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City of London PEEL 2018


How legitimately does the force treat the public and its workforce?

Last updated 02/05/2019
Requires improvement

The force requires improvement in the legitimacy with which it treats the public and its workforce.

Its leaders understand and value the benefits of community engagement. There is a positive culture around ethics and fair decision making, both internally and in dealings with the public.

However, a major problem for the force is a lack of external scrutiny. The local independent advisory group and the community scrutiny group have not been functioning for some time.

The force’s supervision of stop and search has improved during 2018, as has its monitoring of stop and search data. However, it could also do more to analyse its use of these powers.

In relation to ethical and lawful workforce behaviour, the force requires improvement. It needs to improve its anti-corruption assessment and control strategy, which are currently of a low standard. It also needs to improve the capacity and capability of its counter-corruption units.

Questions for Legitimacy


To what extent does the force treat all of the people it serves with fairness and respect?

Requires improvement

Areas for improvement

  • The force should ensure that effective external scrutiny takes place in relation to the its use of force.
  • The force should ensure that effective external scrutiny takes place in relation to its stop and search powers.
  • The force should extend its unconscious bias training to all its workforce.

We set out our detailed findings below. These are the basis for our judgment of the force’s performance in this area.

Treating people fairly and respectfully

City of London Police leaders understand and value the benefits of community engagement, fairness and transparency in decision making. Fairness is one of the force’s values and this is evident in its leadership training. Officers and staff told us they felt empowered to make decisions. We found evidence that the Code of Ethics and fair decision making are considered in senior management meetings, about areas from finance to operational effectiveness. This positive culture sets a good example for the workforce and encourages them to treat the public fairly.

The force engages well with the public and officers make effective use of social media. The force took advice from other forces about how best to use social media and has improved this service as a result. It makes sure that its workforce is aware of national guidelines on social media use.

This work is supplemented by a corporate magazine aimed at a public readership. In its latest survey, it asked readers about fairness and respect shown by City of London Police’s workforce, among other things. The force will tailor its communications strategy in response to feedback that the public want to use email and social media to communicate.

The force tailors its approach to engagement according to the needs of different communities. There is a large Bangladeshi community in the City of London, and the force is using its bilingual officers to translate community messages into Urdu. The area is also home to many businesses and banks, and the force has found supportive ways to engage with them, such as attending seminars and asking officers to spend time talking to staff.

Both residents and businesses in the local area influence policing priorities. For example, at community meetings people raised concerns over aggressive begging and repeated shoplifting. The force does not have a neighbourhood watch scheme, due to the size and make-up of the City of London. Instead it uses volunteers and the special constabulary to involve local people in its crime prevention and problem-solving activities. The local independent advisory group and the community scrutiny group have not been providing adequate scrutiny for some time, and the force recognises this as a problem. Despite attempts to address this, there have been difficulties attracting local people to take part, due to the small resident population in the area. The force has invited members of similar groups in neighbouring areas to join a new advisory group in the City of London, but this is not yet in place.

Most, but not all, of the workforce receive unconscious bias training, aimed at helping them to identify and overcome any biases they may have. It is part of initial training for new officers, vulnerability training and ongoing stop and search training – but the force should offer this training to all its workforce.

Using force

In the last 12 months, almost all officers have been trained in how to use force. Those we spoke to could describe how to do so fairly and proportionately. Although it submits its use of force data in line with National Police Chiefs’ Council guidelines, we found during our recent custody inspection that City of London Police does not properly record all the uses of force in custody suites. As a result, it doesn’t know the extent to which force is being used fairly and appropriately in custody suites.

The force has a new, comprehensive dataset on this issue, but it doesn’t monitor use of force by individual officers. This means that it is difficult for the force to see trends or check that all officers are using force appropriately and fairly. Supervisors do not review CCTV footage from custody or body-worn video footage, and the force’s policy on the use of body-worn video cameras does not make it clear to officers when they should turn the recording on.

It is positive that the public can see the whole use of force dataset on City of London Police’s website. However, this does not compensate for the lack of effective external scrutiny.

Using stop and search powers

The supervision of stop and search in the City of London has vastly improved during 2018. Supervisors are now checking stop and search records and referring them back to officers when needed. The force has low numbers of stop and searches and so can scrutinise each record. All officers have received training in stop and search.

We reviewed a representative sample of 452 stop and search records to assess the reasonableness of the recorded grounds. We found that 75 percent had reasonable grounds recorded. Our assessment is based on the grounds recorded by the searching officer and not the grounds that existed at the time of the search.

In our 2017 legitimacy report, we recommended that all forces should:

  • monitor and analyse comprehensive stop and search data to understand reasons for disparities;
  • take action on those; and
  • publish the analysis and the action by July 2018.

We found that the force has complied with some of this recommendation. But it doesn’t:

  • separately identify drug possession and supply-type offences to understand the extent to which they differ between people from different ethnicities; or
  • identify the prevalence of possession-only drug searches and how they align with force-level priorities.

Since last year, the force’s monitoring of stop and search data has also improved significantly. Its governance group for stop and search is well attended by members of the force, including training and learning department staff and representatives from staff groups. There is a new stop and search lead, who has brought renewed focus to improving the force’s use of these powers. The force published an explanation of the disparity between the use of stop and search on black, Asian and minority ethnic people and others in its public data on its website.

However, there is still room for improvement. The force does not monitor people who are searched numerous times or officers who use stop and search unusually frequently. Nor does it monitor body-worn video footage of stop and search encounters. As mentioned above, the force policy on body-worn video cameras does not state that officers should turn on the recording at the start of a stop and search. The force acknowledges that it needs to do further analysis aimed at improving its use of stop and search.

The force does not currently have effective external scrutiny of stop and search, but it is trying to address this, as outlined above.

Summary for question 1

How well does the force ensure that its workforce behaves ethically and lawfully?

Requires improvement

Areas for improvement

  • The force should ensure its anti-corruption strategic threat assessment and control strategy are comprehensive, up-to-date and include current data.
  • The force should ensure that its counter-corruption unit:
    • has enough capability and capacity to counter corruption effectively and proactively;
    • can fully monitor all of its computer systems, including mobile data, to proactively identify data breaches, protect the force’s data and identify computer misuse; and
    • builds effective relationships with individuals and organisations that support and work with vulnerable people.

We set out our detailed findings below. These are the basis for our judgment of the force’s performance in this area.

Maintaining an ethical culture

Leaders continue to promote the Code of Ethics with its emphasis on integrity, fairness and professionalism, and the wider workforce understands these principles. The principles set out in the code appear prominently in all strategic documents, such as the policing plan and the corporate plan, and a Code of Ethics impact assessment is also now included in report templates for strategic boards.

The workforce can discuss ethical dilemmas in a variety of different ways. Several officers and staff have volunteered to be members of the challenge forum and are called ‘ethics associates’. Their role is to raise ethical questions around everyday activities and decisions.

The force is a founding member of the London forces collaborative ethics panel (the London Police Challenge Forum). This has recently been relaunched and we will assess its effectiveness over the next 12 months. The force also has an integrity standards board, which is chaired by the assistant commissioner. This considers individual officers and staff and organisational integrity, and the workforce spoke highly of it. The professional standards department uses this board to publicise lessons learned from misconduct investigations and grievance complaints.

In 2016, we recommended that, within two years, all members of the police workforce should have received at least the lowest level of vetting clearance for their roles. The force has now achieved this: there is no backlog of vetting health checks, aftercare and renewals. An intranet page and a quarterly newsletter are the main channels for clarifying and reinforcing acceptable and unacceptable behaviours for the workforce. These also include details from misconduct cases. The professional standards department runs a learning and development forum that includes material from the Independent Office for Police Conduct and provides training to supervisors and probationers.

Tackling corruption

The force has not yet completed its anti-corruption strategic assessment for 2019, but the standard of its current assessment is not good. It contains out-of-date information and does not include profiles of potentially corrupt officers or key locations for corrupt activity. The force’s local counter-corruption control strategy is also of a low standard. It does not include communication and engagement with the workforce and partners, including charities that work with vulnerable victims. It has not been widely shared in the force. However, the anti-corruption unit is making progress in implementing its measures.

The force does not use organisational information, such as email accounts and logs from crime reports, to proactively identify those people who are at risk of corruption. However, some are identified through its vetting and performance review process, and they are asked to attend an early intervention meeting. Following this, the officer is subject to further checks for a set time.

The anti-corruption unit is not staffed to a level where it can look for corruption. The force cannot yet fully monitor all its IT systems because the software has limited capability and is not compatible with all the force’s IT systems. This means the force must rely on audits of individual systems, which can be time-consuming.

In 2016, we made a national recommendation that all forces should form links with agencies that support vulnerable victims to look for information about police officers abusing their position for a sexual purpose. The force has not yet addressed this. Nor has it addressed the other elements of our 2016 recommendation regarding the capacity within the anti-corruption unit and its ability to monitor IT systems. Anti-corruption unit staff have worked with some external organisations, such as outreach workers and victim liaison. However, this work has not been followed up, which means that the force cannot reliably claim to have tackled this issue.

However, the force recognises the abuse of position for a sexual purpose as serious corruption, and this is reflected in its counter-corruption strategic threat assessment and control strategy. All the cases we reviewed had been appropriately referred to the Independent Office for Police Conduct. The force has given guidance and briefings to recruits, transferees and supervisors. It should do so for other officers and staff.

Summary for question 2

To what extent does the force treat its workforce with fairness and respect?


This question was not subject to detailed inspection in 2018/19, and our judgment from the 2017 legitimacy inspection has been carried over.