Annex to Home Secretary’s letter – Vetting, misconduct and misogyny in the police service: review of progress
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On 18 January 2023, the Home Secretary commissioned us under section 54(2B) of the Police Act 1996 to undertake an urgent review of progress on vetting and counter‑corruption in England and Wales. We were specifically asked to look at the extent to which all forces have taken steps towards implementing the recommendations of our inspection into vetting, misconduct and misogyny. We were asked to highlight where further action is required.
We have summarised our main findings in a letter to the Home Secretary. This annex provides additional detail, including an explanation of the work we have undertaken to verify force self-assessments. We conducted this as a rapid review against tight timescales. It isn’t a comprehensive re-inspection. It shows that, overall, forces have undoubtedly improved since our inspection, but not all forces demonstrate acceptable progress for some recommendations.
Our terms of reference
On 3 March 2023, we published our terms of reference:
We will examine the extent to which all forces have taken steps to implement the recommendations we made in our 2022 thematic inspection report An inspection of vetting, misconduct, and misogyny in the police service. We will also examine how forces have addressed the areas for improvement (AFIs) outlined in this report.
Specifically, we will:
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seek to verify responses to the National Police Chiefs’ Council’s (NPCC) request for forces to make self-assessments of their progress against the recommendations in our report;
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examine the extent to which chief officers have prioritised vetting in their forces;
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establish whether there are any barriers to implementing the recommendations; and
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recommend where further action or inspection might be required.
Force self-assessments
At the point we were commissioned, the NPCC had separately asked all police forces in England and Wales to complete a monthly self-assessment of their progress against the recommendations and AFIs in our report. The NPCC shared the January and February force self-assessments with us.
As part of their self-assessment, each force was asked to grade their progress using the following red, amber, green (RAG) ratings:
Figure 1: RAG ratings
Rating | Definition |
Red | Recommendation/AFI will not be, or is unlikely to be, implemented in full by its deadline |
Amber | Recommendation/AFI will be, or is likely to be, implemented in full by its deadline |
Green | Recommendation/AFI has already been implemented in full |
We undertook a range of activities to verify some forces’ responses, as far as we were able to in the timescale available. As a result, we carried out our own assessments in order to estimate each force’s progress. Charts in this annex compare the two assessments.
Concerns about some forces’ self-assessments
Forces and the NPCC worked quickly to provide the self-assessments. For each force, we considered whether the self-assessments accurately reflected the grading the force gave itself.
To varying degrees, they offer assurance that the recommendations are being acted upon. However, the quality of forces’ initial submissions varied. A few forces appeared to have either downplayed or overstated their progress in some areas. And in some instances, forces didn’t provide a RAG rating. Some responses lacked sufficient detail. This meant they didn’t offer an accurate assessment of their progress. In February 2023, in conjunction with the NPCC, we asked these forces to provide additional information. This allowed us to make a more informed estimate of their progress.
We also made enquiries to verify or refute the information provided by forces. However, our estimates of progress aren’t based on extensive fieldwork. They rely heavily on force assessments, some of which are incomplete. We have added the following ratings to account for this.
Figure 2: Our additional ratings
Rating | Definition |
Grey | Recommendation/AFI – we were unable to provide a grading against the full recommendation on the information provided |
Blue | Recommendation/AFI – the force did not provide a grading |
Activity to verify force self-assessments
To verify the force self-assessments and to form our own view on progress we have:
- reviewed written updates from the NPCC leads for professional standards and ethics, vetting, counter-corruption and integrity;
- interviewed members of the NPCC vetting portfolio and tasking group; and
- compared force self-assessments with the findings from our most recent vetting and counter-corruption inspections (between 19 September 2022 and 12 December 2022, we inspected eight forces).
We have also examined documents including:
- the draft vetting code of practice;
- the vetting appeals panel training guidance;
- a selection of force vetting decision-making templates;
- documents relating to the Police National Database (PND) pilot and historical ‘data wash’;
- counter-corruption strategic threat assessments; control strategies and action plans; and
- sexual harassment policies.
Vetting, misconduct and counter-corruption file review
To further verify and test the accuracy of the information that forces provided to the NPCC, we reviewed:
- 300 vetting files involving cases with adverse information in 10 forces;
- 149 prejudicial and improper behaviour (PIB) misconduct files in 22 forces; and
- 80 sexual misconduct counter-corruption intelligence files in 19 forces.
In several instances, we discussed our file review findings with force personnel.
Update from other bodies
In our initial report, we made recommendations to other bodies, such as the Independent Office for Police Conduct, College of Policing (CoP), Home Office and NPCC. They have provided written updates on their progress in meeting those recommendations. Given the limitations of our statutory powers, we haven’t sought to verify their updates.
Summary of forces’ progress: vetting
In our report, we made 9 vetting-related recommendations to each of the 43 police forces in England and Wales, amounting to 387 recommendations in total. Cautiously, we estimate that 73 percent have been or are likely to be addressed by the deadline. More specifically:
- Three recommendations are likely to be achieved by at least 90 percent of forces. These relate to vetting decision-making, vetting reviews after misconduct proceedings and routine use of the PND to monitor the workforce.
- Four recommendations are likely to be achieved by about 70 percent of forces. These relate to identifying vetting clearance decisions with adverse information within IT systems, quality assurance processes, analysing data to identify any disproportionality and managing changes to individuals’ personal circumstances.
- Two recommendations are likely to be achieved by less than 50 percent of forces. These relate to the use of risk mitigation and ensuring that all people in designated posts have management vetting
Vetting file review
To help us assess forces’ efforts to address our recommendations, we examined 300 vetting files in 10 forces that were handled between 1 December 2022 and 31 January 2023. Encouragingly, we found notable improvements in vetting decision-making since our thematic inspection. Nevertheless, while forces have become less likely to give clearance to unsuitable applicants, we found 13 cases of concern in 6 of the 10 forces. These included cases where the applicant had:
- a connection with an organised crime group;
- a history of allegations of domestic abuse against several partners;
- a history of allegations of dishonesty (including a criminal charge);
- unexplained debts; or
- deliberately omitted significant information from their vetting application form.
They also included cases where the applicant had a family member who had been imprisoned for:
- drug dealing; or
- serious sexual offences and was now a registered sex offender.
In all 13 cases, we disagreed with the vetting decisions and weren’t satisfied that the forces had adequately considered the risks associated with appointing the applicants. We informed the forces of our concerns.
Some of these are illustrated in the case studies below.
Case study
Case study 1
An applicant for a police staff firearms licensing role was found to be associated with a member of an organised crime group. He failed to disclose this. The force said it conducted a vetting interview, but there was no record of this. The force granted clearance and employed him, but there was no evidence that the decision-maker had properly assessed the identified risks. The force didn’t use any risk mitigation. Following our findings, the force suspended his vetting clearance.
Case study
Case study 2
An applicant for a police officer role declared on his vetting application that a business they owned outside the UK had folded leaving him in debt. He declared that he had been evicted twice and had a car repossessed. The force granted vetting clearance, but the rationale recorded didn’t properly address the financial risk. The force didn’t conduct a vetting interview to enquire further about his debts or implement any risk mitigation such as regular reviews of his finances. Following our findings, the force withdrew his vetting clearance.
Case study
Case study 3
An applicant for a police officer role had been cautioned in 2006 for possession of a ball-bearing gun when aged 14. He also declared on his vetting application form that between 2019 and 2021, he had domestic disputes with his ex-wife. His ex-wife made a complaint of harassment and applied for a non-molestation order. The order wasn’t granted when his ex-wife failed to attend the family court hearing. The applicant’s brother had numerous criminal convictions from 2015 to 2016. These included supplying controlled drugs, for which he was imprisoned. Surprisingly, there was no vetting interview. In granting clearance, relevant risk factors were overlooked, particularly his brother’s involvement in serious and organised crime. Following our findings, the force withdrew vetting clearance.
Case study
Case study 4
The grandfather of an applicant for a police staff role had been imprisoned in 2021 for a sexual assault and had recently been released. The applicant declared this on her vetting application form. The vetting unit didn’t interview the applicant to establish her level of contact with her grandfather. The force didn’t record any rationale for its decision to grant clearance. There was no evidence that it had given due consideration to the relevant risk factors or risk mitigation, such as monitoring the applicant’s use of the force’s IT. Following our findings, the force conducted a vetting interview to establish the applicant’s relationship with the grandfather. It granted clearance with risk mitigation in place.
Case study
Case study 5
Vetting enquires revealed that an applicant to become a police officer had a fixed penalty notice for disorder. This followed their arrest in 2006 after being ejected from a bar when aged 22. The applicant failed to disclose this, but the force didn’t record any interview with the applicant about this failure. Clearance was granted but the rationale recorded didn’t provide any evidence that the non-disclosure had been considered. Following our findings, the force reviewed the vetting and decided the overall risk was low.
Case study
Case study 6
An applicant for a police staff role had previously come to police attention. He was suspected to have sent an unwanted explicit image to a 16-year-old girl when he was also aged 16. The force was aware of several domestic incidents between 2014 and 2018 involving a pattern of threatening words towards his mother and several former partners. None of the incidents resulted in a prosecution. He was granted clearance, but the rationale recorded on the vetting file wasn’t completed in sufficient detail. It didn’t demonstrate that the force had considered the identified risks. The force agreed with our assessment, but we don’t know if it has acted on it.
Case study
Case study 7
An applicant to be a direct entry detective constable declared on his vetting application form that police received three allegations of dishonesty against him between 2005 and 2016. One case in 2014 resulted in a charge of theft of a phone at a family business. The case resulted in a not guilty outcome when the Crown Prosecution Service offered no evidence. He was recruited. The rationale for the vetting decision to grant clearance was insufficient. It focused on the lack of criminal conviction rather than examining why the case was discontinued. In granting clearance, the vetting decision-maker stated they would give the applicant “the benefit of the doubt”. In our thematic report, published prior to this decision, we criticised the use of such phrases. We said it didn’t reassure us that the protection of the public, police information or operations was prioritised by decision-makers. The force has accepted our finding, but we are unaware of any subsequent action it has taken.
In a further 26 cases in 5 of the 10 forces, we agreed with the vetting decisions but found decision-makers hadn’t adequately recorded their rationale for granting vetting clearance.
Quality assurance, disproportionality and risk management
Only 24 forces have introduced a quality assurance process for vetting decisions. The remaining forces intend to do so by the deadline. Only five forces reported that they currently gather data and conduct analysis of their vetting decisions across all protected characteristics to identify and understand any disproportionality. Six of our recommendations from the thematic inspection relate to establishing better processes for assessing, analysing and managing risks concerning vetting decisions.
Nearly all forces now have processes to identify files containing adverse information using their vetting IT systems. The remaining forces are working with their vetting IT system suppliers to create solutions or intend to do so at the next scheduled system update. This won’t be achieved by the deadline.
During our review of vetting files, we found examples in six forces of risk mitigation not being used. Such measures would have provided additional assurance for vetting clearance decisions.
Thirty-eight forces reported that they conduct vetting reviews following misconduct proceedings. Although the recommendation deadline hasn’t been met, we can’t see any justification for why the remaining five forces haven’t already introduced this.
We estimate that most forces won’t meet the recommendation relating to management vetting in time. Almost half reported having people in designated posts without the correct vetting clearance. Many cited a lack of resources and IT limitations as reasons for this.
Most forces now consider the implications for vetting when individuals report changes to their personal circumstances – for example, marital status, name changes or significant changes to personal finances. But worryingly, two forces didn’t conduct any enquires once a notification was received.
The NPCC is currently working with forces to check their workforce against the PND. This historical ‘data wash’ will help forces understand how viable it is for them to routinely use the PND as we recommended. Some forces are concerned that checking the accuracy of results will increase workloads. There are also concerns that the PND doesn’t have the capacity to cope with such increased demand.
Forces’ progress against identified AFIs: vetting
We identified two AFIs in our thematic report relating to vetting. One relates to vetting interviews. During our vetting file review, we found 11 examples where a vetting interview should have been conducted but wasn’t.
The second AFI relates to automated links between forces’ vetting and human resources IT systems. No force has successfully addressed this. Sixteen forces told the NPCC that they were planning to link their IT systems if possible but provided no timescales. A further 14 forces reported they intended to negotiate with suppliers to ensure such links were incorporated into any future IT procurement.
Vetting recommendations to other bodies
We made eight vetting-related recommendations to other bodies. We are told that six of them are on track to be addressed by the deadline. They relate to:
- changes to national guidance in respect of obtaining pre-employment history;
- making vetting decisions;
- handling vetting appeals;
- conducting reviews after misconduct proceedings; and
- how forces should respond when someone seeking to transfer to another force is refused vetting by that force.
The CoP expressed reservations about the remaining two recommendations.
The first relates to increasing the frequency of vetting renewals. The CoP suggested that without a significant increase in vetting unit staff nationally, this recommendation would recreate the huge numbers of police personnel with expired vetting that we found in the past. The CoP estimates that 1.2 million hours and an additional 800 vetting staff would be needed to renew existing vetting clearances. Inevitably, increasing the frequency will increase workloads, but we have been unable to verify the CoP’s estimate.
The CoP also expressed reservations about meeting the deadline for changing the vetting authorised professional practice (APP).
We recommended that the APP should be more prescriptive about what types of roles require management vetting. There is wide variation across forces in roles, role titles and role requirements, so it isn’t straightforward. However, the CoP told us that guidance for forces in relation to the types of roles that require management vetting is to be included in the amended APP.
We also recommended that the APP should give better guidance on the vetting of police personnel working with vulnerable people. This work is underway but isn’t likely to meet the deadline. A subgroup of the NPCC vetting working group has been specifically examining roles and vetting levels. It aims to develop guidance for a future APP update to ensure consistency across forces. The subgroup is considering whether management vetting is an effective means of assessing suitability for personnel with frequent access to vulnerable people. They are consulting with academics at Bournemouth University. We were told that the subgroup’s work won’t be concluded in time for the amended APP later this year.
We recognise the complexity of this work and are satisfied the CoP and NPCC are working towards addressing the recommendation.
Summary of forces’ progress: counter-corruption and misconduct
In our report, we made 19 recommendations related to counter-corruption and misconduct to each of the 43 police forces in England and Wales, amounting to 817 recommendations in total. With a reasonable degree of confidence, we estimate that at least 90 percent have been or are likely to be addressed by the deadline. More specifically:
- Eighteen recommendations are likely to be addressed by at least 90 percent of forces. Two of these recommendations aim to increase forces’ understanding of misogynistic and predatory behaviour. Four seek to improve the collection of corruption intelligence. Eight aim to introduce better processes to manage corruption risks. Four are designed to improve the way that forces assess and investigate allegations of misconduct.
- One recommendation is only likely to be addressed by about 60 percent of forces. This requires forces to review allegations of PIB recorded in the previous three years.
For the purposes of this review, we separated these 19 counter-corruption and misconduct-related recommendations into 4 areas.
Misogynistic and predatory behaviour
Two recommendations relate to forces’ definitions and understanding of what constitutes misogynistic and predatory behaviour in a policing context. The recommendations included the adoption of the NPCC sexual harassment policy and the ability to identify PIB‑related misconduct.
We estimate that 96 percent of forces will meet the deadline for addressing these recommendations.
Collection of corruption intelligence
Four recommendations relate to improving the way the police collect corruption-related intelligence. This includes forces making sure they can monitor IT systems and proactively seek corruption-related intelligence.
We recommended that counter-corruption units improve relationships with external agencies and organisations that work with and support vulnerable people. When sexual misconduct intelligence is received, forces must have effective processes to manage any identified risks.
During this review, we have seen improvements in how forces collect this type of intelligence. We assess that 96 percent of forces will meet the deadline for addressing these four recommendations.
Managing corruption risks
Eight recommendations relate to establishing better processes for assessing, analysing and managing risks concerning corruption investigations and information security. This includes the management of mobile devices.
We recommended that forces improve the way that corruption-related intelligence is categorised and that they analyse their intelligence to produce current counter-corruption strategic threat assessments.
Forces are required to have regular intelligence meetings that help to identify personnel who may present corruption risks. Forces must also have effective ways to manage business interests and any personnel with notifiable associations. Personnel should complete annual integrity reviews with their supervisors.
We estimate that 91 percent of forces will address these recommendations by the deadline.
Allegations of misconduct
Five recommendations relate to improving the way police assess and investigate allegations of misconduct and counter-corruption intelligence.
One recommendation was for chief constables to carry out reviews of all allegations relating to PIB recorded from the last three years. Only 27 forces stated that they are likely to have carried out such reviews by the deadline.
To help us assess forces’ efforts to address our recommendations in this area, we examined 149 recent PIB misconduct files and 80 sexual misconduct intelligence files. Our review found that, contrary to the update they provided to the NPCC, four forces weren’t routinely using investigation plans to properly manage these cases. We found a lack of supervisory oversight in these investigations. Five forces were still not thoroughly investigating PIB.
On a more positive note, we found appropriate authorities were making better initial assessments of the severity of allegations, supported by sound written rationales. This led to forces identifying more cases of gross misconduct from the outset. We estimate that 86 percent of forces will address these five recommendations by the deadline.
Forces’ progress against identified AFIs: counter-corruption and misconduct
We identified three AFIs in our thematic report relating to counter-corruption and misconduct.
One AFI related to forces’ understanding of the scale of misogynistic and improper behaviour in the workplace. Almost every force reported that they are working towards this.
Another AFI related to correctly categorising sexual misconduct. Every force reported to the NPCC that they do so. However, we found a small number of examples where they didn’t. The final AFI related to forces sharing an edited version of their counter-corruption strategic threat assessment with the workforce. Most forces either do this already or have plans to do so.
Counter-corruption and misconduct recommendations to other bodies
To other bodies, we made seven recommendations related to counter-corruption and misconduct.
- Two recommendations require the NPCC to consult with the Independent Office for Police Conduct to define PIB and devise a means of flagging PIB cases on databases that record complaints and misconduct. We have been told this work is progressing.
- One recommendation requires the CoP to consult with the NPCC to improve guidance to forces on personal relationships and behaviours in the workplace. We have been told that work on this recommendation is on track to be addressed by the deadline.
- One recommendation requires the NPCC to design a sampling regime for decisions by appropriate authorities. We have been told that work is on track to be addressed by the deadline.
- The remaining three recommendations aim to extend the scope of the law relating to police complaint and misconduct procedures. This will involve the Home Office working with NPCC leads to make changes to statutory regulations and to outline how they should be applied. Understandably, these legislative changes will take more time.
Areas for further inspection
We were asked to highlight where further action is required. The areas that would merit further inspection are:
- vetting decisions, accompanying rationale and use of risk mitigation measures;
- reviews of vetting status when personal circumstances change or after misconduct proceedings;
- designated post lists and management vetting arrangements;
- identifying, understanding and responding to disproportionality in vetting decisions;
- investigation and management of PIB cases (both intelligence and misconduct);
- results of the review of investigations into allegations relating to PIB recorded in the past three years; and
- forces’ understanding of the scale of misogynistic or other improper behaviour towards women in the workplace.
Figure 3: Progress made against recommendations in our 2022 thematic inspection report by all forces in England and Wales measured using RAG ratings since September 2022
Figure 4: Progress made against recommendations in our 2022 thematic inspection report by each force in England and Wales measured using RAG ratings since September 2022
We have published the raw data for figures 3 and 4 in separate data sheets.
- Table containing all RAG ratings by police forces (Spreadsheet)
- Table containing all RAG ratings by HMICFRS (Spreadsheet)
Figure 5: All ratings
Rating | Definition |
Red | Recommendation/AFI will not be, or is unlikely to be, implemented in full by its deadline |
Amber | Recommendation/AFI will be, or is likely to be, implemented in full by its deadline |
Green | Recommendation/AFI has already been implemented in full |
Blue | Force did not provide a grading |
Grey | We were unable to provide a grading against the full recommendation on the information provided |
Recommendations
Recommendations
Recommendation 1
By 31 October 2023, the College of Policing should update its guidance on the minimum standard of pre-employment checks that forces must carry out before appointing an officer or member of staff. Every chief constable should make sure their force complies with the guidance. As a minimum, pre-employment checks should:
- obtain and verify previous employment history for at least the previous five years (including dates of employment, roles carried out and reason for leaving); and
- verify the qualifications the applicant claims to have.
Recommendations
Recommendation 2
By 30 April 2023, chief constables should establish and begin operation of a process to identify, within their vetting IT systems, vetting clearance records where:
- applicants have committed criminal offences; and/or
- the record contains other types of concerning adverse information.
Recommendations
Recommendation 3
By 30 April 2023, chief constables should take steps to make sure that, when granting vetting clearance to applicants with concerning adverse information about them:
- vetting units, counter-corruption units, professional standards departments, and HR departments (working together where necessary) create and implement effective risk mitigation strategies;
- these units have enough capacity and capability for this purpose;
- responsibilities for implementing specific elements of the risk mitigation strategy are clearly defined; and
- there is robust oversight.
Recommendations
Recommendation 4
By 30 April 2023, chief constables should make sure that when concerning adverse information has been identified during the vetting process, all vetting decisions (refusals, clearances and appeals) are supported with a sufficiently detailed written rationale that:
- follows the National Decision Model;
- includes the identification of all relevant risks; and
- takes full account of the relevant risk factors described in the Vetting Authorised Professional Practice.
Recommendations
Recommendation 5
By 31 October 2023, the College of Policing, working with the lead for vetting, should change the Vetting Authorised Professional Practice to give improved clarity in relation to:
- a greater focus on protecting the public;
- mitigation factors that may be employed;
- the weight to be applied to adverse information found on social media; and
- an obligation to record sufficiently detailed rationale, noting all identified risks and taking full account of all relevant factors, when coming to a vetting decision.
Recommendations
Recommendation 6
By 31 October 2023, the College of Policing, working with the National Police Chiefs’ Council lead for vetting, should include a vetting decision-making template within the Vetting Authorised Professional Practice to standardise decision-making.
Recommendations
Recommendation 7
By 31 October 2023, chief constables should introduce an effective quality assurance process to review vetting decisions, including routine dip sampling of:
- rejections; and
- clearances where the vetting process revealed concerning adverse information.
Recommendations
Recommendation 8
By 30 April 2023, chief constables should make sure they comply with the Vetting Authorised Professional Practice by analysing vetting data to identify, understand and respond to any disproportionality.
Recommendations
Recommendation 9
By 31 October 2023, the College of Policing, working with the National Police Chiefs’ Council lead for vetting, should change the Vetting Authorised Professional Practice to include guidance for dealing with vetting appeals. This should include specific guidance concerning the composition and role of vetting panels. The guidance should be consistent with the Vetting Code of Practice, particularly in relation to decision-making responsibilities and the involvement of HR professionals.
Recommendations
Recommendation 10
By 31 October 2023, the College of Policing, working with the National Police Chiefs’ Council lead for vetting, should change the Vetting Authorised Professional Practice to make it clear that, if an officer is reduced in rank following misconduct proceedings, forces should review their suitability to keep their current level of vetting clearance.
Recommendations
Recommendation 11
By 30 April 2023, chief constables who have not already done so should establish and begin operation of a policy requiring that, at the conclusion of misconduct proceedings where an officer, special constable or member of staff has been issued with a written warning or a final written warning, or been reduced in rank, their vetting status is reviewed.
Recommendations
Recommendation 12
By 31 October 2023, the College of Policing, working with the National Police Chiefs’ Council lead for vetting, should change the Vetting Authorised Professional Practice to be more prescriptive about what types of roles require management vetting, and give guidance on how people working with vulnerable individuals are vetted. This should include an emphasis on roles that specifically involve working closely with vulnerable people.
Recommendations
Recommendation 13
By 31 October 2023, chief constables who have not already done so should establish and begin operation of a process to:
- identify the required vetting level for all posts within the force, including designated posts requiring management vetting; and
- determine the vetting status of all police officers and staff in designated posts.
As soon as possible after this, these chief constables should:
- make sure that all designated postholders are vetted to the enhanced (management vetting) level using all the minimum checks listed in the Vetting Authorised Professional Practice; and
- give continued assurance that designated postholders always have the requisite level of vetting.
Recommendations
Recommendation 14
By 31 October 2023, the College of Policing, in consultation with the National Police Chiefs’ Council lead for vetting, should change the Vetting Authorised Professional Practice to prescribe intervals substantially shorter than ten and seven years for the renewal of recruitment vetting and management vetting respectively.
Recommendations
Recommendation 15
By 30 April 2023, chief constables should:
- make sure that all police officers and staff are made aware of the requirement to report any changes to their personal circumstances;
- establish a process through which all parts of the organisation that need to know about reported changes, particularly the force vetting unit, are always made aware of them; and
- make sure that where a change of circumstances creates additional risks, these are fully documented and assessed. If necessary, additional risks should lead to a review of the individual’s vetting status.
Recommendations
Recommendation 16
By 31 December 2023, chief constables should make routine use of the Police National Database (PND) as a tool for revealing any unreported adverse information about officers and staff. To help this, the College of Policing should:
- working with the National Police Chiefs’ Council lead for counter-corruption, change the Counter-Corruption (Intelligence) APP to include a requirement for the PND to be used in this way; and
- change the PND Code of Practice (and any subsequent code of practice concerning the Law Enforcement Data System) to include a specific provision that allows for the PND to be used in this way.
Recommendations
Recommendation 17
By 31 October 2023, the College of Policing, working with the National Police Chiefs’ Council lead for vetting, should change the Vetting Authorised Professional Practice to give guidance that:
- in every case where a transferee is refused vetting clearance, the originating force should carry out its own review of the individual’s vetting status; and
- the two forces involved exchange relevant information about the reasons for the refusal decision.
Recommendations
Recommendation 18
By 30 April 2023, chief constables should make sure that there is a robust response to any criminal allegation made by one member of their force against another. This should include:
- consistent recording of allegations;
- improved investigation standards; and
- sufficient support for victims and compliance with the Code of Practice for Victims of Crime in England and Wales.
Recommendations
Recommendation 19
By 31 October 2023, the Home Office, working with the National Police Chiefs’ Council lead for complaints and misconduct, and the Independent Office for Police Conduct, should make sure that police officers who make criminal allegations against other members of their own force are afforded rights similar to those held by members of the public who make criminal allegations. These should include:
- the right to complain about the conduct of officers concerned with the handling of the allegation, including its recording and investigation; and
- the right to appeal against the outcome of such a complaint.
Recommendations
Recommendation 20
By 30 April 2023, chief constables should adopt the National Police Chiefs’ Council sexual harassment policy.
Recommendations
Recommendation 21
By 30 April 2023, the College of Policing, working with the National Police Chiefs’ Council lead for ethics and integrity, should extend the scope of the Appropriate personal relationships and behaviours in the workplace (PDF document) guidance. An amended version should include guidance in relation to non-consensual behaviours as well as consensual relationships.
Recommendations
Recommendation 22
By 30 April 2023, the National Police Chiefs’ Council and the College of Policing, in consultation with the Independent Office for Police Conduct, should define prejudicial and improper behaviour, using the definition contained in this report or a suitable alternative.
Recommendations
Recommendation 23
By 31 October 2023, the National Police Chiefs’ Council lead for complaints and misconduct, in consultation with the relevant IT provider and the Independent Office for Police Conduct, should arrange to add a prejudicial and improper behaviour identifier flag to the professional standards database used to record complaints and misconduct.
Recommendations
Recommendation 24
By 31 October 2023, chief constables should make sure their professional standards departments attach a prejudicial and improper behaviour flag to all newly recorded relevant cases.
Recommendations
Recommendation 25
By 30 April 2023, chief constables should make sure their professional standards departments and counter-corruption units routinely carry out all reasonable wider inquiries when dealing with reports of prejudicial and improper behaviour. These inquiries should ordinarily include (but not be limited to) sampling the following, in relation to the officer under investigation:
their use of IT systems;
- incidents they attended and incidents they are otherwise connected to;
- their use of work mobile devices;
- their body-worn video recordings;
- radio location checks; and
- misconduct history.
Recommendations
Recommendation 26
By 30 April 2023, chief constables should make sure their professional standards departments:
- produce and follow an investigation plan, endorsed by a supervisor, for all misconduct investigations; and
- check all reasonable lines of inquiry in the investigation plan have been concluded before finalising the investigation.
Recommendations
Recommendation 27
By 30 April 2023, the National Police Chiefs’ Council lead for complaints and misconduct should design a sampling regime for appropriate authorities’ decisions. This is to quality assure the decisions and identify any learning. The sampling should make sure that appropriate authorities’ decisions:
- are consistent;
- maintain public confidence in, and the reputation of, the police service;
- uphold high standards in policing and deter misconduct; and
- protect the public.
Recommendations
Recommendation 28
By 30 April 2023, in the forces where we have not carried out fieldwork during this inspection, chief constables who have not already carried out a review of all allegations relating to prejudicial and improper behaviour, should do so. The review should be of cases from the last three years where the alleged perpetrator was a serving police officer or member of staff. The review should establish whether:
- victims and witnesses were properly supported;
- all appropriate authority assessments, including assessments which didn’t result in a complaint or misconduct investigation, were correct;
- investigations were comprehensive; and
- any necessary steps are taken to improve the quality of future investigations.
These reviews will be subject to examination during our next round of inspections of professional standards departments.
Recommendations
Recommendation 29
With immediate effect, chief constables must make sure that forces use Regulation 13 of the Police Regulations 2003 for underperforming officers during their probationary period, rather than the Police (Performance) Regulations 2020.
Recommendations
Recommendation 30
By 31 December 2023, the Home Office, working with the National Police Chiefs’ Council lead for complaints and misconduct and the College of Policing, should make sure that forces can use Regulation 13 of the Police Regulations 2003 effectively to discharge probationers who don’t achieve the required educational or academic standard during their probationary period.
Recommendations
Recommendation 31
By 31 October 2023, the Home Office, working with the College of Policing and the National Police Chiefs’ Council lead for complaints and misconduct, should make sure that, during pre-employment or vetting checks, police forces can identify any applicants previously discharged under Regulation 13 of the Police Regulations 2003.
Recommendations
Recommendation 32
By 30 April 2023, chief constables should make sure that:
- all intelligence concerning possible sexual misconduct by officers or staff (including abuse of position for a sexual purpose and internal sexual misconduct) is subject to a risk assessment process, with action taken to minimise any risk identified; and
- rigorous additional oversight arrangements are in place to monitor the behaviour of officers subject to the risk assessment process, especially in cases assessed as high risk.
Recommendations
Recommendation 33
By 31 March 2023, chief constables should make sure that counter-corruption units (CCUs) have established relationships with external bodies that support vulnerable people who may be at risk of abuse of position for a sexual purpose, such as sex-worker support services, drug, alcohol and mental health charities. This is to:
- encourage the disclosure by such bodies to the force’s CCU of corruption‑related intelligence relating to the sexual abuse of vulnerable people by police officers and staff;
- help the staff from these bodies to understand the warning signs to look for; and
- make sure they are made aware of how such information should be disclosed to the CCU.
Recommendations
Recommendation 34
By 30 April 2023, chief constables should make sure that their counter-corruption units actively seek corruption-related intelligence as a matter of routine.
Recommendations
Recommendation 35
By 31 March 2023, to protect the information contained within their systems and help them to identify potentially corrupt officers and staff, chief constables should make sure that:
- their force has the ability to monitor all use of its IT systems; and
- the force uses this for counter-corruption purposes to enhance its investigative and proactive intelligence gathering capabilities.
Recommendations
Recommendations
Recommendation 37
By 30 April 2023, chief constables should:
- convene, and hold on a regular and continuing basis, people intelligence meetings; or
- establish and begin operation of an alternative process to support the presentation and exchange of corruption-related intelligence to identify officers and staff who may present a corruption risk.
Recommendations
Recommendation 38
By 30 April 2023, chief constables should make sure that all corruption-related intelligence is categorised in accordance with the National Police Chiefs’ Council counter-corruption categories (and any revised version of these).
Recommendations
Recommendation 39
By 30 April 2023, chief constables should make sure they have a current counter‑corruption strategic threat assessment, in accordance with the Counter‑Corruption (Intelligence) Authorised Professional Practice.
Recommendations
Recommendation 40
By 30 April 2023, chief constables should make sure their counter-corruption units:
- produce and follow an investigation plan, endorsed by a supervisor, for all counter-corruption investigations; and
- check all reasonable lines of inquiry in the investigation plan have been concluded before finalising the investigation.
Recommendations
Recommendation 41
By 30 April 2023, chief constables should strengthen their business interest monitoring procedures to make sure that:
- records are managed in accordance with policy and include cases where authorisation has been refused;
- the force actively monitors compliance with conditions that are attached to the approval, or where the application is refused;
- regular reviews of each approval are carried out; and
- all supervisors are properly briefed about business interests held by members of their teams.
Recommendations
Recommendation 42
By 30 April 2023, chief constables should strengthen their notifiable association procedures to make sure that:
- they are compliant with the Counter-Corruption (Prevention) Authorised Professional Practice (APP) and that the obligation to disclose all associations listed in the APP is explicit;
- there is an effective monitoring process to make sure that any conditions imposed are being complied with; and
- all supervisors are correctly briefed on the notifiable associations declared by members of their teams.
Recommendations
Areas for improvement
Areas for improvement
Area for improvement 1
Forces’ use of vetting interviews is an area for improvement. In more cases, forces should interview applicants to explore adverse information of relevance to the case. This should help with assessing risk. When they carry out such interviews, forces should maintain accurate records and give copies of these to interviewees.
Areas for improvement
Area for improvement 2
Automated links between force vetting and HR IT systems are an area for improvement. When specifying and procuring new IT systems for these purposes, or developing existing ones, forces should seek to establish automated links between them.
Areas for improvement
Area for improvement 3
Forces’ understanding of the scale of misogynistic and improper behaviour towards female officers and staff is an area for improvement. Forces should seek to understand the nature and scale of this behaviour (like the work carried out by Devon and Cornwall Police) and take any necessary action to address their findings.
Areas for improvement
Area for improvement 4
Forces’ data quality is an area for improvement. Forces should make sure they accurately categorise all items of sexual misconduct intelligence. Sexual misconduct cases that don’t meet the definition of AoPSP (because they don’t involve the public) shouldn’t be recorded as AoPSP.
Areas for improvement
Area for improvement 5
Workforce awareness of corruption-related threats is an area for improvement. Forces should routinely brief police officers and staff on the pertinent and sanitised content of their annual counter-corruption strategic threat assessment.
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Vetting, misconduct and misogyny in the police service: review of progress