A report into the effectiveness of integrity arrangements in Lincolnshire Police
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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. 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 Lincolnshire Police’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 | Requires improvement |
Tackling potential corruption | Requires improvement |
We set out our detailed findings about things the force 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
Lincolnshire Police is adequate at vetting its police officers and staff.
Area for improvement
The force should improve its vetting arrangements
The force should make sure that when adverse information has been identified during the vetting process:
- all vetting decisions (refusals, clearances and appeals) are supported with a sufficiently detailed written rationale; and
- the force vetting unit creates and implements effective risk mitigation strategies, with clearly defined responsibilities and robust oversight.
These were recommendations in our 2022 national report ‘An inspection of vetting, misconduct and misogyny in the police service’. The force still hasn’t implemented them.
When the force refused vetting clearance, it recorded thorough rationale. It used the national decision model (NDM) effectively and made reference to vetting authorised professional practice (APP). But where the force vetting unit granted vetting clearance in cases when adverse information had been identified, it made less reference to the APP. It didn’t make effective use of the NDM nor consistently use risk mitigation measures.
More specific reference to the vetting APP and the NDM would help the force demonstrate it had considered all identified risks and prompt the force to apply risk mitigation measures.
Also, the anti-corruption unit doesn’t have the capacity to implement some risk mitigation measures. This poses a potential risk for the force.
During our case file review, we found three cases where the recorded rationale didn’t consider all identified risks or relevant risk mitigations.
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 October 2022. The HR department uses a separate IT system. The HR department provides the FVU with information about workforce changes to overcome the lack of system integration. This helps the force keep track of internal moves, promotions and people leaving the force. The FVU and HR can access some elements of the other’s IT system. The FVU has a member of staff responsible for administration and receiving all notifications from HR.
The FVU uses the vetting system to make sure all police personnel have the correct level of vetting for their role. It uses information collated from its IT system to track vetting renewals in advance, so the force sends documentation to people before a renewal is due.
Any records with adverse information added to the vetting IT system since November 2022 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
Lincolnshire Police told us that as of 3 June 2024, it had a total of 2,402 police officers, special constables, police staff and police community support officers.
The force told us that all personnel had the correct level of vetting for their role and that it had maintained this position for the last six months. There were two members of the workforce with expired vetting, but both these were on long-term sick leave. The force has a process to make sure their vetting is prioritised when they return to work.
Demand and workload
The FVU is adequately staffed. The force has recently increased the staffing levels by two vetting officers and one supervisor. It now has four full-time equivalent vetting officers, a vetting supervisor, a vetting administrator and a part-time vetting manager.
The FVU manages renewals on the vetting IT system. At the time of our inspection, the force told us it had 20 vetting applications waiting to be processed.
The FVU and HR work together effectively to predict demand. This includes monitoring the progress of all recruitment and promotion processes and new vetting applications. Previously the force ran recruitment campaigns for all posts twice a year, which put pressure on the FVU. To address this, the force has adopted a staggered approach and now runs recruitment processes throughout the year.
The force vetting manager maintains a record of the predicted number of police officer recruits 18 months in advance. This means the FVU can consider this recruitment information alongside vetting renewal data to manage demand effectively.
Lincolnshire Police grants non-police personnel vetting (NPPV) clearance to contractors. The FVU has granted this clearance to 1,399 people. At the time of our inspection, the FVU told us they all had current vetting. 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 are linked to NPPV clearances. If vetting expires, the card is no longer usable. If vetting is removed, the vetting manager arranges for the access card to be cancelled. The FVU tells the IT department to cancel access to IT systems if vetting expires or is removed.
The force uses the national contractor vetting service hosted by Warwickshire Police to vet some non-police personnel. The clearances for these NPPV posts are overseen by the Lincolnshire Police department to which each person is contracted. These NPPV cases aren’t monitored by the FVU. The FVU should assure itself that it has sufficient oversight of those NPPV cases.
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 force told us it has designated 724 posts and maintains a list of them. There are 819 people in these posts. When HR creates a new role, the vetting manager determines if MV is necessary. The force last reviewed its designated posts list in 2023.
Generally, the force doesn’t allow individuals to take up a designated post before it grants MV clearance. The FVU prioritises MV applications to make sure that designated posts can be filled without delay. The force 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.
Lincolnshire Police 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 force won’t accept a transferee with a live PSD case. Where the force refuses vetting for a transferee, it informs the home force outlining the reason for the refusal.
Where an officer aiming to transfer from Lincolnshire Police fails vetting in the force to which they are applying, the FVU examines the reason for refusal. The force considers implementing risk mitigation measures or removing the individual’s vetting clearance if necessary.
Change of circumstances
The force has taken 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 force publishes a reminder of this in the PSD newsletter that it produces every three months.
However, the role of the FVU and the requirement to report changes in circumstances aren’t included in any of the training provided by the PSD or anti-corruption unit (ACU). There is an opportunity for the force to use this training to increase the workforce’s understanding of vetting procedures.
In September 2023, the force required all its police personnel to complete an annual integrity health check. As a result of this, the FVU received 257 change of circumstances notifications.
When members of the workforce report changes of circumstances to the FVU, it carries out vetting enquiries to identify risks and to decide if the person’s vetting status is affected.
Misconduct vetting review
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
Force vetting officers carry out all the relevant checks and make vetting decisions using a decision-making template. They record the rationale for their decisions and can give vetting clearance to people with adverse information. The vetting supervisor has their own caseload but will assist the force vetting officers with difficult cases.
During our inspection, we found that when the FVU refused clearance, it recorded thorough rationale. It used the national decision model (NDM) effectively and made reference to the vetting APP.
But where the FVU granted vetting clearance in cases when adverse information had been identified, it made less reference to the APP. There was also no evidence it had used the NDM. Better use of this model and the APP would assist vetting decision‑makers to write more structured rationales.
Vetting interviews
Force vetting officers regularly carry out interviews to clarify written responses in vetting applications. These can be in person or on the telephone. 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
Lincolnshire Police doesn’t consistently use risk mitigation measures in vetting clearance cases when adverse information has been identified. The force sometimes imposes a restriction on where somebody can be posted. But this is confined to personnel who are already serving when the force becomes aware of new adverse information. The force told us that this isn’t a particularly effective risk mitigation measure due to the size of the force and number of officers. So it chooses not to use posting restrictions and instead refuses clearance.
The FVU uses risk mitigation measures when an applicant for vetting clearance has undischarged debt or other financial difficulties. It makes sure this is aligned to the applicant’s probationary period where appropriate and reviews it every three to six months.
The FVU checks information with other departments prior to applying risk mitigation measures where there are third-party risks such as notifiable associations. However, we were told the ACU doesn’t have the capacity to implement some risk mitigation measures. This poses a potential risk to the force.
Lincolnshire Police produces an annual counter-corruption strategic threat assessment (STA) outlining the current threats facing the force. FVU staff told us they weren’t aware of the assessment, or the threats contained within it. The ACU hasn’t shared the STA with them. This is contrary to the vetting APP. The ACU should make sure vetting decision-makers know the main corruption threats facing the force.
Vetting appeals
The FVU manages vetting appeals from both external and internal candidates. The vetting manager is the appeals officer in all cases unless they had prior involvement in the initial decision.
Quality assurance
Lincolnshire Police has a quality assurance process for vetting decision-making. The vetting manager and the head of the information management unit carry out a review of all cases where vetting has been rejected. The force quality assures these vetting decisions a month after the decision. We consider this a sensible approach because it allows for the vetting appeal period.
The force also dip samples 10 percent, or 5 cases if that is greater, of vetting clearances with adverse information. But if the quality assurance process raises any doubts about the individual’s suitability, they may have already started working for the force. The force should make sure it dip samples these decisions before the appointment. This will allow the vetting manager to ratify or overturn clearance decisions and implement additional risk mitigation measures if necessary.
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 force analyses the outcomes of all 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 vetting manager produces this data every quarter for the force’s legitimacy board. The force reported that it hadn’t found any evidence of disproportionality in its vetting decisions.
Vetting file review
With a vetting specialist from another force, we reviewed 31 vetting clearance decisions from the 3 years preceding our inspection. These files related to police personnel who had previously committed criminal offences or the force had other concerns about. The files included transferee and recruitment vetting decisions.
We agreed with most of the force’s decisions. But in three cases the recorded rationale didn’t consider all identified risks or relevant risk mitigations. For example, there were cases where the force should have considered risks posed by third parties, such as an applicant’s father with serious criminal convictions. We also found an example where the applicant had left out significant information from a vetting form, but the FVU didn’t question this.
The recorded rationales would benefit from more specific reference to the vetting APP and the NDM. This would help the force to account for all identified risks and prompt it to implement risk mitigation measures.
Upholding the standards of professional behaviour
Lincolnshire Police requires improvement at upholding the standards of professional behaviour and addressing potential breaches.
Promoting the standards of professional behaviour and integrating organisational learning within the workforce
Area for improvement
The force needs to improve its processes for the collection, sharing and evaluation of organisational learning relating to the standards of professional behaviour
The force doesn’t have a clear process to collect and share organisational learning. The deputy chief constable has oversight of organisational learning, but there is no associated governance structure.
The professional standards department (PSD) produces a quarterly report to identify patterns and trends in public complaints. But this data doesn’t include those complaints resolved outside the PSD. And PSD investigators rarely record learning from cases. This means force is missing opportunities to identify and act on trends, address concerns and make improvements.
We identified organisational learning as an area for improvement in our report ‘Police effectiveness, efficiency and legitimacy 2018/19: an inspection of Lincolnshire Police’ published in February 2020. It is disappointing to see that the force still hasn’t addressed this.
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 inconsistency in the training the PSD provides to different policing areas, departments and ranks across the force. We found the force provides training for new officers on the Code of Ethics and expected standards of professional behaviour. It doesn’t provide the training to new members of police staff. Instead, line managers are responsible for making sure new staff complete the College of Policing’s online training.
The force offers leadership sessions for all new supervisors. This reinforces the expected standards of professional behaviour. But there is no routine training provided to officers and staff other than in these circumstances, unless they are seeking a specialist role where bespoke training may be provided.
PSD training doesn’t include guidance about vetting. This is a missed opportunity for the force.
The force takes steps to improve the workforce’s awareness of the expected standards of professional behaviour by circulating the internal publication ‘The Standard’ online and in print. This includes lessons from PSD investigations, learning from the Independent Office for Police Conduct (IOPC) bulletin and updates on legislation. Most people we spoke to were aware of ‘The Standard’ and spoke positively about it.
We were told that the PSD used to hold regular events across the force and offer opportunities for “drop-in chats and myth-busting”. We were told they were interesting and informative, but no longer take place. The chief constable’s roadshows include a session on force culture.
The force publicises the outcome of police officers’ gross misconduct hearings on its intranet and external websites. Chief officers produce internal videos to discuss the outcomes. A recent example included the chief constable explaining a case involving the misuse of social media, where he read out the inappropriate messages.
The force has also agreed with trade union Unison that it will publish the outcomes of police staff disciplinary processes with the individuals’ anonymity protected. The PSD asks staff associations for advice on the best way to communicate the results of complaint and conduct investigations.
The workforce’s understanding of the expected standards of professional behaviour
Lincolnshire Police provides PSD training to various groups in the workforce, although there is no central record of who has completed it. The force also doesn’t have any formal mechanisms in place to evaluate how well its workforce understands standards of professional behaviour. The force checks understanding through some recruitment processes, such as promotion boards. And the PSD says it uses informal indicators such as calls for advice and increases in referrals following specific campaigns to gauge effectiveness.
Police officers and staff we spoke to had an inconsistent understanding of the standards of professional behaviour. They reported receiving different levels of training. The workforce felt the PSD lacked visibility. Despite this, most police officers and staff we spoke to felt confident to approach the PSD and report breaches of standards. They can do this directly, or by emails, phone calls and confidential reporting lines.
The force has created a voluntary cultural advocate role. Police personnel can ask for advice from the advocates or approach them to report suspected wrongdoing to the PSD on their behalf. The PSD may also send cultural advocates to areas where there are perceived problems. This includes where people feel under-valued or supervisors are failing to address poor behaviour. We heard limited evidence of the use of the cultural advocates.
Organisational learning
Lincolnshire Police doesn’t have an effective process for collecting and sharing organisational learning. The deputy chief constable oversees organisational learning, but there is no associated governance structure.
The PSD occasionally shares learning from individual cases with the workforce. Recent examples include advice on the use of social media and body-worn video. The PSD has a form where investigators can record learning from their cases, but they rarely use it.
The office manager produces a quarterly report on public complaints for the head of PSD to identify patterns and trends. This informs organisational learning. The complaints are broken down by category and geographic location. The force compiles the report using data from its complaint and conduct IT system Centurion. This data is incomplete as it doesn’t include complaints resolved through service recovery by the force control room or on local policing areas. This means the force is missing opportunities to identify and act on trends in complaints and conduct matters to address concerns and make improvements.
Handling and investigating public complaints, conduct matters and other potential breaches of the standards of professional behaviour
Area for improvement
The force needs to improve the way it responds to complaints and conduct allegations
This is in respect of the force’s:
- initial handling of complaints and conduct allegations;
- management of the investigation of complaints and conduct allegations; and
- service to complainants.
The force’s initial handling of complaints and conduct matters doesn’t always comply with statutory guidance. The professional standards department (PSD) doesn’t dip sample cases resolved through service recovery by the force control room or local area inspectors to make sure they have been handled in accordance with the Independent Office for Police Conduct statutory guidance.
We found in all the complaint cases we reviewed where service recovery wasn’t appropriate, complaint handlers completed a pro forma document with the details. They sent this to an appropriate authority to make an initial decision on how to handle the complaint. The PSD then recorded the complaint on its IT system Centurion. This delay in recording complaints doesn’t comply with statutory guidance. There was a similar delay for recordable conduct matters.
In the 39 complaint and conduct cases we reviewed, we found 11 cases that should have been referred to the Independent Office for Police Conduct. The PSD had referred eight of them.
The force’s investigation of complaints and conduct allegations is mostly thorough and proportionate. But it should improve the management of its investigations. Overall, we found a lack of auditable decision-making and a lack of supervisory oversight. Terms of reference were present in only half of the 20 investigated cases we examined. And only one case had an investigation plan. We saw little evidence of how, and to what extent, PSD supervisors provide direction to investigators on how to manage cases.
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 force still hasn’t implemented this.
The PSD also doesn’t have a consistent approach for recording progress of investigations on Centurion, which would help it manage these cases.
The service the force provides to complainants doesn’t always comply with statutory requirements. We saw no evidence that the force provides regular, meaningful updates to public complainants or other interested persons, for example the person making the allegation or witnesses. Letters to complainants lacked sufficient explanation of, or rationale for, the way the force had decided to handle the complaint.
We dip sampled an additional three cases where the PSD had investigated a complaint and found that in each case the investigation team hadn’t sent the complainant an outcome letter or informed them of their right to a review.
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. Forces must make sure their workforce acts ethically and lawfully. And, if the force finds any problems with behavioural standards, it must show that it acts quickly and appropriately to address them. The force 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
We found there were effective governance structures and processes in place in Lincolnshire Police’s PSD. The deputy chief constable is the appropriate authority and has governance of the PSD. There is a scheme of delegation which clearly sets out by whom and at what level individual decisions must be made. The force recently trained two inspectors and a member of police staff to be delegated appropriate authorities. This was done to support the detective chief inspector to carry out initial severity assessments in a more timely manner. Generally, members of the PSD we spoke to felt that the structure of the department is fit for purpose.
The PSD recently secured additional funding and appointed two new investigators. All PSD investigators felt there was sufficient capacity in the department and their workload was manageable. This is partly because local area inspectors deal with low‑level complaint and conduct matters. And complaints the control room resolves through service recovery aren’t part of their workload.
At the time of our inspection, PSD investigators were holding less than 10 cases each, except for the meetings and hearings officer who had 12. Many of these cases weren’t complex and some were paused awaiting the outcome of criminal proceedings.
Training and experience in the professional standards department
The PSD is an experienced crime-focused team with a mix of backgrounds and additional skill sets. The low turnover in the department means that many case investigators have at least two years’ experience in their role. The force has recruited officers who are already trained to professionalising investigations programme level 2 to the department. The force wants all PSD police staff to be trained to this level as well. All investigators and appropriate authorities have completed the one-week College of Policing-endorsed PSD training. The complaints resolution team also reported having specific training from the IOPC to understand recent changes to the Police (Conduct) Regulations 2020.
The induction training for PSD recruits is limited and there is no routine continuing professional development. However, in 2023 the PSD office manager carried out a training needs analysis for all members of the department. This has made sure all investigators and staff have completed the mandatory training required for their role. It has also resulted in some bespoke training provided by the learning and development team, for example on disclosure.
The force doesn’t provide the PSD with formal Centurion training. The Centurion service provider recently reviewed the way the PSD used the system and recommended that the force arrange such training. Inconsistent use of Centurion prevents effective oversight and makes it difficult to audit cases.
The PSD doesn’t oversee complaints that come into the control room. Nor does it oversee complaint or conduct investigations into police staff. The local area inspectors, appointed by HR, may not have the knowledge and experience to effectively investigate complaints or allegations of misconduct. For example, PSD investigators are trained to recognise and investigate allegations that contain an element of discrimination. Local area inspectors and control room staff may not. Instead, the force relies on its equality, diversity and inclusion team to alert local managers and control room staff to look out for discriminatory allegations.
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 force made sound decisions when handling complaints and conduct allegations. This included whether the force 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 force 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 force doesn’t have an effective policy or process for control room call handlers to resolve complaints through service recovery.
Control room personnel can resolve complaints at the time or direct them to a local area inspector. They take these decisions without consulting the PSD. The PSD doesn’t dip sample these cases to make sure they are suitable for service recovery and handled in accordance with the IOPC statutory guidance.
Call handlers make decisions without guidance and the necessary training. This is potentially leading to inconsistent levels of service and outcomes for complainants. When call handlers resolve a complaint, they record and close the call log on the command-and-control system. The call handler should use a specific complaint‑related code so that the force can identify the complaints. But the force doesn’t check if call handlers apply codes accurately.
With this model, the force can’t assure itself that all risks are appropriately identified and responded to. It also can’t fully understand the nature and volume of lower-level complaints made by the public and address any issues.
PSD managers attend a daily meeting to discuss some complaints referred to the department and triage them. The chair gives initial direction about how the case should be progressed. Often complaint handlers will complete appropriate initial enquiries and, where possible, resolve the complaint through service recovery.
Where service recovery isn’t possible, complaint handlers complete a pro forma document. They send it to the appropriate authority, who makes an initial decision on how to handle the complaint. It is only at this point that the PSD formally records the complaint on Centurion. This means there is a potential delay in the force recording complaints under Schedule 3 of the Police Reform Act 2002. This doesn’t comply with statutory guidance. But in the majority of cases it recorded under Schedule 3, the PSD’s initial handling decision complied with statutory guidance and was recorded with rationale.
We reviewed 5 complaints recorded under Schedule 3 where the PSD decided to take no further action. These decisions were appropriate. The PSD quickly updated the complainant and provided them with a sufficiently detailed rationale. The PSD also highlighted which review body the complainant could ask to review the case if they weren’t satisfied with the outcome.
Initial handling of conduct matters
The PSD only records matters deemed to be recordable conduct on Centurion after the appropriate authority makes an initial severity assessment. This could cause a delay that is contrary to statutory guidance.
We reviewed 20 conduct cases and found that in 19 of them the severity assessments were reasonable and proportionate. The appropriate authority referred to previous allegations and the College of Policing guidance. However, there were several cases where the PSD hadn’t identified all the allegations within the case, or appropriately categorised and recorded them on Centurion.
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. They include a serious assault, a serious sexual offence or serious corruption. They also include 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.
Investigators that we spoke to understood how to deal with complaints or conduct matters that included an element of alleged discrimination. Complaint resolution team members also described how they use a guidance document as part of their decision‑making process. However, in our file review we found 11 cases that required referral to the IOPC, but the PSD had only referred 8. And it referred one further case approximately two weeks after the matter came to its attention.
There was an allegation of police criminality in 12 of the 39 cases we examined. These included potential offences under the Public Order Act 1986 and the Computer Misuse Act 1990. In all 12 cases, the investigator acknowledged that a crime may have been committed. Where the force dealt with the case as an internal misconduct matter rather than a crime, it was appropriate and documented. We were told that complaint and misconduct investigations in criminal cases deemed to be sub judice are suspended until the conclusion of criminal proceedings. But the force will continue with the investigation of any allegations that wouldn’t unfairly influence the criminal investigation.
Accessibility of the public complaints system
Forces in England and Wales have a statutory obligation to promote access to their complaints system, and to make sure the public can use it. The force should make sure that its complaints system is accessible to everyone. This includes people with protected characteristics and those from hard-to-reach communities.
In 2021 the PSD worked with the force’s independent advisory group to review complaint processes and the documentation available to the public. The force’s equality, diversity and inclusion board has also worked with charity Just Lincolnshire to make services, including the complaints process, accessible to more people. This included improving accessibility for people with autism, people who don’t speak English as their first language and people with disabilities. For complaints made through the police portal Single Online Home, the complainant can fill in a text box to highlight they have a disability, speak English as a second language or have a particular need.
Control room personnel can use text-to-speak programmes to converse with people with impaired hearing. The force also uses translation services.
When it receives a complaint, the complaint resolution team records any additional requirements the complainant may have on Centurion and states the action that should be taken.
We found the force generally supported complainants who may have needed additional assistance. Of the 20 complaint cases we examined, additional support may have been required on 4 occasions. The force provided it on three occasions.
Processes and governance for investigating and resolving public complaints and conduct matters
The standard of investigations
Investigations are an opportunity for the force 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.
We found that in most cases the force carried out proportionate investigations in both complaints and conduct matters. When cases were resolved otherwise than by investigation, the force’s approach was also generally proportionate.
Where the force carried out an investigation, the appropriate authority made a thorough initial and final severity assessment. And there was some evidence that the appropriate authority reviewed these as the investigations progressed.
We reviewed 39 cases. There was a lack of auditable decision-making and supervision in all of them.
We were told that the PSD detective chief inspector holds formal tasking meetings every three weeks to oversee investigations. The PSD supervisors hold weekly workload management meetings. Investigators provide verbal updates at these meetings but don’t record them on Centurion.
We reviewed 25 cases where a complaint or conduct matter had been investigated. We found appropriate terms of reference were recorded in only 11 of them. And only one of these cases had an investigation plan. Investigators provide updates on their cases in different ways, but we found no decision logs on Centurion. The PSD has created an enquiry log template to attach to Centurion for updating investigations, but investigators aren’t using it. This means that if the direction of the investigation changes, the reason isn’t recorded. And at the close of an investigation, supervisors can’t carry out a final review to make sure all tasks have been completed.
As a result, we can’t assess the extent to which PSD supervisors provide direction to investigators on how cases should be managed. The lack of documentation also limits the PSD’s ability to quality assure work and has implications for both disclosure and its compliance with the management of police information APP. The PSD needs to address this.
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.
Lincolnshire Police considers the welfare of accused police personnel and those making internal conduct allegations. The PSD completes a comprehensive risk assessment when it serves misconduct papers.
It issues a welfare notice to support people that are subject to misconduct proceedings. The force has produced a leaflet highlighting sources of support provided by internal and external bodies. This includes a range of mental health support. Volunteer single points of contact across the force can offer additional support to colleagues when required. The HR department is in the process of producing bespoke guidance for these volunteers and managers to support them in their role. It will include how and how often the person accused of misconduct should be contacted.
The force can allocate welfare single points of contact to personnel making allegations, although this happens less. Officers and staff we spoke to felt there was less support for personnel who reported wrongdoing or were witnesses. They felt the force needed to rectify this.
The force now requests that the relevant staff association provides a ‘friend’ to support the officer or member of staff who is reporting wrongdoing. The workforce has received this favourably.
PSD managers also consider the welfare of their staff. PSD managers use regular conversations to discuss welfare as well as performance. The investigators we spoke to felt supported and that managers considered their welfare.
Suspension and restriction of members of the workforce
We checked the force documented its decisions about the suspension or redeployment of an accused person during an investigation. And we examined whether accelerated procedures were being used appropriately in gross misconduct cases.
Lincolnshire Police has a policy covering the suspension, restriction or redeployment of its officers. In all cases we reviewed, where it was appropriate the force considered suspending or redeploying personnel who were the subject of complaint or conduct allegations. We could see this in the appropriate authorities’ severity assessments.
If the head of the PSD is satisfied the suspension criteria are met, they provide recommendations to the deputy chief constable. At the time of our inspection, the force had two suspended officers.
The force reviews suspensions every 28 days. However, we were told that suspended officers aren’t always informed of this. This is contrary to Regulation 11 of the Police (Conduct) Regulations 2020.
The force uses accelerated procedures when appropriate. The chief constable has completed one accelerated procedure since April 2024, with another imminent.
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 force 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.
Lincolnshire Police needs to improve the level of service it provides to complainants.
The team that handles complaints recognises that every complainant should be treated with respect and be kept up to date by their preferred means of communication. The team does this by following IOPC guidance. The office manager dip samples ten cases per team member every month to make sure this is the case.
A staff member is responsible for prompting complaint investigation team colleagues and local area inspectors to update complainants. There is an established escalation process if they don’t update complainants. But during our case file review we saw no evidence that the force provided regular, meaningful updates to public complainants, interested persons or the subject of the allegation.
The PSD doesn’t include sufficient explanation or rationale for handling decisions in letters it sends to complainants. We dip sampled three additional complaint cases investigated by the force. In each case the investigation team hadn’t sent the complainant an outcome letter or any communication informing them of their right to review. The PSD has a pro forma outcome letter that is simple to complete and upload. It contains all the relevant information the force should provide to complainants. However, PSD investigators aren’t using it.
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 13 applications for a review of complaint cases that Lincolnshire Police had investigated. It found that two had an outcome that wasn’t reasonable and proportionate.
During the same period, the IOPC carried out 13 reviews of complaints the force had concluded otherwise than by investigation. It found that five cases had an outcome that wasn’t reasonable and proportionate.
The Office of the Police and Crime Commissioner finalised 107 complaint reviews during that same period. It found that the outcome wasn’t reasonable and proportionate in 28 cases.
Information sharing
It is important that the force gathers and shares adverse information about members of its workforce. This helps to make sure that it maintains professional standards and identifies and mitigates risks. In our inspection, we examined:
- whether the force can record adverse information;
- whether departments holding this information shared it appropriately within the force; and
- whether the force considered such information when making decisions about complaint and conduct matters.
The recording and sharing of adverse information
As already highlighted in this report, the PSD doesn’t routinely review complaints resolved through service recovery by control room personnel or by local area inspectors. They aren’t recorded on Centurion and aren’t linked to complainants’, officers’ or staff records. This means that the PSD may not be aware of police personnel who are subject to repeated low-level complaints.
We reviewed seven conduct cases and two complaints from the public concerning members of police staff. The HR department investigates conduct allegations against police staff. We were told that the PSD make a final decision in consultation with HR. But we saw little evidence on Centurion of communication between HR and the PSD in the cases we reviewed.
The PSD doesn’t have access to HR’s IT system. This means information on HR systems isn’t part of PSD intelligence gathering. The PSD is unable to see all the information about personnel with allegations made against them before it makes decisions.
Centurion flags if an officer receives 3 complaints in a rolling 12-month period. When this happens, the PSD office manager produces a report highlighting the associated complaints and records the intervention on Centurion. The PSD then sends this information to the officer’s chief inspector for action. If a second management intervention is generated for the same officer, the PSD complaints and conduct detective inspector will review the case.
The appropriate authority doesn’t review all employment tribunals and linked grievances or civil litigation claims. Instead, a senior HR manager verbally updates the PSD in a monthly meeting, but this isn’t recorded in the minutes. This means the PSD relies on HR to identify and highlight misconduct in these cases. There is a risk that HR staff may not know the IOPC guidelines for identifying and handling allegations of discrimination.
The PSD has a pro forma notice to inform the vetting unit that an officer or member of staff is under investigation. We saw evidence the PSD used it.
The consideration of relevant information
In our case file review, we saw some evidence that the PSD researches complaint and conduct history on Centurion and makes the relevant enquiries to other areas of the force. The PSD considers this information when assessing the severity of allegations and during investigations. However, this wasn’t consistent in all cases.
Holding police officers and staff accountable for their behaviour
Area for improvement
The force needs to improve its understanding of potential disproportionality in the handling, investigation and resolution of complaints and conduct matters
The force 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 that, in most cases, professional standards department decision-making was proportionate and fair at both the initial assessment and final determination stage. We found some evidence that the force has taken steps to try to ensure fairness and consistency. For example, it takes part in regional peer reviews of cases. But this doesn’t provide the level of understanding the force needs to address any potential disproportionality.
To fully understand disproportionality in its professional standards department decision-making and the reasons for it, the force should carry out detailed analysis across the nine protected characteristics. It can then address any such disproportionality.
We identified this as an area for improvement in our report ‘Police effectiveness, efficiency and legitimacy 2018/19: an inspection of Lincolnshire Police’ published in February 2020. It is disappointing that the force still hasn’t addressed it.
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 force must make sure that its approach to complaints and conduct matters, and the resulting outcomes, are proportionate to the allegations and investigation findings.
Our case file review found that, in most cases, Lincolnshire Police’s PSD decision‑making was proportionate and fair at both the initial assessment and final determination stage. But there is inconsistency in the way the force investigates cases. The appropriate authority carries out initial assessments in complaint and conduct matters for both police officers and staff. HR oversees investigations against staff and the PSD oversees officer cases. The head of the PSD makes all final determinations on officer cases and does this in consultation with HR for staff.
The force also takes part in a monthly meeting of the regional heads of PSD. In this meeting, the Lincolnshire Police PSD puts forward two anonymised cases for peer review to test whether its decision-making is fair and proportionate.
The PSD doesn’t carry out any formal, detailed analysis to establish if there is any disproportionality across the nine protected characteristics in its investigations and decision-making.
The force has a network known as SMILE (Supporting Minorities in Lincolnshire through Engagement), made up of officers and staff who identify as being part of a minority group based on their ethnicity. To make sure unconscious bias isn’t influencing PSD decision-making, the legitimacy board asked SMILE to consider any themes arising from complaints that may affect people from a minority ethnic background.
As we mentioned earlier in this report, the force’s inconsistent use of Centurion makes the auditing of cases for consistency and fairness difficult. And the lack of oversight of complaints dealt with by service recovery in the control room means we are unable to comment on the fairness and consistency of decision-making in those cases.
The Police Regulations 2003 Regulation 13 decisions to discharge an officer on probation are taken by the force’s learning and development team, supported by HR. The force has reviewed its policy and process on Regulation 13 and arranged additional training on its use. The HR team is now responsible for the process. Personnel told us that the force uses Regulation 13 proportionately. We saw no evidence the force used Regulation 13 where it should have applied misconduct proceedings.
Tackling potential corruption
Lincolnshire Police requires improvement 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
Lincolnshire Police can’t monitor some of its IT systems across mobile and desktop devices to identify data breaches, protect the force’s data and identify computer misuse.
We identified this as an area for improvement in our last inspection. The force responded and introduced IT monitoring software. But it has recently identified difficulties monitoring some of its IT systems. The force recognises this as a risk and has recorded it on its risk register. Additionally, the force makes use of auditing to overcome these difficulties. This mitigates some potential risks.
The ACU proactively monitors activity on mobile and desktop devices. This helps identify potential misconduct including improper contact with vulnerable victims. We saw evidence the ACU monitors the IT use of police personnel who are the subject of other corruption intelligence.
The ACU uses the IT monitoring software to proactively monitor personnel when intelligence shows they may pose a higher risk. The ACU identifies them through analysis of intelligence reports, information from public complaints and misconduct reports. The ACU analyst maintains a comprehensive register of all police personnel who may present a corruption risk. The ACU records what action it takes to manage and mitigate the risks these individuals may pose.
ACUs and IT departments should meet regularly to make sure that the ACU can monitor and audit new IT systems and software.
The Lincolnshire Police ACU is involved in the procurement of new IT systems. ACU staff attend Directorate of Data Technology meetings. The force has identified what it needs to allow effective monitoring, auditing and investigation of the use of its IT systems. The IT department takes this into account when developing or procuring new software.
IT monitoring policy
The force has a lawful business monitoring policy for monitoring and recording the workforce’s communications. The policy allows the ACU to audit all force 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 force 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.
Lincolnshire Police can identify which members of the workforce are accessing different IT systems through their unique log-in details. The force 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 ACU 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.
Lincolnshire Police doesn’t permit encrypted apps on force devices, but the deputy chief constable can authorise their use in exceptional circumstances. At the time of our inspection, no such requests had been made.
The force has a comprehensive social media policy and detailed guidance, which it has circulated to the workforce. It explains that police personnel can use the force’s social media accounts for the benefit of communicating with the public, but they must use it professionally and securely. The corporate communications team must approve all new accounts and maintains oversight of how personnel use social media. The force was due to review the policy in May 2024.
The PSD and the ACU provide training and guidance to the workforce about the risks associated with social media use. Officers and staff we spoke to showed a good awareness of the force’s expectations of them regarding the use of social media and encrypted apps.
Tackling potential corruption
Area for improvement
The force should improve how it collects, assesses, develops and investigates counter-corruption intelligence
The force should make sure that:
- it produces an effective control strategy and implementation plan with named people responsible for actions, aligned to its counter-corruption strategic threat assessment, and uses these to manage corruption threats effectively;
- it establishes a people intelligence meeting or an alternative process to support the regular and continuing exchange of corruption-related intelligence so officers and staff who may pose a corruption threat are identified;
- it maintains effective working relationships with external agencies and organisations that support vulnerable people to encourage reporting and safeguard potential victims; and
- its anti-corruption unit (ACU) has sufficient resources and suitably trained staff to meet demand, tackle corruption effectively and allow for proactive intelligence collection.
These issues have been raised in one or both of the reports ‘An inspection of vetting, misconduct and misogyny in the police service’ published in 2022 and ‘Police effectiveness, efficiency and legitimacy 2018/19: an inspection of Lincolnshire Police’ published in February 2020. It is disappointing to see that the force still hasn’t addressed these issues. The force’s counter-corruption control strategy is missing some significant control measures we would have expected to see. The control strategy would be more effective if the force used a more structured approach, with a consistent level of detail recorded for each threat identified in its strategic threat assessment. It should use the framework outlined in the counter-corruption (intelligence) APP.
The force’s implementation plan isn’t effective. Many actions in the plan weren’t being progressed. ACU staff assigned to carry out this work hadn’t been trained and lacked the capacity to complete it. And senior managers didn’t oversee the plan.
The ACU is therefore not using the STA and associated control strategy and implementation plan effectively to address corruption threats.
The force doesn’t have an established people intelligence meeting. The force is therefore missing opportunities to identify officers and staff who pose a corruption risk.
The ACU hasn’t established working relationships to build trust with external agencies and organisations that support vulnerable people. So it also hasn’t provided training to help them understand warning signs of the abuse of position for a sexual purpose. And the ACU hasn’t told these organisations how to share such information with it. The force is missing opportunities to gather corruption‑related intelligence regarding the sexual abuse of vulnerable people by police officers and staff.
ACU staffing levels mostly meet current demand, but workloads are increasing. The ACU told us it doesn’t have sufficient capacity to implement the measures identified in its control strategy effectively. ACU staff don’t always have the capacity to help the force vetting unit take risk mitigation measures. In addition, the detective chief inspector in the ACU provides training sessions to new recruits and newly promoted officers and staff. This commitment has an impact on their capacity to manage daily business. Only one member of the ACU has completed the College of Policing bronze counter-corruption course.
These capacity gaps, coupled with the lack of specialist counter-corruption training and increasing demand, mean the ACU’s current resources may not be sufficient to fully achieve its aims and objectives.
Intelligence
Sources of corruption-related intelligence
Lincolnshire Police actively seeks corruption-related intelligence as a matter of routine. The force refers to this as its “pure proactive” approach. Each week, the ACU allocates one staff member the task of proactively searching for corruption-related intelligence. Staff use a variety of methods and systems to carry out this work. During our inspection, we were told the ACU has carried out 400 proactive searches, which have resulted in 40 new intelligence cases. The force told us that during periods of high demand it may pause this proactive work.
The force has an anonymous confidential reporting line. Between January 2023 and December 2023, it received 34 reports (39 in 2022 and 38 in 2021). The force also now uses the national Crimestoppers integrity line. This resulted in ten reports in 2023.
We examined 60 corruption intelligence files. In 22 of these cases, we found police personnel directly reported corruption intelligence to the ACU. A member of the public had made a report in six 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, 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 Lincolnshire Police 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.
Lincolnshire Police has a comprehensive counter-corruption STA. It identifies the force’s main risks, for example sexual misconduct, disclosure of information and misuse of force IT systems. The risks include the workforce’s vulnerability to corruption through factors such as alcohol misuse, gambling, unmanageable debt and criminal associations.
The force publishes an edited version of the STA on its intranet and uses posters to raise awareness across the workforce of the current corruption threats. During our inspection, we found the ACU hadn’t made the vetting unit aware of the STA. They should make sure vetting decision-makers understand the threats faced by the force.
Counter-corruption control strategy
The force has produced a counter-corruption control strategy. The control strategy priorities mirror those identified in the STA. The ACU assigns a staff member to each threat. It provides them with a list of tactical options to counter the threat.
The force doesn’t use a recognised approach to address the threats identified, for example the 4P-approach (pursue, prepare, protect and prevent) or MoRiLE. This means the force’s control strategy is missing some significant control measures to mitigate risks. For example, there is no action to establish working relationships with external agencies and organisations that support vulnerable people who may be at risk of APSP.
The control strategy would be more effective if the force had a structured approach with a consistent level of detail recorded for each threat. It should use the framework outlined in the counter-corruption (intelligence) APP.
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. But the force doesn’t have an effective implementation plan. Some tasks have been routinely included in the implementation plan since 2021. But the force told us the ACU didn’t have the training or capacity to complete the work. Senior managers said they don’t oversee the implementation plan.
This means the force 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 force 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.
Lincolnshire Police doesn’t have an established people intelligence meeting that would provide an opportunity to identify police officers and staff who may pose a corruption risk.
PSD daily management meeting discusses complaints and conduct matters reported in the preceding 24 hours. ACU staff attend, but they weren’t confident PSD investigators were sharing all the information they had. The force should make sure all potential corruption information is shared at these meetings. It should also consider the potential benefits of the vetting manager attending. They would be able to note corruption-related matters that may affect an individual’s vetting status.
Partnership working to identify potential corruption
The ACU hasn’t established working relationships to build trust with external agencies and organisations that support vulnerable people. The force is missing opportunities to gather corruption-related intelligence relating to the potential sexual abuse of vulnerable people by police personnel and safeguard potential victims.
In the 12 months preceding our inspection, the ACU hasn’t provided any training on APSP to external agencies such as sex worker support services, drugs and alcohol services and mental health charities. This would help these organisations to understand the signs of APSP and how to share information with the ACU. During our file review, we found no examples of intelligence reports of suspected corruption originating from partner agencies.
We identified this as an area for improvement in our last inspection of Lincolnshire Police, published in February 2020. Furthermore, this was a recommendation in our national inspection of vetting, misconduct, and misogyny in the police service. The force told us that this inactivity was mainly due to a lack of resources. Given the length of time that has elapsed, and the relative ease of addressing this issue, this isn’t acceptable.
Managing corruption threats
Intelligence development
We reviewed 60 corruption intelligence files. In 58 cases the ACU responded effectively and used a variety of techniques to develop the intelligence. But we found the force had missed opportunities to develop intelligence and mitigate corruption risks in two cases. These cases included an allegation that three officers’ details were found in a suspect’s mobile phone and a case of unlawful disclosure of information, namely a custody photograph.
We found the force refers appropriate corruption cases to the IOPC.
Only two of the cases we reviewed resulted from proactive intelligence collection, but the ACU makes good use of proactive IT monitoring.
Corruption investigations
Of the 60 corruption intelligence files we reviewed, 13 resulted in a counter-corruption investigation. We found the standard of investigation was good in all cases.
In contrast to the PSD’s complaint and conduct investigations, which we mentioned earlier, every case had an investigation plan which was meaningful and 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 a notable person list to manage officers and staff who may pose a corruption risk. The ACU identifies them through intelligence reports and information from public complaints and misconduct reports. The intelligence relates to sexual misconduct and a range of other corruption risks.
ACU staff research all known intelligence and previous reports on people on the list. The ACU inspector or their deputy then assesses the potential risk posed by the officer or staff member. The force records any action it takes to investigate or mitigate the risks. We found good oversight of these cases.
Capacity and capability to investigate corruption
The ACU is a small team of experienced investigators and an analyst. However, the force told us that only one member of the ACU has completed the College of Policing bronze counter-corruption course. The force agreed it needed to complete a skills analysis to understand the capability of all staff in the unit.
The ACU investigates all cases of APSP. It completes an initial investigation for other types of corruption and decides if the case should be transferred to PSD for further investigation.
Staffing levels mostly meet current demand. However, the force recognises ACU workloads are increasing. We have already noted that the ACU is unable to complete implementation plan tasks. Similarly, the ACU doesn’t always have the capacity to implement risk mitigation measures proposed by the vetting unit, such as routine IT monitoring. The detective chief inspector provides training to new recruits and newly promoted police personnel. The detective chief inspector told us that this reduces their capacity to manage other ACU activities.
These capacity limitations, coupled with the lack of specialist counter-corruption training and increasing demand, mean the ACU’s current resources may not be sufficient to fully achieve all its aims and objectives.
Specialist resources
Officers and staff in the ACU, 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 force’s organised crime meeting.
When required, the force 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 force 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 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.
Lincolnshire Police’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 force has an effective process to manage notifiable associations. The ACU maintains a register and records the type of association, frequency of contact and level of criminality. The ACU grades the association based on the perceived level of risk. It refers medium and high-risk cases to the vetting unit and the cases are overseen by an ACU supervisor. The force audits IT systems in all cases to identify any misuse. Local supervisors are responsible for monitoring compliance with any conditions attached to the association. The system highlights when reviews are due (every 12 months).
From 1 January to 7 June 2024, the ACU received 93 notifiable association reports. In 2023, it received 167 reports and in 2022 it received 140.
Business interests
The force has an effective process to manage business interests. The ACU keeps a business interests register on the Centurion system.
The workforce can submit business interest applications to the ACU via an online form. The 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 type of business interest. Managers in the ACU review all high and medium-risk cases before authorising them with or without conditions. From 1 January to 7 June 2024, the ACU has refused 5 business interest applications.
Local supervisors are responsible for monitoring compliance with any conditions imposed. The ACU 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 force records all compliance checks on Centurion.
The force business interest policy doesn’t require staff to declare voluntary work. We would encourage the force to review this. Requiring members of the workforce to declare such work would allow the force to consider its compatibility with the person’s role in the police. It would also allow the force to introduce any conditions needed.
At the time of our inspection, the force had 275 current business interests approved. The ACU reviews them every 12 months.
Gifts and hospitality
The force has an effective process to manage gifts and hospitality. The PSD keeps a record of gifts and hospitality on the Centurion system.
The workforce must submit notifications about gifts and hospitality offered through an online form to the PSD. Police personnel must ask for approval from their line manager and departmental head to keep the gift or accept the hospitality. The ACU completes checks to make sure that accepting the gift doesn’t pose a potential risk of corruption. Every six months the force publishes an online record of the gifts and hospitality, including those accepted and refused.
In 2022, the force recorded 94 gifts and hospitality applications. In 2023, it recorded 53 applications. From 1 January to 7 June 2024, the ACU had recorded 25.
Sexual misconduct
The force recognises APSP as serious corruption. We found the ACU records such cases correctly. It consistently refers them to the IOPC.
Of the 60 ACU corruption intelligence files we reviewed, 6 related to APSP. We found five of these cases had been handled effectively. But in one case there was a reasonable line of enquiry which the ACU investigator hadn’t completed. This related to a potential APSP victim having several officers’ contact details in her mobile phone.
In the counter-corruption STA and control strategy, the force lists APSP as one of the main threats it faces. However, as mentioned earlier in this report, we were told the ACU lacks capacity to implement many of the tasks identified in the strategy. The lack of activity recorded in the force’s implementation plan shows that the ACU isn’t making sufficient progress to tackle this threat.
The ACU and PSD provide training sessions to officers and staff across the force. The training has a specific section relating to APSP and includes the warning signs to look out for. We found a good knowledge of APSP across the workforce.
The force uses the College Learn APSP training package provided by the College of Policing to train its workforce. The force made this training mandatory and told us that, at the time of our inspection, 94 percent of all police personnel had completed it.
Lincolnshire Police 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 Lincolnshire Police