National Assessment Framework

The purpose of this document is to set out details of the national assessment framework for biometric data outcomes in Scotland to be used by the Scottish Biometrics Commissioner when conducting the general function prescribed in law to support and promote the adoption of lawful, effective, and ethical practices in relation to the acquisition, retention, use, and destruction of biometric data for criminal justice and police purposes in Scotland. (Scottish Biometrics Commissioner Act 2020, Section 2 (1).)

This document should be read in parallel with our Code of Practice once brought into regulation by Scottish Ministers which will establish a statutory framework of Guiding Principles and Ethical Considerations on the acquisition, retention, use, and destruction of biometric data for criminal justice and policing purposes in Scotland. This assessment framework for biometric data outcomes is based on the Public Sector Improvement Framework (PSIF) methodology in Scotland developed by the Improvement Service. The Framework, together with our Code of Practice is intended to provide both a self-assessment framework for those to whom our legal jurisdiction extends, and to serve as a mechanism through which we can assess biometric data outcomes in support of the national outcomes for Scotland.

PSIF allows people to understand and manage the relationship between what their organisation does and the outcomes it achieves. This framework shall guide our work and together with our Code of Practice can also serve as a self-evaluation model for the undernoted when considering their approach to biometric data and technologies:

1. Police Scotland,
2. Scottish Police Authority (SPA),
3. Police Investigations and Review Commissioner (PIRC)

PSIF is a recognised management framework in Scotland endorsed by the Scottish Government which allows organisations to achieve success and to understand gaps and possible solutions, empowering them to progress.

The concept of quality management and measurement frameworks in the public sector is not new, and in Scotland PSIF has been developed by the Improvement Service primarily for use in local government.(https://www.improvementservice.org.uk/)

Such frameworks are already in use in the policing sector in Scotland, for example in the Inspection Framework adopted by Her Majesty’s Inspectorate of Constabulary in Scotland (HMICS), and the corresponding self-assessment tools used by Police Scotland.

To ensure synergy within the wider policing family in Scotland, the Scottish Biometrics Commissioner will also adopt the six self-evaluation framework themes from PSIF already utilised by HMICS and Police Scotland that are of most relevance to the policing and criminal justice context in Scotland. These themes are:

• Leadership and governance
• Planning and process
• People
• Resources
• Partnerships
• Outcomes

However, as the functions and duties of the Scottish Biometrics Commissioner relate solely to biometric data within the policing and criminal justice sector, and to the corresponding physical samples to which such data relates, we have designed a bespoke set of quality indicators for biometrics aligned to PSIF which underpin these themes.

Our Framework methodology has been developed in partnership and has been quality assured by the Improvement Service. Our Framework and our Code of Practice provide the lens through which we will discharge our general function to support and promote the adoption of lawful, effective, and ethical practices in relation to the acquisition, retention, use, and destruction of biometric data for criminal justice and police purposes in Scotland.

This initial version of our Framework is not set in stone and will continue to be reviewed and updated considering experience of what works, as well as any changes in the wider context within which we operate including 360 feedback which will be sought from the various organisations and agencies with whom we work.

Dr Brian Plastow
Scottish Biometrics Commissioner
19 January 2022

The Scottish Biometrics Commissioner is a juristic person, independent of the Scottish Government and appointed by Her Majesty, on the recommendation of the Scottish Parliament. The Commissioner is a parliamentary office holder accountable to the Scottish Parliament, and ultimately to the people of Scotland. The Commissioner has a small number of staff who assist in discharging the Commissioner’s functions and obligations, including the preparation and revision of a Code of Practice on biometric data for criminal justice and policing purposes in Scotland.

The Scottish Biometrics Commissioner is established under the Scottish Biometrics Commissioner Act 2020.

The Commissioner’s general function is to support and promote the adoption of
lawful, effective, and ethical practices in relation to the acquisition, retention, use and
destruction of biometric data for criminal justice and police purposes by:

• The Police Service of Scotland (Police Scotland),
• Scottish Police Authority (SPA),
• Police Investigations and Review Commissioner

The Commissioner has wide ranged general powers and may do anything which appears to the Commissioner to be necessary or expedient for the purposes of, or in connection with, the performance of the Commissioner’s functions, or to be otherwise conducive to the performance of those functions. (Scottish Biometrics Commissioner Act 2020, Section 4)

The Scottish Biometrics Commissioner Act 2020 contains the following definition:

‘In this Act, “biometric data” means information about an individual’s physical, biological, physiological, or behavioural characteristics which is capable of being used, on its own or in combination with other information (whether or not biometric data), to establish the identity of an individual, and may include:

1. Physical data comprising or derived from a print or impression of or taken from an individual’s body,
2. A photograph or other recording of an individual’s body or any part of an individual’s body,
3. Samples of or taken from any part of an individual’s body from which information can be derived, and
4. Information derived from such samples (Scottish Biometrics Commissioner Act 2020, Section 34)

As a values-led organisation, we will conduct our activities in a way that is Independent, Transparent, Proportionate and Accountable:

• Independent - We will always act independently and publish impartial and objective review reports. Our professional advice will be informed and unbiased. The Scottish Biometrics Commissioner is a juristic person, appointed by Her Majesty the Queen on the nomination of the Scottish Parliament and is independent of Scottish Government.
• Transparent - We will be open about what we do and give reasons for our decisions. We will publish our reports and findings and will not restrict information unless deemed necessary to protect the identity of data subjects, or due to wider public interest considerations.
• Proportionate - We will ensure that our activity is proportionate and does not exceed what is necessary to achieve our statutory purpose. We will minimise the burden of any review activity on Police Scotland, the Scottish Police Authority, and the Police Investigations and Review Commissioner. We will ensure that the way that we do what we do is necessary, effective, and efficient.
• Accountable - We will be accountable for what we do to the Scottish Parliament and will submit ourselves to whatever scrutiny is appropriate to our function. We will promote equality, diversity, and human rights in everything that we do.

Scotland does not have a national biometrics strategy relating to devolved areas of policy such as criminal justice and policing. However, in 2018, the Home Office published a Biometrics Strategy for the Home Office sector in England and Wales, including plans for the
shared UK policing databases some of which incorporate Scottish policing sector biometric data. (Home Office Biometrics Strategy 2018. )

The Home Office strategy has important implications for Scotland given the aggregation of Scottish biometric data such as fingerprints, DNA profiles, and photographs to common UK policing databases, and the reciprocal access to the biometric records of citizens in other jurisdictions by policing and criminal justice sector bodies in Scotland.

Within this wider context, the overarching National Outcomes for Scotland, our Justice Priorities, our distinct Scottish Criminal Justice legislation, and the Strategic Police Priorities for Scotland provide a strategic framework against which to assess how well biometric data policy, practices, and procedures contribute to support those national priorities and outcomes. In addition, public authorities in Scotland within the policing and criminal justice sector must comply with the law, including international law and human rights treaty obligations.

In 2016, Scottish Government laid the Strategic Police Priorities for Scotland before the Scottish Parliament.
(Strategic Police Priorities for Scotland, Scottish Government: 2016)

The Strategic Priorities were developed following extensive public engagement. This informed the development of seven interdependent policing priorities:

• Localism - Ensure that the needs of local communities are understood and reflected in the planning and delivery of policing at a local and national level
• Inclusion - Ensure our police service is accessible and responsive to the needs of all people in Scotland.
• Prevention - Ensure our police service works to protect people by preventing crime and reducing fear of crime through communication, education, innovation, and partnership working.
• Response - Focus policing on improving the wellbeing of individuals and communities by tackling crime and responding to and investigating incidents effectively and efficiently.
• Collaborate Working - Ensure that our police service works productively with partners at local, national, and international levels to deliver better outcomes for people in Scotland.
• Accountability  - Continuously improve public confidence in policing and inspire trust by being transparent, accountable, and acting with integrity, fairness, and respect. 
• Adaptability - Ensure our police service takes advantage of new opportunities and meets emerging threats and challenges. 

In 2018, the new National Performance Framework was launched jointly by the Scottish Government and COSLA. It provides a structure around which public bodies and their partners can align activities and decisions towards shared objectives and outcomes.

It sets out 11 long-term outcomes for Scotland, underpinned by 81 national performance indicators against which progress can be measured.

The National Performance Framework are as follows:

• grow up loved, safe and respected so that they realise their full potential
• live in communities that are inclusive, empowered, resilient and safe
• are creative and their vibrant and diverse cultures are expressed and enjoyed widely
• have a globally competitive, entrepreneurial, inclusive and sustainable economy
• are well educated, skilled and able to contribute to society
• value, enjoy, protect and enhance their environment
• have thriving and innovative businesses, with quality jobs and fair work for everyone
• are healthy and active
• respect, protect and fulfil human rights and live free from discrimination
• are open, connected and make a positive contribution internationally
• tackle poverty by sharing opportunities, wealth and power more equally

you can find more about the outcomes at https://nationalperformance.gov.scot/national-outcomes

Although the Scottish Biometrics Commissioner and the bodies to which our functions extend are independent of Scottish Government, all conduct activities in Scotland for the collective benefit of citizens and therefore it is important that a tangible link exists between policing and criminal justice outcomes and Scottish Government aspirations. The Strategic Police Priorities for Scotland and the National Outcomes of delivering community safety, protecting equalities and human rights, avoiding discrimination, and making a positive contribution internationally demonstrate this connection and accordingly are of direct relevance to how biometric data and technologies are used for criminal justice and policing purposes in Scotland.

In 2018, Scottish Government also published the Justice Vision and Priorities Delivery Plan. A range of strategies, programmes and legislation underpin the Justice Vision for ‘A Just, Safe and Resilient Scotland’.

The Justice Vision contains four strategic outcomes and seven priorities.

Outcomes

• We live in safe, cohesive and resilient communities
• Prevention and early intervention improve wellbeing and life chances
• Our system and interventions are proportionate, fair and effective
• We deliver person-centred, modern and affordable public services

Priorities

• We will enable our communities to be safe and supportive, where individuals exercise their rights and responsibilities
• We will enable our people, economy and infrastructure to respond to major risk, recover from emergencies and adapt to emerging threats
• We will modernise civil and criminal law and the justice system to meet the needs of people in Scotland in the 21st Century
• We will work with others to improve health and wellbeing in justice settings, focusing on mental health and substance use
• We will work to quickly identify offenders and ensure responses are proportionate, just, effective and promote rehabilitation
• We will improve the experience of victims and witnesses, minimising court attendance and supporting them to give best evidence
• We will use prison only where necessary to address offending or to protect public safety, focusing on recovery and reintegration

The way that biometric data and technologies are used in Scotland are also of direct relevance to the Justice Vision, outcomes, and priorities for Scotland. Collectively, the National Outcomes for Scotland, our Policing Priorities, and our Justice Priorities inform the respective strategic plans of Police Scotland, the Scottish Police Authority and the Police Investigations and Review Commissioner, and consequentially the Scottish Biometrics Commissioner.

In conducting our statutory functions, we will also consider the broader context of public sector reform in Scotland. In response to a report by the Christie Commission, Scottish Government has set out its approach to the future delivery of public services in Scotland based on four key pillars:

• Prevention – reducing future demand by preventing problems arising or dealing with them early.
• Performance – a sharp focus on improving performance through greater transparency, innovation and use of digital technology.
• People – greater investment in people who deliver services through enhanced workforce development and effective leadership.
• Partnership – developing local partnerships and collaboration, and bringing public, third and private sector partners together with communities to deliver shared outcomes. (Scottish Government, Renewing Scotland’s public services: priorities for reform in response to the Christie Commission 2011, and Dr Campbell Christie, Commission on the future delivery of public services 2011.)

In exercising our general function as previously described, the Commissioner is to keep under review the law, policy and practice relating to the acquisition, retention, use and destruction of biometric data by or on behalf of Police Scotland, the Scottish Police Authority and the Police Investigations and Review Commissioner.

We must also promote public awareness and understanding of the powers and duties these persons have in relation to the acquisition, retention, use and destruction of biometric data, how those powers and duties are exercised, and how the exercise of those powers and duties can be monitored or challenged.

In supporting and promoting the adoption of lawful, effective, and ethical practices, we must have regard to the interests of children and young people, and to vulnerable persons.(Scottish Biometrics Commissioner Act 2020, Section 2 (6). )

Details of how we will exercise our general function can be viewed in our Strategic Plan 2021 to 2025.(The Scottish Biometrics Commissioner 4-year Strategic Plan 2021-2025 was laid before the Scottish Parliament on 24 November 2021.)

When discharging our statutory functions, we will use our National Assessment Framework, based on PSIF, to consider strategic direction, execution, and results in relation to biometric data used for criminal justice and policing purposes by the bodies to whom our statutory powers extend. Our framework has 6 outcome headings and contains 42 quality indicators that have been nuanced to the biometric data context.

As set out in the introduction to this Framework, our approach to making professional assessments about the quality of biometric data outcomes is based on the 6 themes from PSIF that are of most relevance to the criminal justice and policing context in Scotland. Our approach to these themes is as follows:

• Outcomes - We will focus on the overall performance of the organisation in relation to biometric data and technologies and seek to examine success in delivering demonstrable, high quality and improved outcomes in support of statutory functions and national outcomes including human rights and equality
• Leadership and governance - We will examine strategic leadership and governance, scrutiny, and accountability arrangements for biometric data and technologies to assess whether the organisation is delivering its overall vision in support of statutory functions and national outcomes including human rights and equality.
• Partnerships - We will assess how well partners work together to support the delivery of criminal justice, community safety and policing outcomes in relation to biometric data and technologies, including human rights and equality. This will include an assessment of partnership working in Scotland, and where appropriate to the functions of the organisation, wider UK, and international partnerships in connection with biometric data exchange and the operation of shared technologies.
• Planning and process - We will examine the effectiveness of strategy and planning processes in relation to the acquisition, retention, use, and destruction of biometric data including human rights and equality. We will consider whether processes comply with the Code of Practice developed by the Scottish Biometrics Commissioner and consider safeguards and special arrangements when collecting biometric data from children, young people, and vulnerable persons.
• People - We will assess whether staff working with biometric data and technologies have the skills and competencies required to deliver on agreed outcomes and priorities. This will include an assessment of familiarity with the concept of unconscious bias, and how well staff understand the reliability and validity of technologies and how human interaction with such technologies can impact on equality, human-rights, ethical and privacy considerations.
• Resources - A key element of resourcing is the consideration of best value. We will assess whether organisations collecting biometric data for criminal justice and policing purposes in Scotland have the resources to manage and control Scottish biometric data in accordance with Scottish legislation, operational policies, human rights and equality, lawfulness, and any Codes of Practice in terms of its use.

The following tables provide specific details of the quality indicators/statements that will be considered for each theme of our assessment framework for biometric data. The framework of indicators, together with our Code of Practice, is designed to provide a substructure through which to help evaluate overall direction, execution, and results and to help improve independent oversight, governance, and scrutiny. Using these indicators, we aim to identify strengths and areas for improvement that can be built into an improvement plan.

• A1
  1. Strategies, Standard Operating Procedures (SOPs), and policies are in place for the acquisition, retention, use and destruction of biometric data and samples.
  2. The outcomes whether for verification, identification, or elimination purposes are clearly articulated in key policy documents and demonstrate a contribution to national priorities and outcomes.
• A2
  1. There are measures in place to monitor the outcomes from biometric data analysis and comparison. For example, data on Criminal Justice (CJ) Profiles added and removed, the matching of CJ Profiles to Crime Scene Profiles to assist crime solvency, data on crime scene match rates etc.
  2. Such data is published and updated on a regular basis to promote public understanding and awareness.
• A3
  1. The demand for the acquisition of biometric data through criminal justice sampling following arrest, and the demand from the creation of biometric samples derived from crime-scene materials are monitored and understood.
  2. The information is used to make improvements in the way services are prioritised, resourced and delivered.
• A4
  • There are clear indicators of effectiveness and efficiency linked to strategic priorities and outcomes. For example, the utilisation of complex DNA analysis and interpretation to support or discount investigative hypotheses.

• A5
  • Evidence and measures collected as part of a comprehensive performance management framework are compared with relevant benchmarks and trends, are appropriately segmented by biometric data category, (for example fingerprints, DNA, photographs) and are used to understand strengths and areas for improvement.
• A6
  • Qualitative measures are in place to assess low volume but high value outcomes. For example, to adequately capture the value of advanced DNA profiling technology and tangible outcomes in terms of offering powerful new insights to current or cold case investigations.
• A7
  • Performance management enables the demonstration of quality of service and best value, linking effectively with risk management and continuous improvement processes.

• B1
  1. Criminal Justice and/or Forensic Science strategies for biometric data are clearly communicated.
  2. The principles of lawfulness, proportionality and necessity are embedded in the leadership and governance regimes in pursuit of national outcomes.
• B2
  1. Leaders promote a culture of effectiveness, efficiency and sustainability and drive and support change, improvement, and best value.
  2. A culture of integrity, fairness, respect, and the protection of human rights is applied to leadership and governance considerations.
• B3
  • Data security, community impact, equality impact, and privacy impact assessments are conducted in respect of biometric data and technologies ensuring that ethical and human-rights considerations are embedded into operational practice and policy.
• B4
  1. Leaders actively build, support, and participate in strategic partnerships including UK leadership, governance, and oversight arrangements for biometric and forensic data.
  2. Governance arrangements are in place to ensure that Scottish law and policy is applied to the governance of Scottish biometric data collections when aggregated to UK biometric databases.
• B5
  • There are clear governance and accountability arrangements for the organisation in relation to biometric data that hold leaders to account for delivering services effectively and efficiently.
• B6
  • There is effective, objective, and transparent scrutiny that allows challenge of strategy and policy implementation, decision making and performance.
• B7
  1. Performance and delivery against outcomes are reported to relevant staff, partners, the public and stakeholders.
  2. This is used to facilitate continuous improvement.

• C1
  1. There are organisational structures, strategies, policies, plans and processes in place for the management of biometric data.
  2. The acquisition, retention, use and destruction of biometric data is based in law and where legal gaps exist it otherwise adheres to the Code of Practice developed by the Scottish Biometrics Commissioner.
  3. Planning and processes support the delivery of desired outcomes effectively and efficiently.
• C2
  • Key processes (including statutory duties) are mapped, reviewed, and improved. These consider the impact they may have on other areas of the organisation or other organisations, including processes undertaken in partnership.
• C3
  • A culture of innovation, learning and improvement is promoted by identifying internal and external risk factors and good practice that could impact upon the delivery of outcomes and priorities. Information is shared widely to facilitate improvement.
• C4
  1. Changes to the way that biometric data or technologies is managed takes place through a structured process to ensure the defined impact and benefits from improvement actions are realised at an appropriate pace.
  2. The reliability of biometric technologies capable of automated search and comparison are validated and accredited.
• C5
  1. Engagement with the public, partners and stakeholders is an integral part of planning and improving services.
  2. Information on biometric data is available in ways that meet community needs and preferences.
  3. Safeguards and special arrangements are in place when collecting biometric data from children, young people, and vulnerable persons.
• C6
  • There are effective complaints procedures, which include a commitment to investigate and resolve them within a defined time limit. This information is used to improve services.
• C7
  • There are effective quality assurance and audit processes for biometric data sets and corresponding sample capture techniques to support learning and continuous improvement.

• D1
  • There are appropriate structures and processes in place to support core values and ensure that staff working with biometric data and technologies have the skills and competencies required to deliver on agreed outcomes and priorities.
• D2
  1. A culture of equality and fairness, social responsibility and contribution to wider community wellbeing is promoted and encouraged.
  2. Staff working with biometric data and technologies are familiar with the concept of unconscious bias, and understand how the use of data can impact on equalities, ethical, human-rights and privacy considerations
• D3
  • Effective communication and engagement strategies are in place that meet the needs of staff and keep them informed and involved.
• D4
  • People acquiring, retaining, using, or destroying biometric data understand the outcomes and priorities they are working towards, and their contributions are valued and recognised.
• D5
  • People are encouraged to share information, knowledge and good practice and are involved in reviewing and improving the organisation while working together as a team.
• D6
  1. Systems for staff working with biometric data and technologies are quality assured, and/or are externally validated or accredited.
  2. People’s performance is reviewed, and appropriate training and development opportunities provided, including induction processes.
• D7
  • The impact that the investment in training and development has had on the
    performance and service delivered is evaluated.

• E1
  • Investment decisions in biometric data and technologies align to strategy and are subject to the production of robust business cases which are appropriately prioritised and scrutinised through internal and external governance. Business cases have clearly articulated benefits which can be measured as part of performance reporting.
• E2
  • Organisations collecting biometric data for criminal justice and policing purposes in Scotland have the resources to manage and control Scottish biometric data in accordance with Scottish legislation, operational policies, and any Codes of Practice in terms of its use. This should include mechanisms to control the quality and use of that data when aggregated to shared UK databases such as IDENT1, NDNAD and PND.
• E3
  • There is a clearly aligned financial strategy, financial management and governance processes for biometric databases and technologies which include risk assessment and transparent reporting.
• E4
  • Information and intelligence are managed appropriately, and staff have access to the information they require to make evidence-based decisions and deliver effective, efficient, and improving services.
• E5
  • Biometric data is effectively protected and made available securely to appropriate and relevant people and partners in accordance with privacy laws including UK GDPR, the Data Protection Act 2018, and guidance from the UK Information
    Commissioner (ICO) on the processing of biometric data for law enforcement purposes. Data sharing with other agencies complies with the ICO Code of Practice on Data Sharing.
• E6
  • The benefits, opportunities, and risks of using digital technologies are understood. Technology is used effectively and efficiently to support operational strategy, manage resources and assets, and support and improve services.
• E7
  • Accredited techniques in forensic science are adequately resourced to enhance forensic and biometric data capability and integrity, and to unlock value in accordance with the established crime scene to court model in Scotland.

• F1
  • There is an agreed vision, purpose and objectives for partnership work involving biometric data or technologies that supports the delivery of national outcomes for Scotland.
• F2
  • Strategic partnership arrangements for the exchange of biometric data for policing and criminal justice purposes within Scotland prioritise and manage shared opportunities and risks.
• F3
  • Strategic partnership arrangements for the exchange of Scottish biometric data with other UK and international jurisdictions prioritise and manage shared opportunities and risks.
• F4
  • The nature and extent of financial investment in shared UK biometric databases maintained for policing and criminal justice processes is understood and supports the delivery of policing priorities, justice priorities and/or national outcomes for
    Scotland.
• F5
  • Effective governance arrangements are in place to manage, deliver, and review partnerships and progress against shared outcomes and priorities.
• F6
  • Partnership exchange of biometric data supports effective service delivery and outcomes for communities. The impact and outcome of partnership activity is measured and understood.
• F7
  • The exchange of Scottish biometrics data contained within UK policing databases such as IDENT1, NDNAD or PND with non-policing functions of the Home Office has a clear legal basis in Scotland, and agreed data control mechanisms determine the purpose, means, and safeguards, for the exchange and processing of sensitive personal data.

To assess each of the themes within our Framework, we will systematically review the evidence to consider three key criteria.

• Direction – We will consider whether there is a clear rationale behind the approach taken and whether the direction and approach support relevant strategies and is linked and integrated with other relevant approaches.
• Execution – We will consider whether the approaches and execution are implemented in a timely manner and whether the execution is structured and enables flexibility and organisational agility.
• Results – We will consider the effectiveness and efficiency of approaches in terms of results and outcomes and whether learning and creativity is used to generate opportunities for improvement.

This Framework document, together with our Code of Practice, can also provide a structure for self-evaluation. It is designed to elicit contextual information (qualitative analysis) and provide triangulated evidence sources against which judgements may be arrived at in a professional manner by the Scottish Biometrics Commissioner. However, wider use by practitioners is encouraged as part of the self-evaluation process. The framework is designed to support both qualitative analysis and quantitative analysis and should not be viewed as a tick box exercise.

The nature of self-evaluation can vary according to the specific area under review. Demonstrating an understanding of what is being done well, what needs to be improved and how improvement can be monitored, achieved, and evaluated is key to self-evaluation. Whatever the precise approach, the key test of the resulting self-evaluation report is the ability to demonstrate how high quality is sustained and improvement ensured.

PSIF has also produced a self-assessment checklist process to help organisations understand the self-assessment process and this may be viewed on the Improvement Service Website. The Improvement Service also work with public bodies in Scotland to facilitate such self-assessment on their behalf, including via on-line survey tools.

The object of self-assessment is to identify and create an Improvement Plan in response to identified areas of potential weakness. This may be done through qualitative and quantitative analysis. In relation to quantitative approaches such as staff survey methodologies, PSIF advocates using the Likert Scale checklist which is a psychometric rating scale. Under this approach, organisations would consider the 42 quality statements in this National Assessment Framework and ask members of staff to apply a rating for each statement within the framework in accordance with the undernoted rating scale. This provides quantitative data. Similarly, staff completing the self-assessment record their reason why for example they strongly agree or strongly disagree with a particular self assessment statement from the Framework. This contextual information provides rich qualitative data for analysis and further consolidation and interpretation. Collectively, both data sets provide robust evidence of self-assessment.

Likert Scale

Often such staff surveys can be done on-line and anonymously using tools such as Smartsurvey.10 The consolidated output from such an approach will help organisations to identify areas of strength and will also help to identify areas of potential weakness for inclusion in an Improvement Plan