Risk Management intranet site or through Risk Management. To access the risk register template, use the link below: Risk Register Template Each Portfolio Holder/LPA/Business area head is responsible for populating and maintaining their risk register. Risk Management will assist a designated member from each team in reviewing the information provided, however they are not responsible for its accuracy or the assessments made against each risk. The register is used to contain each Head’s assessment of their business. To access the Risk Management intranet site, use the link below: Risk Management Intranet Site Terminology A full list of terminology for Risk Management can be accessed on the Risk Management intranet site, using the link below: Risk Management Terminology Strategic Risk Management Change Management Team Gloucestershire Constabulary Police Headquarters|No.1 Waterwells|Quedgeley|GL2 2AN www.gloucestershire.police.uk RMF Version 2.9 revised 15 Nov 2012 18