A report into the effectiveness of integrity arrangements in Hampshire and Isle of Wight Constabulary

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, professional standards departments (PSDs) and counter‑corruption units. 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 Hampshire and Isle of Wight Constabulary’s vetting, professional standards and counter-corruption arrangements. Our judgments are as follows:

Area	Grade
Vetting police officers and staff	Requires improvement
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

Hampshire and Isle of Wight Constabulary requires improvement at vetting its police officers and staff.

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 March 2024. The HR department uses a separate IT system. To overcome the lack of system integration, the HR department provides the FVU with information about workforce changes. This helps the constabulary keep track of internal moves, promotions and people leaving the constabulary.

HR can access some elements of the vetting IT system. But the FVU can’t access the HR system.

The FVU uses the vetting IT system to monitor if police personnel have the correct level of vetting for their role.

Any records with adverse information that have been added to the vetting IT system since March 2024 have an attention notice attached to flag them. Older records may hold adverse information, but this isn’t searchable until the record is updated and the attention notice attached.

Current vetting of the workforce

Hampshire and Isle of Wight Constabulary told us that as of 1 July 2024, it had a total of 5,940 police officers, special constables, police staff and police community support officers.

The constabulary told us that there were 313 personnel who don’t hold current vetting or the correct level of vetting for their role. At the time of our inspection, there were 252 people in the constabulary whose vetting had expired. This means they didn’t hold a valid vetting clearance for their role. Of these, 49 were in posts designated for a higher level of vetting, management vetting (MV). A further 61 were in designated posts, but had never been cleared to that level.

Demand and workload

The FVU doesn’t have enough staff to meet the demand it faces. Over the last 12 months, the constabulary has increased the FVU’s establishment by 3 vetting analysts and a vetting supervisor. The FVU now has 14 full-time equivalent vetting analysts, 2 vetting supervisors and a vetting manager. The constabulary is now recruiting more vetting analysts so that it will have 17 full-time equivalent posts. We were told that the FVU was planning to advertise for a new post of FVU administration officer.

At the time of our inspection, analysts were working on 223 vetting applications. There were a further 462 vetting applications waiting to be processed. In addition, the FVU hadn’t yet asked 203 individuals with expired recruitment vetting to submit their renewal forms. The oldest of these cases was vetting that had expired in March 2023. We would have expected the FVU to have progressed these.

The FVU, HR and recruiting departments work together effectively to predict demand. This includes monitoring the progress of all internal and external recruitment, promotion processes and new vetting applications.

Hampshire and Isle of Wight Constabulary grants non-police personnel vetting (NPPV) clearance to contractors and volunteers. At the time of our inspection the FVU told us there were 3,995 people with NPPV clearance. Five contractors had expired vetting. All five of them were being re-vetted.

Departments that have responsibility for contractors inform the FVU when they are no longer in contract. The FVU then reviews their vetting status. Access cards for contractors on specific projects are linked to NPPV clearances. If vetting expires, the FVU cancels the individual’s card. And it tells the IT department to cancel their access to IT systems.

The constabulary has a specific department with responsibility for recruiting temporary workers. The national contractor vetting service hosted by Warwickshire Police completes vetting for these individuals. The FVU has a record of the vetting status for all the constabulary’s contractors, including any temporary agency workers.

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 486 designated posts and keeps a list of them. There are 1,537 people in these posts. When HR creates a new post, the vetting manager decides if MV is necessary and updates the designated posts list. The constabulary last reviewed its designated posts list in 2024, immediately before our inspection.

Hampshire and Isle of Wight Constabulary isn’t managing its MV process effectively. The FVU told us that an external provider had provided HR services for the constabulary, but the agreement had ended.

The constabulary took back responsibility for HR and reconciled its vetting and HR data. This identified 61 people moved into designated posts without the required MV clearance. The vetting manager assured us this wouldn’t happen now and moves to designated posts would only occur if the individual had the correct level of vetting. At the time of our inspection, there were also 49 people in designated posts whose MV had expired. Some cases involved vetting that had expired six months before.

The constabulary should make sure it has an effective process in place to assure itself that designated postholders always have MV. This relates to a recommendation we made in our national 2022 report, ‘An inspection of vetting, misconduct, and misogyny in the police service’.

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 new to their force, even if they are transferring from another force with a current vetting clearance.

Hampshire and Isle of Wight 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 counter-corruption unit intelligence, from all forces in which the individual has previously served.

The constabulary will sometimes accept a transferee with a live PSD case. Where a transferee has a live complaint or conduct investigation, the vetting manager reviews the case and refers it to the head of PSD. They consult with the appropriate authority of the originating force. The decision on whether the transfer to the constabulary should be allowed will depend on the nature of the live complaint or conduct matter. Where either of the appropriate authorities doesn’t agree to the transfer, the vetting manager refuses clearance or defers the decision.

Where an officer trying to transfer from Hampshire and Isle of Wight 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

The constabulary has taken steps to improve the workforce’s awareness of the requirement 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 requirement in the PSD newsletter, ‘Reputation Matters’, that it produces every three months. The requirement to report changes in circumstances is included in anti-corruption unit (ACU) training.

The constabulary’s current HR IT system allows members of the workforce to update their personal details directly on the system. In these circumstances, the system doesn’t alert either HR or the FVU that details have been changed. This means the FVU may be unaware of changes that could affect an individual’s vetting status.

In September 2024, the constabulary required all its police personnel to complete an annual integrity health check linked to their annual performance development review. This health check includes any change of circumstances. The review can’t be closed without this element being completed.

When members of the workforce report changes of circumstances to the FVU, it carries out vetting enquiries to identify risks and to decide if they affect the person’s vetting status. The constabulary told us about a case in which it revoked an individual’s vetting following a significant change of circumstances. The individual resigned.

Misconduct vetting review

The PSD investigating officer or the misconduct meeting co-ordinator 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.

The FVU will also review a person’s vetting status following misconduct proceedings that don’t result in one of these outcomes if the PSD refers the case to the unit.

Vetting decisions

Vetting analysts in the FVU carry out all the relevant checks and make vetting decisions in cases where there is no adverse information. Where there is adverse information, the constabulary’s process requires the vetting file to be referred to a supervisor. The vetting manager makes the final decision.

But we saw evidence of the vetting analysts failing to identify information as adverse. For example, we saw an individual with significant financial debt and another subject to an earlier anti-corruption investigation. In these cases, analysts granted clearance without referring the file through the management structure. The vetting manager was already aware of this issue. At the time of our inspection, the constabulary was providing the analysts with training to improve their understanding in this area.

In other respects, we found that decision-making in more recent cases has improved. Vetting decision-makers recorded thorough rationale, used the national decision model effectively and made reference to the vetting APP.

Vetting interviews

The constabulary told us vetting analysts regularly carry out interviews to clarify written responses in vetting applications. The interviews are usually held in person. Analysts keep a written record of the discussion and offer a copy of the notes to the applicant. This is in line with the vetting APP.

In our case file review, we found ten cases where an interview with the applicant wasn’t carried out but would have been beneficial. This would have helped decision‑makers to clarify details provided in the application. This might include the nature of previous police contacts, the extent of any contact with third parties of concern, or to explore potential financial risks. We identified this as an area for improvement in our national 2022 report, ‘An inspection of vetting, misconduct, and misogyny in the police service’.

Risk mitigation

The constabulary uses a range of risk mitigation measures in vetting clearance cases when adverse information has been shown. The FVU uses regular financial reviews as a risk mitigation measure when an applicant has undischarged debt or other financial difficulties. And it sometimes imposes a restriction on where somebody can be posted.

The FVU consults with the ACU prior to applying risk mitigation measures where there are third-party risks, such as notifiable associations. Police officers and staff who associate with, for example, criminals, private investigators or members of extremist groups must notify the force of the association so the force can manage any associated risks.

The FVU also has its own auditor. As part of the vetting process, the auditor checks for potential misuse of IT systems. This includes the constabulary’s intelligence and crime recording systems and mobile devices. The auditor then refers appropriate cases to PSD.

Hampshire and Isle of Wight Constabulary produces an annual counter-corruption strategic threat assessment (STA) outlining the threats facing the constabulary. FVU staff told us the ACU has provided them with a briefing pack to make them aware of the assessment and the threats described within it. The ACU has shared a copy of the STA with the vetting manager and an edited version with the vetting supervisors.

Vetting appeals

The constabulary has different processes for vetting appeals from external and internal candidates.

When an appeal is received, it is sent to the appeal officer. This is the ACU detective chief inspector unless they took part in the original vetting decision. In these cases, the head of PSD becomes the appeal officer. If the appeal is rejected, internal candidates only can submit a further appeal to the deputy chief constable.

Quality assurance

Hampshire and Isle of Wight Constabulary has a quality assurance process for vetting decision-making.

The ACU detective chief inspector dip samples decisions made by the vetting manager every month. They review three decisions where clearance has been given even though research identified adverse information. They review three cases where the candidate was refused vetting clearance but didn’t appeal the decision.

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.

At the time of our inspection the constabulary didn’t analyse the outcomes of vetting applications from people who declare one or more of the nine protected characteristics (age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation).

The constabulary has been collecting the data for all nine protected characteristics since March 2024, when its new vetting IT system was introduced. The constabulary told us there isn’t yet sufficient data to complete meaningful analysis. The constabulary agreed with us that the process hasn’t yet developed sufficiently for it to understand if any disproportionality exists in its vetting decisions.

Vetting file review

With a vetting specialist from another force, we reviewed 25 vetting clearance decisions from the 3 years preceding our inspection. These files related to police personnel who had previously committed criminal offences or the constabulary had other concerns about. The files included transferee and recruitment vetting decisions.

We agreed with 18 of the constabulary’s decisions. But in the remaining seven cases the recorded rationale didn’t consider all identified risks or relevant risk mitigations.

For example, there were three cases where the vetting analyst should have acknowledged a trace as adverse and referred it to a supervisor. These related to financial concerns and an earlier anti-corruption investigation. The clearance decision in those cases would then have been subject to further scrutiny. In another case, the final vetting decision focused on a financial risk but not a misconduct finding.

We also saw two examples of transferees being accepted after a chief officer overruled the vetting process. And a chief officer overturned a vetting refusal decision on appeal without sufficiently considering the risk posed by the individual.

The more recent cases we reviewed had improved recorded rationales. They included specific reference to the vetting APP and use of the national decision model.

Upholding the standards of professional behaviour

Hampshire and Isle of Wight 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 supervisory or managerial 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

Hampshire and Isle of Wight Constabulary uses a variety of methods to reinforce organisational learning and the standards of professional behaviour.

We found the constabulary provides initial training for the workforce on the expected standards of behaviour and provides extra training for supervisors.

Managers in the PSD and ACU provide training to new recruits, transferees, re-joiners and sergeants and inspectors at leadership courses. The constabulary also provides training on ethics and culture to sergeants and inspectors. The culture and legitimacy lead, a chief superintendent, presents at these sessions. They include material on decision-making and an ethical dilemma case study.

The constabulary has developed a mandatory training programme called Inclusion Matters. It has divided the programme into four sessions with the last session covering integrity, being an upstander not a bystander, privilege, challenging inappropriate behaviour, standards of professional behaviour and the Code of Ethics. At the time of our inspection, approximately 5,000 members of the workforce had attended the Inclusion Matters training, with approximately 1,000 still to complete it.

The PSD produces a quarterly ‘Reputation Matters’ newsletter that it circulates across the workforce to reinforce standards and share organisational learning. It includes the Independent Office for Police Conduct (IOPC) Learning the Lessons bulletins and the outcome of gross misconduct cases. The constabulary told us that there were 4,645 views of the online spring 2024 edition. The PSD also produces a hard copy and distributes it across the constabulary. The chief constable broadcasts video messages on the intranet highlighting specific details from notable cases.

The constabulary encourages personnel to submit ethical dilemmas to the ethics committee. The committee considers these to identify organisational improvement opportunities and promote integrity, impartiality, public service and transparency. The constabulary has created a Code of Ethics intranet page as a reference point for officers and staff. It also hosts online drop-in sessions led by the deputy chief constable and head of PSD.

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

At the time of our inspection, Hampshire and Isle of Wight Constabulary didn’t have a formal process to check that its workforce understands the expected standards of professional behaviour and related organisational learning.

The constabulary is beginning to try to establish whether the workforce understands this learning, for example, through questionnaires and focus groups.

Since 2022, the constabulary has been able to see how many views a PSD publication receives. It also considers some informal measures, such as general demand in the PSD and the number of reports made through its confidential reporting lines. But it doesn’t have a formal process to check that the workforce understands the expected standards of professional behaviour and related organisational learning.

Organisational learning

At the time of our inspection, Hampshire and Isle of Wight Constabulary’s processes for the collection and sharing of organisational learning were still being developed. There was no organisational learning board, but the organisational learning team reported to the deputy chief constable’s delivery board. The deputy chief constable has overall responsibility for organisational learning.

The constabulary intends to introduce an operational learning board in summer 2025 to improve how it collates, analyses, risk assesses and then shares organisational learning. It has appointed a chief superintendent to lead the project.

The PSD chief superintendent is responsible for collecting and sharing organisational learning originating from within the department. The role is separate from the organisational learning team. At the time of our inspection, they had been in post three months and the PSD had produced two organisational learning bulletins. The PSD holds debriefs following gross misconduct hearings to identify learning.

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

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 sufficient resources to the task, including appropriately trained and experienced personnel.

Governance and capacity in the professional standards department

A chief superintendent heads the PSD, reporting directly to the deputy chief constable, with a superintendent deputy. The complaints and misconduct team consists of a chief inspector and two inspectors. One inspector leads the complaints resolution unit, while the other leads three teams of PSD investigators. The complaints and misconduct team also has a police perpetrated domestic abuse team and a business support unit.

The constabulary logged a higher number of complaints and associated allegations than most similar forces and national averages. During the period April to June 2024, the constabulary logged 942 complaints. The most similar force average was 651 and the national average was 526. Similarly, it logged 150 complaints and 209 allegations per 1,000 employees. The most similar force average was 110 complaints and 185 allegations, with the national average being 89 complaints and 155 allegations.

PSD managers and members told us that, despite this demand, it was well resourced. They said it generally had the capacity to meet demand because the constabulary had invested in the PSD over the last few years.

The PSD had recently applied for an extra detective inspector post to lead the police perpetrated domestic abuse team. This post will provide additional resilience to the appropriate authorities where the progress of cases is delayed awaiting initial assessment and final determination decisions. The new post should also make sure appropriate authorities have capacity to review severity assessments as investigations progress.

Training and experience within the professional standards department

The PSD workforce has a good range of experience as the PSD recruits from the criminal investigation department and other specialist roles. However, we found that the level of training varied.

The constabulary told us it provides training and accreditation to PSD officers and staff. This includes the College of Policing’s accredited training and training from a barrister who is experienced in police misconduct regulations. All PSD police officer investigators are trained to at least professionalising investigations programme (PIP) level 1. The detective sergeants are all trained to PIP level 2.

The police staff investigators aren’t accredited to PIP standards. They have a basic level of investigative training and only manage misconduct and gross misconduct cases. The PSD investigation team passes any allegations of criminality by police officers and staff to investigators outside the PSD. This could lead to fragmented, inefficient, lengthier investigations, particularly for less complex criminal matters.

Members of the PSD investigation team told us that they aren’t as knowledgeable when dealing with cases involving police staff. They weren’t as familiar with police staff terms and conditions as they are with the Police (Conduct) Regulations 2020 and therefore required additional support for these investigations.

The police perpetrated domestic abuse team had a good level of training. Its five police officers were all trained to PIP level 2. We were told following our inspection that the team deals with all criminal matters relating to domestic abuse allegations, except rape. They also deal with all related conduct matters.

The PSD command team is experienced and trained to the appropriate level to effectively carry out its role. The ACU detective chief inspector and their deputy, a detective superintendent, are experienced PIP level 3 detectives.

The command team doesn’t take part in the PSD out-of-hours call rota, other than being informally available to provide telephone advice when needed. Instead,non‑PSD senior detectives trained to PIP level 3 receive death and serious injury training from the IOPC and PSD so they can carry out the role of initial investigating officer prior to the arrival of the IOPC senior investigating officer.

The on-call PSD role carries a great deal of responsibility given the potential impact on public and internal staff confidence. It requires capabilities in effectively managing and often directing senior internal and external stakeholders as well as frontline supervisors to very tight deadlines. We urge the constabulary to satisfy itself that the level and seniority of its formal out-of-hours PSD cover is enough.

PSD investigators told us the constabulary doesn’t provide formal structured Centurion training, which has a direct impact on their ability to use the system. Some members of the PSD workforce expressed frustration at the lack of training. We describe the problems this creates later in this report.

Experienced colleagues from the business support unit and complaints resolution unit train the personnel that join them. But some PSD personnel told us neither team has received any formal training in recognising, handling and investigating discrimination cases. This could limit their ability to comply with statutory requirements.

The PSD told us it has now developed a structured training package for future recruits to the units. The training includes the use of Centurion and control room log systems.

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 classified as 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 complaints 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 later 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.

Initial handling of public complaints

The constabulary receives public complaints through its website, contact centre, IOPC website, direct reports to officers or staff, the enquiry office, or the office of the police and crime commissioner.

The logging and initial handling of complaint and conduct cases in Hampshire and Isle of Wight Constabulary is, in most cases, compliant with IOPC statutory guidance.

The constabulary generally logs complaint matters in a timely way. During our case file review, we saw the PSD logged cases within one or two days. It contacted the complainant soon afterwards. This was supported by the IOPC Police Complaints Information Bulletin for the period April 2024 to June 2024. It showed the constabulary takes an average of one day to log complaints and an average of one day to make initial contact with the complainant.

However, the PSD wasn’t timely in notifying the complainant of its handling decision. In 7 of the 20 complaint cases we examined, the delay was more than 14 days. In two further cases, the delay was more than eight days. But initial letters to complainants were of a good standard.

The business support team logs and triages the case and then allocates it to the most appropriate team. It allocates most of the cases to the complaints resolution unit in the first instance. During our file review, we saw a small number of cases where this was clearly not appropriate. In one example, the complainant alleged an officer had broken his collar bone. In another, the complainant alleged that a bite by a police dog had resulted in a wound needing 33 stiches. In the third case, the complainant alleged an officer broke his arm while he was in custody. All three allegations should have been referred to the IOPC straight away.

The PSD did make appropriate IOPC referrals in the first two cases. The IOPC reallocated them to the PSD for investigation. There was a delay of 18 days before the PSD properly referred the broken collar bone case. The business support team didn’t record a rationale for why it allocated this case to the complaints resolution unit.

We found the custody-related case when dip sampling cases that had been service recovered. We brought this to the attention of the constabulary during our inspection. The constabulary is finalising more cases outside Schedule 3 by way of service recovery than most similar forces and the national average. During the period April to June 2024, it finalised 758 complaints (91 percent) outside Schedule 3. The average of the most similar force was 62 percent and the national average was 64 percent.

Initial handling of conduct matters

We found that the constabulary handled 19 out of 20 conduct cases appropriately.

In 12 of the 20 cases, the business support team recorded a handling decision and appropriate rationale within 2 days. During our case file review, we examined several severity assessments. They were of a high standard, thorough and with good rationale. In some cases, the PSD made the severity assessment and handling decision within the first two days. In relevant cases, it reviewed severity assessments as cases progressed.

We also found that the constabulary was recording some conduct cases as recordable conduct when they weren’t. This appeared to be because of a misunderstanding of the statutory guidance. This didn’t affect how the PSD dealt with and resolved the cases, but it doesn’t comply with the statutory guidance. We urge the constabulary to provide further training to personnel recording conduct matters.

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 characteristic.

As we noted earlier in this report, the six cases that required referral to the IOPC were all eventually referred.

We found allegations of police criminality in 7 of the 40 cases we examined. These included potential offences under the Misuse of Drugs Act 1971, the Computer Misuse Act 1990, and the Data Protection Act 2018. In four of the cases, the PSD identified the potential criminal offence and dealt with the cases appropriately. However, in three cases it didn’t identify the criminal aspect. These cases involved:

• an officer testing positive for controlled drugs;
• an officer sending misogynistic, homophobic, racist and other inappropriate messages on their mobile phone; and
• an allegation of assault, aggravated by an element of discrimination.

In the cases of the controlled drugs and the mobile phone comments, the officers resigned. Both were later dismissed at an accelerated misconduct hearing and placed on the barred list.

In some cases, it may be proportionate and justifiable to deal with a case as misconduct rather than as a crime. But the constabulary should document and record a clear rationale as to why it isn’t investigating the matter as a crime.

We found during our case file review that the constabulary didn’t have a standardised way of using Centurion to record and handle complaints and allegations. And it isn’t using the system to its full capability. We saw numerous examples where investigators were storing documents on shared computer drives away from Centurion. In some cases, we were unable to locate relevant documents that investigators had stored elsewhere. And we saw progress logs on Centurion that didn’t record the name of the person making the entry or the time of the entry.

In 2022, the constabulary commissioned a review from the Centurion service provider. In January 2023, the provider made 55 recommendations for how the constabulary could improve its use of the Centurion system. As part of our document review, we saw an internal email dated August 2024. It provided a very brief update on progress with the recommendations. It stated that the constabulary had implemented some recommendations, but it didn’t agree with others.

The email didn’t explain how the recommendations had been implemented. It wasn’t clear to us whether some recommendations had been implemented. We urge the constabulary to review the report and its recommendations considering our inspection findings.

The constabulary isn’t identifying all sexual misconduct and discrimination elements in the conduct and complaint cases it records. Of the 40 cases we examined, 6 had an element of alleged sexual misconduct or discrimination. The PSD correctly identified and recorded it on three occasions, but in one sexual misconduct case and two discrimination cases it didn’t.

Accessibility of the force 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.

We found the public complaints process on the constabulary’s website is accessible and user-friendly. It contains clear step-by-step guidance that explains:

• what can be complained about;
• how to make a complaint;
• what happens with that complaint; and
• what the complainant can do if they are dissatisfied with the outcome.

There are links throughout the website directing people to the correct sections.

Additionally, the PSD organisational learning officer has attended training days for the constabulary’s community engagement advisors. The officer shared how to make a complaint on behalf of harder-to-reach groups who may trust the police less.

The constabulary told us of other work with partner organisations, for example charities and community support groups, specifically around early identification of improper behaviour and how to report it. The public can share concerns through the constabulary’s Let’s Talk public survey. The constabulary is also using the survey to measure public understanding and satisfaction with the complaints process.

Sometimes complainants need extra support during the complaints process. For example, where they have a disability such as a visual impairment. We examined 20 complaint cases and found 2 where the complainant may have needed additional support. In one case, the complainant had a physical disability. In the other, there were mental health concerns, and the constabulary provided extra support. During our dip sampling of cases resolved through service recovery, we saw another case where the complainant needed additional support. The constabulary had provided it.

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

The standard of investigations

Investigations are an opportunity for forces 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 of 20 investigation cases, we saw a good standard of investigation in 19 of them. The investigating officer had prepared a final report or outcome letter of a high standard. They were thorough, well presented and included clear rationales. The appropriate authorities’ final determinations were thorough.

In addition, supervisory oversight was documented in most cases. Regular reviews by supervisors were evident in 5 of the 7 investigated complaint cases and 10 of the 14 conduct cases.

We found that the PSD had recorded terms of reference in most investigation cases. But they appeared to be a standard form of words. Terms of reference are important to set and maintain the direction, focus and limits of the investigation. They should be specific to each case.

We examined 14 conduct investigations. In all cases, investigators recorded their decisions and associated rationale. We also examined seven complaint investigations and found six had a record of the decisions made and rationale.

We saw no formal use of decision logs. We saw individual policy entries and individual decisions in various locations within some records on Centurion. We didn’t see a consistent way of recording decisions or the rationale for them.

There are clear opportunities for the constabulary to standardise the use of Centurion to help supervisors and auditors.

We found 10 of 14 conduct cases and all of 7 complaint cases had an investigation plan. The constabulary has developed an investigation plan template, but investigators rarely used this or Centurion’s investigation plan function. As a result, there was no consistency to how investigators were structuring or recording the plans. Some plans were merely a list of actions completed and those still outstanding.

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’. Hampshire and Isle of Wight constabulary has still not fully implemented this recommendation.

When the constabulary resolved complaint cases otherwise than by investigation, this approach was proportionate in many cases. However, we found that it was dealing with some of these cases as if they were an investigation, resulting in a thorough report. The constabulary is spending more time on these cases than is necessary.

We dip sampled five complaint cases where the constabulary had decided to take no further action. In each case it complied with statutory requirements and provided a detailed explanation to the complainant.

The deputy head of PSD told us they chair a monthly quality assurance meeting where misconduct and gross misconduct cases are dip sampled to make sure cases are of a high quality.

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. This includes personnel accused of wrongdoing, those who have made allegations, and those investigating.

Hampshire and Isle of Wight Constabulary considers the welfare of accused police personnel, those making internal conduct allegations and witnesses. In May 2024, the constabulary appointed approximately 20 welfare support officers from the workforce to support personnel being investigated for gross misconduct. The welfare support officers complete early risk assessments and identify what additional support is available internally and externally.

The police perpetrated domestic abuse team has a member of staff dedicated to supporting people making allegations and witnesses. And the deputy chief constable has met members of the workforce who have raised or challenged inappropriate behaviour to offer support and reassurance.

The constabulary has prepared a series of support and guidance documents for use in conduct and complaint investigations.

There is a victims and witnesses charter for use in misconduct investigations. The two-page document sets out the minimum standards that victims and witnesses in misconduct investigations can expect from the PSD, Police Federation and UNISON. It includes the provision of welfare support and services that meets individuals’ needs.

The constabulary has created comprehensive victim and witness information packs. These describe the complaint or misconduct investigation process for members of the public or workforce.

There are guidance documents for senior managers, personnel in welfare support roles and personnel facing investigation. The documents include a flowchart, a checklist and a questionnaire to help discussion with a person under investigation, as well as a welfare support agreement.

There is also a duty of care risk assessment. This document and action plan is used in criminal and gross misconduct cases and where the constabulary has suspended an individual.

Some personnel told us that the constabulary provides a limited level of welfare support. They said more support appeared to be available for those making allegations than the accused. Others told us the constabulary supports them. This included an officer who received a good level of welfare support while their partner faced gross misconduct proceedings.

We were told that if the PSD doesn’t attend in person, it orders arrested officers leaving custody to attend a police station at an appointed time to be served with misconduct papers. Some personnel expressed concern at the lack of care afforded to these officers at a time they would be understandably vulnerable. It isn’t clear what the officer’s status is, whether they are suspended or on restricted duties, or what misconduct process they are likely to face. Some personnel felt this situation occurred because out-of-hours custody releases were inconvenient to the PSD. The PSD told us that it is aware of this happening on one occasion and that this practice has now ceased.

The PSD also provides welfare support to its own officers and staff. PSD personnel told us the work was relentless and the PSD senior leadership team acknowledge that it is a tough role. To address this, PSD managers arrange development days away from the workplace and supervisors hold welfare meetings with personnel.

Suspension and restriction of members of the workforce

Hampshire and Isle of Wight Constabulary doesn’t have a suspension and redeployment policy. The force may wish to consider developing one.

We found that the constabulary considered suspending or redeploying the accused person in 13 of the 15 cases we examined where it was appropriate. At the time of our inspection, the constabulary told us there were 14 members of its workforce suspended. The deputy chief constable reviews all suspensions every 28 days.

The constabulary uses accelerated procedures where appropriate. In the year up to our inspection, the constabulary carried out nine accelerated 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.

Hampshire and Isle of Wight Constabulary provided a good level of service to most complainants. We concluded that in 18 of the 20 complaint cases we examined the complainant received a good standard of service. Investigators provided timely and meaningful updates in all seven of the investigated cases we examined. And we found outcome letters to complainants were comprehensive with good rationales.

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 Hampshire and Isle of Wight Constabulary had investigated. It found that four cases had an outcome that wasn’t reasonable and proportionate.

During the same period, the IOPC carried out 47 reviews of complaint cases the constabulary had concluded otherwise than by investigation. It found that 18 cases had an outcome that wasn’t reasonable and proportionate.

The office of the police and crime commissioner finalised 126 reviews during that same period. It found that the outcome wasn’t reasonable and proportionate in 18 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 with others; and
• whether the constabulary considered such information when making decisions about complaint and conduct matters.

The recording and sharing of adverse information

Hampshire and Isle of Wight Constabulary regularly shares relevant information between departments and has established processes for doing so. We found the PSD works with HR, vetting and the anti-corruption unit when dealing with complaint and conduct matters.

The constabulary shares relevant information through the monthly strategic people intelligence board. The head of PSD chairs the meeting. The deputy head of PSD, the director of people and development, the CCU, the constabulary solicitor, vetting personnel and the head of people services attend.

In addition, the head of PSD chairs a daily management meeting. Representatives from across the PSD attend, as well as the vetting manager and corporate communications. The meeting has a fixed agenda to make sure that attendees share relevant information, and matters are prioritised and correctly resourced.

The constabulary has effective processes in place to make sure potential misconduct in civil claim cases, grievances and employment tribunals is identified and referred to the PSD.

The consideration of relevant information

Members of the PSD told us that when they receive a new complaint or conduct matter, they make checks on the accused’s previous conduct and complaint history. This is important to determine patterns of behaviour and make sure they deal with the case in the most appropriate manner.

However, we didn’t find any evidence the PSD had researched the history of the accused person in 35 of the 40 conduct and complaint cases we reviewed. We strongly urge the constabulary to carry out these checks and record that it has done so on Centurion.

Holding police officers and staff accountable for their behaviour

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.

In PSD complaint and conduct investigations, the constabulary’s decision-making is proportionate, consistent and fair. We found no evidence of disproportionality.

The constabulary has processes in place to review the fairness, consistency and proportionality of approach in PSD decision-making. The business support team and appropriate authority make most of the initial assessments of complaint cases. They share these assessments with the PSD senior management team to make sure the constabulary has a consistent approach.

In addition, the PSD chief inspector reviews severity assessments at a twice-weekly meeting. The PSD superintendent carries out a 28-day review of all gross misconduct cases. And the head of PSD makes the final determinations in gross misconduct cases.

During our reality testing, we spoke with individual personnel. Most stated they didn’t see any disparity or unfairness in PSD decisions and case outcomes.

However, we found that the constabulary doesn’t carry out any formal analysis of PSD investigations and decision-making to establish if there is disproportionality across the nine protected characteristics. To fully understand whether disproportionality exists, the reasons for it and take action to address it, the constabulary should carry out a detailed analysis of disproportionality.

Tackling potential corruption

Hampshire and Isle of Wight Constabulary is adequate at tackling potential corruption and protecting the information it holds.

Protecting the information the force 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 force to create alerts which immediately tell investigating officers when a specific file has been accessed or printed.

Most forces 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 force. The force 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

Hampshire and Isle of Wight Constabulary can monitor all its IT systems across mobile and desktop devices to identify data breaches, protect the constabulary’s data and identify computer misuse. The ACU has a dedicated IT auditor. The auditor has identified the key processes required to effectively audit the access of data across all the constabulary’s IT systems. The IT auditor makes sure that all ACU staff can use these processes during their investigations.

The ACU proactively monitors activity on mobile and desktop devices. This helps identify potential misconduct including improper contact with vulnerable victims. We saw evidence that the ACU monitors the IT use of police personnel who are the subject of corruption intelligence.

The ACU proactively monitors personnel who intelligence has shown may pose a higher risk. The ACU identifies the personnel through analysis of intelligence reports, information from public complaints and misconduct reports. A dedicated ACU ‘protect’ officer maintains a comprehensive register of all personnel who may present a corruption risk. ACU personnel record what action they take to manage and mitigate these risks.

ACUs and IT departments should meet regularly to make sure that the ACU can monitor and audit any new IT systems and software.

Hampshire and Isle of Wight Constabulary ACU is involved in the procurement of any new IT systems. A senior business partner from the IT department works with the ACU. The constabulary has identified what it needs to effectively monitor, audit and investigate the use of its IT systems. The IT department takes this into account when developing or procuring new software.

IT monitoring policy

The constabulary has a lawful business monitoring policy for monitoring and recording the workforce’s communications. The policy allows the ACU 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 constabulary owned handheld and other mobile systems.

Digital device management

Management of digital devices is important when protecting information. It is essential that forces have right 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.

The constabulary can identify which members of the workforce are accessing different IT systems. A register identifying all mobile devices and to whom they are issued is kept by the IT department. ACU staff have access to this register. We found that this register was accurate. It identified the current user of every mobile device.

In addition, police personnel must use their own unique log-in details to access the constabulary’s IT systems. During our anti-corruption file review we found that ACU investigators could 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.

Hampshire and Isle of Wight Constabulary doesn’t allow the use of encrypted apps on its devices unless it has been specifically authorised. It is restricted to certain roles and routinely monitored by supervisors.

The constabulary has a comprehensive social media policy and detailed guidance. This has been circulated to the workforce. It explains that police personnel can use the constabulary’s social media accounts to communicate with the public, but they must use them professionally and securely. The corporate communications team must approve all new accounts and oversees how personnel use social media.

The PSD and the ACU provide training and guidance to the workforce about the risks associated with social media use. Personnel that we spoke to had a good awareness of the constabulary’s expectations of them on the use of social media and encrypted apps.

Tackling potential corruption

Intelligence

Sources of corruption-related intelligence

Hampshire and Isle of Wight Constabulary actively and routinely looks for corruption‑related intelligence. The ACU has a dedicated ‘prevent officer’ who carries out this work using a variety of methods and system audits. But the constabulary told us that the increase in reports of corruption and the improved capability to develop them have reduced the ACU’s capacity to proactively look for intelligence. For example, when the prevent officer is on annual leave, other ACU personnel might not have sufficient capacity to do this work.

The constabulary uses its confidential reporting line, ’confide in us’, and the national Crimestoppers integrity line. The constabulary told us that between January 2021 and December 2021, it received 294 reports through its own reporting line. In 2022 it received 226 reports and in 2023 it received 312. From 1 January 2024 up to the date of our inspection, 23 September 2024, it received 203 reports.

We examined 60 corruption intelligence files. We found police personnel directly reported corruption intelligence to the ACU in 18 of these cases. A member of the public had made a report in seven cases. We found two further cases that were the result of proactive intelligence work. Further sources of corruption-related intelligence included the FVU, external agencies, self-referrals 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 Hampshire and Isle of Wight Constabulary correctly categorises all corruption-related intelligence in line with the counter-corruption 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.

Hampshire and Isle of Wight Constabulary has produced a comprehensive counter‑corruption STA. It identifies the constabulary’s main corruption risks. These‑include violence against women and girls and police perpetrated domestic abuse, sexual misconduct (including APSP), theft and fraud, and controlled drug use and supply.

The constabulary publishes an edited version of the STA on its intranet. It uses posters to raise awareness across the workforce of the current corruption threats.

Counter-corruption control strategy

The constabulary has produced a counter-corruption control strategy. The control strategy priorities mirror those identified in the STA.

The constabulary uses the 4P approach (prevent, pursue, protect and prepare) to address the threats. It has identified a list of tactical options to counter the identified threats. The control strategy doesn’t identify who has responsibility for each of these actions. This means there may be a lack of accountability for completion of this work.

Implementation plan

Each corruption threat identified in the STA and control strategy should be considered in detail and action taken to address it within set timescales through an implementation plan. But the constabulary doesn’t have a current implementation plan. The constabulary told us the ACU was waiting for the draft STA and control strategy to receive final approval from the deputy chief constable before writing its implementation plan.

Once the STA and control strategy are approved, the constabulary should write the implementation plan without delay.

Exchanging information on people who may be a concern

Forces may hold people intelligence meetings to help identify officers and staff who may pose a corruption threat. Representatives from different parts of the force attend the meetings 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.

Hampshire and Isle of Wight Constabulary has an established process to identify police officers and staff who may pose a corruption risk. The constabulary holds a strategic people intelligence board meeting every month. The attendees include personnel from a wide range of departments.

When an individual is identified as a corruption risk, the constabulary considers referring them to the strategic people intelligence board. Using all the available data, the ACU researcher writes a report on the potential risk members of the workforce pose. The attendees at the meeting discuss each case, then agree a risk mitigation plan. ACU personnel are responsible for implementing the plan and keeping written records of the action they take.

Attendees at the PSD daily tasking meeting discuss complaint and conduct matters that have been reported in the previous 24 hours. There is a fixed agenda, which includes an update of previous actions. The head of PSD, head of ACU and the vetting manager attend this meeting.

Partnership working to identify potential corruption

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

At the time of our inspection, the prevent officer had provided several presentations about abuse of position for a sexual purpose (APSP) to a range of external organisations. These included domestic abuse support agencies, several safeguarding teams, St John Ambulance and staff from Winchester University. The presentations are designed to help staff understand the warning signs of APSP and report corruption-related intelligence to the ACU.

The constabulary has a clear plan to provide these training presentations to other external bodies. We are pleased to see the constabulary has invested in such an important role in the ACU.

Managing corruption threats

Intelligence development

We reviewed 60 corruption intelligence files. In 57 cases, the ACU responded effectively and used a variety of techniques to develop the intelligence. But we found the constabulary had missed opportunities to develop intelligence and mitigate corruption risks in three cases. These cases included two allegations of sexual misconduct and one report relating to an inappropriate association.

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

Although only two of the cases we reviewed resulted from proactive intelligence collection, the ACU makes good use of proactive IT monitoring.

Corruption investigations

Of the 60 corruption intelligence files we reviewed, 18 resulted in an anti-corruption investigation. We found the standard of investigation was good in all 18 cases. However, we found two cases which had been waiting for the appropriate authority to make a final decision since April and May 2024 respectively. This is too long.

In contrast to the PSD’s complaint and conduct investigations, every case had a meaningful investigation plan endorsed by a supervisor. Investigators followed the plan and concluded all reasonable lines of enquiry before the investigation was finalised. In every case, a supervisor checked the investigation was complete and endorsed it.

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. ACUs 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.

The ACU maintains two risk registers to help manage officers and staff who may pose a corruption risk. One risk register relates to people who may pose a sexual misconduct risk. The other risk register relates to people who may pose other risks, including financial vulnerability and alcohol misuse/dependency. The ACU identifies these people through intelligence reports, analytical work, reports of misconduct and information from public complaints.

ACU personnel research all known intelligence and previous reports on people on the registers. They then carry out a risk assessment to categorise the level of risk posed. The constabulary records any action it takes to investigate or mitigate the risks.

During our inspection, we found the ACU dealt with most sexual misconduct-related intelligence effectively using its risk matrix. However, we found four sexual misconduct-related cases that hadn’t been subject to this process. Using a risk matrix in these cases was a recommendation in our national 2022 report, ‘An inspection of vetting, misconduct, and misogyny in the police service’.

In the weeks before our inspection, the ACU recruited a dedicated ‘protect officer’ to manage its risk matrices more effectively. This is encouraging. The constabulary should review the way that it identifies this type of intelligence to further improve the management of its sexual misconduct register. This is to make sure that the ACU protect officer is notified of all individuals who come to notice for any sexual‑related matters.

Capacity and capability to investigate corruption

The ACU is a small team of experienced intelligence officers, investigators, a prevent officer, a protect officer, a systems auditor, an analyst and a researcher. All the ACU investigators have completed the College of Policing silver or bronze counter‑corruption course. ACU personnel have a range of experience and skills. Their experience includes protecting vulnerable people, serious and organised crime investigation, financial intelligence and digital media training. The unit investigates all cases of corruption.

ACU staffing levels mostly meet current demand. However, the constabulary recognises workloads are increasing. It told us it intends to increase the ACU’s investigative capacity by two posts.

Specialist resources

ACU officers and staff, including the senior management team, are experienced in covert law enforcement. The ACU 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 organisation from corruption.

The counter-corruption (prevention) APP sets out what policies forces should have and gives guidance on their content. Our inspectors examine policies in:

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

Notifiable associations policies cover how the force 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 force allows or forbids officers and staff to have other jobs, interests or activities. Policies should explain how the force 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.

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

Notifiable associations

The constabulary has an effective process to manage notifiable associations. There is a dedicated member of ACU staff who maintains a register and records the type of association, frequency of contact and level of criminality. The ACU uses a matrix to grade the association based on the perceived level of risk. It refers all medium and high-risk cases to the vetting unit. ACU supervisors oversee them. The ACU audits IT systems in all cases to identify any misuse. Local line managers are responsible for monitoring compliance with any conditions attached to the association. The notifiable association system highlights when reviews are due, which is every 12 months.

From 1 January 2022 and 31 December 2022, the ACU received 130 notifiable association reports. In 2023, it received 167. Between 1 January 2024 and the date of our inspection 23 September 2024, it had received 133.

Business interests

The constabulary has an effective process to manage business interests. A dedicated member of the ACU maintains a business interests register on Centurion. The workforce can submit business interest applications to ACU using an online form. ACU will only consider applications if the officer or staff member has:

• a current performance development review;
• no misconduct issues;
• satisfactory attendance; and
• approval from their line manager and departmental head.

The ACU risk assesses the types of business interests but doesn’t grade them. ACU managers review all cases before authorising them, with or without conditions. In the 24 months preceding the inspection, the ACU had refused 16 business interest applications. This was due to the applicant’s sickness absence or performance record. Personnel periodically check that the officer or staff member is complying with the refusal decision and records it on Centurion.

Local line managers are responsible for monitoring compliance with any conditions imposed.

The business interests policy requires officers and staff to declare voluntary work.

At the time of our inspection, the constabulary had 274 current business interests approved. The ACU reviews them every 12 months.

Gifts and hospitality

The constabulary has an effective process to manage gifts and hospitality.

The workforce must submit notifications about gifts and hospitality offered through an online form to the PSD, which keeps a record. Police personnel must ask for approval from their line manager and departmental head to keep the gift or accept the hospitality. The head of PSD makes the final decision. The constabulary publishes its gifts and hospitality records online.

Sexual misconduct

The constabulary recognises abuse of position for a sexual purpose (APSP) as serious corruption. In the counter-corruption STA and control strategy, the constabulary lists APSP as one of the main threats it faces. We found the ACU records such cases correctly. It consistently refers them to the IOPC.

Of the 60 ACU corruption intelligence files we reviewed, 11 related to APSP. We found 10 of these cases had been handled effectively. The other case was an allegation that a member of staff was in a sexual relationship with a member of the public who they had met while attending an incident at their home. There were several reasonable lines of enquiry which the ACU investigator hadn’t completed. For example, the force didn’t carry out a full IT systems audit or review other incidents attended by the individual.

The constabulary told us that the ACU and PSD routinely provide training sessions to officers and staff across the constabulary. The training has a specific section relating to APSP and includes the warning signs to look for. We found a good knowledge of APSP across the workforce.

The constabulary uses the College Learn APSP training package provided by the College of Policing. The constabulary made this training mandatory. It told us that, at the time of our inspection, 80 percent of all police personnel had completed it. This means one in five members of the workforce haven’t completed the training. We urge the constabulary to address this issue.

Hampshire and Isle of Wight 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 Hampshire and Isle of Wight Constabulary