Wiltshire PEEL 2018

This question was not subject to detailed inspection in 2018/19, and our judgment from the 2017 legitimacy inspection has been carried over. However, we reviewed a representative sample of 249 stop and search records to assess the reasonableness of the recorded grounds. We found that 89 percent had reasonable grounds recorded. Our assessment is based on the grounds the searching officer recorded 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 to reduce those disparities; 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 identify the extent to which find rates differ between people from different ethnicities and across different types of searches (including separate identification of find rates for drug possession and supply-type offences). Also, it isn’t clear that the force monitors enough data to identify the prevalence of possession-only drug searches or the extent to which these align with local or force-level priorities.

We reviewed the force’s website and found that it publishes stop and search data and a brief explanation of the disproportionality rate. But it doesn’t publish analysis to understand the reasons for disparities or an explanation of any subsequent action taken.

We will continue to monitor progress in this area.

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

Wiltshire Police’s leaders continue to promote the force’s values and the Code of Ethics. The workforce also understands them.

The chief constable and other members of the executive leadership team send regular, positive messages to reinforce the importance of maintaining high standards of ethical behaviour. These messages are communicated at the force’s events for leaders and the wider workforce. The chief constable has also promoted the force’s values on a series of video blogs (Vlogs) and online chats. We found that the workforce views the chief constable and other senior leaders positively. Senior leaders are said to be accessible and open to ideas and challenge.

During our inspection, we examined the extent to which supervisors and staff understand the Code of Ethics and the force’s values. Examples of ethical decision making included redistributing resources to strike the right balance between operational requirements and wellbeing needs, reimbursing costs for replacing personal clothing damaged during police activity and requests for time off at short notice because of significant personal events. We identified how decision makers in the professional standards department (PSD) also refer to the Code of Ethics when they make decisions on how complaints and conduct investigations should be handled.

During 2018, the force introduced an annual integrity health check. It reminds officers and staff of the obligation to notify the force of factors that may expose them to corruption risks, such as business interests and associations with members of the public who could compromise their integrity. The integrity check applies to the whole workforce and forms part of the annual performance development review process. At the time of our inspection, the force said 800 members of the workforce had undergone the checks.

We found that officers and staff had a thorough understanding of their obligation to notify the force of any changes to their personal circumstances. The PSD newsletter, called ‘The Standard’, reinforces the importance of these requirements. Force policies include references to diversity. A rolling programme of reviews is taking place to ensure that policies contain clearer references to the Code of Ethics. These measures should help the force maintain an ethical culture. They should also maintain community confidence in the force’s legitimacy.

The force introduced an ethics board in 2014, but the frequency of meetings reduced significantly over the last twelve months. The workforce used to be able to refer difficult ethical issues to this board for discussion, but after comparing the format with national best practice, leaders deemed the forum ineffective. The meeting has recently been refreshed under the leadership of the deputy chief constable. Changes include representation from the office of the PCC and independent members of the public. We found that the force uses the new board actively to inform ethical decision making. Recent examples include topics raised for discussion as a result of the significant policing operation in Salisbury in 2018.

Wiltshire Police intends to expand the membership of the ethics board to make it more representative of local communities and to include both young people and members of diverse groups. The force recognises that it needs to improve communication to the workforce of the results of decisions made at the ethics board and thereby encourage the submission of more ethical dilemmas.

The force has a no-blame culture that encourages learning. We found that the PSD takes a proportionate approach to handling complaint and conduct cases. It encourages supervisors to deal with minor matters of underperformance promptly to promote organisational learning and continuous improvement. We found examples of cases where the PSD had referred matters to supervisors appropriately. We confirmed that supervisors had reviewed those cases with their teams when mistakes had been made, to share learning and prevent reoccurrence. Supervisors felt that they would receive support from the force if they made minor mistakes in good faith. They were able to explain how they record the rationale for their decisions using the national decision model to ensure accuracy. They also understood force expectations of their standards of professional behaviour.

During our 2017 inspection, we examined whether the force was developing and maintaining an ethical culture through effective vetting protocols. We found that it was not complying with all aspects of the national vetting standards because some officers and staff had not been re-vetted at the correct intervals. This meant that the force did not understand fully the security risks that could be posed by some officers and staff.

The force has made some progress in this area, but risks remain. It still needs to do more to comply with the vetting code of practice and approved professional practice. Wiltshire Police has recently invested in its people services vetting unit (PSVU), increasing its capacity to reduce the backlog of vetting cases that need to be reassessed. A senior member of staff now manages the unit. The PSVU has completed a status review of all members of the workforce. This allows the force to prioritise the re-vetting of officers and staff who occupy high-risk, sensitive posts in an appropriate and proportionate way.

We reviewed the force’s plans for the reduction of its vetting backlog and found them to be achievable. The deputy chief constable leads on fulfilling these plans. Progress against the plan is reviewed monthly at the people intelligence board. At the time of our inspection, the force stated that 10 percent of the workforce (187 people) still needed a review of their vetting. At the time of our inspection, the force was still in the process of evaluating the status of personnel who are not directly employed, such as contractors and volunteers.

The force will not comply with our recommendation to vet all members of its workforce in accordance with the vetting code of practice by December 2018. But it has confirmed that all members of its workforce have been vetted at some point. Overall, vetting is not yet being done to the standard set by the National Police Chiefs’ Council. The force acknowledges the position and is working to address the situation while managing continuous risks and priorities.

The manager of the PSVU and members of the team perform a weekly review of the unit’s vetting decisions. This is to ensure that decisions are both consistent and proportionate to the potential risks. These decisions reflect approved professional practice and the rationale for each is recorded. Applicants can appeal the unit’s decisions. More complex cases are discussed at an ethics panel before making a decision.

The strategic standards board, chaired by the head of PSD, examines vetting data. Recruitment processes are reviewed to identify how decisions made at different stages of the recruitment process can affect different groups of people. But the force does not yet evaluate how its vetting decisions may affect the recruitment of under-represented groups. As a result, the force is missing opportunities to increase recruitment by removing disparities in its vetting decisions.

The force complies with its obligations to provide details to the College of Policing for the barred and advisory lists. This prevents people who have left the service under investigation, or who have been dismissed or prohibited, from re-joining or working in law enforcement.

Wiltshire Police clarifies and reinforces standards of behaviour well. Staff from the CCU provide members of the public who are considering applying to join the force with regular, face-to-face information on corruption prevention. Existing members of the workforce receive similar messages. The PSD newsletter, ‘The Standard’, contains useful information on potential risks to integrity such as the requirement to declare gifts and hospitality. The force’s intranet site contains easily accessible guidance.

The force circulates examples of ethical dilemmas to strengthen messages regarding ethics and clarify expected standards of behaviour among the workforce. During our inspection, we tested workforce knowledge of the risks to integrity. Officers and staff who had undergone the annual integrity health check process were able to explain the risks. This confirmed that the process has reinforced standards of behaviour effectively. The force complements this by publishing the outcomes of misconduct hearings both internally to the workforce and externally to the public. Chief officers and the PSD use the learning gained from individual cases to reinforce the quality of their messages to the workforce.

Tackling corruption

Wiltshire Police identifies and manages internal corruption risks adequately. However, it conducts only limited monitoring of its ICT systems. This reduces its ability to identify and respond to corruption risks.

The force has previously completed both a counter corruption strategic assessment and a control strategy, but they both need to be updated. The force is aware of this requirement and is in the process of refreshing both products so they accurately describe current corruption risks. The force needs this analysis and information if it is to understand current risks and be able to address them effectively. The head of PSD leads on progress with both products. The force expects this work to be complete by April 2019.

The force manages the risks of workforce corruption effectively. Members of the people intelligence board represent different departments from across the organisation. They review information and identify ways to support individuals, teams and supervisors. The force also uses the information held in its registers of business interests and notifiable associations. It compares this information with financial and other forms of intelligence to identify members of the workforce who may be at risk of corruption.

During fieldwork, we identified cases where the force had intervened to mitigate risks. We also noted that cases are tracked at meetings that the PSD attends. Wiltshire Police uses drug testing and performs 120 such tests each year. But the force still needs to make more proactive use of the intelligence it holds. This includes how it monitors compliance with decisions made about business interests and reportable associations.

We reviewed 60 cases and found that once the force has identified a potential issue, it assesses and develops intelligence to a good standard. However, the CCU’s ability to monitor the use of ICT systems, including hand-held and remote devices, remains limited, although it does have the ability to monitor open source and social media.

The absence of monitoring presents a risk to information security. The force has evaluated commercial software products but hasn’t yet identified a system that meets its monitoring needs. We will examine this facility again in future inspections. The force also needs to consider the capability and capacity of its CCU to review intelligence and move investigations forward.

The CCU has made progress by forging effective links with other agencies that support vulnerable people, including victims of crime. The force promotes whistleblowing policies and anonymous reporting systems. It liaises regularly with statutory partners and voluntary agencies to raise awareness of corruption risks, including the abuse of position for a sexual purpose.

The force has adopted the National Police Chiefs’ Council’s strategy to respond to the problem of police officers and staff who abuse their position for a sexual purpose. It recognises this behaviour as serious corruption and refers cases to the Independent Office for Police Conduct. We identified that the force has benefitted from its links with other agencies in developing intelligence information about corrupt behaviour. Notably, the CCU has developed a method of classifying information to identify predatory behaviour. It has reviewed national best practice and refined this further by incorporating academic research. This allows the force to prioritise cases, using a matrix of information about behaviours, to select the most suitable options to tackle misbehaviour effectively. The PSD has prepared a video about abuse of position for a sexual purpose. It raises awareness of the harmful effects of this type of behaviour and the serious consequences for individuals who engage in it. However, the force’s inability to monitor its systems means that it has not yet achieved our 2016 national recommendation on abuse of position. Additionally, the capacity of the CCU to handle intelligence is unclear.

The workforce demonstrated a good understanding of the harm caused by abuse of position for a sexual purpose. This understanding reflects the importance the force has placed on responding effectively to individuals who abuse their position. Our inspection confirmed that supervisors are vigilant in responding to warning signs that an individual may be abusing their position for a sexual purpose. The force promotes the use of confidential systems for reporting inappropriate behaviour. The workforce understands the consequences of developing inappropriate relationships with members of the public. Cases are actively publicised to show how corrupt behaviour is dealt with.

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

Improving fairness at work

In our 2017 inspection, we graded Wiltshire Police as good for the ways in which it treats its workforce with fairness and respect. This year, we were pleased that the force has continued to make progress in the way leaders seek feedback and challenge from the workforce.

We found that the force communicates decisions to officers and staff effectively. We also found that the workforce is becoming more actively involved in the forums and processes that are provided for giving feedback to senior leaders. When we spoke to officers and staff, they told us that these forums provide them with good routes for making suggestions and giving feedback to senior leaders. The executive leadership team (ELT) recently held events where it used an interactive tool (Slido) to obtain responses from officers and staff as on-the-spot feedback to chief officers.

Officers and staff in different locations across the force also told us that the chief constable regularly visits them in the workplace. He takes the time to patrol with officers and PCSOs to understand the challenges they face. These contacts have resulted in several improvements such as using special constables on the community policing teams and providing better safety equipment, such as spit guards and fluorescent tactical vests.

The ELT launched a campaign called #BuildingOnSuccess, which was designed to seek feedback and challenge from the workforce. The campaign ran for 40 days and officers and staff were invited to put forward ideas and suggestions for improvement. The force drew around 65 suggestions from this initiative across an array of topics. The force has adopted some of the suggestions. One example is the provision of ‘trauma teddies’, knitted by police officers and staff to give to children who have suffered a tragedy.

The force has taken a more proactive approach to reporting the results of the annual staff survey, which it uses to identify and assess any change in workforce opinions. All officers and staff can receive a summary of the results, the detail behind those summaries and regular updates from the ELT through video and online blogs and a chat page.

Wiltshire Police is improving its approach to dealing with grievances and workforce concerns. The force recently introduced a new resolution procedure to replace its previous grievance procedure. The workforce has a good understanding of the new policy. When we spoke to officers and staff, those who have used the new procedure and taken part in the mediation process told us the process had been swift, effective and satisfactory.

The force monitors the number of grievances recorded through its people intelligence board where it develops and reviews a profile of risks. Line managers of staff who have been identified as a potential risk are expected to attend this meeting; plans are developed to manage concerns. The force has trained 12 employees in mediation to aid this approach. Those trained for this role feel this system of resolution is working well, but that it could be used more widely.

Our grievance file review showed that, under the old procedure, the force properly identified, investigated and resolved grievances or workplace concerns, in line with the ACAS (Advisory, Conciliation and Arbitration Service) Code of Practice and Guidance, in only six out of ten cases examined.

Line managers are unclear about their responsibilities. As a result, effective oversight to ensure that investigations are completed within the recommended ACAS Guidance and Code of Practice is missing. The introduction of the new resolution procedure should resolve this.

The force analyses data to identify issues that affect perceptions of fairness and respect. The employee survey is the main source of data for analysis of workforce perceptions, as well as departmental surveys. The #BuildingOnSuccess campaign and staff forums complement these, giving staff an opportunity to raise workforce concerns. This has led to changes in workforce practice and improvements in the services provided.

For example, after the workforce raised concerns about an increase in assaults on police officers, the ELT implemented a seven-point assault plan. The plan improves the level of support for officers and staff. It also clearly sets out the standards of investigation expected in such cases.

Officers and staff we spoke to during the inspection were aware of issues that had been raised and resulted in a change in practice. Replacement of the old grievance procedure with a new one, as described earlier, was one example.

Wiltshire Police operates effective processes to reduce the disparities in its workforce representation. It has made a considerable effort to increase, and celebrate, diversity across the workforce. This year the Department for Work and Pensions awarded it the highest level of accreditation of ‘Level 3: Disability Confident Leader’. This recognises the force’s progress in recruiting and retaining people with disabilities and entitles the force to mentor other organisations and businesses wishing to improve in this area. The force has also worked closely with the Down’s Syndrome Association’s WorkFit service. It has been able to offer both voluntary work and paid employment to people with additional needs.

Wiltshire Police has a good understanding of the make-up and diversity of its workforce. It actively monitors and reviews information that allows it to identify disproportionality and acts to rectify this. Its people, culture, and inclusion strategy brings together relevant workstreams. The strategy provides the force with a comprehensive plan to reduce workforce disparity.

The force has a dedicated diversity and inclusion team with a seconded officer from the Black Police Association on the team. The force has also run a series of workshops for potential PCSOs and PCs from BAME backgrounds. It has worked with consultants to encourage and create opportunities for these candidates. The outcome of this work has yet to be fully realised. But the force is optimistic that it will continue to reduce the disparities in its workforce when it opens recruitment to PCSOs in July 2019, and to police officers in September 2019.

It is encouraging that the number of BAME special constables in the force has increased. Currently, 1.7 percent of the workforce identifies as BAME. This compares with the local population of 5.2 percent. The force has no BAME officers above the rank of sergeant. But it has taken steps to develop officers and staff from diverse backgrounds and has identified several talented, competent individuals through its BAME talent management scheme. This offers bespoke support for those officers and staff seeking development opportunities, as well as an opportunity to network, identify mentors and engage with the ELT. The force has also recently introduced a reverse mentoring scheme, which focuses on recruiting mentors from diverse backgrounds. It offers support and advice to members of the ELT to enhance their understanding of diversity issues and raise awareness of potential obstacles to success.

The force acknowledges the need to do more to encourage people from different communities to join. Every five weeks, it runs an experience day that gives potential recruits an insight into the opportunities on offer. To ensure the force can better support BAME applicants in future, the recruitment team has arranged to visit the police training centre at Ryton to observe its SEARCH assessment centre for new recruits.

The force understands the value of having a diverse workforce. It is actively trying to increase the representation of lesbian, gay, bisexual and transgender (LGBT) people across its workforce. It has also set aside funding and time to help establish the LGBT network and support community events.

As of 31 March 2018, 49 percent of the total workforce identify as female. The proportion of female officers is lower, at 375 of 1,021, or 36.7 percent. Among sergeants, 33.5 percent are female, as are 14 percent of inspectors and 33 percent of all ranks above inspector (or equivalent). The force has a staff support network that works on several identified themes to support female employees. It includes subjects such as pregnancy and menopause support. The force has also signed up to the #HeforShe campaign, which supports gender equality.

The force is getting better at retaining officers and staff who have protected characteristics. BAME officers and staff are not disproportionally subject to complaint or misconduct allegations.

Supporting workforce wellbeing

Wiltshire Police has continued to develop and improve its understanding of workforce wellbeing. Welfare, morale and wellbeing are recognised and included in the 2017-2021 Police and Crime Plan and are considered in all force plans and policies. The strategic wellbeing board works to improve and monitor wellbeing provision and awareness. Its approach is detailed within its 2018-2021 people, culture and inclusion strategy. The Blue Light Wellbeing Framework underpins this approach and is informed by a comprehensive set of data on the wellbeing of officers and staff. The force has a good understanding of the threats to the wellbeing of its workforce. It conducts analysis of a cross-section of management information, such as workforce sickness and assault data, to identify and understand patterns and trends.

Leaders prioritise wellbeing and work effectively with occupational health services to ensure there is no delay in accessing services. Long-standing health screening is provided, such as blood pressure checks and advice about lifestyle and long-term health. Health promotion and education is provided on obesity, alcohol and smoking, as well as the impact of stress on physical and mental wellbeing. The recruitment process also includes an in-depth clinical assessment, based on medical standards.

Risk assessment-based medicals (RABM), both psychological and physiological, safeguard officers and staff in specific roles. They provide preventive screening and identify mental health problems, in line with NICE guidelines. Occupational health referrals can also be made using indicators such as increases in injuries and absence management. The head of the occupational health unit (OHU) regularly reviews the RABM programme. The heads of OHU and health and safety meet annually to review the programme, to be sure it remains current and fit for purpose.

A dedicated full-time mental health nurse works within the OHU department to provide expertise in prevention and early intervention. The nurse advises managers on mental health issues and on managing individuals who are experiencing mental health problems. A psychological wellbeing assessment is conducted, and interventions are put in place where appropriate.

The established people intelligence board reviews wellbeing performance indicators such as sickness, injuries, performance and complaints to identify risks and potential problems. This enables the force to concentrate on high-risk groups and provide early intervention. Effective support groups include peer support, cancer, pregnancy and menopause. Peer supporters have been introduced to champion the Blue Light charter and help reduce the perceived stigma surrounding mental health. The force also holds exit interviews with members of officers and staff who leave. We found good evidence of line managers holding regular one-to-ones with officers and staff.

Wiltshire Police is taking part in the national trauma survey. All staff have been informed about this through an internal communication. This survey is the UK’s first force-wide policing survey to assess trauma management and working conditions. The University of Cambridge is managing it independently. Once it has received the results, the force intends to use them to inform its strategic objectives and delivery plan.

The force has also taken part in the recent Police Federation of England and Wales Pay and Morale Survey. Results show that in 2018 fewer officers in Wiltshire Police reported low morale (36.3 percent) than any other force in England and Wales. Members of the force were also least likely to feel they were being treated unfairly (18.3 percent). The force had the lowest number of respondents who said they would not recommend others to join the police. These are all very positive indicators for the force.

To ensure officers and staff get the support they need, all line managers receive wellness training. Line managers across the force see wellbeing as part of their role and undergo training to be aware of early indicators of mental health concerns, so that their teams and departments can be monitored. Staff told us that leaders in the force place a significant focus on wellbeing and on both mental health and officer fatigue. Supervisors told us they hold regular one-to-one meetings with their officers and staff where they review workloads and explore wellbeing needs. The workforce is also subject to the integrity health check as part of their professional development review. This explores topics such as business interests, reportable associations and exposure to financial risk. All managers also have access to a wellness tool kit. This provides advice on how and when to use personal risk assessments and wellbeing plans. The tool kit also directs them to other sources of information. The 2017 force staff survey did not evaluate wellbeing provision. However, 82 percent replied positively to the question: “I know where I can access support at work if I need it”.

The force’s occupational health provision is effective and meets demand. The levels of support available to the workforce are appropriate. After a referral, which can include self-referrals, a response will be made by phone or in person within two days. Emergency appointments are available if a case is assessed as urgent. Wiltshire Police makes a higher number of referrals to occupational health services than the average across England and Wales. Officers and staff we spoke to during the inspection consider the provision of occupational health support to be good.

The force is good at supporting absent officers and staff and those reporting, or subject to, misconduct and grievance allegations. The sickness rate is 0.9, compared with the national rate for England and Wales forces of 1.1.

All supervisors have received training in attendance management. RABMs are completed when appropriate. Designated welfare officers are appointed to support people going through misconduct and grievance processes. The force also recognises the welfare needs of officers responsible for investigating misconduct allegations and supports them through the process. Anyone subject to gross misconduct allegations receives a tailored support package, after occupational health has made its assessment.

The number of rest days accrued by officers in Wiltshire is below the number for England and Wales of 7.9. The force states that 1,400 days have been accrued by its workforce of 1,021 officers, which equates to 1.4 rest days per officer. 

Managing performance and development of officers and staff

The force manages the performance and development of its workforce effectively and has recently introduced a new electronic personal development review process (referred to as the e-PDR) for all officers and staff. This tracks individual performance and enables the force to align the appraisal to the competency and values framework (honesty and integrity, teamwork, professionalism, personal responsibility and putting people first). The system allows line managers to review officers and staff’s continuous professional development. This ensures the appropriate level of supervision, supports career development and allows for managing poor performance. When we spoke to officers and staff, we found that they used the new e-PDR system regularly. The officers we spoke to also valued it. We found examples of supervisors meeting officers and staff every five or six weeks to manage their performance. We also saw instances when officers and staff had been given comprehensive support.

The force completed its last full staff survey in 2017. At that time, the results suggested only 35 percent of respondents felt the force tackled poor performance effectively. This was coupled with a low level of confidence in the ability of managers to have ‘difficult conversations’ with staff. Managers and staff have now all had training on how to carry out fair performance assessments. The training included instruction on how to address poor performance through the unsatisfactory performance process. The force has also adopted a system called Beyond 360º to review an individual performance from a range of perspectives, taking into account colleague and peer evaluations. This is intended to help managers make more informed judgements about individual performance.

Wiltshire Police does not engage with the direct entry scheme for inspectors or superintendents. Nor does it use the Fast Track programme. But it is committed to developing its workforce and has made a considerable investment in opportunities for officers and staff to improve existing skills and develop new ones. Several initiatives are now on offer. These include the developing leaders programme, senior leadership programme and an apprenticeship programme for existing officers and staff.

All officers and staff who have the support of line managers can access these programmes and promotion processes. The process involves a values-based assessment, using the College of Policing’s Competency and Values Framework. People can take responsibility for their own professional development, acquire new skills and gain appropriate accreditation. Assessment processes for the development programmes are managed internally. The developing leaders programme is aimed at aspiring sergeants and police staff equivalents. Tests to get on to this programme have been outsourced. The senior leadership programme is for aspiring superintendents and police staff equivalents.

Promotion does not depend on a candidate being in a programme, nor do the programmes guarantee promotion.

The force uses a ‘gateway assessment’ process, with oversight from staff associations and HR, to select candidates for promotion. Most officers and staff who we spoke to consider the processes to be fair and open. The gateway system is a well-established means to access promotion opportunities. A panel decides whether applicants meet the role criteria, after which an independent panel makes the final selection. The same approach is not taken with police staff, who must apply for roles through conventional application and interview processes. People in under-represented groups have received help with preparing for promotion processes. The staff we spoke to thought this was fair.

The force is striving to identify talented individuals through a recently implemented talent management board. A survey has been done to establish whether the right candidates are being identified. This survey also allows people to give feedback on factors they think should be included in the assessment. All unsuccessful candidates receive feedback and mentoring.