Essay: Police officers – attitudes to stalking reports in the UK

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  • Police officers - attitudes to stalking reports in the UK
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1- Introduction

Stalking episodes can last a few weeks, to a few years, with even brief periods of stalking resulting in emotional distress and physical harm (Mullen et al, 2009). Furthermore, around 20-40% of stalking victims are found to experience symptoms of mental disorder as a result of being stalked (Pathé and Mullen, 1997). Stalking can also impact other aspects of a victim’s life, with victims often feeling the need to cut themselves off from society by moving away, changing jobs, and being afraid to leave their homes. As with any crime, a victim can go to the police for support and information, but some victims feel that police officers have not shown to effectively intervene and protect them.

As effects can be so adverse, it is crucial for police responses to be efficient and taken as seriously as they would with any other crime. Victims of stalking have specifically expressed that they feel ‘let down’ by police officers and prosecutors across England and Wales in regards to the support given to victims, and the actions taken to tackle the crime (Bulman, 2017). One stalking victim in regards to the police response to her allegation, expressed “its got to the point where I actually said to my mum one night: ‘Do you know what? I’m going to be a story in the newspaper. I’m going to be another one of those girls that gets murdered by her ex’” (The Independent, 2017). It is thought that police officers often hold negative views towards stalking cases, with victims feeling that they are not receiving the help that they feel they should, often resulting in serious consequences. This research seeks to examine police officer attitudes towards such allegations, arguing that the overall attitude to stalking is of indifference to other crimes.

1.1 Research Aims

The main focus of this research is to analyze how police officers in the United Kingdom feel about investigating stalking reports, by looking at what these officers are most likely to do when stalking cases are presented to them. Specifically, the aims for this piece of research is to:

1) Examine police officer attitudes and experiences towards stalking cases.
2) Examine how police officers analyze and investigate reports of stalking, and consider the implications of the approaches that they employ.
3) Question the proportion of officers taking reports of stalking seriously

With the strategy and methodology of the study, these aims can be met through the use of an effective questionnaire, and the answers provided from the respondents. Careful consideration has been taken in regards to the particular research question and methodology, in order to gain a greater insight into the perspectives of police officers, in the most efficient way possible.

1.2 Stalking Terminology

Stalking is very closely linked with the term harassment, with the Crown Prosecution Service (PHA Section 2, 1997), addressing both terms as repeated and unwanted behaviour causing alarm or distress to the victim. In addition to these terms linking together, cases of stalking and harassment are often included under the domestic violence definition, resulting in domestic violence legal policies being relevant.

Stalking is a crime of power and control, with the intention of intimidating the victim, however it can be separated into two categories. Physical stalking is the first form, which includes the act of regular unwanted contact, loitering near the victim, sending unwanted gifts, the damaging of victims property, or threatening the victim (NoBullying.com, 2015). The other form of stalking is cyber-stalking, which refers to online harassment, however this research specifically refers to the physical stalking information set out by the Protection from Harassment Act (1997), due to the wider understanding of its nature. The CPS specifically states online that the offence is not retrospective, and is available to act as a further option for prosecutors to consider when selecting charges. The Protection from Harassment act (Section 2A-3, 1997) states some of the specific behaviors associated with stalking as opposed to a strict legal definition, as:

(a) Following a person
(b) Contacting, or attempting to contact, a person by any means
(c) Loitering in any place
(d) Interfering with any property in the possession of a person
(e) Watching or spying on a person.

2- Literature Review

The key ideas of the academic literature are reviewed and addressed within this chapter, separated into subheadings, in order to clearly identify each of the ideas. This literature review will address previous research surrounding stalking and how cases have been handled by the Criminal Justice system, as highly documented within the media, in order to justify the need for this research.

Existing literature specifically regarding police responses to stalking is rather limited, with the behavior often escalating over a period of time, so it is necessary to understand police perceptions on other types of crime in order to understand how serious officers take matters of stalking. The Crown Prosecution Service figures revealed that during 2013/14, only 743 stalking cases were prosecuted, in comparison to 9,792 harassment cases being prosecuted, stating how only 1% of all reported stalking cases resulted in a charge and prosecution, in comparison to the 16% of harassment cases (Paladin, National Stalking Advocacy Service, 2015). These figures of responses to domestic violence were even found to be less than adequate (Hattendorf and Tollerud, 1997, page 15). The criminal justice system carries a responsibility to all individuals, no matter what the level of seriousness the reported crime may be, however figures have suggested that only a tiny proportion of all stalking cases are being recorded by police, with the British Crime Survey (2015) reporting only 7,706 of stalking cases were recorded by police throughout England and Wales, although 1.1 million people had experienced stalking over a period of a year. From this, the Suzy Lamplugh trust (2016) stated that only about half of stalking victims go to the police, as those who are reporting such crimes are being made to feel “like a nuisance and not a victim” (Stalking victim to the Guardian, 2016).

2.1 HMCPSI and HMIC Inspection

The only inspection to look at the police and Crown Prosecution Service responses to harassment and stalking was carried out by Her Majesty’s Crown Prosecution Service Inspectorate and Her Majesty’s Inspectorate of Constabulary. The inspection was conducted in 2016/17 and aimed to address the responses to harassment and stalking crimes. The report claimed to find evidence that their services understood the risks of such crimes, and found examples of positive practice where victim’s needs were prioritized (HMIC, 2017), in addition to finding individual officers and prosecutors who took positive action to protect victims and investigate and prosecute the perpetrators. However, positive action was only illustrated after the victim made numerous reports. In addition to this, the investigation process was found to be good, however it was consistently followed by poor victim care during the criminal justice process, and successful prosecutions were followed by failure to apply for restraining orders.

The number of prosecutions for stalking also remained the same between 2014/15 and 2015/16, even though there was an increase in stalking crimes being recorded within the same period (HMCPSI and HMIC report, 2017, page 13). The inspection report also looked into the use of DASH forms, a model which was implemented across all police services in the United Kingdom in 2009, which provides a checklist of questions to ask victims of domestic abuse, stalking, and honour based violence (Dash risk model, 2009). The report found the DASH form to be a well-establish method of assessing risks to victims, and is in common use in the majority of police forces. The form provides a risk assessment for victims of crime, allowing information to be gathered in a consistent method, with a comprehensive view of risks faced by the victim (HMIC report, 2017, page 41). However the use of the form does not explain the full extent of the crime, and provides no freedom within the answers. The questions within the form are not always relevant to certain stalking victims, and can often be dismissed with officers feeling that the questions are not appropriate with the certain case in hand. It is also essential for officers to understand the true definition of stalking, and for them to correctly identify a stalking victim. If an officer is without such knowledge, they are unable to effectively use the DASH model, making it an incompetent and inconsistent risk assessment tool.

The inspection was conducted within forces by the use of interviews with respondents consisting of senior and operational lead officers, and focus groups consisting of frontline officers and partner agencies. The senior-staff who were responsible for harassment and stalking prosecutions were also interviewed, along with focus groups with prosecutors (HMIC report, 2017, page 108). With such high-ranking individuals being interviewed by well-established teams, respondents may become dishonest in their answers, in order to prove that they are doing their jobs to the correct standards. In opposition to the inspection, this particular research on police responses to stalking can provide an honest piece of research, as police officers are responding to the questionnaires with complete anonymity, therefore providing more honest answers. As the researcher in this dissertation holds no prejudice towards the police service, complete biasness is avoided in this experiment, allowing more reliable data to be collected and analyzed.

2.2 Criminal Justice Responses

In order for police responses to be effective, police officers should understand the nature of the crime in question, the legal definition of it, its various forms, its relationships with other crimes, and the impact the crime can have on the victim(s) (Velazquez, Garcia, and Joyce, 2009, page 258). However, stalkers are often able to continue on with their unwanted behaviour which have often resulted in increasingly violent acts, with the Metropolitan Police Service finding that 40% of domestic homicide victims were also stalked (ACPO Homicide Working Group, 2003), which can be explained by the unwillingness or inability of the criminal justice system to effectively intervene (Model Stalking Code Revisited, 2007, page 258). The police are the gatekeepers of law enforcement and criminal justice systems, which therefore explains the importance of police duties being carried out consistently and effectively.

Stalking as an offence on its own was only introduced in 2012, with harassment being the referenced crime prior to this date, so police officers were unable to respond to allegations with any type of suggested action. The Protection from Harassment Act 1997 was introduced to deal with stalking and harassment behaviours, but did not specifically define or name stalking as an offence, and instead defined two types of harassment (Stalking Briefing Paper, 2017, page 3). After many campaigns suggesting the Act was not effective in dealing with stalking, the Act was amended in order to specifically accommodate for the offence of stalking. The Protection of Harassment Act 1997 was amended by the Protection of Freedoms Act 2012, and created two new specific stalking offences (Section 2A-1) (Crown Prosecution Service, 2012), those being:

(a) Pursuing a course of conduct which amounts to stalking
(b) Involving fear of violence or serious alarm or distress.

The Crown Prosecution Service also published legal guidance on stalking, along with the College of Policing website creating stalking guidance on their website specifically for the police, and the National Police Chiefs’ Council launching a new protocol on how to handle stalking cases (Stalking Briefing Paper, 2017, page 3). However, the reformed act and newly formed guidance had only created brief guidelines, in addition to very brief definitions. Although stalking was made a crime on it’s own, the crime is still heavily linked with harassment, and only provides a very brief add-on to the harassment offence. The legislation and guidance does not present harassment and stalking as two different offences, and can therefore lead to police officers and prosecutors charging individuals with the wrong offence, and supporting victims with insufficient advice and support.

2.3 The Case of Alice Ruggles

The case of Alice Ruggles has been a highly publicized case within recent media stories, with deadly consequence occurring possibly due to the lack of support available for stalking victims. Media outlet, Chronicle Live (2017), reported the case of Alice and the timeline of events, which led to her brutal murder by her stalker. Alice and her stalker, Trimaan Dhillon, were previously in a relationship with one another, before Alice decided to end the relationship after a year of dating, with Dhillon attempting to control Alice, developing an unhealthy relationship and an isolated life. A month after the break-up, Dhillon started to harass Alice, and was able to hack into her social media accounts in order to monitor her activity, as well as contacting a man Alice was hoping to start a new relationship with. Soon after, Alice started to panic after gifts were left outside of her window by Dhillon, resulting in an official statement being made to the police about the incident. Alice explained to the police how an ex boyfriend had hacked into her account, repeatedly knocked on her door during the night, tapped on her bedroom window, and left flowers and chocolates outside her window. Dhillon went on to leave voicemail messages to Alice, stating that he did not want to kill her, so Alice again called the police, stating that she felt “harassed, alarmed, distressed, scared, and terrified of his actions” and explained “I’m being stalked and I want it to stop” (Kennedy, The Mirror, 2017). The police issued a police information notice (PIN) warning to Trimaan Dhillon, which serves as a warning to the recipient that their behavior is causing distress, and if their behavior continues, they are unable to claim the ‘reasonable person’ defense (West Mercia Police, 2015). However, Dhilon ignored this notice and went on to post a parcel to Alice containing photos of them both together. Alice contacted the police again, but was unable to speak to the same officer as before. Instead, the call handler told Alice that it was her decision as to what she wanted to happen, with Alice telling her sister that she felt “palmed off by the police” and that “they will respond when he has stabbed me”. The stalking came to an end two days later, when Dhillon drove to Alice’s flat and waited for her to finish work. Alice was in her bedroom when Dhillon broke in through an open window, and launched a vicious attack on her, leaving her for dead on the floor. Alice’s flat-mate returned home to find her lifeless body on the floor and called the police, instantly naming Dhillon as a suspect. By the time he was arrested, Dhillon had dumped the murder weapon and Alice’s phone.

Alice’s family publically stated that they felt much more work must to be done to publicize and identify stalking and controlling behavior, to tackle the root causes, and to stop them developing out of control (Kennedy, 2017). Alice spoke to the police on two occasions, with the police failing on both times to control the behavior of her stalker. Dhillon was almost a foot taller and three stone heavier than Alice, yet the police were either unable to recognize the enormous threat he placed upon her, or were unwilling to take any serious type of action. It is therefore possible to assume that Alice may still be alive today if things were handled differently.
3- Methodology
The primary aim of this chapter is to outline the research methodology used to answer the research question, including the research design used, the participants involved, the analysis of methodology used, and the ethical considerations taken into account. The overall aim of this study is to examine police officer attitudes towards stalking cases, by looking at how quick officers respond to reports, and what officers feel is the most appropriate action to take in comparison to other crimes. The most appropriate methodology decided upon was a mixed method approach, aiming to discover the attitudes officers have towards allegations, and how many of these officers treated the crime in a serious manner, therefore discovering if this is an issue within contemporary UK. The mixed method approach used for this research takes the form of a written questionnaire, which includes both quantitative and qualitative questions, allowing the most efficient data to be conducted.

The only prior research to police responses was carried out by professionals to their own employees, as documented in the Stalking Briefing Paper. Therefore, I wished to explore similar information from a general research point, taking the form of a less important individual in order to gain more honest and accurate responses. The previous inspection did not conduct one-on-one interviews with police officers, and did not ask them about their views on stalking cases. Instead, they looked at the tools in place to assist with stalking matters. This research attempts to look deeper into the current attitudes towards working with stalking cases.
3.1 Research Design
A design framework assembles the methods that will be used during the research process, showing how the methods are organized to answer the research questions, with a strategy being the logic behind it (Punch, 2016, page 80). What constitutes the truth and knowledge of each individual guides the way people think, which frames the way individuals view the world. According to Schwandt (2001, page 51), this is known as a paradigm to social scientists, and certain paradigms can be associated with certain methodologies. Each approach to researching a topic can lead to different pathways to retaining information, with each having their own way of understanding and analyzing the research itself. Within the paradigm, a theoretical perspective is undertaken when selecting a methodology, in order to understand what knowledge is to be believed in the research, with this process being described as epistemology. This research consists of an objectivist epistemology, with things existing as meaningful entities independently of consciousness and experience, and having truth and meaning within them as objects, with objective truth and meaning being attained from careful research (Crotty, 1998, page 3). This correlates with a positivist theoretical perspective, that being that knowledge is directly based on experience, facts, and causes of behaviour (Bogdan and Biklen, 2003, page 58), further to a deductive orientation approach used to test theories. Positivism relates to the view that research should be conducted by the use of scientific evidence, by using experiments, statistics, and qualitative results, in order to obtain the truth about society (Crossman, 2018), in which the methodology this research uses is embedded in.

In order to generate the most appropriate data for the research, a mixed method approach was used. According to Creswell (2003, page 5) a mixed method involves the collection and analysis of data in the mixture of qualitative and quantitative approaches in many phases of the research process. As a method it focuses on collecting, analyzing, and mixing both quantitative and qualitative data in a single study or series of studies. Its central premise is that this mixed method approach provides a greater understanding of the problem than one approach alone. A fixed design framework taking the form of a questionnaire was chosen for the collection of data due to its practically. According to Robson (2011, page 83-90) fixed designs call for a tight pre specification at the outset, and employ both experimental and non-experimental research methods. The advantages of self-completion questionnaires being used in research is pointed out by Walliman (2016, page 124), who describes the method as being cheap and quick to administer, and an easy and convenient way to question a large number of cases over a large geographical area. Research conducted in this way also allows personal influence and biasness from the researcher to be eliminated, allowing the chance for truthful responses. Primarily, the method is a variable approach, strengthening the research. Response rate can often be low with self-completion questionnaires, making it essential to send out the questionnaire to a very large sample.

A semi-structured questionnaire formed the research design, in order to generate the specific information needed for this study, which includes the use of both closed and open-ended questions. Closed questions can produce data, allowing a quantitative analysis with a predetermined agenda and little flexibility in the respondent’s answers, with open-ended questions allowing the respondents to freely answer questions in their own words, providing greater qualification in their response, forming qualitative data (The University of Sheffield, 2014).

The questionnaire firstly provides an introduction to the research topic, which is then followed by 15 questions on the matter (figure 3.1). Each section of questions provides very brief instructions on how to answer the questions, ensuring participants are aware of how to complete the questionnaire with the closed and open-ended answers. Keeping the questions as short and simple as possible was important, in order to increase the likelihood for the participants to understand the question being asked, resulting in more accurate responses (Cairns and Cox, 2008). Once a sufficient number of responses were collected, the questionnaire was then taken offline to be analyzed.

3.2 Participants

As the questionnaire was formed online, a link was created and forwarded in an email to all police forces within the United Kingdom. This email contained information about the researcher, the purpose of the questionnaire, and instructions of how it can be completed (figure 3.2). As time is so crucial to police officers, it was important to send out the questionnaire to the whole police population in order to gain a sufficient amount of officers who had the time to complete the questions. Whilst there were a number of police forces that felt they did not have the time to assist with the research, a range of forces agreed to help. These forces then forwarded the initial email on to their police officers, asking them to complete the questionnaire. 50 police officers completed the questionnaires fully, however a sufficient amount of participants started the questionnaire and did not finish, making their responses exempt.

This type of method created a convenience sample, a common type of non-probability sampling, due to the researcher using individuals who were available and willing to complete the questionnaires from a select population. These participants volunteered to answer the questions, and therefore are a convenient sample (Explorable, 2009).

3.3 Analysis

The analysis of data specifically describes how the collected data will be analyzed, which in the case for this research is through two different methods. For the qualitative element of this research, that being the open-ended questions, a thematic analysis will be conducted. A thematic analysis is a method for identifying, analyzing, and reporting patterns within data, which can describe data sets in detail (Boyatzis, 1998, page 79). When analyzing information embedded throughout the questionnaire, themes and concepts are discovered (Rubin and Rubin, 1995, page 80). These themes capture important information about the data in relation to the research question, representing a level of patterned response (Braun and Clarke, 2006, page 82). The responses from this research will be coded in a systematic way, collating data relevant to each question. These codes will then be devised into potential themes, whilst ensuring each theme relates to the research aims, creating a final opportunity for analysis, by selecting extract examples and producing a report of the analysis (Braun and Clarke, 2006, page 87). This type of design provides a flexible research tool, allowing detailed data to be accounted for. The quantitative element of the research will be analyzed through SPSS, calculating how many responses were applied to each question, and therefore providing a quick and efficient method of compiling the responses together. It must be noted that whilst this study is not necessarily statistically significant, it is a suggestive and illustrative piece of work.

3.4 Ethical Considerations

Ethical issues may arise when research is conducted with living things, with such issues including privacy, cruelty, honesty, and fairness. It is therefore vital for these factors to be taken into consideration when conducting research primarily ensuring no harm is caused to respondents and researchers. Ethical approval was not needed for this research, however ethical considerations must always be considered when researching.

It is pointed out by Alldred and Gillies (2002, citied in Social Research Methods, 2016, p90) that speech can be a messy form of communication, and by writing it down, individuals can make an account readable and interpret what is meant in a simpler form, rather than interpreting verbal communication in an opposed way. Before the questionnaires were voluntarily completed, each respondent was assured that there would be no compulsory requirement to take part in the research and would be able to withdraw at any time during the process, with informed consent ensuring the respondents were fully aware of the research and willingly gave their consent to take part. Respondents were also assured of their anonymity, with no names being asked, and respondents having the option to include the name of the police force they work for. Security and privacy was another ethical factor taken into consideration, with completed questionnaires being stored on a password-protected computer, only accessible by the primary researcher. The most crucial ethical element taken into consideration was informed consent.
4- Results
This chapter contains the data collected from the questionnaires and will present the specific statistical data, consisting of both the quantitative and qualitative results. Out of the 15 questions asked, 11 of the questions were of a quantitative nature, with the remaining four being qualitative. All 50 responses were analyzed in correspondence with the suitable method, with the qualitative results being analyzed using a thematic analysis and the quantitative results being analyzed through SPSS. For the thematic analysis, the results for each question were compiled together and analyzed in order to find any apparent themes. The compiled questionnaire answers can be found in the appendix. The following results are devised into sections, in order to understand the theme of the questions set, with all charts being presented in the appendix (for example, figure 4.1). The findings are as follows:

4.1 The Sample Results
The results relating to the sample of respondents can be seen in the appendix (figure 4.1, 4.2, 4.3), but do not need to be discussed in this research, as they provide no context to the aims.

4.2 Working with Stalkers
The next questions were also quantitative, and were therefore also analyzed through SPSS. The questions were an attempt to briefly understand the attitudes and work of the police officers. Figure 4.4 provides the responses participants gave in regards to their interest of stalking cases in the form of a pie chart, options being if they would prefer to investigate stalking cases presented to them, or if they would prefer to pass the case on. There was only an 8% difference in the answers, with 54% of the sample stating they would investigate the case themselves, and 46% preferring to pass the case on. The next question asked was in regards to PIN notices, which specifically asked if the officer has personally ever issued any during their time as an officer. Whilst the majority of officers had issued a PIN notice before (38 officers), there were 12 officers who have not ever issued one (shown in figure 4.5 bar chart). The final question within this section of the questionnaire asked if the officers were aware of the DASH (2009) model, a checklist in which officers should refer to when assessing stalking allegations. All but two officers were aware of the model, with 48 participants responding with ‘yes’ to the question (figure 4.6).
4.3 Opinions on stalking/stalkers
The next set of closed questions consists of agree and disagree answers. The aim of these questions was to see how much the respondents agree with the statements provided to them, to gain a wider understanding on their attitudes towards such situations. Figure 4.7 shows how respondents were asked if they agree or disagree with the statement ‘a stalker is not a criminal, they merely do not understand their rights from their wrongs’. The figure shows how the majority of respondents had strongly disagreed with the statement (64%), with another 30% still disagreeing, but not as strongly. The remaining three participants provided mixed views with the statement, with 1 participant strongly agreeing, 1 agreeing, and 1 being unsure.

The next statement ‘if an individual does not seem afraid then I am less likely to take quick action’, provided more of a mixture of results. Figure 4.8 shows how only 12 respondents strongly disagreed with the statement, with the biggest amount of the sample slightly disagreeing (25 officers). 9 police officers were not sure on their views regarding the statement, however there were 4 officers who did agree that they are less likely to take quick action. None of the participants strongly agreed with the statement.

The next statement was ‘stalking victims often overreact’, in which 30 respondents disagreed. Whilst this was transcribed to 60% of the sample, the remaining answers were split. 16% of the respondents were unsure (8 officers), and 22% (11 respondents) strongly disagreed with the statement. 1 respondent however, did agree with the statement (figure 4.9). Respondents were also provided with the statement ‘male stalkers are more serious than female stalkers’ (figure 4.10). Only 2% of the sample agreed with the statement, and just over half of the sample disagreed (52%). Furthermore, 30% strongly disagreed, with the remaining 16% being unsure on their views.

The final statement was ‘If there has been no physical violence, then I do not feel action needs to be taken’ (figure 4.11). None of the participants agreed with this statement, with all participants either disagreeing or strongly disagreeing. The responses were split 50/50, with 25 police officers stating they disagree, and 25 strongly disagreeing.

4.4 Thematic Analysis results
The remaining questions allowed the respondents to write their answers freely within the provided space, without having pre-set answers provided for them. The data was narrowed down into similar responses, allowing a number of themes to be made prominent, therefore giving a general overview of the results. The thematic analysis tables can be found in the appendices. The first question analyzed by thematic analysis was ‘how many reports of stalking have you roughly investigated during your time of work?’ which primarily showed that many officers had only investigated between 1-5 cases, and those that had investigated more cases had worked as an officer for significantly longer. However, the use of thematic analysis produced a ‘crossover of cases’ theme. Many officers felt there was a cross over between cases of harassment and stalking, making it difficult to determine the number of cases they have investigated (figure 4.12)

The second question ‘what would your first point of action be for an allegation of stalking?’ produced a number of themes through the thematic analysis (figure 4.13). The main theme was that there was ‘no homogenous protocol’. The respondents provided different answers in regards to the first point of action they would take, showcasing the fact that there is no formal protocol officers follow when dealing with stalking cases. Four sub-themes were produced as to what specific action officers would take, those being to make verbal contact with the victim, arrest the offender, safeguard the victim, or complete a full formal investigation. The next question asked was in correspondence with the previous question, stating ‘if the stalking continued, what would your next step be?’ which provided an overall theme of ‘arrest/remand in custody’ with officers being likely to arrest offenders, or requesting suspects who have already been arrested, a remand in custody (figure 4.14). Another question analyzed through thematic analysis asked ‘what are your opinions on PIN notices?’ with the theme of ‘little value for high level cases’ emerging. Two sub-themes were apparent, with many officers stating that PIN notices are ‘pointless’ and only useful for ‘low level’ cases (figure 4.15). The final question analyzed by thematic analysis asked participants ‘do you believe the DASH (2009) model is an effective model to use?’ which resulted in a very prominent theme emerging (figure 4.16). All but a few officers felt the model is effective, however there were two sub-themes within this that had arisen. The main theme suggested that the model is effective, however the sub-themes found that it is long-winded, and that the model is only effective if the officer completing the DASH checklist uses it properly.

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