A report into the effectiveness of integrity arrangements in Derbyshire Constabulary

Published on: 22 January 2025

About us

His Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS) independently assesses the effectiveness and efficiency of police forces and fire and rescue services to make communities safer. In preparing our reports, we ask the questions the public would ask and publish the answers in an accessible form. We use our expertise to interpret the evidence and make recommendations for improvement.

Introduction

Background

When serving police officers and police staff are involved in misconduct or carry out criminal acts, it seriously reduces public trust and confidence in the police. It means the public are less likely to feel that police personnel behave in a lawful, ethical and fair manner. Public interest in police behaviour is high. The government and police service are increasing their focus on improving vetting, challenging misconduct and tackling corruption. We acknowledge this is increasing the demand placed on teams in force vetting units (FVUs), professional standards departments (PSDs) and counter‑corruption units (CCUs). But this work is essential to making sure the right people join the police service, and all officers and staff continue to work with integrity. We must make sure those working to keep communities safe can be trusted to do so.

In autumn 2023, we paused our rolling inspection programme assessing the effectiveness of vetting and counter-corruption arrangements in police forces in England and Wales. We have now developed an integrity inspection programme that also examines force professional standards.

All police forces we inspect in the integrity programme will now receive separate graded judgments for vetting, professional standards and counter-corruption.

Our judgments

Our inspection assessed the effectiveness of Derbyshire Constabulary’s vetting, professional standards and counter-corruption arrangements. Our judgments are as follows:

Area Grade
Vetting police officers and staff Adequate
Upholding the standards of professional behaviour Adequate
Tackling potential corruption Adequate

We set out our detailed findings about things the constabulary is doing well and where it should improve in the rest of this report.

At the end of our inspection, we briefed senior officers about our findings.

Terminology in this report

Our report contains references to, among other things, ‘national’ definitions, priorities, policies, systems, responsibilities and processes.

In some instances, ‘national’ means applying to England or Wales, or England and Wales. In others, it means applying to England, Wales and Scotland, or the whole of the United Kingdom.

Vetting police officers and staff

Derbyshire Constabulary is adequate at vetting its police officers and staff.

Area for improvement

The constabulary needs to improve its vetting arrangements

The constabulary should make sure that:

  • it has a robust process to research and assess all notifications of changes of circumstances in a timely manner; and
  • all personnel are made aware of the requirement to report any changes to their personal circumstances.

The constabulary has taken some steps to improve the workforce’s awareness that they must report any changes of personal circumstances. But we spoke to some personnel who weren’t aware they needed to report certain changes. At the time of our inspection, the force vetting unit told us it had 73 changes of circumstance waiting to be researched and assessed. This means the constabulary doesn’t know any potential risks they may contain. Also, the constabulary conceded that its notification-of-change forms didn’t include all categories of changes in enough detail.

These issues relate to a recommendation from our 2022 national report ‘An inspection of vetting, misconduct and misogyny in the police service’. The constabulary still hasn’t implemented this recommendation.

Area for improvement

The constabulary needs to improve its understanding of potential disproportionality in its vetting decisions

The constabulary should make sure that it analyses vetting data to identify, understand and respond to any disproportionality.

The constabulary collects information around all nine protected characteristics. But it has only just started analysing this data. The process hasn’t yet developed enough for the constabulary to understand if disproportionality exists in its vetting decisions.

This is a recommendation in our 2022 national report ‘An inspection of vetting, misconduct and misogyny in the police service’. The constabulary still hasn’t implemented this recommendation.

Vetting authorised professional practice

In 2021, the College of Policing published the authorised professional practice (APP) on vetting. The APP explains the role of vetting in assessing the suitability of people to serve as a police officer, special constable or member of staff. And it explains the vetting of non-police personnel. For each clearance level, it sets out the minimum checks that should be completed on the applicant, their family and associates. It also provides forces with examples of control measures which they could use to mitigate any risks.

The vetting APP applies to the police forces maintained for the police areas of England and Wales as defined in section 1 of the Police Act 1996.

Force vetting IT system

The FVU uses a vetting IT system that was introduced in 2017. An additional updated vetting IT system was implemented in September 2023. The HR department uses a separate IT system. HR provides the FVU with information about workforce changes using an e-recruitment form to overcome this lack of system integration. This helps the FVU keep track of new recruits, internal police staff and officer moves, promotions and people leaving the constabulary. The FVU also has access to all recruitment data including references from previous employers.

The FVU uses the vetting system to make sure all police personnel have the correct level of vetting for their role. The FVU uses information collated from its IT system to track vetting renewals 90 days in advance. This means the constabulary has time to send application documentation to individuals before a renewal is due.

Records in the FVU IT system with adverse information are clearly marked.

Current vetting of the workforce

Derbyshire Constabulary told us that as of 17 June 2024, it had a total of 3,182 police officers, special constables, police staff and police community support officers.

The constabulary told us that all personnel had the correct level of vetting for their roles. The constabulary has sustained this position for several years. At the time of our inspection, there were no personnel with expired vetting clearance.

Demand and workload

The FVU manages renewals on the vetting IT system. At the time of our inspection, the constabulary told us it had yet to process 46 vetting renewal applications. None of these were for expired vetting.

The FVU and HR work together effectively to predict demand. The constabulary monitors recruitment as part of a five-year plan. In addition, there is a 12-month plan that checks the progress of vetting clearances for officers, call handlers and those in specialist posts. The force vetting manager holds a weekly meeting with vetting staff to make sure they can manage their workload effectively and reallocates work if necessary. The FVU is adequately staffed.

The constabulary no longer uses the national contractor vetting service hosted by Warwickshire Police to carry out non-police personnel vetting (NPPV) checks.

In 2022, it increased staffing levels in the FVU by two vetting officers and one administrative assistant to take on NPPV work. The constabulary told us it had granted NPPV clearance to 1,595 contractors and volunteers. It told us that all NPPV cases managed by the FVU had current vetting.

Other departments responsible for individual contractors inform the FVU when the contract expires. The FVU then reviews their vetting status. If vetting expires or is removed, the FVU arranges for the relevant departments to remove access to police premises and IT systems. The constabulary accepts vetting clearance for contractors if it has been completed by another police force or the national contractor vetting service.

Designated posts

Some police roles have access to more sensitive information and require a higher level of vetting known as management vetting (MV). The extent to which the role requires working with vulnerable people is also a factor for forces to consider when deciding if a role requires MV. The vetting APP states that forces should keep a record of all MV roles on a designated posts list.

The constabulary told us it has 444 designated posts and it maintains a list of them. It told us there are 2,080 individuals that occupy these posts. When HR creates a new role, the vetting manager determines if MV is necessary. The constabulary updates the designated post list continually and reviews it once a year.

Generally, the constabulary doesn’t allow individuals to take up a designated post before it grants MV clearance. The constabulary will consider moving an individual into a designated post without the correct level of vetting if there is an operational necessity. In these cases, the vetting manager completes a risk assessment and consults the relevant head of department. They decide together if the constabulary can manage the risk effectively.

The constabulary told us that everyone in a designated post had MV clearance. We examined five MV files. In each case, the FVU had completed all the required minimum checks in line with the APP. And in each case the individual had the correct level of vetting for their post.

Transferees

Vetting APP allows forces to accept vetting clearance from another force if it is no more than one year old. But many forces choose to vet officers and staff who are new to their force, even if they are transferring from another force with a current vetting clearance.

Derbyshire Constabulary has chosen to vet all transferees and those who have left the service and applied to rejoin. The FVU requests a PSD complaint and conduct history, as well as any CCU intelligence, from all forces in which the individual has previously served.

Occasionally, the constabulary will accept a transferee with a live complaint or conduct investigation. The vetting manager reviews these cases and refers it to the head of PSD. They consult the appropriate authority of the parent force. The decision on the transfer depends on the nature of the live complaint or conduct matter.

When the constabulary refuses vetting for a transferee, it informs the home force and outlines the reason for refusal.

Where an officer trying to transfer from Derbyshire Constabulary fails vetting in the force to which they are applying, the FVU examines the reason for refusal. The constabulary considers implementing risk mitigation measures or removing the individual’s vetting clearance if necessary.

Change of circumstances

Derbyshire Constabulary has taken some steps to improve the workforce’s awareness of the obligation to report any changes in personal circumstances. This includes reporting significant changes to personal finances, and changes of name or marital status, for example. The constabulary publishes a reminder of this on its intranet every six months.

The constabulary requires all its police personnel to complete an annual integrity health check as part of their personal development review. During these discussions line managers ask their staff if there are any changes to their personal circumstances. FVU vetting clearance letters remind the workforce they need to report changes.

The number of changes reported has increased. This is encouraging. The FVU told us it received 148 notifications between 1 January 2022 and 31 December 2023. From January 2024 to the time of our inspection in June 2024, it had received 176 notifications. The FVU told us 73 of these notifications were yet to be researched and assessed. This means the constabulary doesn’t know any potential corruption risks in them.

We spoke to some officers and staff who weren’t aware of the need to report certain changes, for example, a financial gift or if any of their children had reached the age of ten. The constabulary conceded that its notification-of-change forms didn’t include these areas in enough detail.

Misconduct vetting review

The vetting manager reviews an individual’s vetting status if they are under investigation for gross misconduct. The vetting manager can place conditions on an individual’s vetting clearance. On occasions this can restrict what the person can do while under investigation. HR staff are responsible for moving an individual into another role when required.

HR informs the FVU of all misconduct meeting or misconduct hearing outcomes. The FVU told us it complies with the APP requirement to review a person’s vetting status if misconduct proceedings result in reduction in rank, written warning or final written warning.

Vetting decisions

Research officers carry out all the relevant vetting checks and make clearance decisions in cases where there is no adverse information. Where there is adverse information, and the research officer considers clearance is appropriate, the vetting supervisor will review the case and decide whether to give vetting clearance.

The vetting manager makes the final decision in cases where there is adverse information about the applicant and risk mitigation measures are needed. If the applicant has a conviction or police caution, the deputy chief constable makes the final decision.

During our inspection, there were older cases in which the FVU didn’t refer to the vetting APP when recording rationale for clearance decisions. In more recent cases, FVU personnel recorded their decision rationale more consistently and thoroughly. It made greater reference to APP and used the national decision model effectively.

Vetting interviews

Vetting research officers regularly carry out telephone or face-to-face interviews to clarify written responses in applications. They keep a written record of their discussions and provide copies of the notes to the applicant. This is in line with the vetting APP.

Risk mitigation

Derbyshire Constabulary uses risk mitigation measures in vetting clearance cases when adverse information has been identified. The vetting manager makes the decision on whether to give clearance where risk mitigation measures are needed.

If the applicant has undischarged debt or other financial difficulties, the FVU may give them conditional clearance. It carries out reviews every 3 or 12 months to make sure the applicant is keeping to the conditions.

It is difficult to restrict where an applicant can be posted due to the size of the constabulary and number of officers. However, the constabulary mitigates third-party risks, such as notifiable associations, through posting or restrictions on home working. The FVU advises HR of the restrictions, and they are recorded on the applicant’s personal file. Supervisors are responsible for managing restrictions and making sure the applicant is aware of the conditions.

If there are third-party risks, the FVU consults other departments before it applies risk mitigation measures. For example, the FVU notifies the CCU if IT monitoring is recommended. The CCU reports the results back to the FVU.

Derbyshire Constabulary produces an annual counter-corruption strategic threat assessment (STA) outlining the current threats it faces. FVU staff told us they weren’t aware of the assessment, or the threats contained within it. However, the vetting manager told us the CCU had shared the corruption risks with the FVU in July 2023. The CCU should take further steps to make sure staff in the vetting unit know the main corruption threats facing the constabulary.

Vetting appeals

Derbyshire Constabulary holds a vetting appeals panel once a month. The vetting manager chairs the panel unless they were involved in the original decision. In these cases, an independent chief inspector or superintendent chairs the panel.

The appeals panel includes representatives from Unison, the inclusion manager, representatives from the race equality network and disability network, and the security manager. The constabulary will also invite representatives of other staff networks when appropriate.

One of the requirements of the ‘Vetting Code of Practice 2023’ is that “Decision‑making in respect of vetting clearance should be separate from, and independent of, recruitment and other human resources processes.” We were told a senior HR officer also attends the constabulary’s vetting appeal meetings. They are there in a purely advisory capacity and aren’t part of any decision-making. The chair of the appeals panel makes the final decision.

Quality assurance

Derbyshire Constabulary has a quality assurance process for vetting decision-making.

The FVU completes an audit every two weeks by selecting vetting files completed by each of its research officers. These include clearance decisions with adverse information and vetting refusals. A suitably experienced research officer reviews these cases and discusses the results with the vetting manager.

Disproportionality

The APP states there is a risk that vetting has a disproportionate impact on underrepresented groups. Furthermore, it requires forces to monitor vetting applications, at all levels, against protected characteristics to understand whether there is any disproportionate impact on particular groups. Where disproportionality is identified, forces must take positive steps to address this.

The constabulary collects information around all nine protected characteristics (age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation). However, it has only just started analysing this data. The process hasn’t yet developed enough for the constabulary to understand if disproportionality exists in its vetting decisions.

Vetting file review

With a vetting specialist from another force, we reviewed 28 vetting clearance decisions from the 3 years preceding our inspection. These files related to police personnel who had previously committed criminal offences or that the constabulary had other concerns about. The files included transferee and recruitment vetting decisions.

We agreed with 27 of the constabulary’s vetting decisions. In one case we disagreed, because the FVU didn’t fully explore the reasons for the applicant’s failure to declare a Fixed Penalty Notice. It should have treated this as a potential honesty and integrity matter.

Upholding the standards of professional behaviour

Derbyshire Constabulary is adequate at upholding the standards of professional behaviour and addressing potential breaches.

Promoting the standards of professional behaviour and integrating organisational learning within the workforce

Public confidence in the police depends on police officers and staff showing high standards of professional behaviour. It is important that everyone in a supervisor or manager role leads by example in maintaining those standards. They should do this by challenging poor behaviour in others and showing the standards in their own behaviour. Each force should create and develop a culture of organisational learning, which will help to raise the standards of professional behaviour in its workforce.

The standards of professional behaviour that police officers should follow are set out in two places. Schedule 2 of the Police (Conduct) Regulations 2020 sets out the legally required standards. And the College of Policing’s Code of Ethics lays out the professional standards expected from all police officers and staff. The latest version of the Code of Ethics was published in 2024.

Promoting high standards of professional behaviour

There is a comprehensive approach to training and awareness of the standards of professional behaviour across Derbyshire Constabulary.

The constabulary frequently features the standards of professional behaviour on its intranet. The log-in screen for access to IT systems, laptops and mobile devices also displays the constabulary’s ethical policing principles of courage, respect and public service.

The constabulary provides training for new recruits and newly promoted sergeants and inspectors on annual leadership development courses. We were told officers wanting promotion need to complete a workbook including a section on professional standards. The constabulary provides ongoing training through College Learn.

The PSD has recently sought to become more visible to the workforce to promote the standards of professional behaviour. It has presented at the chief constable’s roadshow and attended local briefings. It has provided bespoke training for specific teams, such as emergency response teams. The PSD’s interactive Line in the Sand programme is of note. It explains that it isn’t always an incident that results in dismissal, but the attempt to cover it up.

The PSDs prevention officer carries out a pivotal role in co-ordinating and providing much of this training. They are developing a new starter guide. This contains links to all relevant integrity policies and includes reminders that police personnel must report changes in personal circumstances. The prevention officer also works with staff associations and some external service providers. This includes independent sexual violence advisers and independent domestic violence advisers. This is to invite or provide information on concerns about behaviours of police officers and staff.

The constabulary publishes all outcomes from gross misconduct hearings on its intranet and external website. Police officers and staff we spoke to were aware of this. They said that the publications effectively used the circumstances of the cases to highlight the standards of professional behaviour expected and the lessons learned.

The workforce’s understanding of the expected standards of professional behaviour

Derbyshire Constabulary hasn’t carried out a formal evaluation of how well its workforce understands the standards of professional behaviour. However, the PSD uses informal indicators, such as requests for advice and referrals to help establish this. Recruitment processes, such as promotion boards and external police recruitment interviews, also include questions on maintaining professional standards.

Police officers and staff we spoke to were aware of the expected standards and could recall training from the PSD. They found the PSD to be approachable. All said they had a good understanding of how to report potential breaches of the standards to the PSD directly, through their line manager or by using confidential reporting systems.

Organisational learning

The deputy chief constable chairs strategic meetings including the constabulary’s organisational learning oversight meeting and the force improvement board. This means organisational learning is overseen by a chief officer.

The prevention officer collates case studies from CCU and PSD investigations and complaints the constabulary has resolved through service recovery. These are recorded on a pro forma document and sent to the force improvement unit. The constabulary circulates Independent Office for Police Conduct (IOPC) ‘Learning the Lessons’ bulletins, other national learning and best practice. The force improvement unit decides the most appropriate medium to share learning and maintains a record detailing this. The constabulary uses indicators such as the number of clicks on an intranet article to monitor the workforce’s interaction with publications.

Handling and investigating public complaints, conduct matters and other potential breaches of the standards of professional behaviour

Area for improvement

The constabulary needs to improve its investigation of complaints and conduct allegations

The constabulary doesn’t always carry out thorough and proportionate investigations of complaints and misconduct. And its management of investigations falls short of the standards required.

We reviewed 26 complaint and conduct investigations. Five weren’t thorough and proportionate. We only saw one case where the PSD had interviewed the subject of misconduct allegations in person. In some cases, the PSD reduced the severity assessment down from gross misconduct because the appropriate authority deemed the reflective practice review process to be appropriate. They made this decision based on the accused’s written response, without testing the evidence in interview or exploring other opportunities to gather evidence.

Investigators had recorded terms of reference in all complaint and conduct cases dealt with by way of investigation. But only six contained a decision or policy log and only two had an investigation plan. Only eight had any record they had been supervised. Even where there was documented supervision, we found this was too brief and didn’t provide enough direction for the investigators.

We recommended that forces should produce and follow an investigation plan, endorsed by a supervisor in our 2022 national report ‘An inspection of vetting, misconduct and misogyny in the police service’. The constabulary still hasn’t implemented this recommendation.

The PSD also has an inconsistent approach for recording progress on its complaint and conduct IT system Centurion. This would help the constabulary manage complaint and conduct cases more effectively.

Capacity and capability in the professional standards department

Public co-operation and support are an important part of helping the police to reduce crime and keep people safe. Police actions that are perceived to be unfair, disrespectful, discriminatory, or corrupt can damage public confidence and trust. Constabularies must make sure their workforce acts ethically and lawfully. And, if the constabulary finds any problems with behavioural standards, it must show that it acts quickly and appropriately to address them. The constabulary should have effective governance and the right organisational structure to allow the PSD to carry out its role. It should also allocate enough resources to the task, including appropriately trained and experienced personnel.

Governance and capacity in the professional standards department

The deputy chief constable oversees PSD performance through a series of governance and assurance meetings attended by PSD senior managers. There is a scheme of delegation that clearly sets out by whom and at what level individual decisions must be made.

The constabulary recently decided that the PSD would resolve all complaints recorded under Schedule 3 of the Police Reform Act 2002, rather than sending some to local policing teams. PSD personnel told us this made roles and responsibilities clearer. They felt it provided a better quality, more consistent service.

To manage the extra workload, the constabulary has appointed a fourth appropriate authority, a detective inspector, in the PSD. It has also added two detective sergeants. Some PSD personnel reported they now had capacity to carry out their roles despite the increase in cases. However, some felt that additional supervisors were needed.

The complaints resolution team has one supervisor and seven team members. It handles all service recovery and Schedule 3 complaints being dealt with otherwise than by investigation. If the complaints resolution team identifies cases that require investigation, it passes them to PSD investigators. At the time of our inspection, each PSD investigator had an average caseload of 16 cases. These were a mixture of complaints, conduct matters and death and serious injury cases.

Training and experience in the professional standards department

The constabulary provides PSD personnel with training to help them to carry out most of their roles effectively. They have all completed the College of Policing-endorsed course on complaint handling and conduct investigation. And all except one PSD investigator have completed level 2 of the Professionalising Investigations Programme (PIP). However, the CCU passes some corruption investigations to the PSD. The constabulary should assure itself that the PSD personnel allocated these cases are sufficiently trained.

It has proactively recruited experienced detectives into the department, especially detectives with public protection unit experience. The constabulary told us that around half of the PSD investigators are new to the department and therefore inexperienced in dealing with complaints and conduct matters.

All appropriate authorities have received relevant training for their role or are scheduled to receive it this year.

PSD personnel have two continuing professional development days a year. We were told that they can make specific requests for training. These have included training on service recovery, sub judice and vetting. The constabulary uploads some of this training to an online platform for PSD staff to revisit when they need to. PSD administrators have been trained to use Centurion and Niche. But we found inconsistent use of Centurion by the complaints resolution team and PSD investigators. We therefore urge the constabulary to extend Centurion training to all PSD personnel.

Complaints resolution team personnel have attended IOPC training on discrimination. This helps them to identify discrimination cases during the initial handling process and deal with them appropriately. However, the PSD investigators only had a basic understanding of what constitutes discrimination and their responsibilities in such cases. The constabulary told us that training is planned to address this.

Processes for the identification and initial handling of potential breaches of the standards of professional behaviour

The UK Government introduced the Police (Conduct) Regulations 2020 and the Police (Complaints and Misconduct) Regulations 2020 to provide a more flexible approach to handling conduct matters and complaints about the police.

To promote a culture of learning in police forces, the new regulations include a practice requiring improvement process. This means that complaints or conduct matters that aren’t potential misconduct or gross misconduct can be resolved quickly and informally. The intention is to give the best possible response to the complainant.

We assessed whether the constabulary made sound decisions when handling complaints and conduct allegations. This included whether the constabulary made any necessary referrals to the IOPC and complied with statutory requirements by making handling decisions in a timely manner.

The initial handling of complaint and conduct matters

When the constabulary receives complaints and allegations of breaches of the standards of professional behaviour, it must assess them. This is to decide whether they need to be formally recorded under Schedule 3 of the Police Reform Act 2002. This is in line with the statutory guidance for the police complaints system. This process creates accurate, auditable records that can be relied on in subsequent investigations and disciplinary proceedings.

All 43 police forces in England and Wales use the Centurion software to record complaints and conduct matters that are being handled under Schedule 3 of the Police Reform Act 2002.

Initial handling of public complaints

The constabulary generally logs, records and makes handling decisions for Schedule 3 complaints from the public in a timely way. Of the 20 complaints we reviewed, the PSD recorded 13 within 2 days. And in 18 cases it made a handling decision within 2 days of recording the complaint. We didn’t identify any undue delay in recording the remainder of the cases.

In 19 out of 20 of the cases we reviewed, the handling decision complied with statutory guidance. Individual allegations within a complaint were accurately identified and recorded. However, the rationale for the handling decision was recorded effectively in only eight cases.

We reviewed 10 complaints that the PSD resolved outside Schedule 3. We found the constabulary’s decision to do this was appropriate in nine of them. One case contained an allegation that, if proven, could have resulted in misconduct or gross misconduct proceedings. This was a complaint that Derbyshire Constabulary had failed to properly investigate domestic abuse allegations and as a result missed opportunities to secure forensic evidence. The PSD should have recorded this under Schedule 3 and investigated it.

Initial handling of conduct matters

We reviewed 20 conduct cases. The PSD recorded 12 of them within 2 days. In 12 cases it completed severity assessments within 2 days of recording the case. In the remaining conduct cases, we didn’t identify any undue delays. Individual allegations within conduct cases were mostly accurately identified and recorded.

In 19 out of 20 cases the appropriate authority’s initial severity assessment was reasonable and proportionate. In most cases there was evidence the appropriate authority reviewed their severity assessment during the investigation where necessary.

Initial actions relating to complaint and conduct cases

The appropriate authority must refer a complaint or conduct matter to the IOPC when it includes certain types of allegations. These include a serious assault, a serious sexual offence or serious corruption. Or any criminal offence or behaviour which is liable to lead to disciplinary proceedings and which, in either case, is aggravated by discriminatory behaviour on the grounds of race, sex, religion or other protected characteristics.

We identified 7 out of 40 complaint and conduct cases that required a mandatory referral to the IOPC. The constabulary had correctly identified and referred all of them.

In 6 of the 40 cases we examined, there was an allegation of police criminality. These included potential offences under the Theft Act 1968, the Computer Misuse Act 1990 and the Data Protection Act 2018. The investigator acknowledged that a crime may have been committed and recorded it on Centurion in five of these cases. The case where a potential crime wasn’t acknowledged and recorded related to computer misuse. According to the files, the constabulary only carried out a criminal investigation in one of the six cases. In some cases it may be proportionate to deal with a matter as internal misconduct rather than as a crime. But the constabulary should record a clear rationale for this decision. There was no rationale recorded on Centurion to explain why the constabulary didn’t pursue criminal investigations in five of the six cases.

Accessibility of the public complaints system

Forces in England and Wales have a statutory obligation to promote access to the complaints system and to make sure the public can use it. The constabulary should make sure that its complaints system is accessible to everyone. This includes people with protected characteristics and those from hard-to-reach communities.

Derbyshire Constabulary has made efforts to review the public’s access to its complaints system. The equality manager has reviewed the accessibility of the website. The public can make a complaint through the constabulary’s online system, by telephone, in writing or via the IOPC.

We found limited evidence the constabulary promotes the complaints system externally. Police officers and staff we spoke to weren’t aware of any efforts to inform hard-to-reach communities about the complaints process.

The constabulary doesn’t consistently support complainants who may need additional assistance. Of the 20 Schedule 3 complaint cases we examined, complainants may have needed additional support on 3 occasions. The constabulary provided it on two of them. In two of the ten service recovery cases we reviewed, complainants may have needed additional support. But there was no evidence the PSD explored this.

Two of the complainants who it appears didn’t receive additional support were domestic abuse victims. And the other reported having a mental health condition and stated they would need support when dealing with the police.

The constabulary should make sure that the needs of complainants are consistently considered and recorded in all cases.

Processes and governance for investigating and resolving public complaints and conduct matters

The standard of investigations

Investigations are an opportunity for the constabulary to address the concerns of the public and the workforce. They help forces to learn and improve and, where necessary, to hold officers and staff accountable. They can be lengthy and have a major impact on everyone involved. So it is extremely important that they are both thorough and proportionate to the seriousness of the allegation or concern.

During our case file review, we found that 5 out of 26 complaint and conduct investigations weren’t thorough and proportionate. These five were all conduct matters. We only saw one case where the PSD had interviewed the accused person. In all other cases, it invited them to provide a written response. In some cases, the PSD reduced the severity assessment down from gross misconduct because the appropriate authority deemed the reflective practice review process to be appropriate. They made this decision based on the accused’s written response, without testing the evidence in interview or exploring other opportunities to gather evidence. Two cases included potential criminal allegations.

The PSD dealt with 12 complaint cases otherwise than by investigation. This was a proportionate approach in all but one of them. In 2 of the 12 cases, complainants exercised their right to review and neither were upheld.

The PSD isn’t using Centurion in a standardised way to manage investigations. It records progress, decision logs and supervisory reviews inconsistently. This makes it difficult to audit or quality assure investigations.

Investigators had recorded terms of reference in all 26 complaint and conduct cases dealt with by way of investigation that we reviewed. But investigators had maintained decision logs in only six of them. Only 2 of the 26 cases had an investigation plan. Regular supervision had been recorded in only eight and this was too brief and didn’t direct investigators effectively. We were told that the constabulary has a fortnightly case update meeting and a monthly gross misconduct case meeting where this direction may be provided. But it isn’t recorded on Centurion.

In all the cases, the investigating officer or case handler had prepared a final report or outcome letter that was thorough, well presented, and included a clear rationale. In most conduct cases, the appropriate authority made a thorough final determination.

Welfare support for personnel involved in complaint and conduct investigations

Police forces need to make sure that they always consider the welfare of all police personnel involved in a professional standards investigation: whether they have been accused of wrongdoing, have made allegations, or are carrying out the investigations.

Derbyshire Constabulary considers the welfare of accused police personnel and those making internal conduct allegations.

There is a structured support package in place for those accused of wrongdoing. The constabulary makes sure the accused person is provided with welfare support when the PSD serves regulatory notices. This includes the support of a volunteer welfare officer who can provide support, signpost to services and provide information leaflets.

The constabulary told us there were 70 active welfare officers at the time of our inspection. A further 20 have been trained but not deployed. The CCU prevention officer co-ordinates their training. A recent event included presentations from the occupational health unit and the Police Federation.

Officers and staff we spoke to were also aware of support available from staff associations, Blue Light Champions and supervisors.

Some people under investigation are asked to complete a risk assessment to identify what support they may need outside work and whether there is a risk of their mental health suffering.

The support available to police personnel who report wrongdoing or raise concerns is less formalised and often relies on line managers. However, we were told of some examples where individuals had been signposted to counselling from an employee welfare service provider and victim support services.

Suspension and restriction of members of the workforce

During our inspection, we checked whether the constabulary documented its decisions about the suspension or redeployment of the accused person during an investigation. And we examined whether accelerated procedures were being used appropriately.

Derbyshire Constabulary has a current policy on suspension and restricted duties. When carrying out the severity assessment, the appropriate authority must consider whether the suspension criteria is met. If so, they send their recommendation to the head of PSD to review, who in turn submits it to the deputy chief constable for a decision. The deputy chief constable reviews each suspension every 28 days, unless circumstances change.

At the time of our inspection, the constabulary told us that four officers and one member of staff were suspended. A further 27 officers and staff were on restricted duties. However, in our case file review, we found that in over half of the cases where it was appropriate to consider suspension and restricted duties there was no record of this.

The constabulary recognises that it could use accelerated procedures more effectively. We were told that it only uses them in criminal conviction cases. Where there are multiple allegations in a case, the constabulary should separate out the allegations that necessitate further investigation and those where incontrovertible evidence is available. Derbyshire Constabulary isn’t doing this and is missing opportunities to take cases with incontrovertible evidence to accelerated procedure hearings.

The service provided to complainants

An important part of creating and maintaining trust and confidence in policing is providing a good level of service to complainants.

Complainants can expect to be involved in an investigation from the outset. They are entitled to:

  • receive a copy of the terms of reference for the investigation;
  • provide their account of events; and
  • receive regular, meaningful and timely updates.

We examined whether the constabulary has effective processes in place, to make sure it provides a good level of service to complainants.

We also examined the number of cases where complainants exercised their right to review, and how many of these reviews were upheld by the IOPC or the police and crime commissioner.

Derbyshire Constabulary provided a good level of service to complainants in respect of how it initially handled complaints. This was carried out in a timely manner and mostly in accordance with statutory guidance. We found evidence of complainants being provided with regular and meaningful updates. But, due to the lack of information recorded on Centurion, we were unable to tell whether the PSD sent complainants a copy of the terms of reference for investigations.

In some cases, when complainants are dissatisfied with the outcome of an investigation, they can ask the IOPC for a review. Between 1 April 2023 and 31 March 2024, the IOPC finalised 12 applications for a review of complaint cases that Derbyshire Constabulary had investigated. It found that four had an outcome that wasn’t reasonable and proportionate.

During the same period, the IOPC carried out nine reviews of complaints the constabulary had concluded otherwise than by investigation. It found that three cases had an outcome that wasn’t reasonable and proportionate.

The office of the police and crime commissioner finalised 81 complaint reviews during the same period. It found that the outcome wasn’t reasonable and proportionate in eight cases.

Information sharing

It is important that the constabulary gathers and shares adverse information about members of its workforce. This helps to make sure that professional standards are maintained and that risks are identified and mitigated. In our inspection, we examined:

  • whether the constabulary is able to record adverse information;
  • whether departments holding this information shared it appropriately within the constabulary; and
  • whether the constabulary considered such information when making decisions about complaint and conduct matters.
The recording and sharing of adverse information

Derbyshire Constabulary shares relevant information between departments and has an established process for doing so. We found the PSD acted in collaboration with HR, the FVU, the CCU and local area divisions and departments when dealing with complaint and conduct matters. The PSD, HR, the FVU, corporate communications staff and the constabulary’s legal representatives attend a monthly case review meeting. These meetings are used to discuss gross misconduct investigations and high-profile cases, and to share information about police personnel of concern.

The minutes of the corporate case review meeting confirm that there was discussion regarding:

  • gross misconduct cases;
  • civil litigation cases;
  • employment tribunals;
  • public liability claims;
  • negotiated exits;
  • probationer cases;
  • performance issues;
  • attendance issues;
  • medical retirement; and
  • sickness.

The PSD regularly notifies the FVU of the outcome of misconduct proceedings.

The consideration of relevant information

In our case file review, we saw evidence that the constabulary considers complaint and conduct history on Centurion when assessing the severity of allegations. But this wasn’t a consistent, formal process. Information sharing depends on the knowledge of individual team members. It also depends on an automatic flagging system in Centurion that notifies the user when there are 3 or more cases recorded against an individual within a 12-month period.

Holding police officers and staff accountable for their behaviour

Area for improvement

The constabulary needs to improve its understanding of potential disproportionality in the handling, investigation and resolution of complaints and conduct matters

The constabulary doesn’t carry out any formal analysis to establish if there is any disproportionality across the nine protected characteristics in its investigations and decision-making.

We found some evidence that the constabulary has taken steps to improve fairness and consistency in decision-making. For instance, it trains people carrying out misconduct meetings and gross misconduct hearings and participates in regional peer reviews of cases. But this falls short of the level of understanding required by the constabulary to address any potential disproportionality.

To fully understand disproportionality in its professional standards department decision-making and the reasons for it, the constabulary should carry out detailed analysis across the nine protected characteristics. It can then address any such disproportionality.

Consistency and fairness in decision-making

Officers and staff must be held accountable in a fair and impartial way. And decision‑making needs to be consistent. The constabulary must make sure that its approach to complaints and conduct matters, and the resulting outcomes, are proportionate to the allegations and investigation findings.

The constabulary has an established scheme of delegation, which includes four appropriate authorities, in the PSD. They are responsible for officer and staff complaints and conduct matters. This structure allows for them to informally moderate each other’s decision-making. They can cover work if an appropriate authority is unavailable or there is a conflict of interest. To make sure decisions are consistent, the detective chief inspector completes initial assessments, and the head of PSD carries out the final determination.

Where an appropriate authority deems the reflective practice review process to be appropriate, the head of PSD tries to carry out most discussions to make sure officers and staff receive a consistent message.

The constabulary also takes part in a monthly meeting of regional PSD heads. The constabulary takes two anonymised cases for peer review to make sure that decision-making has been fair and proportionate.

The head of PSD provides training to all chief inspectors who sit on misconduct panels to make sure their decision-making is consistent. An administrator supports the misconduct process to make sure they comply with regulations and are fair.

Derbyshire Constabulary has a clear The Police Regulations 2003 Regulation 13 policy covering the discharge of probationers, which HR leads on. We heard that the constabulary uses Regulation 13 proportionately and we saw no evidence it was used where misconduct proceedings should be applied.

PSD doesn’t carry out any formal detailed analysis to establish if there is any disproportionality across the nine protected characteristics in their investigations and decision-making. The constabulary told us it is planning to improve its internal capabilities to monitor and analyse data, outcomes and disproportionality. This will be the responsibility of the CCU analyst, but the role is new and still being refined. People we spoke to weren’t aware of any evidence or perception of disproportionality in decisions concerning police officers and staff, junior and senior police personnel or those with protected characteristics. They believed the PSD decision-making processes were equitable and fair.

The local policing body’s chief operating officer meets regularly with staff associations to make sure any concerns about the consistency of decisions are addressed. The staff associations haven’t raised this as an issue. The police and crime commissioner and their review officer meet regularly with the head of PSD and the appropriate authority to discuss current cases, trends, issues and resolutions in complaint and conduct matters.

The constabulary also has a three-tier structure for ethics and the PSD is present at each stage. There is an ethics taskforce led by the chief superintendent of corporate services. This is a group of up to 25 people from across the constabulary that discuss ethical matters. Above this sits an ethical board which heads of departments and divisions attend to consider strategic issues, such as the results of staff surveys. The ethics committee sits above this and is also attended by independent members.

Tackling potential corruption

Derbyshire Constabulary is adequate at tackling potential corruption and protecting the information it holds.

Protecting the information the constabulary holds

Lawful business and IT monitoring capability

Lawful business monitoring is a legitimate way for forces to monitor their information systems and methods of communication. By using lawful business monitoring, forces can identify unlawful access to police records, wrongful disclosure of police data, computer misuse and improper use of communication devices.

The counter-corruption (intelligence) APP (unpublished) gives guidance on IT monitoring and states that the use of monitoring and auditing software has significant prevention, intelligence gathering and enforcement advantages. For example, such systems allow the constabulary to create alerts which immediately tell investigating officers when a specific file has been accessed or printed.

Most constabularies can use IT monitoring to gather corruption-related intelligence to help identify corrupt individuals. IT monitoring can be particularly useful when identifying irregular use of systems and use by police personnel who are of concern to the constabulary. The constabulary can use automated checks:

  • when investigating individuals where there are integrity concerns;
  • where mitigations are required because of notifiable associations;
  • where the vetting process has raised concerns; and
  • to make sure that access to force data is for a lawful policing purpose.
Use of IT monitoring software to tackle corruption

Derbyshire Constabulary can monitor all its IT systems across mobile and desktop devices and proactively checks activity on them. This helps identify potential misconduct including improper contact with vulnerable victims. In addition, the constabulary uses its IT monitoring capability to enhance its counter-corruption investigations.

The constabulary also uses the IT monitoring software to proactively monitor personnel when intelligence shows they may pose a higher risk. The CCU identifies them through analysis of intelligence reports, information from public complaints and misconduct reports. It maintains a record of all police personnel who may be a corruption risk. The CCU records what action it takes to manage and mitigate the risks these individuals may pose.

CCUs and IT departments should meet regularly to make sure that the CCU can monitor and audit new IT systems and software. Derbyshire Constabulary makes sure the CCU is always involved in the procurement of any new IT system it intends to introduce. The deputy chief constable will only authorise the procurement of new software once the IT department confirms it has consulted the CCU. This helps make sure the constabulary can effectively monitor, audit and investigate the use of its IT systems to tackle potential corruption.

IT monitoring policy

The constabulary has a lawful business monitoring policy for monitoring and recording the workforce’s communications. The policy allows the CCU to audit all the constabulary’s mobile phone data. In addition, it allows for proactive monitoring of IT systems to identify and tackle corruption.

The policy provides the workforce with clear guidance regarding their expectation of privacy when using handheld and other mobile systems.

Digital device management

Management of digital devices is important when protecting information. It is essential that forces have accurate records of who has each device so that it can hold the person accountable for its use. Police personnel must also understand the restrictions on the use of force-supplied devices. This is to make sure they aren’t used for unauthorised purposes.

Derbyshire Constabulary has an established system of mobile device management and can attribute all mobile phones and tablets it issues to individuals across the workforce.

The constabulary can identify which officers and staff are accessing different IT systems through their unique log-in details. The constabulary relies on this to attribute its mobile devices, rather than using a database identifying who they allocated the device to. During our counter-corruption file review we found that CCU investigators can easily attribute mobile devices to the user.

Social media

If forces allow the use of encrypted applications (apps) on force-issue mobile phones, it is very difficult to monitor what police personnel are sharing on these devices. Derbyshire Constabulary doesn’t allow the use of encrypted apps on its devices.

The constabulary has a comprehensive social media policy on its intranet that provides clear guidance to the workforce. The digital communications development team manages all the constabulary’s social media accounts. The communication and engagement department monitors the accounts to make that content complies with the policy. The policy is current and due for a further review in January 2025.

Officers and staff we spoke to showed a general awareness of the constabulary’s expectations of them regarding the use of social media.

Tackling potential corruption

Area for improvement

The constabulary needs to improve how it collects, assesses, develops and investigates counter-corruption intelligence

The constabulary should make sure that:

  • it produces an effective counter-corruption strategic threat assessment (STA), associated control strategy and implementation plan with named people responsible for actions, and uses these to manage corruption threats effectively; and
  • its counter-corruption unit (CCU) has sufficient resources and suitably trained staff to meet demand, tackle corruption effectively and allow for proactive intelligence

The constabulary doesn’t have a current counter-corruption STA. Its most recent plan used data from July 2021 to June 2022 and lacked detailed analysis. And its counter-corruption control strategy priorities aren’t consistent with its most recent counter-corruption STA. It used data from the regional STA to develop the control strategy rather than using its own STA.

The implementation plan covers the threats identified in its control strategy. The CCU records the progress it is making to address the corruption threats. But this process isn’t effective as many actions in the plan weren’t being progressed. The constabulary told us CCU staff don’t have enough capacity to complete them. And senior managers didn’t have oversight of the plan.

The CCU is therefore not using the STA and associated control strategy and implementation plan effectively to address corruption threats. We made a recommendation about this in our 2022 national report ‘An inspection of vetting, misconduct and misogyny in the police service’. The constabulary still hasn’t implemented this recommendation.

The current structure means the CCU has enough resource to develop potential corruption intelligence. But beyond this, its capacity is limited. The CCU personnel responsible for carrying out the actions identified in the counter-corruption control strategy don’t have enough capacity. Furthermore, CCU staff told us that proactive work is sometimes paused due to high demand.

CCU staff develop corruption intelligence, but don’t retain cases beyond the covert investigation stage. The CCU often transfers corruption investigations to the PSD. Very few CCU staff have completed the College of Policing bronze counter-corruption course. The constabulary should assure itself that its current structure provides appropriate specialist expertise to corruption investigations.

These capacity gaps, coupled with the lack of specialist counter-corruption training, mean the CCU’s current resources may not be enough to fully achieve its aims and objectives.

Intelligence

Sources of corruption-related intelligence

Derbyshire Constabulary actively looks for corruption-related intelligence as a matter of routine. Each week a member of CCU staff is allocated the task. Staff use a variety of methods and systems to carry out this work. CCU staff told us that during periods of high demand they may pause this proactive work.

People can report suspected wrongdoing and corruption intelligence through two anonymous confidential reporting lines, Bad Apple and the national Crimestoppers integrity line. Police personnel can access both reporting systems through the intranet.

Over the past three years, the constabulary has seen an increase in the number of reports. The CCU received 13 reports in 2022, 32 in 2023 and 27 reports from 1 January 2024 up to the date of our inspection 17 June 2024.

We examined 60 corruption intelligence files. In 14 of these cases, we found police personnel reported the intelligence using a confidential reporting line. In 11 cases, personnel directly reported the corruption intelligence to the CCU. We only found two cases that were the result of proactive intelligence collection. Further sources of corruption-related intelligence included the FVU, external agencies, self-referrals, examination of body-worn video footage, reports from covert human intelligence sources and other forces.

Police corruption categorisation

The counter-corruption (intelligence) APP lists 12 categories of corruption-related intelligence. Forces should use these categories when recording intelligence. In addition, forces can use this data to help them identify their biggest corruption threats.

Forces should make sure they accurately categorise all items of sexual misconduct intelligence. Sexual misconduct cases that don’t meet the definition of abuse of position for a sexual purpose (APSP) because they don’t involve the public shouldn’t be recorded as APSP.

We found Derbyshire Constabulary correctly categorises all corruption-related intelligence in line with the counter-corruption (intelligence) APP.

Identifying corruption threats

Counter-corruption strategic threat assessment

The counter-corruption (intelligence) APP states that all forces should produce an annual counter-corruption STA detailing the corruption threats they face.

At the time of our inspection, Derbyshire Constabulary didn’t have a current counter‑corruption STA. The constabulary used data from July 2021 to June 2022 to prepare its most recent assessment. It lists the main risks but lacks detailed analysis. The risks include sexual misconduct in the workplace, APSP, disclosure of information, inappropriate associations and the workforce’s vulnerability to corruption through inappropriate sexual behaviour, such as use of escort agencies. We were told the constabulary was due to publish a new STA in July 2024.

Without a current STA the constabulary is unable to raise awareness across the workforce of the corruption threats it faces. During our inspection, we found the CCU don’t make the FVU aware of the STA. It is important that vetting decision-makers understand the main corruption threats. When the constabulary publishes its STA in July 2024, it should make sure all the workforce is aware of it.

Counter-corruption control strategy

Derbyshire Constabulary’s counter-corruption control strategy priorities aren’t consistent with its most recent STA. The constabulary used data from the regional STA to develop the control strategy rather than using its own STA.

Implementation plan

The implementation plan covers the threats identified in the control strategy. The CCU records the progress it is making to address the corruption threats.

However, the constabulary told us it wasn’t carrying out the actions it had identified in its control strategy. The constabulary told us CCU staff don’t have enough capacity to complete them. Senior managers said they have no oversight of the implementation plan. The constabulary isn’t using the STA, control strategy and implementation plan effectively to address corruption threats.

Exchanging information on people who may be a concern

Where forces have people intelligence meetings, they can help to identify officers and staff who may pose a corruption threat. The meetings bring together representatives from different parts of the constabulary to exchange information on those who may be of concern. This can include, but isn’t limited to, information relating to:

  • management of unsatisfactory performance;
  • sickness management and absenteeism;
  • public complaints;
  • corruption-related intelligence;
  • internal misconduct cases;
  • internet use;
  • unusually high overtime and expenses;
  • business interests;
  • debt management problems;
  • inappropriate use of force-issue credit cards; and
  • excessive use of force phones, including text messages.

Police personnel discussed in these meetings can often appear in more than one category. Because relevant information is often held by several departments, corruption risks can easily be missed.

Derbyshire Constabulary has an established process to help identify police officers and staff who may pose a corruption threat. The constabulary holds a corporate case review meeting every month. Attendees are consistent with those required for a people intelligence meeting.

When someone is identified as a corruption risk, the constabulary considers referring them to the tactical risk management panel. The panel is made up of representatives from numerous departments. The CCU writes a report on the potential risks individuals pose using all the available data. The panel then agrees a risk mitigation plan. The CCU is responsible for implementing the plan and keeping written records of the actions it takes.

The PSD has a daily tasking meeting where staff discuss complaints and conduct that have been reported in the preceding 24 hours. The head of PSD, head of CCU and the vetting manager attend.

Partnership working to identify potential corruption

The constabulary has developed and maintained working relationships to build trust with external agencies and organisations who support vulnerable people who may be at risk of abuse by police personnel. This means the constabulary is more likely to gather corruption intelligence relating to potential sexual abuse and safeguard vulnerable people.

The CCU has a dedicated prevention and engagement officer. We are pleased to see the constabulary invest in this important role.

The officer has given several APSP presentations to a range of external organisations and agencies. The presentations help staff in these bodies to recognise the warning signs of APSP and understand how to report corruption-related intelligence.

One presentation was attended by 98 people including representatives from a domestic abuse support agency, a child sexual exploitation charity, child and young person services and the University of Derby.

The constabulary has a clear plan to provide these training presentations to raise awareness of APSP to other external bodies in the future.

Managing corruption threats

Intelligence development

In 57 of the 60 corruption intelligence files we reviewed, the CCU responded effectively and used a good variety of techniques to develop intelligence. But we found the constabulary had missed opportunities to develop intelligence and mitigate corruption risks in the remaining three cases. These cases included allegations of misusing IT systems and the unlawful disclosure of information.

We found the constabulary refers appropriate corruption cases to the IOPC.

The CCU makes good proactive use of IT monitoring to look for intelligence. However, only two cases we reviewed resulted from this activity. One of these cases related to APSP. The CCU allocates resources to carry out proactive intelligence gathering when it has capacity.

Corruption investigations

Of the 60 corruption intelligence files we reviewed, 3 resulted in a counter-corruption investigation managed by the CCU. We found the standard of investigation was good in every case.

In contrast to the PSD’s complaint and conduct investigations mentioned earlier in this report, every case had an investigation plan which was meaningful and endorsed by a supervisor. CCU investigators followed the plan and concluded all reasonable lines of enquiry before the investigation was finalised.

Risk management

If forces become aware of a police officer or member of staff who is potentially a perpetrator of APSP, they should assess the risk posed by that individual. Forces tend to do this using a risk matrix. This prompts the assessor to consider all the circumstances and record the findings. Anti-corruption units then categorise each case as low, medium or high risk.

The types of behaviour that would trigger a force to assess someone against the risk matrix include:

  • inappropriate behaviour with or towards staff;
  • inappropriate sexual comments to members of staff or to the public in general;
  • sending a large number of calls, texts, instant messages or emails to vulnerable people;
  • sending emails or any messages of a sexual nature; and
  • intelligence or information about inappropriate sexual behaviour off duty.

Individuals assessed by forces as presenting a medium or high risk should be subject to additional oversight.

Derbyshire Constabulary uses a risk matrix to monitor officers and staff who are a concern. For example, personnel who are the subject of an allegation or intelligence relating to sexual misconduct or APSP. CCU staff research all known intelligence and previous reports on the individual and grade the level of risk they pose as green, amber or red.

Each case is assigned to a CCU staff member who is responsible for taking action to manage and mitigate the risks identified. The CCU detective inspector reviews the risk matrix each month to monitor progress. We found the matrix was comprehensive and managed well by the CCU.

Capacity and capability to investigate corruption

The CCU is a small team of experienced detectives, investigators and an analyst. However, only two members of staff have completed the College of Policing bronze counter-corruption course. The constabulary has recruited 2 police staff into the unit in the last 18 months. The current structure means the unit has enough resource to develop potential corruption intelligence. But beyond this, CCU capacity is limited.

The CCU staff develop corruption intelligence but don’t retain some cases beyond the covert investigation stage. The CCU decides if the case should be transferred to PSD for further investigation. This includes APSP cases, which often involve vulnerable victims and are likely to attract significant public interest. PSD staff aren’t corruption specialists. The constabulary should make sure that its current structure provides the right specialist expertise to these critical investigations.

As stated earlier, the constabulary isn’t carrying out the actions identified in its control strategy. The constabulary told us CCU staff don’t have the capacity to complete them. Furthermore, CCU staff told us that proactive work is sometimes paused due to high demand.

These capacity limitations, coupled with the lack of specialist counter-corruption training, mean the CCU’s current resources may not be enough to fully achieve all its aims and objectives.

Specialist resources

Officers and staff in the CCU, including the senior management team, are experienced in covert law enforcement. The CCU has good working relationships with the serious and organised crime unit and attends the constabulary’s organised crime meeting.

When required, the constabulary can access resources for covert investigations through the regional organised crime unit.

During our file review we didn’t identify any missed opportunities to use covert tactics to support corruption investigations.

Policies designed to prevent corruption

Clear and concise corruption prevention policies help to guard against corrupt activity. But they can’t guarantee to prevent corruption or, in themselves, stop corrupt practice. They provide guidance on how police officers and staff should behave. Policies should clearly state what is expected of personnel and what actions they should take to protect themselves and the constabulary from corruption.

The counter-corruption (prevention) APP sets out what policies forces should have and gives guidance on their content. We examined policies on:

  • notifiable associations;
  • business interests; and
  • gifts and hospitality.

Notifiable associations policies cover how the constabulary should manage the risks related to officers and staff who may associate with, for example, criminals, private investigators or members of extremist groups. The policies should require officers and staff to disclose such associations.

Business interests policies should state when the constabulary allows or forbids officers and staff to have other jobs, interests or activities. Policies should explain how the constabulary will manage the risks that arise when this is allowed.

Gifts and hospitality policies should cover the circumstances in which police officers and staff should accept or reject offers of gifts or hospitality.

Derbyshire Constabulary’s corruption prevention policies are comprehensive and reflect APP guidance. Generally, we found officers and staff had a good understanding of the policies.

Notifiable associations

The constabulary has an effective process to manage notifiable associations. At the time of our inspection, the FVU had recently taken over responsibility for managing the notifiable association register. A dedicated staff member reviews and records the type of association, frequency of contact and level of criminality. They grade the association based on the perceived level of risk.

The constabulary audits its IT systems in all notifiable association cases to identify any systems misuse and inappropriate access to police data.

The vetting manager is responsible for all high-risk cases and high-risk individuals are subjects of a risk management meeting between the vetting manager and CCU. Local supervisors are responsible for monitoring compliance of any conditions attached to the association. The constabulary reviews all high-risk cases every three months. It reviews medium and low-risk cases every 12 months.

The constabulary told us it had recently withdrawn an individual’s vetting clearance because they had breached the conditions of their association. This led to the individual’s dismissal.

At the time of our inspection, the constabulary told us it had recorded 670 notifiable associations. Of these, it had assessed 8 as high-risk, 105 medium-risk and 422 low‑risk. The constabulary had recorded a further 135 associations for intelligence purposes only.

Business interests

The constabulary has an effective system to manage business interests. The CCU keeps a business interests register on Centurion and the FVU updates the vetting IT system accordingly. The constabulary reviews all business interests every 12 months.

The workforce can submit business interest applications to the CCU using an online form. The constabulary only considers applications if the officer or staff member has approval from their line manager and departmental head or divisional commander. The CCU also consults the FVU, HR and PSD as part of the approval process.

Local supervisors are responsible for monitoring compliance with conditions. The CCU completes checks where it doesn’t authorise a business interest to make sure the officer or staff member is complying with the refusal decision. The constabulary records all compliance checks.

The constabulary’s business interest policy requires staff to declare any voluntary work that has the potential to affect the reputation of Derbyshire Constabulary.

At the time of our inspection, the constabulary told us it had recorded 737 business interest applications. Of these, seven were refusals.

Gifts and hospitality

The constabulary has an established system to manage gifts and hospitality.

The workforce must submit notifications about gifts and hospitality to the PSD using an online form. The PSD keeps a record on Centurion. Police personnel must ask for approval from their line manager and department head or divisional commander to keep the gift or accept the hospitality.

During our inspection, we noted a reduction in the number of entries made in the gifts and hospitality register. The constabulary told us that the PSD had recently reallocated responsibility for managing this process to a new staff member. This may account for the reduction. The constabulary should review this to make sure the PSD has considered and registered all gifts and hospitality appropriately.

In 2022, the constabulary recorded 72 gifts and hospitality applications. In 2023, it recorded 67 applications. From 1 January to 21 June 2024, it had recorded 15.

Sexual misconduct

The constabulary recognises APSP as serious corruption. We found the CCU records such cases correctly and it consistently refers them to the IOPC.

Of the 60 CCU corruption intelligence files we reviewed, 11 related to APSP. We found these cases had been handled effectively.

In the counter-corruption STA and control strategy the constabulary lists APSP as one of the main threats it faces. However, as we mentioned earlier in this report, we were told the CCU staff don’t have capacity to implement many of the actions identified in the strategy. The lack of activity recorded in the constabulary’s implementation plan shows that the CCU isn’t making enough progress to tackle this threat.

The CCU and PSD provide training sessions to various groups across the constabulary. This covers APSP and sexual harassment in the workplace. The constabulary also provides an APSP online training package for its workforce.

Police officers and staff we spoke to generally had a good knowledge of APSP. However, not all those we spoke to had completed their online training.

The constabulary uses the College Learn package on APSP recently provided by the College of Policing to train its workforce. The constabulary made this training mandatory. All personnel should have completed it by 31 December 2023, but only half did. The constabulary recently published guidance regarding the completion of mandatory training. It should take action to make sure that all personnel have completed the College Learn training.

Derbyshire Constabulary has adopted the National Police Chiefs’ Council sexual harassment policy in line with our national recommendation.

Back to publication

A report into the effectiveness of integrity arrangements in Derbyshire Constabulary