Transparency data

6 September 2022: National Law Enforcement Data Programme (NLEDP) accounting officer assessment

Updated 2 April 2024

Objectives

The Police National Computer (PNC) is the most important national policing information system in the UK. Since 1974 it has been the main database of criminal records and is used by front-line officers from all police forces in the UK to understand who they are interacting with. The PNC is also accessed by, or provides data to, another 127 organisations with a range of restrictions on what they can access.

Whilst the PNC has evolved significantly, it is limited by the 1970s software on which it runs. This means, for example, PNC cannot display images and is not user intuitive. The software PNC is based upon ceased being taught in universities 30 years ago and there is a rapidly diminishing pool of people who can understand the programming language and underlying technologies. For these reasons, the PNC is now rapidly reaching end of life and needs to be replaced.

The National Law Enforcement Data Programme (NLEDP) was established in 2016 and will incrementally replace PNC with the Law Enforcement Data Service (LEDS) enhancing the ability of Law Enforcement to protect the public. The first LEDS capabilities have been available for use from March 2022. Information will be more joined up and aligned to new ways of working developed by operational users. LEDS is designed to be continuously improved. This means that new features and capabilities will be incrementally added as the roles of policing and law enforcement develop. Capability will no longer lag operational need.

Under the original scope for NLEDP, it was envisaged that the PNC would also be combined with the Police National Database (PND) into a single system. The PND is a national intelligence information management system that improves the ability of the Police Service to manage and share intelligence and other operational information, to prevent and detect crime and make communities safer. The PND offers a capability for policing and other law enforcement agencies to share, access and search locally generated intelligence information electronically, overcoming artificial geographical and jurisdictional boundaries. The PND was set up following the Bichard Inquiry into the Soham murders where issues in police intelligence gathering and sharing were identified.

Between 2016 and 2020 NLEDP faced some significant challenges that impacted on progress and delivery, and the programme was subject to a number of reviews with the Infrastructure and Projects Authority (IPA) and the National Audit Office (NAO). In addition, the programme undertook a comprehensive internal optimisation review during the summer of 2020 which reviewed in detail scope, cost and plans. These activities identified that the level of effort required to deliver the LEDS had significantly increased compared to original estimates, mainly caused by the high level of complexity involved in moving to LEDS from the PNC, a system that had grown organically over 45+ years.

The concerns were shared by the Chief Constables Reference Group (CCRG) and the Home Office worked closely with them, the National Police Technology Council (NPTC) and Operational Communications in Policing (OCiP) to identify ways to move forward.

The Home Office recognised challenges across the Major Law Enforcement portfolio and accelerated plans to split the responsibilities of the Senior Responsible Owner (SRO) across the different law enforcement programmes. In October 2020 the Home Office appointed a new SRO for NLEDP. The Home Office also established an External Assurance Team, referred to as the “NLEDP Red Team”, to independently review the scope, architecture and delivery approach of the programme.

In November 2020, having reviewed the recommendations from both the NAO review and the NLEDP Red Team, the programme was placed into reset with the majority of staff offboarded, leaving a core team in place. Under the new SRO, the programme, supported by external consultants, established a range of criteria that needed to be achieved to allow the programme to exit reset.

Project Stage

Having successfully addressed the issues preventing the programme from moving forward and following approval from the Home Office Finance and Investment Committee (FIC) in July 2021, the Programme was able to exit reset and enter into a Pathfinder Phase of its lifecycle. NLEDP is pioneering a new technique for the delivery of large and complex capabilities in the Department. Instead of delivering a single “monolithic” system, the Programme is developing several capabilities (or “Products”) that will developed and delivered incrementally to form the LEDS. This approach was defined within the revised Full Business Case approved at the Home Office FIC on 29th July 2021. The Business Case for LEDS is resubmitted for review and approval to FIC every six to nine months, with the latest iteration being approved on 17th February 2022.

Having achieved all critical success factors and having delivered two new products into Private Beta by 31st March 2022, the LEDS programme transitioned from the Pathfinder Phase (where various aspects of the programme delivery approach were being proven, alongside the evolution of the partnership working model between Policing and the Home Office) to the Scaled Delivery Phase. This phase focuses on running multiple product teams in parallel across all Police National Computer (PNC) capabilities alongside working on products moving from delivery into adoption. This will enable the programme to maintain and demonstrate the burn down of reliance on PNC.

HM Treasury approved the July 2021 business case on 27 April 2022, and a Treasury Approval Process (TAP) panel took place on 1 August 2022 for the latest business case. Now that the programme has exited the pathfinder phase, the Home Office believe it is appropriate to produce an Accounting Officer assessment.

Further background and context

LEDS was originally going to combine both the PNC and the PND. However, due to the high level of complexity involved in just replacing PNC, a joint decision was made by Policing and the Home Office in November 2020 to remove PND from scope and to reset the Programme. PND is now being progressed as a separate dedicated programme.

It is necessary that the PNC would continue to run in parallel with LEDS until the end of 2025 during which time the revised programme would incrementally replace PNC capabilities and services. The Programme has advanced plans in place to assist police forces, and other user organisations, to adopt LEDS and the Home Office is making further investment in the PNC so that it remains fully operational and supported until fully decommissioned in March 2026. The PNC remains highly stable, with millions of criminal records checks performed each month.

In addition to replacing the PNC, where reasonable additional functionality will be added, LEDS will develop new data services that will improve public protection and criminal justice outcomes. The combination of new technology and ways of working will provide additional benefits, including a reduction in future running costs and substantial end user efficiency and effectiveness benefits.

In summary, LEDS will provide:

• Modern, affordable, adaptable services and processes that can evolve to address new business priorities
• Data where it is needed, i.e. through handheld mobile devices
• A system designed with the needs of the user in mind
• Images, including those of people that are wanted or missing
• The ability to set proactive alerts on individuals who are known to be frequently interacting with the police.
• Better alignment with human rights, equality, and data protection acts
• A reduced risk of system failure and outage compared to PNC

This assessment is made due to NLEDP scope and approach to delivery changing significantly and because the programme has exited pathfinder phase following a significant reset.

Assessment against the Accounting Officer Standards.

1. Regularity

The Programme’s whole life cost is contained within the overall Home Office Delegated Expenditure Limit for police resource and capital expenditure. The Programme’s expenditure is contained within the income arising from contributions to the Home Office for the provision of Police IT services and from the Department’s administrative resource. The investment requires business case approval from HM Treasury to ensure compliance with Managing Public Money. Home Office Finance and Investment Committee provides control to programme expenditure by the approval of a full Programme business case for each stage of development. These business cases are developed at least annually. Reports on the progress against expenditure are included in the Departmental Treasury Minute.

One of the Home Office’s priority outcomes is to reduce crime. The Department’s current Outcome Delivery Plans for reducing crime relies upon NLEDP implementing LEDS to provide a new joined-up information system to prevent crime and better safeguard the public. LEDS will replace the current functionality in the PNC incrementally through the delivery of a series of LEDS products. Each product will be assured for regularity during its development. This will include identifying the legal basis and the provision of guidance for how each product should be used. This will include activity by UK Police forces and law enforcement organisations in addition to Police Forces in Crown Dependencies such as Jersey, Guernsey, and Isle of Man.

The Secretary of State has broad powers under the Police Act (1996) to provide, maintain or contribute to organisations, facilities and services considered necessary or expedient for promoting the efficiency or effectiveness of the police. The term Common Services can include organisations that are not England and Wales police forces if the Home Secretary considers it necessary or expedient for the efficiency or effectiveness of policing. Both the PNC and LEDS are included within the definition of Common Services.

Operational control of the data in PNC is maintained through the Police Information Access Panel (PIAP). A similar mechanism will be repeated in LEDS once the information that the PNC currently holds is held in LEDS. Much of the personal data is governed under legislation concerning criminal records, although other information deemed valuable in a policing and law enforcement context will be held on LEDS as is the case on the PNC. The Information Commissioner’s Office is discussing with the Home Office and Policing how best to ensure better alignment with the Data Protection Act (2018) for the Police National Computer, although this will require the implementation of LEDS in order to be fully realised.

Regularity Conclusion

The use of information within both the PNC and LEDS is supported either by explicit legislation, or by common law duties and powers. The police also have common law powers to share information with other public bodies where it is in the public interest to do so in pursuit of the police’s functions and functions of the body with whom the information is being shared. The PNC contains and LEDS will maintain a robust audit capability to enable compliance checks with operational and legislative requirements. Where additional benefit can be gained through new legislation there is a process to identify this and to develop options, however, the project does not require new or amended legislation to progress and therefore the programme conforms to the Regularity Accounting Officer standard.

2. Propriety

The NLEDP supports the Department’s Outcome Delivery Plan, principally the priority outcome of reducing crime critical to the Home Office’s public safety mission. The Home Office, through NLEDP, is developing LEDS to replace PNC. The PNC currently provides police and law enforcement agencies with access to a centralised source of information concerning individuals, property and vehicles, gathered and used for law enforcement, policing and safeguarding purposes. This information will be used for the prevention, investigation, detection and prosecution of criminal offences, the execution of criminal penalties, and for wider policing purposes, such as the safeguarding of children and vulnerable adults and the protection of property. PNC is the single most important national policing system in the UK. The NLEDP is relocating the multiple existing data sets currently maintained within PNC into a new technology platform in LEDS. This will better ensure that officers are able to use information to detect and prevent crime and safeguard the public in line with the requirements of the data protection legislation. The development work on LEDS will, in due course, result in the decommissioning of PNC, with an expected net saving in operational costs. It is therefore in the public interest for this Programme to deliver.

The reset of the Programme was approved in July 2021. Continuous improvements to the delivery capability are being maintained. The new resources to deliver the capability are now in place or are being recruited. These plans and the regularly updated full business case are scrutinised through the Home Office Finance and Investment Committee process, through the Programme’s oversight board, by HM Treasury and through stakeholder governance. This is a complex programme currently assessed by the Infrastructure and Projects Authority (IPA) as having a delivery confidence assessment of Amber which is reflective of the significant scale and complexity of NLEDP.

The senior stakeholders needed for successful outcomes are intimately involved in the delivery. A broad spectrum of civil society organisations are involved in the scrutiny of the LEDS delivery outcomes and through this community the public has informed visibility of LEDS. Key documentation will also be published on gov.uk to aid transparency and accountability.

LEDS will incrementally replace the PNC with a series of products. Each product is assessed during its development phase against ethical themes under the Data Ethics Framework which assesses the proportionality of the use of data through each product. The assessment will take a risk-based approach, with a broad spectrum of internal (Home Office) and policing scrutiny during the development of each product. The Office of the Data Protection Officer will assure data protection risks and the Police Information Access Panel will ultimately approve the product designs from a data protection perspective. This assessment will also ensure the legality of each product being developed by the programme. Additionally, Civil Society Organisations and the Information Commissioner’s Office will review key documentation throughout the Programme’s lifecycle. A Parliamentary Code of practice for LEDS is being prepared in partnership with the College of Policing to guide the behaviours whilst using, managing, and governing LEDS.

A key element of the propriety standard is whether any proposal is sustainable including whether sufficient public resources are available and are likely to continue to be available. Affordability was a concern prior to the Programme’s reset. It is recognized that continued alignment between the future funding need and the allocation is required. The Programme’s continued funding will be secured through the continued successful demonstration of delivery. Detailed discussions are ongoing to ensure that activities and costs of decommissioning the PNC are fully planned and achieved.

Propriety Conclusion

In summary, the proposal supports a significant proportion of the Department’s Priority outcomes, the affordability risks are known, clear and well managed. The legal risks are surfaced through an extensive process and signed off at an appropriate level. The stakeholder involvement is significant, ensuring the capabilities are delivered to standard. The public remains informed through a network of civil society organisations and further public documentation is planned. The Information Commissioner’s Office kept informed about the development of LEDS and about significant issues as they arise. I therefore consider the programme to align with the principles documented in Managing Public Money and to conform to the Propriety Accounting Officer standard.

3. Value for Money

A robust cost-benefit model has been developed in support of regular NLEDP business case submissions. This analysis is undertaken in line with Green Book best practice, considering benefits, costs, risks, and uncertainty. It concludes that the preferred way forward represents good value for money and is recommended as the preferred option.

Benefits

Benefits from efficiency savings, cost savings and outcome improvements for public and private sector stakeholders have been identified and appraised over a 15-year appraisal period from FY2021/22 to FY2035/36. A benefits-tracking framework and realisation plan has been established to monitor all programme benefits. Key benefits that will be delivered by NLEDP include:

• Improved safeguarding of missing persons. The National Register of Missing Persons (NRMP) will establish a national record of current and historic missing events. This will give much needed help to policing and other partner agencies in their efforts to better safeguard vulnerable individuals.
• Efficiency of missing persons investigations. The NRMP allows lines of enquiry for investigations to be more quickly established and resolved, reducing the escalating cost of a long running investigation.
• Reduced inefficiency from PNC outages. LEDS will be a more performant and available system than PNC, reducing the considerable disruption and inefficiency from system outages, which are forecast to increase over time.
• Reduced time to train new users. There is a considerable overhead in training new system users, particularly on PNC. LEDS is a more intuitive system for new users with less time required to complete initial training, reducing the burden of abstraction of staff as well as direct training costs.

The benefits delivered to date are from the rollout of PARS (Photographs at the Roadside). Being able to access DVLA images via mobile devices offers officers lines of enquiry to establish identity more quickly, leading to time saving and operational safety benefits for both officers and the public.

The Baseline

The PNC is an element of critical national infrastructure that is reaching the end of its life. It will require replacing within the next five years and therefore a do-nothing baseline has been disregarded from our analysis. A do minimum investment has instead been used as the baseline for analysis on NLEDP. The do minimum option modelled is the lowest reasonable cost to keep PNC running until 2036. The do minimum option presented meets the minimum requirements of the service from an operational, but not from a security, perspective.

Net Present Social Value (NPSV)

The NPSV analysis is performed through an economic appraisal, which treats costs differently compared with a financial analysis undertaken as part of a finance case. The present value of costs for the baseline option is £294m. The present value of costs for the preferred LEDS option is £517m. Relative to this baseline, the present value of costs for the preferred LEDS option (including Optimism bias and risk) is therefore £222m. The central estimate present value of benefits for the preferred LEDS option including Optimism bias is £318m. The central estimate of the preferred option is that NLEDP will therefore generate an NPSV of £95m.

Alongside this positive NPSV, consideration should be given to non-monetised factors. Unlike the baseline option, the preferred option aims to deliver system functions that minimise or remove the current legal compliance risks faced by the PNC. Additional non-monetised benefits include opportunities to improve societal outcomes through broader use of driver images and broader access to the PNC. A fuller list of identified non-monetised benefits is provided in the economic section of the NLEDP business case.

Risk

£31m of risk mitigation and residual risk have been identified and included in the central NPSV estimates. Key risks to the Programme include the feasibility and solution quality of two-way replication, and any additional resource being needed to complete the mitigating actions.

Sensitivity analysis has been undertaken to demonstrate the impact of changing key components of the cost-benefit analysis. Ranges have been produced to estimate the reasonable best-case and worst-case scenarios. The NPSV range is estimated to be -£49m to £264m, with a central estimate of £95m.

The central estimate NPSV suggests that the preferred option represents value for money. The range modelling suggests that cost delays and reductions in delivered benefits could lead to a negative NPSV. In this instance the NPSV would need to be considered alongside the non-monetised factors to judge whether the preferred option still represents value for money.

Impairment

After successfully exiting the reset in July 2021, a review was undertaken of capital expenditure incurred to the end of FY20/21 to identify elements that can be reused and those that cannot, resulting in an impairment of approximately £75m being recognised in FY21/22.  The NPSV analysis assumes all NLEDP capital is fully impaired by the end of the appraisal period (2035/36), therefore this £75m financial impairment has no additional impact on the value for money assessment.

Value for Money Conclusion

Taking account of the points above, I consider that the programme direction agreed in the July 2021 and February 2022 full business cases does conform to the Value for Money Accounting Officer standard. However, in the event that the NPSV was to turn negative, then the Accounting Officer advice will be updated and resubmitted.

4. Feasibility

The LEDS programme is being delivered to provide a PNC equivalent service, enabling the retirement of the legacy PNC architecture. The current PNC service will be unavailable beyond 31st March 2026 and support cannot be extended beyond this point. The LEDS development and delivery plan is therefore designed in response to this critical date. The current delivery plan aims to complete all development early 2024, with full adoption to follow by end-2025.

As part of the 2021 programme reset, and in response to a critical NAO recommendation, LEDS is delivering as a pathfinder for product centric design and has adopted an agile development approach. During the past 12 months the programme has made significant progress in embedding these delivery approaches to optimise success of programme delivery within the challenging timescales.

Again, as part of the reset it was recognised that to drive the successful delivery of an extremely complex national technology programme like NLEDP, that there was a need for a fundamentally different working relationship between Policing and the Home Office. There have been significant improvements in this area. Working in greater partnership with Policing colleagues, who are embedded into key programme roles, is helping to drive effective decision making and ensure products are developed that deliver on Policing requirements. This also helps to ensure that the views of Policing are represented at all levels and supports adoption of the new service.

The programme is following best practice and adhering to all recommended review and assurance processes. The actions taken on recommendations from these regular periodic reviews are borne out by the results of the external (IPA) Gateway reviews undertaken by the programme in September 2019 (Amber/Red), November 2019 (Amber), April 2021 (Amber), July 2021 (Amber) and January 2022 (Amber). An amber rating is considered realistically reflective of programmes of the scale and complexity of NLEDP. The recommendations from these Gateway 0 reviews (around resourcing, governance, long-term funding, stakeholder engagement strategy, development of the business case, and assurance of IT transformation delivery) continue to be addressed. IPA representatives are periodically updated on the progress of these recommendations.

The programme’s commercial procurement has continued following reset with contracts awarded to suppliers focusing on different products. Longer term the programme is responding to recommendations to secure longer term delivery frameworks to support delivery across all LEDS products.

The Programme’s delivery model is based upon delivering a series of products rather than a single “big-bang delivery”. The delivery is now organised around teams that are focused on products. This allows greater flexibility of commissioning and transparency of costs.

Resourcing the programme with the right quality and quantity of skilled individuals via both civil service and contingent labour routes has been a challenge for the programme. The programme has undertaken a forensic review into the lengthy resourcing process (from identification and confirmation of resource requirements) to identify and address issues. The programme has also reprofiled resourcing based on the roadmap for delivery and maturing its approaches to proactively plan for when critical resources are needed, and the time taken to onboard.

The adoption of LEDS products by police forces and other organisations is being addressed by a dedicated team backed by specific funds to enable those organisations to conduct the necessary business change in preparation for adopting LEDS products. There is also a clear and mutual understanding of the role which Standard interface Replacement Gateways (SRG) play in the deployment of LEDS products. This team is now working in collaboration with SRG providers to align development and delivery plans.

Projections of costs estimates for completion of the LEDS programme are developing well and informed by maturity of design and experience of delivery to date. There remain some specific focus areas including resourcing and service management which continue to be developed.

The programme has undertaken significant work in the maturity of identification, assessment and management of Risks, Actions, Issues, and Decisions (RAID). One of the significant drivers of delivery confidence is the volume and complexity of dependencies related to the programme. The primary internal programme dependency is the 2-way replication functionality supporting the parallel running of LEDS and PNC during the development and adoption window. There are a number of other critical cross-Police and Public Protection Technology (PPPT) portfolio dependencies including the availability and functionality of the Law Enforcement Cloud Platform, availability of a finite number of skilled PNC resources and the successful pre-deployment of the National Identity Access Management (NIAM) solution to support effective development and deployment of LEDS.

Delivery confidence has significantly improved since the 2021 reset, with the move to a product centric approach, agile development approach, the strengthening of the NLEDP leadership team, and the successful initial product deployments in March 2022.

Feasibility Conclusion

NLEDP remains highly complex with associated levels of risk and as such requires ongoing attention to delivery and focus on feasibility and risk mitigation. With this in mind, and based on the latest IPA review, and FIC scrutiny of the resultant revised business case, I consider the programme to meet the Feasibility Accounting Officer standard but will continue to monitor this closely.

Summary Conclusion

The National Law Enforcement Data Programme conforms to the four Accounting Officer standards of Regularity, Propriety, Value for Money, and Feasibility.

The time critical requirement to replace the aging and inflexible infrastructure of the PNC and enable the development of 21st Century capabilities for policing is of such importance as to warrant the continued progress of the programme.

As the Accounting Officer for the Home Office, I have considered and approved this assessment of NLEDP.

This Accounting Officer Assessment will be published on the Government’s website (GOV.UK). Copies will be deposited in the Library of the House of Commons and sent to the Comptroller and Auditor General, Treasury Officer of Accounts and the Chair of the Public Accounts Committee.

Matthew Rycroft

Permanent Secretary

6 September 2022