Annex to Home Secretary’s letter – Vetting, misconduct and misogyny in the police service: review of progress

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:

• 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;

• examine the extent to which chief officers have prioritised vetting in their forces;

• establish whether there are any barriers to implementing the recommendations; and

• 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.

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

Areas for improvement

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Vetting, misconduct and misogyny in the police service: review of progress