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Joint review of police custody recommendations

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Inspection reports

26th August 2026

Since 2023 HM Inspectorate of Constabulary in Scotland and Healthcare Improvement Scotland have jointly undertaken a programme of inspections aimed at assessing the treatment of individuals detained at police custody centres across Scotland. Our reviews have looked at the physical conditions in which detainees are held, as well as analysing the quality of the custody centres operations at each location, and the healthcare services provided. Having published 10 such joint custody inspection reports to date, in which we made a total of 45 recommendations to Police Scotland and 104 recommendations to NHS boards, we took the decision to carry out a review of the progress made against these recommendations. The findings set out in this report are primarily drawn from our published joint inspection reports and our examination of progress made on recommendations during this review. As part of this joint review, HMICS inspectors also examined custody records on the National Custody System (NCS) to assess operational practice, interviewed custody staff, supervisors and senior officers, and carried out onsite visits to observe custody operations and assess implementation of inspection recommendation in practice. Inspection work carried out by HIS included the analysis improvement plans, evidence submissions and internal risk assessments, as well as undertaking focus groups with key partners to gather system-wide insight and triangulate findings. The resultant report identifies where progress has been made against recommendations and also highlights ongoing challenges. It also makes two new recommendations for Police Scotland concerning its custody operations, and one for NHS boards in relation to healthcare provision within police custody.

Additional

  • Joint review of police custody recommendations
  • HM Inspectorate of Constabulary in Scotland
  • Our review
  • Key findings
  • Recommendations
  • Methodology
  • Context
  • Leadership
  • Delivery
  • Outcomes
  • Healthcare

  • Joint review of police custody recommendations
  • HM Inspectorate of Constabulary in Scotland
  • Our review
  • Key findings
  • Recommendations
  • Methodology
  • Context
  • Leadership
  • Delivery
  • Outcomes
  • Healthcare

Introduction

122. This section of our report summarises national progress made in the delivery of healthcare within police custody centres since the commencement of our joint inspection of police custody centres. It reflects:

  • work undertaken by HIS and HMICS through the inspection programme

  • common themes and issues identified across multiple sites

  • examples of good practice and strengthened processes

  • areas where improvements have been made, and

  • areas where further action is required at local and national level.

123. The purpose is to:

  • provide a clear national overview of progress

  • assess the extent to which healthcare recommendations have been addressed

  • support shared learning and national consistency, and

  • inform future joint inspection and improvement activity.

124. We have utilised our Framework to Inspect Healthcare Provision within Police Custody Centres to establish a consistent national methodology for evaluating quality, safety and effectiveness. The framework draws on national standards, human rights principles and expected healthcare equivalence.

125. This has been used throughout our joint custody inspection programme, and in undertaking this evaluative review of recommendations.

126. As noted previously in this report, we have undertaken joint custody inspections across several police divisions and NHS board areas. Details of the areas we have visited are outlined in appendices as well as information on the number of recommendations and areas for improvement made.

National findings

127. Overall, inspection activity demonstrated meaningful progress in the governance, quality and safety of healthcare provision within police custody. However, progress has been variable across Scotland, with significant variation remaining in governance maturity, access to specialist services, workforce resilience, and digital infrastructure. These areas continue to be the main barriers to achieving consistently safe, effective and equitable healthcare for people detained in police custody.

128. Clinical governance arrangements encompass the systems, processes and accountability structures through which NHS boards and HSCPs assure themselves that healthcare delivered within police custody is safe, effective, person centred and subject to continuous improvement. Clinical governance remains one of the most variable and influential elements of healthcare delivery within police custody. Our custody inspections consistently highlighted weaknesses in the structures, oversight mechanisms and reporting arrangements that underpin safe and effective care. Across Scotland, HIS and HMICS found considerable variation in how governance was organised, how risks were identified and escalated, and how NHS boards assured themselves that the care delivered in police custody was safe, consistent and aligned with national expectations.

Progress and good practice

129. Across Scotland, NHS boards have taken steps to strengthen clinical governance arrangements in response to inspection findings. Many NHS boards have enhanced governance documentation, reporting processes and risk management systems, with evidence of improved quality assurance mechanisms, more structured action planning and better internal communication.

130. Inspections identified positive examples where NHS boards had established dedicated governance groups which focused on police custody healthcare. These groups brought together operational leads, senior managers and clinicians to strengthen oversight and improve accountability. They provide a platform for reviewing clinical risks, monitoring action plans and strengthening links to NHS board level governance committees.

131. Some NHS boards demonstrated improvements in clinical audit cycles. Where structured audit programmes had been implemented, regular audits of record keeping, infection prevention and control, medicines management and clinical documentation supported more proactive oversight and helped promote greater consistency in the delivery of care.

132. Progress was also evident in staff training and development, particularly where national resources or network led approaches had been introduced. National partners, including the National Police Care Network, provided targeted training that strengthened governance capability. The rollout of training on the Istanbul Protocol improved staff understanding of the assessment and documentation of injuries and supported more effective embedding of human-rights principles within clinical governance practice.

133. The implementation of Public Services Delivery, Scotland’s National Police Care Network TOM, is expected to provide a more consistent and structured approach to the delivery of healthcare in police custody across Scotland. The TOM sets out clear expectations for governance, workforce capability, clinical oversight and service delivery, supporting improved professional development, greater standardisation of training and enhanced access to clinical leadership and peer support across services.

Key issues and remaining risks

134. Workforce capacity and capability remain closely linked to the effectiveness of clinical governance arrangements. Ongoing vacancies, staff turnover and variability in staffing models, including access to registered mental health nurse (RMN) expertise, continue to impact service resilience and limit NHS boards’ ability to provide sustained assurance over the safety and quality of care in police custody. Despite areas of progress, inspections continue to identify significant and persistent weaknesses in clinical governance arrangements across police custody healthcare services.

135. Marked variation remains in how governance structures are organised, how risks are identified and escalated and how NHS boards provide assurance that care is delivered safely and in line with national expectations. A recurring issue was a lack of clarity around governance roles, responsibilities and escalation pathways. While some services operated within clearly defined frameworks, others lacked clear ownership of oversight and quality assurance. In several police custody centres, this resulted in healthcare provision that was reactive rather than proactively monitored or strategically managed. These challenges were compounded in some areas by the absence of systematic performance reporting or formal mechanisms for reviewing clinical risks.

136. Inconsistent or poorly established audit processes remained a common finding. In many police custody centres, routine clinical audit either did not take place or lacked the structure required to generate meaningful assurance. These weaknesses limited NHS boards' ability to obtain assurance regarding the quality, safety and consistency of healthcare provided within police custody settings.

137. Inspections also identified ongoing weaknesses in incident reporting, adverse event review, learning systems and complaints handling. In some areas, clinical incidents were not reliably raised, recorded or reviewed, reducing opportunities for learning and potentially allowing recurring risks to remain unaddressed. Information for detainees on how to make complaints was often not clearly visible or easily accessible, and complaint handling processes were not always embedded within strong governance arrangements.

138. Workforce support also remained a significant area of risk within governance arrangements. Inspectors observed gaps in structured induction and clinical supervision for healthcare staff in several police custody centres. In some NHS boards, clinicians commenced work in police custody settings without a formal induction or orientation to the specific risks of the custodial environment. Clinical supervision arrangements were inconsistent at a national level, with many healthcare professionals lacking regular, structured opportunities for reflective practice, peer review and professional support. These gaps increased the risk of practice variation and inconsistency in clinical decision making.

139. Although progress has been made, the level of improvement remains uneven, reflecting variation in local infrastructure, workforce capacity and governance maturity. Until clinical supervision, induction processes, workforce sustainability and escalation pathways are consistently embedded, and governance structures are fully effective across all services, NHS boards may continue to face challenges in providing assurance that care in police custody is safe, person centred and delivered in line with national expectations.

Access to healthcare screening and role boundaries

140. Access to healthcare in police custody relies on police custody staff undertaking the initial screening of individuals on arrival. This first stage of assessment determines whether clinical input is required, how urgently a person should be seen and what risks require management until healthcare staff can attend. Inspections have consistently found that this essential triage activity is undertaken by police custody staff who are not clinically trained yet are required to make decisions involving complex physical and mental health presentations. While this process is necessary within current service models, it continues to contribute to variability in access to care and places significant responsibility on non‑clinical staff.

Progress and good practice

141. Inspection evidence indicates some improvement in awareness, escalation pathways and staff confidence in identifying health‑related risks within police custody. In some police custody centres, clearer escalation pathways were in place, supporting police custody staff to recognise signs of deterioration more confidently and to seek healthcare input at an earlier stage. A series of webinars delivered through the National Police Care Network, including sessions focused on risk identification, has supported improvements in staff knowledge and confidence when responding to health concerns.

142. In a number of areas, effective working relationships between police custody staff and healthcare teams supported more responsive communication. Where these arrangements operated well, inspectors observed quicker identification of high‑risk presentations and improved continuity of care. In addition, where NHS boards had invested in clearer guidance for police custody staff, there was improved understanding of role boundaries and responsibilities. Police custody staff in these areas reported increased confidence and greater consistency in decision making when managing detainees with health needs.

Key issues and remaining risks

143. Despite these areas of improvement, access to healthcare in police custody remains variable across Scotland. Inspections consistently highlighted significant differences in how detainees are screened, including variation in documentation, interpretation of health concerns and thresholds for escalation to healthcare services.

144. A recurring national issue remains the absence of clear, nationally agreed expectations around waiting times for healthcare assessment in police custody. While inspectors recognise that a rigid target‑based approach would be inappropriate, given that urgency must be informed by clinical judgement, the lack of national clarity continues to contribute to delays and inconsistency in access to care. This was particularly evident for individuals experiencing mental health crises, substance withdrawal or acute physical health needs.

145. Variation in access to healthcare remains a systemic issue. As identified in the aforementioned national baseline review and confirmed through subsequent inspection activity, progress has been uneven and continues to rely heavily on local service design, staffing levels and informal relationships between police custody and healthcare staff, rather than being underpinned by consistently applied national standards.

146. In police custody centres without 24 hour onsite healthcare provision, police custody staff continue to manage individuals with significant health needs for prolonged periods. Inspection evidence indicates that, in some cases, custody staff were asked to undertake activities that approached or crossed into clinical tasks. This reflects longstanding role boundary pressures identified in the baseline review and places staff in unsupported positions, while increasing risk for individuals whose needs require timely clinical assessment and monitoring.

147. Across all police custody settings, non clinical staff remain central to the identification, monitoring and escalation of health needs. While this reliance is partially mitigated in some areas through on site clinical provision or access to telephone advice, it continues to place significant weight on non clinical judgement at critical decision points. Where healthcare is provided through off site or on call models, reliance on non clinical staff may be prolonged, and clarity around role boundaries becomes increasingly dependent on the strength of local arrangements rather than consistent national assurance.

148. Inspections also identified limited consistency in how waiting times for healthcare assessment were recorded, reviewed and escalated. This reduces visibility of unmet need within police custody environments and limits NHS boards’ ability to monitor whether delays remain proportionate to clinical risk. As a result, current arrangements do not consistently provide sufficient assurance that risks associated with delayed or deferred clinical assessment are being systematically identified, monitored and mitigated.

Clinical environment and infection prevention and control (IPC)

149. The clinical environment within police custody settings plays a key role in supporting safe, effective and dignified healthcare. Our joint custody inspections identified some progress in local infection prevention and control arrangements, alongside continuing challenges linked to infrastructure, equipment management and oversight.

Progress and good practice

150. Inspections identified examples of positive practice where NHS boards had taken action to strengthen IPC arrangements within police custody settings. In some centres, dedicated IPC leads had been introduced, supporting clearer accountability and more consistent application of standards. Improved stock management systems and structured checklists were also in place in several locations, helping staff to maintain supplies and complete routine equipment checks more reliably.

151. Where governance arrangements were clear, and staff engagement was strong, inspections found improved compliance with IPC standards. In these settings, environmental risks were better identified and mitigated through regular monitoring, clearer documentation and more structured oversight.

152. Several NHS boards had also introduced new or revised cleaning schedules, strengthened equipment‑checking processes and improved documentation of IPC audits. These actions were supported by local action plans and follow‑up activity, demonstrating responsiveness to inspection recommendations and contributing to improved assurance in affected centres.

Key issues and remaining risks

153. Despite these improvements, inspections continued to identify widespread and systemic gaps in IPC compliance. Common issues included incorrectly labelled or overfilled sharps containers, inconsistent segregation of clinical waste and insufficient or poorly managed supplies of personal protective equipment. These weaknesses were often linked to unclear local arrangements for replenishment, auditing and routine monitoring of essential IPC resources.

154. The management of emergency equipment remained a significant area of concern. In several police custody centres, emergency bags were found to be incomplete, out of date or lacking evidence of regular checks. These findings presented a clear clinical risk and highlighted ongoing weaknesses in local governance and assurance processes.

155. Environmental constraints also continued to limit the quality and safety of care. Many police custody centres operated within ageing estates, with clinical rooms that were too small, poorly ventilated or otherwise unsuitable for modern healthcare delivery. Inadequate space created practical challenges for staff and, in some cases, compromised privacy and dignity during clinical assessments.

156. While some aspects of IPC practice have improved, inspections found that environmental risks remain largely unresolved, particularly where improvement requires wider organisational planning or capital investment. Inconsistent oversight, especially in remote or rural police custody centres, continues to pose risks to patient safety. Until environmental standards and IPC arrangements are more consistently embedded and monitored, the clinical environment will remain a limiting factor in the delivery of safe and effective healthcare in police custody.

Digital and information systems

157. Digital infrastructure continues to represent one of the most persistent and system‑wide challenges affecting healthcare delivery in police custody. The national baseline review identified significant limitations in digital systems as a critical barrier to the delivery of safe and effective care, particularly in relation to clinical documentation, information sharing and continuity of care. Findings from inspections confirm that these challenges remain evident in practice, indicating that the issues identified through the review have not yet been fully resolved.

Progress and good practice

158. In a small number of police custody centres, healthcare staff demonstrated consistent and effective use of the digital systems available to them. Where clearer local processes were in place, records were completed more reliably, and continuity of clinical information was better maintained. These examples illustrated the potential benefits of digital systems when supported by clear expectations and staff engagement.

159. Some services also made limited use of available data to support service planning or inform staffing and resource decisions. Although constrained by system limitations, these approaches highlighted how improved digital functionality could strengthen governance, oversight and quality assurance if systems were fit for purpose.

160. At a national level, the National Police Care Network escalated concerns about the primary clinical recording system to the Scottish Government and engaged with the system supplier to clarify upgrade plans and address performance issues. This represented important system‑level recognition of the risks and the need for coordinated action.

Key issues and remaining risks

161. Despite these developments, inspections confirmed that digital infrastructure remains a significant and unresolved risk. A consistent finding was the lack of essential functionality within the primary healthcare recording system used in police custody settings. Staff reported that the system was unreliable, slow, and unable to support meaningful data capture, extraction or reporting. This severely limited NHS boards’ ability to monitor performance, audit care or gain assurance around quality and safety.

162. The absence of interoperability between NHS and police custody systems continued to present a major barrier to safe and efficient care. As electronic transfer of information is not possible, critical healthcare information must be shared verbally, in writing or via email. These manual processes increase the risk of errors, omissions and inconsistent record‑keeping and undermine continuity of care, particularly at key transition points.

163. Digital capability remains one of the highest‑risk areas with the least local control over improvement. System limitations continue to affect the accuracy and accessibility of clinical information, delay decision‑making and increase reliance on staff workarounds. While national escalation has taken place, the pace of improvement remains slow, and inspection findings indicate that digital constraints continue to impede the delivery of safe, effective and integrated healthcare in police custody.

Mental health care

164. Mental health continues to represent one of the most significant and complex areas of need within police custody. Inspection activity confirmed ongoing efforts to improve pathways and collaboration in some areas, however, access to timely, specialist mental health assessment remains inconsistent and subject to significant national variation.

Progress and good practice

165. Inspections identified examples of improving practice where care pathways were clearly defined and supported by effective joint working arrangements. In these areas, detainees experienced more timely access to specialist mental health advice, increased use of validated assessment tools and improved coordination between police custody healthcare teams and community mental health services.

166. Some NHS boards responded directly to inspection findings by clarifying escalation routes and formalising referral processes to secondary mental health services. These actions contributed to reduced reliance on police custody as a place of safety and improved clarity for staff managing individuals in mental distress.

167. Where governance arrangements supported collaboration across agencies, inspectors observed stronger decision making and improved continuity of care, particularly during transitions between police custody, health services and community‑based support.

Key issues and remaining risks

168. Despite these improvements, inspections consistently found delays in access to secondary mental health services. Detainees experiencing mental distress often waited extended periods for specialist assessment, and in some cases were subject to multiple assessments before accessing appropriate care. These delays continued to place pressure on police custody environments that are not designed to manage prolonged mental health crises.

169. Challenges were particularly pronounced in rural and remote areas, where geography, travel time and workforce shortages further limited timely access to specialist mental health provision. In these settings, police custody staff and healthcare teams were often required to manage complex presentations for extended periods with limited support.

170. Variation in local care pathways and governance arrangements meant that the quality and timeliness of mental health care in police custody depended heavily on local structures and relationships. Limited availability of RMNs remained a significant factor, with registered general nurses frequently undertaking initial mental health assessments in the absence of specialist support.

171. Although inspection activity has driven some improvements, systemic delays and inconsistencies in mental health pathways persist nationally. Workforce constraints, particularly limited RMN capacity, continue to affect both the quality and consistency of care. Until access to specialist mental health assessment is more timely, equitable and consistently embedded across Scotland, mental health will remain one of the highest‑risk areas within police custody healthcare.

Substance use

172. Substance use represents a significant and persistent area of health need within police custody, with many detainees arriving intoxicated, in withdrawal, or at risk of harm. Inspection activity identified examples of improving practice and collaboration, alongside continuing variation and gaps in access to consistent, evidence‑based care.

Progress and good practice

173. Inspections identified examples of good practice in the management of substance use and withdrawal. Some police custody centres demonstrated more robust approaches to safe withdrawal management, supported by improvements in prescribing processes and clearer clinical oversight.

174. Several NHS boards had introduced or updated standard operating procedures for the delivery of MAT, clarifying expectations around prescribing, continuity of care and links with community substance use services. These changes supported safer transitions between police custody, court and community settings.

175. Improved engagement between police custody healthcare teams and community substance use services was evident in some areas. This closer collaboration supported more reliable continuity of treatment on release and improved planning for individuals at high risk of relapse or overdose.

176. Inspection evidence also showed that some NHS boards had strengthened substance use screening processes, prescribing decisions and clinical documentation. In response to identified gaps, local working groups had been established to review practice and align service delivery more closely with national MAT standards.

Key issues and remaining risks

177. Despite these improvements, inspections continued to identify significant national variation in the delivery of MAT. In many police custody centres, detainees did not consistently receive Opioid Substitution Therapy (OST) prior to court attendance or immediately following liberation. This disruption to treatment can increase the risk of relapse, overdose and disengagement from community services.

178. Screening processes for substance use remained inconsistent, and validated withdrawal assessment tools were not used reliably across police custody settings. These gaps limited the ability of staff to assess risk accurately and provide timely, appropriate clinical interventions.

179. Access to harm reduction interventions also remained variable. In particular, availability of Naloxone and consistent arrangements for overdose prevention education differed across NHS boards and police custody centres, reducing assurance that risks associated with release from police custody were being effectively mitigated.

180. Overall, while inspection activity has driven some strengthening of local practice, lack of national consistency continues to affect the quality and equity of substance use care in police custody. Until MAT delivery, harm reduction and screening arrangements are more consistently embedded across Scotland, substance use will remain a significant area of risk for detainees and health services alike.

Medicines management and continuity of care

181. Medicines management is a critical component of safe and effective healthcare in police custody, encompassing prescribing, storage, administration and continuity of medication during transitions into, through and out of custody. Inspection activity identified examples of strengthening governance and assurance, alongside persistent risks linked to variation in practice and system constraints.

Progress and good practice

182. Inspections identified notable improvements where NHS boards had introduced pharmacist support to police custody healthcare services. In these settings, medicines governance was significantly strengthened, with clearer standard operating procedures, improved stock control arrangements and more robust audit and assurance processes.

183. Some NHS boards demonstrated improved management of controlled drugs, including clearer application processes, safer storage arrangements and stronger clinical documentation. These developments supported greater compliance with governance standards and reduced risks associated with medicines handling.

184. Follow‑up engagement confirmed that several services had enhanced local oversight of medicines management, including strengthened audit activity and improved monitoring of stock and expiry dates. Where these processes were embedded, inspectors observed improved consistency and confidence among staff involved in medicines administration.

Key issues and remaining risks

185. Despite these improvements, inspections continued to identify weak or inconsistent governance arrangements around medicines management in several police custody centres. In some settings, staff involved in medicines administration did not consistently receive appropriate training, increasing the risk of medication errors and variation in practice.

186. The lack of interoperable digital systems remained a significant and recurring risk. Medication information was frequently transferred manually between healthcare and police custody staff, increasing the potential for inaccuracies, omissions and incomplete medicines records. These risks were particularly evident at key transition points, including court attendance and liberation.

187. Continuity of medication remained inconsistent across police custody settings. Inspectors found variation in whether individuals received prescribed medicines at appropriate times, and in the arrangements to ensure continuity of treatment on release or transfer. Access to Nicotine Replacement Therapy (NRT) also remained variable, with some detainees reporting a lack of awareness that it was available during custody.

188. Overall, while inspection activity has driven improvements in medicines governance and oversight in some areas, national variation persists. Manual processes for sharing medicines information continue to present a high level of risk, and continuity of care at transition points remains insufficiently assured. Until medicines management arrangements are more consistently standardised and supported by interoperable systems, this area will continue to present a significant clinical risk within police custody healthcare.

189. Inspection findings indicate that referral and diversion arrangements for people experiencing mental health problems, substance use and physical health needs are in place across police custody settings though they are utilised to varying degrees.

190. While police custody staff play a key role in identifying vulnerability and initiating referral and diversion pathways, the effectiveness of these arrangements depends significantly on the availability, responsiveness and integration of healthcare services. The availability and impact of referral and diversion arrangements vary considerably across Scotland, with access to appropriate onward healthcare and support largely determined by local systems and inter‑agency working rather than consistently delivered national arrangements.

National progress on recommendations

191. Since the inspection programme began, we have made 104 recommendations and identified 11 areas for improvement relating to healthcare across all joint police custody inspections. The number of recommendations made for healthcare, categorised by our inspection framework themes, is outlined in appendix D. Our recommendations reflect the breadth and complexity of healthcare delivery in police custody and span a wide range of domains including governance, clinical pathways, medicines management, IPC, digital systems, environmental safety, and workforce development.

192. Analysis of NHS board action plans, follow-up evidence submissions, meetings with service leads, and internal risk assessments, showed that all recommendations had been actively progressed, with none left unaddressed. However, the degree of progress varied nationally.

  • A substantial number of recommendations have been fully implemented, often following significant system or process redesign, the introduction of new governance structures, or strengthened clinical oversight.

  • Many recommendations were partially implemented, where meaningful work had begun, but full embedding required additional time, sustained workforce stability, or clearer system-wide processes.

  • A smaller number of recommendations were inherently dependent on national infrastructure, system design and multi‑agency agreement, meaning that local NHS boards cannot implement them in isolation. Inspection evidence demonstrated that further progress in areas such as digital interoperability and the establishment of consistent national mental health pathways will remain limited without coordinated national leadership and system‑wide action.

193. This distribution of progress reflected a key national theme identified through inspection activity: while positive local change was increasingly evident and achievable, structural barriers, particularly digital limitations, pathway inconsistency, and workforce pressures, continued to slow or constrain the pace and scale of improvement.

Impact of the inspection programme

194. The joint inspection programme has had a clear and positive impact on the quality and safety of healthcare within Scotland’s police custody centres. Evidence from action plans, follow-up meetings and progress inspections, demonstrated that inspections had strengthened governance arrangements, clarified accountability and improved the identification and management of risk. NHS boards introduced more structured IPC processes, strengthened equipment and medicines governance, and improved the quality and consistency of clinical documentation, contributing to safer and more reliable practice.

195. Inspections also prompted NHS boards to redesign key care pathways, particularly in relation to mental health, substance use and medicines management. In many areas, clearer escalation routes were established, withdrawal management procedures were strengthened, and standard operating procedures were aligned more closely with national expectations, including MAT standards. These improvements have contributed to more reliable access to care and a reduction in unnecessary delays.

196. A further notable outcome of the joint inspection programme is the strengthening of shared learning across Scotland. NHS boards are now adopting each other’s tools, audit templates and governance processes, supporting the spread of effective practice and reducing unwarranted variation. As a result, the programme contributed to the development of a stronger national learning culture and improved alignment of practice and standards of care across different regions.

197. The inspection programme has contributed to a shift towards more systematic quality improvement in many areas, although progress remains variable across Scotland.

Summary and next steps

198. Inspection evidence provides assurance that NHS boards have actively engaged with and progressed recommendations arising from custody inspections. This has resulted in measurable improvements in governance, infection prevention and control, medicines management, workforce development and local care pathways. However, significant variation remains across Scotland. The most persistent risks continue to relate to the maturity of clinical governance arrangements, timely access to mental health services, workforce sustainability, digital infrastructure and the consistent implementation of MAT standards. Addressing these challenges will require continued local improvement alongside coordinated national leadership and system wide action.

199. While progress has been made across governance, clinical practice and operational processes, national consistency in the delivery of police custody healthcare remained constrained by several long-standing structural barriers. To build on the improvements achieved to date, further coordinated action will be required at national, NHS board, HSCP, and broader system‑wide levels.

200. A number of key challenges cannot be resolved locally and are dependent on wider national infrastructure and agreement. Digital systems remained one of the most significant barriers, with existing platforms unable to support reliable information‑sharing and effective interoperability between NHS services and police custody systems. Without national investment and digital modernisation, clinical risk and variation in access to care will persist. Similarly, coordinated national action is required to establish clear mental health assessment pathways, including agreed response expectations, to address the delays and inconsistency in access to specialist support identified across inspection activity.

201. Full implementation of Scottish Government MAT standards will require coordinated national and local planning, sufficient and sustained workforce capacity and closer alignment with community prescribing practice. More broadly, workforce sustainability remains a critical issue. The long-term delivery of safe and effective healthcare in police custody is dependent on strengthened staffing models, consistent clinical cover and robust professional support structures including supervision and training.

202. There is also a need to progress a revised Memorandum of Understanding (MoU) between NHS boards, HSCPs and Police Scotland. Existing arrangements did not sufficiently define roles and responsibilities, operational expectations or escalation routes for healthcare delivery in custody settings. A refreshed, shared MoU would help clarify accountability, strengthen governance and support more consistent effective partnership working across Scotland.

203. Addressing these system-level priorities will require sustained and collaborative effort from NHS boards, HSCPs, Police Scotland, Public Services Delivery Scotland, and the Scottish Government. Taken together, these actions represented the next steps needed to deliver equitable, safe and rights-based healthcare for all individuals held in police custody.

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