A report into the effectiveness of integrity arrangements in Surrey Police

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 Surrey Police’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	Requires improvement
Tackling potential corruption	Good

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

Surrey Police 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 in England and Wales as defined in section 1 of the Police Act 1996.

Force vetting IT system

A joint force vetting unit (JFVU) provides the vetting function for both Surrey Police and Sussex Police. The JFVU uses the latest version of a vetting IT system first introduced in Sussex in about 2006. Paper vetting records from Surrey were added onto the IT system in 2016, when the JFVU was formed.

The HR department uses a separate IT system. The HR department provides the JFVU with information about workforce changes to overcome the absence of system integration. The JFVU told us that, previously, this information was lacking and the JFVU didn’t always know about proposed moves.

The JFVU and HR have recently introduced a shared Microsoft Teams channel. They both update this with relevant HR and vetting information. The JFVU has dedicated members of staff responsible for checking the channel for notifications from HR. This helps the force to more effectively track internal moves, promotions and people leaving the force. It allows vetting caseworkers to address any vetting implications.

The JFVU uses the vetting IT system to monitor if police personnel have the correct level of vetting for their role. It uses information collated from its IT system to track vetting renewals 90 days in advance. This means the force has time to send documentation to people before a renewal is due.

Any records in the vetting IT system where there is adverse information, have an attention notice attached to flag them.

Current vetting of the workforce

Surrey Police told us that, as of 7 October 2024, it had a total of 4,328 police officers, special constables, police staff and police community support officers.

The force told us that there are 469 personnel who either don’t hold current vetting or the right level of vetting for their role. At the time of our inspection, there were 30 people in the force whose vetting had expired so they didn’t have valid vetting clearance for their role. One had expired on 15 July 2024. There were 22 people with expired vetting in designated posts that require a higher level of clearance, management vetting (MV). A further 439 were in designated posts but had never been cleared to that level.

Demand and workload

The JFVU doesn’t have enough staff to meet the demand it faces. At the time of our inspection, the force was in the process of recruiting a further five vetting caseworkers. When this recruitment process is complete, the JFVU will have 25 vetting caseworkers (18 full-time equivalent), 4 vetting supervisors (3 full-time equivalent), an administration officer, a vetting manager and a chief inspector as head of vetting.

The force has increased the number of vetting caseworkers, but without increasing the number of supervisors. This is having an adverse impact on the JFVU’s ability to manage its workload. Further, the force acknowledged that one-to-one mentoring of the new vetting caseworkers by their more experienced colleagues will reduce JFVU productivity for several months.

The JFVU manages renewals on the vetting IT system. At the time of our inspection, the force had 530 applications waiting to be processed. These didn’t include the 439 identified designated posts where the postholder has only been vetted to recruitment vetting level. The force acknowledged that it isn’t effectively prioritising higher-risk cases. It should do.

In addition, the JFVU is responsible for managing notifiable associations, business interests, and gift and hospitality for both forces. Vetting caseworkers carry out risk assessments for notifiable associations and business interests. They haven’t had any additional training for this role and don’t have access to the corruption-related intelligence held by the anti-corruption unit (ACU). The JFVU told us this additional workload is having an adverse impact on its ability to meet day-to-day vetting demand. In most forces, vetting units don’t have these extra responsibilities. We urge both Surrey and Sussex forces to reconsider the allocation of this work, particularly as ACU staff are duplicating some of it.

The JFVU and HR work together effectively to predict demand. The force vetting manager (FVM) maintains a record of the predicted number of police officer recruits, which HR provides 12 months in advance. Previously, the JFVU could consider this recruitment information with future vetting renewal data to assist with planning. Recently, this approach has been less effective due to the increase in the overall level of demand.

The JFVU grants non-police personnel vetting (NPPV) clearance to contractors and volunteers. It has granted this clearance to 1,578 people. Ten contractors had expired vetting. All ten were in the process of being re-vetted. The oldest vetting had expired on 26 May 2024.

Departments responsible for contractors inform the JFVU when they are no longer in contract. The JFVU then reviews their vetting status. If vetting is removed or it expires, the JFVU tells the relevant departments to remove the individual’s access to police premises and IT systems.

The force accepts vetting clearances for non-police personnel completed by the national contractor vetting service hosted by Warwickshire Police. The JFVU creates a record in the vetting IT system to track renewals and expiry dates for these cases. The force doesn’t accept NPPV clearances completed by another force.

The JFVU has recently introduced an annual notice to NPPV contractors vetted to a higher level, to encourage them to record any change in circumstances and to confirm that they still need vetting clearance.

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 641 designated posts and maintains a list of them. There are 1,832 people in these posts. When HR creates a new post, the vetting manager determines if MV is necessary. The FVM told us the designated post list had only been finalised shortly before our inspection.

Surrey Police isn’t managing its MV process effectively. The force told us that a recent reconciliation with HR data had identified personnel in designated posts without MV vetting. The force had allowed some personnel to take up a designated post without the JFVU granting MV clearance. The JFVU told us it has agreed a process with HR to make sure that it stops doing this.

The JFVU told us there are 461 people in a designated post without MV clearance. Of these, 22 had expired MV vetting. The other 439 had been placed in designated posts without MV being granted. But the force doesn’t have a full understanding of the risks associated with this many designated postholders not holding MV clearance. The JFVU couldn’t provide us with additional information in relation to these posts, such as which roles the people occupied or for how long they had been in post without MV. This isn’t what we would expect to see in a well-run vetting unit. The force should make sure it has an effective process in place to assure itself that designated postholders always have the required level of vetting. This was part of one of the recommendations we made in our 2022 report, ‘An inspection of vetting, misconduct, and misogyny in the police service’.

We examined five MV files. In each case, the JFVU 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.

Surrey Police has chosen to vet all transferees and those who have left the service and applied to rejoin. The JFVU 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.

Generally, the force won’t accept a transferee with a live PSD case. If the transferee appeals this decision, the vetting manager reviews the case and refers it to the head of PSD. They consult with the appropriate authority of the home force. The decision whether the individual should be allowed to transfer to the force or not will depend on the nature of the live complaint or conduct matter.

Where the force refuses vetting for a transferee, it informs the home force outlining the reason for the refusal.

If an officer trying to transfer from Surrey Police fails vetting in the force to which they are applying, the JFVU 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 JFVU uses force-wide communication channels and publishes a reminder to report change of circumstances in the PSD’s newsletter.

The force now requires all its police personnel to complete an annual integrity health check. This review includes any changes of circumstances. The force told us that 75 percent of the workforce have completed the review.

When members of the workforce report changes of circumstances to the JFVU, it carries out vetting enquiries to identify risks and decide if the person’s vetting status is affected.

The force told us there were 227 change of circumstances notification reports waiting to be risk assessed. The oldest was received by the JFVU on 18 July 2024.

Most of the officers and staff we spoke to were aware of the requirement to report change of circumstances. However, in one work area we found four members of the workforce who said they hadn’t been made aware of what changes in their circumstances they should report, or how they should report them.

Misconduct vetting review

The PSD informs the JFVU of all misconduct meeting or misconduct hearing outcomes. The JFVU 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 JFVU told us, that in the 12 months preceding our inspection it had completed 13 post-misconduct reviews.

Vetting decisions

JFVU caseworkers 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 if the risk is assessed as low. The vetting supervisors make the decision for cases where the risk is higher, or the case is complex. The vetting manager doesn’t usually make initial vetting decisions. The head of vetting is the decision-maker for post-misconduct reviews.

We found that decisions made following the introduction of the decision-making template in July 2024 were well-written. Vetting decision-makers recorded thorough rationale, used the national decision model effectively and made reference to the vetting APP.

Vetting interviews

The force told us vetting supervisors regularly carry out interviews to clarify written responses in vetting applications. These are mainly by phone or online. They keep a written record of their discussion and provide a copy to the applicant. This is in line with the vetting APP.

In our file review, we found six cases where the applicant wasn’t interviewed but it would have been beneficial. This would have helped decision-makers to clarify details provided in the application, such as the extent of any contact with third parties or non‑disclosure of financial risks. We identified this as a national area for improvement in our 2022 report, ‘An inspection of vetting, misconduct, and misogyny in the police service’.

Risk mitigation

Surrey Police uses a range of risk mitigation measures in vetting clearance cases when adverse information has been identified. The JFVU uses regular financial reviews as a risk mitigation measure when an applicant has undischarged debt or other financial difficulties. It consults with the ACU before applying mitigation measures where there are third-party risks, such as notifiable associations. And it sometimes imposes a restriction on where somebody can be posted.

The ACU produces an annual counter-corruption strategic threat assessment (STA) outlining the current threats facing the force.

JFVU staff told us they weren’t aware of the assessment or the threats it contained. The vetting manager was aware of the threats but hadn’t seen the STA. The head of vetting also hadn’t seen the STA. The ACU hasn’t made sure that vetting decision‑makers understand the main corruption threats facing the force by sharing a redacted version of the STA with them. This is contrary to the vetting APP.

Vetting appeals

Surrey Police has different processes for vetting appeals from external and internal candidates.

When an external candidate submits an appeal, it is sent to the appeals officer. This is the vetting manager unless they took part in the original refusal decision. In these cases, the head of vetting becomes the appeal officer.

There is an appeal panel for internal candidates who have their vetting refused or revoked. The panel comprises an assistant chief constable, who is the chair and final decision-maker, a chief inspector and a senior HR manager.

The Vetting Code of Practice 2023, paragraph 5.6 states: “Vetting decision making will be separate from, and independent of recruitment and other Human Resource (HR) functions.” Having an HR manager on the panel as a decision-maker is contrary to the code. At the time of our inspection, the force told us it would issue guidance to clarify that the HR representative has an advisory role. The force should take steps to make sure its vetting appeals process complies with the Vetting Code of Practice and APP.

Quality assurance

Surrey Police has a quality assurance process for vetting decision-making.

Every two weeks, vetting supervisors dip sample a minimum of three vetting clearance decisions with adverse information made by each caseworker. The FVM dip samples three cases per supervisor. This includes both approvals and rejections. The head of vetting quality assures the FVM’s appeal decisions.

This process means the JFVU can provide feedback to decision-makers. The force told us of examples where it had overturned clearance decisions following these quality assurance checks. But the selection of cases to dip sample is random. The JFVU should make sure the quality assurance process is equally effective across both forces it serves. Further, there isn’t a quality assurance process for vetting decisions made by the head of vetting. We encourage the force to put this in place.

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.

Since April 2024, the force has collected data about 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 PSD has produced an analysis of the vetting data reviewed at the quarterly force race action plan meeting. The force has identified several actions it could take when candidates withdraw during the recruitment process.

The JFVU told us it has found only limited evidence of any disproportionality in its vetting decisions. But the force accepts the data it was analysing was limited in quantity. We encourage the force to make sure that analysis to identify any potential disproportionality in its vetting decisions continues. This analysis should improve as the volume of data increases, presenting opportunities to scrutinise cumulative data.

Vetting file review

With a vetting specialist from another force, we reviewed 21 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 15 of the force’s decisions. But in six cases the recorded rationale didn’t consider all identified risks or relevant risk mitigations. There were two cases where the vetting analyst should have recognised information as adverse. The clearance decision in those cases would then have been subject to further scrutiny. We also saw four appeal decisions which overturned the original vetting decision without fully considering and mitigating the risks associated with the applicants.

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

Upholding the standards of professional behaviour

Surrey 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

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

Surrey Police uses a variety of methods to reinforce organisational learning and the standards of professional behaviour.

The PSD provides training on the expected standards of professional behaviour to new officer recruits in three stages:

• during an online meeting before joining;
• in the first couple of days of initial training; and
• at the end of initial training.

The training isn’t as structured for police staff as they don’t join in large numbers.

The force provides an additional three-day leadership course for supervisors. This includes mandatory modules and work-based assessments. Leadership days for senior leaders include presentations from PSD and HR.

The PSD has developed a presentation for new supervisors. This provides guidance on significant areas of PSD work and internal processes. It includes information on abuse of position for sexual purpose (APSP), including warning signs to look out for. The force also arranges continuing professional development days on ethics and standards for sergeants, inspectors, and police staff equivalents.

Mandatory training for the workforce includes the Code of Ethics, APSP, hate crime and misogyny.

The PSD shares guidance on the expected standards through the force intranet. The force told us it has published 40 articles over the last 18 months. Topics included social media use, confidentiality and examples of gross misconduct investigations.

The force publishes the results of gross misconduct proceedings internally on its intranet. It also publishes the results externally on its website for the minimum of 28 days in accordance with the Police (Conduct) Regulations 2020.

PSD supervisors hold an internal monthly learning and debrief meeting where they discuss trends and learning from ongoing complaints and misconduct. The PSD forwards relevant information to the organisational learning board that the force shares with Sussex Police. It sends departmental learning to relevant departments and individual learning to the officer and their supervisor. The force also reviews grievances and employment tribunals to identify areas of learning for sharing.

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

Police officers and staff we spoke to were aware of the expected standards of professional behaviour and could recall PSD training. They felt confident to approach the PSD for advice and had a good understanding of how to make reports through their line manager, direct to the PSD or through confidential reporting systems. They told us PSD supervisors have a high profile across the force and are seen as highly reliable investigators who establish networks with peers and staff.

Most personnel we spoke to were aware of organisational learning through intranet messages. They quoted examples of recent messages including the effective investigation of stalking and harassment, the safe handling of prisoners during transport and APSP.

However, the force doesn’t formally evaluate the workforce’s understanding of standards of professional behaviour beyond reviewing metrics for clicks on an intranet article and changes in levels of reporting.

Organisational learning

Surrey Police doesn’t have a clear process for collecting and sharing organisational learning.

Designated personnel assess potential learning and decide what to do with it. Local boards or senior management teams implement learning relevant to their area. The designated personnel refer force-wide learning to the joint organisational learning board, which meets quarterly and is chaired by the Sussex deputy chief constable.

We reviewed the minutes from a recent organisational learning board meeting. They showed the board discussed a wide range of learning. This included project management and Independent Office of Police Conduct (IOPC) investigations and Learning the Lessons bulletins.

However, there is no formal guidance on the board’s remit. Police personnel also told us that it was difficult to submit learning to the board. This raises questions about the board’s effectiveness and explains why some PSD-specific learning hasn’t reached it.

Surrey Police’s deputy chief constable chairs an organisational reassurance board. The board collects and evaluates recommendations from external professional bodies, peer reviews and internal inspections. This includes PSD-related learning from our inspections and the Angiolini Inquiry.

There are opportunities for the force to improve these processes to make sure it collates and shares organisational learning efficiently and effectively.

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. 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

The deputy chief constable is the senior officer responsible for PSD in Surrey Police. They oversee complaint and conduct matters through regular governance meetings with senior PSD managers. A scheme of delegation clearly sets out responsibilities for named individuals. The force has five senior officers who carry out the role of appropriate authority.

The PSD deals with both conduct matters and complaints. The force changed its investigation structure and practices in August 2024. Each day, a duty team of three different PSD personnel take responsibility for complaint handling and resolution.

PSD sergeants and the complaints manager triage incoming complaints using the THRIVE assessment. They flag priority cases for the duty team to work on each day. These may be complaints suitable for service recovery or those that the force needs to record under Schedule 3 of the Police Reform Act 2002. If the duty team can’t resolve any complaints in a timely way, they take them into their own workload or ask managers to allocate them to another member of the team.

The new system builds resilience and has the potential to speed up complaint handling. However, some PSD personnel felt that the approach wasn’t wholly effective. There was frustration at having to halt serious conduct investigations to be part of the duty response to often less serious matters.

The force recently recruited 2 investigators, making a total of 20. Some PSD personnel said this wasn’t enough to cope with the increased demand. At the time of our inspection, the PSD had three investigator vacancies.

Individual caseloads ranged from 12 to 30 cases. These were complaints and conduct matters of varying complexity and at different stages of the process. Some were paused awaiting a criminal outcome. PSD personnel told us that this workload is too big and is leading to them feeling “stretched”.

It is affecting the force’s ability to implement areas for improvement and recommendations for change raised in national reports, such as the Angiolini Inquiry.

The PSD workforce said the issue is also limiting its ability to focus on prevention work. For example, they told us investigators would like to evaluate performance issues more closely to prevent misconduct arising, which in turn should help manage and reduce demand.

The PSD administration team told us it has spare capacity as some duties have been passed to the investigators. This team has a wealth of knowledge and experience to effectively support investigators.

The force recognises the capacity problem. It has recorded it on the force risk register. The deputy chief constable has commissioned an independent review of PSD capacity and workloads to help address these concerns and identify the correct resourcing levels.

Training and experience within the professional standards department

The force invests in development and training to help the PSD workforce carry out their roles effectively. All appropriate authorities and investigators have received the relevant College of Policing training for their role. All investigators have also completed the College of Policing’s complaint handling training. Every investigator is accredited to professionalising investigations programme (PIP) level 1, with several having attained PIP level 2.

The force’s PSD has developed its own professional standards accreditation scheme for investigators. Investigators must show competencies to a required level. Mentors from within the department coach and support them through their development. This is a positive approach, but current workloads are limiting levels of mentoring and support.

PSD investigators attend internal continuing professional development sessions every two months covering a broad range of topics. The PSD records the training and keeps them as a library for future reference. The PSD workforce can also access videos that have been created to support the professional standards accreditation scheme.

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 complaints 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. 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.

Initial handling of public complaints

The force receives public complaints through its website, contact centre and the IOPC website. It also receives complaints through direct reports to officers or staff, its enquiry office, or the office of the police and crime commissioner. The PSD admin team processes all complaints.

The logging and initial handling of complaint and conduct cases in most cases complies with the IOPC statutory guidance.

The admin team generally logs complaint matters on Centurion in a timely way. As part of our case file review, we examined 29 public complaint cases, 19 under Schedule 3 and 10 outside Schedule 3. The force logged 21 within 1 to 2 days, and a further 7 within 3 to 8 days. One case took more than eight days to log.

In the period 1 April 2024 to 30 June 2024, the IOPC Police Complaints Information Bulletin shows that the force took on average one day to log complaints. This compares to an average of four days for similar forces and a national average of six days. Surrey Police took on average four days to contact complainants, compared to an average of three for similar forces and a national average of six.

We found the force was less timely in making its initial handling decision. We reviewed 19 cases recorded under Schedule 3. In nine cases, the force made its initial handling decision in under eight days. In 8 cases, it took more than 14 days to make an initial handling decision. We saw no rationale to explain these delays and in some cases there was no evidence on Centurion that the force had contacted the complainant during that period.

Equally, we saw limited, or no supervisory oversight during the handling of these complaints.

The force handled and resolved the 10 cases recorded outside Schedule 3 within a reasonable timeframe.

We examined five complaint cases for which the force decided to take no further action. The decisions were all in accordance with IOPC statutory guidance. All five cases had detailed rationale explaining why the case hadn’t been progressed. The force included the rationale in the outcome letter to the complainant in four cases.

Initial handling of conduct matters

Surrey Police should record and make initial handling decisions in conduct cases in a more timely way.

Of the 20 conduct cases we reviewed, the PSD recorded 13 on Centurion within 1 to 2 working days. It recorded a further 3 cases within 8 working days and 2 cases between 8 and 14 days. Two cases took more than 14 days.

We found that in 7 of the 20 conduct cases, the PSD made a handling decision within 2 working days. In a further eight, it made the handling decision within eight working days. However, it took more than 14 days to make the handling decision in 4 of the remaining 5 cases.

In 19 out of 20 of the conduct cases, the PSD had documented its handling decision and recorded its rationale.

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.

In the 39 complaint and conduct cases we examined, 9 cases required referral to the IOPC but the PSD referred only 6. The three cases that weren’t referred related to allegations of sexual assault, corruption and a serious injury.

Four cases we examined had an allegation of police criminality. These included potential offences under the Offences Against The Person Act 1861 and the Road Traffic Act 1988. The force identified the potential crime and dealt with it appropriately in three cases. In one case, the PSD didn’t identify an allegation of corruption as a potential crime. And it didn’t deal with the allegation in accordance with police conduct regulations or the IOPC statutory guidance.

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 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.

Information about the complaints process and how to make a complaint are easily accessible via the front page of both the force’s and office of the police and crime commissioner’s websites. The public can make complaints using an online form, in writing, by telephoning the force or in person. The office for the police and crime commissioner told us it shares information about the complaints system when working with hard-to-reach groups.

Surrey Police doesn’t always support complainants who may need additional assistance. Of the 19 complaint cases we examined, we found 3 where the complainant may have required extra support. For example, one complainant indicated that they had a disability. The force correctly provided appropriate support on two 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 had carried out proportionate investigations in both conduct and complaint matters. We examined 12 investigated cases. The PSD had investigated to an acceptable standard in 11 cases.

The investigation of one case fell far below the required standard. The PSD made no meaningful enquiries into the allegation and didn’t identify the potential crime. There was no evidence of supervisory oversight, no involvement of an appropriate authority for more than two months and no severity assessment carried out.

When the PSD resolved complaint cases otherwise than by investigation, its approach was proportionate in all 11 cases we examined. The investigating officer or case handler’s final report or outcome letter was comprehensive and included clear rationales.

We found investigations and their outcomes to be proportionate but there was a lack of documented investigation planning, auditable decision-making and recorded supervisory oversight.

We reviewed eight complaint investigations. Only four had terms of reference and one had an investigation plan. We saw records of decisions in only three cases and supervisory oversight in two cases.

In the four investigated conduct cases we examined, two had terms of reference and three had an investigation plan. Investigators recorded decisions in all four cases, but supervisory oversight was only present in one.

In all investigated conduct cases, the appropriate authority had made thorough, reasonable and proportionate initial and final severity assessments.

We made a recommendation relating to investigation plans in our 2022 national report, ‘An inspection of vetting, misconduct, and misogyny in the police service’. Surrey Police has still not implemented this recommendation.

The force has developed a case enquiry log in Centurion to help investigators record investigation progress in a consistent way. It isn’t yet fully understood by everyone. We found that the documentation of case progression improved when investigators used the log.

We found inconsistencies in the way the PSD uses Centurion, for example when investigators input information and store documents. Some PSD personnel told us they received Centurion training in one of their continuing professional development sessions held every two months. But the force doesn’t have a current policy or process to standardise the use of Centurion. We encourage the force to develop one.

We reviewed 10 cases that the force had resolved outside Schedule 3. It dealt with all the cases thoroughly and satisfactorily and resolved them within a reasonable timeframe. It was clear that the case officer had contacted the complainant at the outset to fully understand the complaint and their desired resolution. All cases had suitable progress records, and the force provided every complainant with a meaningful explanation of the outcome.

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.

Surrey Police considers the welfare of accused police officers and staff. But the support it provides to personnel making internal conduct allegations and witnesses is less formalised.

Sussex Police and Surrey Police have a joint approach to the provision of welfare support officers including a 17-page guidance document for welfare officers and secondary welfare officers.

The force appoints a welfare support officer to personnel subject to a misconduct or complaint investigation. The force completes a duty of care risk assessment form, which informs the level of support needed. And it makes referrals to other services and agencies where appropriate.

However, we were told that the force doesn’t always provide officers and staff with an appropriate level of welfare support. It only provides a limited amount of training to welfare officers in the form of a booklet and a video. The force doesn’t monitor how many times the welfare officers meet the accused individual or the quality of the meetings. The force doesn’t have a central register that would help it to monitor how many cases a welfare officer is involved in. Effective welfare officers are often used to the extent the work becomes a burden for that individual. We urge the force to take steps to improve the selection, training and supervision of welfare officers.

Some force policies, such as the domestic abuse policy and the whistleblowing policy, outline a level of welfare support for people making domestic abuse allegations or who fall within the definition of a whistleblower. However, there is no formal welfare support for people making allegations outside these categories. The force is working to address this. At the time of our inspection, line managers were responsible for providing welfare support to personnel raising concerns.

The force has a process to support the PSD workforce’s welfare. The PSD management hold informal self-funded breakfast or coffee mornings with its officers and staff. Supervisors also regularly discuss welfare in formal supervision meetings with their team members. The force arranges an annual psychological review for PSD personnel.

Suspension and restriction of members of the workforce

Surrey Police has policies on the suspension and restricted duties of police officers and staff. It considers suspending or redeploying accused officers and staff and has used accelerated procedures. At the time of our inspection, six personnel were suspended.

The force told us that if it can manage the risks, it uses restrictions rather than suspension to keep the individual productive in the workplace. The deputy chief constable and senior PSD personnel make these decisions. Our case file review showed that the force considered suspension or restriction in all complaint and conduct cases where it was appropriate.

In the year before our inspection, Surrey Police used accelerated procedures in misconduct cases three times. Senior personnel told us that there may be opportunities to use the procedures more often.

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.

We found that Surrey Police provided an acceptable standard of service to complainants in most cases.

In one case Surrey Police should have referred the matter to another force as the officer had transferred. Eight investigated cases required the force to provide timely and meaningful updates to the complainant. The force didn’t do this in three cases. In one of those, the complainant disengaged from the process.

However, Surrey Police finalises complaints dealt with other than by investigation more slowly than most similar forces and the national average. During the period April to September 2024, the force took an average of 128 days to resolve these cases compared to an average of 83 days in most similar forces. The national average is 105 days. Investigated cases took an average of 170 days compared to an average of 161 in most similar forces. The national average is 208 days.

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 six applications for a review of complaint cases that Surrey Police had investigated. It found that three cases had an outcome that wasn’t reasonable and proportionate.

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

The office of the police and crime commissioner finalised 21 reviews during that same period. It found that the outcome wasn’t reasonable and proportionate in one of those 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 with others; and
• whether the force considered such information when making decisions about complaint and conduct matters.

The recording and sharing of adverse information

Surrey Police regularly shares relevant information between departments and has an established process for doing so. We found the PSD worked with HR, JFVU, the ACU and force divisions and departments when dealing with complaint and conduct matters.

The force has an established people intelligence board that meets quarterly. Attendees from different departments, including the PSD, ACU, JFVU and HR, share relevant information about officers and staff.

In addition, each policing area has a capacity meeting where they discuss people of interest from an integrity perspective. Information is considered by the people intelligence board if necessary.

The PSD also works with other departments to tackle violence against women and girls involving police personnel. The PSD attends the force violence against women and girls board alongside divisional investigating teams, the sexual offence investigation team, public protection and the media department.

The force has a supportive intervention scheme. The PSD highlights personnel who have received three or more complaints in the previous six months to the individual’s second line manager via their superintendent. The individual’s manager considers whether there are any issues of concern and whether further action is necessary.

The force shares information through the PSD daily management meeting chaired by the head of PSD or their deputy. Representatives from all areas of PSD attend. The meeting discusses events in the previous 24 hours, manages incoming and existing demands, allocates tasks and checks resources.

However, two of the 19 complaint cases we examined contained an allegation of corruption. In both cases there was no evidence that the PSD had shared the matter with the ACU or JFVU.

We asked Surrey Police to supply documents showing its policy on reviewing employment tribunals, grievances, civil claims and the court acquittal of personnel for potential misconduct matters. None contained any reference to the force reviewing the circumstances for any potential misconduct. We saw no other evidence the force carries out these reviews. We strongly encourage the force to do this.

The consideration of relevant information

During our case file review, we found that the PSD generally made further enquiries to better understand an allegation and those involved before making a handling decision. This was evident in 19 of the 20 conduct cases and 16 of 19 complaint cases we examined.

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 force must make sure that its approach to complaints and conduct matters, and the resulting outcomes, are proportionate to the allegations and investigation findings.

Surrey Police has a comprehensive scheme of delegation document. It states who is the delegated decision-making authority in a wide variety of scenarios.

In PSD complaint and conduct investigations, Surrey Police’s decision-making is mostly consistent and fair.

During our case file review, we found that in all 20 conduct cases and 16 of 19 complaint cases, the outcome was proportionate and fair.

In the other three cases, the force didn’t follow statutory guidance. This may have affected the outcome. For example, the PSD filed one case having taken no further action when it should have been referred to another force where the officer had transferred.

Four appropriate authorities carry out all severity assessments and final determination decisions. They discuss cases and compare decisions, which helps to make sure they are consistent. PSD personnel attend regional PSD meetings to discuss cases and benchmark their decisions.

Surrey Police 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. The force should carry out detailed analysis across the nine protected characteristics to fully understand whether disproportionality exists, the reasons for it and what action is needed to address it.

Within the six months before our inspection, the force established a race scrutiny panel to increase scrutiny, decrease disproportionality and help make sure decision‑making is fair. The PSD can ask the panel’s advice and guidance on race‑related conduct and complaint cases. The panel has met four or five times. PSD investigators provide case circumstances and verbal updates. The panel considers the information in private before feeding back to the PSD. The force told us that it asks for the panel’s advice in relevant cases before making a handling decision or final determination.

However, we found some personnel perceive there to be disproportionality in PSD decision-making between officers and staff, and between senior and junior ranks.

Tackling potential corruption

Surrey Police is good 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

Surrey Police can monitor all its IT systems across mobile and desktop devices to identify data breaches, protect the force’s data and identify computer misuse. The ACU has two dedicated IT auditors. The auditors have identified the key processes required to effectively audit the access of data across all the force’s IT systems. The IT auditors make 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 of the ACU conducting IT monitoring and auditing of police personnel who were the subject of other corruption intelligence.

The force also uses the IT monitoring capability to proactively monitor personnel when intelligence shows they may pose a higher risk. The ACU identifies them by analysing intelligence reports, and in response to information from public complaints and reports of misconduct. The ACU detective sergeant maintains a comprehensive register of all police personnel who may present a corruption risk. ACU personnel record what action they take 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 any new IT systems and software. Surrey Police ACU is involved in the procurement of new IT systems.

A senior business partner from the IT department is nominated to work with the ACU. The force has identified what it needs to effectively monitor, audit and investigate the use of its IT systems. The ICT department takes this into account when developing or procuring new software. In addition, ACU auditors regularly test the force’s auditing capability and report any potential gaps.

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 the force’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 force-owned 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.

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

In addition, police personnel must use their unique log-in details to access the force’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. At the time of our inspection, Surrey Police’s IT monitoring software had overcome this. However, as encrypted apps are constantly being updated, the force will need to satisfy itself that its monitoring remains effective.

Surrey Police permits the use of encrypted apps on its devices, and the ACU routinely monitors all the workforce’s communications on these apps.

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 them professionally and securely. The corporate communications team must approve all new force 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. Officers and staff we spoke to had a good awareness of the force’s expectations of them regarding the use of social media and encrypted apps.

Tackling potential corruption

Intelligence

Sources of corruption-related intelligence

Surrey Police actively and routinely looks for corruption-related intelligence. This work is carried out by the ACU’s auditor and researcher. They use a variety of proactive methods and system audits.

However, the force told us it doesn’t carry out random drug testing. It should do so. The force is missing opportunities to deter substance misuse, identify potential misconduct and provide reassurance to the public.

The force uses an anonymous confidential reporting line and the national Crimestoppers integrity line. Between January 2022 and December 2022, it received 59 reports. It received 79 in 2023 and 103 reports from 1 January 2024 up to the date of our inspection, 7 October 2024.

We examined 60 corruption intelligence files. In 20 of these cases, we found police personnel directly reported corruption-related intelligence to the ACU. Members of the public had made a report in seven cases. We found four further cases that were the result of proactive intelligence work. Further sources of corruption-related intelligence included external agencies, 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 APSP because they don’t involve the public shouldn’t be recorded as APSP.

We found Surrey 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.

Surrey Police has produced a comprehensive counter-corruption STA. It identifies the force’s main corruption risks, for example sexual misconduct (including APSP), inappropriate disclosure of information, inappropriate associations and vulnerability (sexual vulnerability, alcohol abuse, gambling and financial issues). It also identifies an emerging threat: theft and fraud.

The force publishes an edited version of the STA on its intranet and uses posters to raise awareness of corruption threats across the workforce. We found the ACU hadn’t made the JFVU aware of the STA. It 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 force has listed the action it plans to take to address the threats under the headings intelligence, enforcement, prevention and communication/engagement. The control strategy doesn’t identify who has responsibility for each of these actions. This means there may be a lack of accountability around 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. The force has a current implementation plan. The plan covers all corruption threats identified in the STA, and some other commonly encountered corruption threats. The ACU has a designated person as a point of contact for each action on the plan. ACU managers monitor progress against these plans at a monthly tasking and co-ordinating group meeting. They also carry out a six-monthly review.

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.

Surrey Police has an established process to identify police officers and staff who may pose a corruption risk. The force holds a people intelligence meeting every month. Attendees include personnel from a wide range of departments across the force.

When an individual is identified as a corruption risk, the force considers referring them to the people intelligence meeting. Using all the available data, the ACU researcher writes a report on the potential risk the person poses. Attendees discuss each case and agree a risk mitigation plan. The ACU is responsible for implementing the plan and keeping written records of the action it takes.

The PSD has a daily tasking meeting to discuss complaints and conduct matters that have been reported in the preceding 24 hours. There is a fixed agenda, which includes an update of previous actions. Managers from the JFVU don’t attend this meeting. We encourage them to do so online.

Partnership working to identify potential corruption

The force 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. It means the force is more likely to gather corruption intelligence relating to the potential sexual abuse of vulnerable people by police personnel and safeguard potential victims.

The ACU has provided several APSP presentations to a range of external agencies, such as domestic abuse support agencies, children’s services and NHS services. The presentations are designed to help staff in these organisations understand the warning signs of APSP and how to share information with the ACU.

The force has a clear plan to provide these training presentations to raise awareness of APSP to other external bodies.

Managing corruption threats

Intelligence development

We reviewed 60 corruption intelligence files. The ACU consistently responded effectively and used a variety of techniques to develop the intelligence.

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

Four 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, 30 resulted in an anti-corruption investigation. We found the standard of investigation was good in all 30 cases. However, in four misconduct investigations we disagreed with the final determination. In a case involving an allegation of sexual misconduct, investigators didn’t interview the senior police officer concerned. They should have. And in three other cases, the force allowed the personnel to resign before the case had been finalised. Two of the cases involved members of staff and the third involved a police officer. All three should have been progressed to a gross misconduct hearing.

In contrast to the PSD’s complaint and conduct investigations, which we mentioned earlier, every case had an investigation plan that 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 matrix to help manage officers and staff who may pose a corruption risk of a sexual nature. The ACU identifies them through intelligence reports and information from public complaints and misconduct reports.

The ACU researches all known intelligence and previous reports on personnel on the matrix. They carry out a risk assessment to categorise the level of risk posed. The force records any action it takes to investigate or mitigate the risks. During our inspection, we found the ACU dealt with sexual misconduct-related intelligence effectively using its risk matrix.

Capacity and capability to investigate corruption

The ACU is a small team of experienced intelligence officers, investigators, two systems auditors, an analyst and a researcher. All ACU investigators have completed the College of Policing silver or bronze counter-corruption course. ACU personnel have a range of experience and skills with some having backgrounds in protecting vulnerable people, serious and organised crime investigation and intelligence. The ACU makes good use of a serving special constable, an IT specialist, to support some of its counter-corruption work.

Staffing levels mostly meet current demand. However, the force recognises ACU workloads are increasing and there is limited resilience within the unit. The force told us that the number of corruption-related intelligence reports the ACU had received had increased by 20 percent in the previous year. This followed a 28 percent increase from the year before. We would encourage the force to continually review the ACU’s capacity to make sure it is able to maintain its current level of counter‑corruption activity.

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. We saw good use of covert tactics to both develop intelligence and support corruption investigations. We didn’t identify any missed opportunities to use covert tactics.

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. We 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.

The force’s corruption prevention policies are comprehensive and reflect APP guidance. Generally, we found officers and staff had a good understanding of them. But unusually, some parts of these policies are managed by the JFVU rather than the ACU.

Notifiable associations

The force should review its processes to manage notifiable associations more efficiently.

Officers and staff notify the JFVU of any notifiable associations using an online form. Additionally, some new applicants may disclose such associations during the vetting process. In all cases, JFVU personnel record the type of association, frequency of contact and level of criminality. They then use a matrix to grade the association based on the perceived level of risk.

Having completed the risk assessment, the JFVU refers all notifiable associations to the ACU. The ACU routinely carries out a further risk assessment process. As the ACU has access to a wider range of intelligence sources, it may identify additional risks. This is a duplication of effort. The first review carried out by the JFVU isn’t necessary. In most forces, notifiable associations are managed solely by the ACU.

ACU staff record all notifiable associations on a register. They then take appropriate action to mitigate any risk. This includes audits of force IT systems to identify any misuse. ACU supervisors review cases graded as medium or high risk and update the JFVU.

Where an individual has disclosed they have a notifiable association, the ACU informs their supervisor and shares any restrictions it has applied.

At the time of our inspection, the JFVU had received 771 notifiable association reports. These consisted of 33 high-risk cases, 56 medium and 682 low.

Business interests

Although the force has a business interests policy, some aspects of its processes to manage them aren’t effective.

The JFVU is responsible for managing Surrey Police’s business interest applications. Personnel can submit applications to the JFVU online. They are recorded on the vetting IT system.

The JFVU 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.

Vetting caseworkers authorise business interests. If there are any concerns, a supervisor makes the decision.

The ACU isn’t involved in the process. This means any intelligence ACU holds isn’t considered before a business interest is authorised. Corruption-related intelligence should inform every business interest decision.

Every three months, the JFVU sends a list of business interest authorisations and rejections to the head of PSD. They are responsible for reviewing the authorisations and documenting that they have done so. Three months is too long a period. We suggest the review should take place monthly.

We saw two business interest applications that appeared to be an extension of the applicant’s policing role. Applications of this type would normally be refused, but the JFVU had authorised them. The head of PSD had already queried the authorisations, and they were being re-considered.

Line managers are responsible for monitoring compliance with any conditions imposed including checks to make sure the officer or staff member is complying with a refusal decision.

At the time of our inspection, the force had authorised 610 business interests. In the 12 months before our inspection, the force rejected 9 applications.

The JFVU reviews business interest authorisations every 12 months. It also reviews business interest authorisation for police personnel who submit a change of circumstances notification.

The business interests policy requires officers and staff to declare voluntary work. The JFVU reviews authorisations every three years.

Gifts and hospitality

The JFVU keeps a record of all gifts and hospitality. Officers and staff must submit an online form to the JFVU to notify the force of any gifts and hospitality they are offered. They must ask for approval from their line manager and departmental head to keep the gift or accept the hospitality.

JFVU personnel decide whether it is appropriate to accept the gift or hospitality. The document used to record this decision is too complex and time consuming. We suggest that the force reviews it.

The force publishes its gifts and hospitality records online.

Sexual misconduct

The force recognises APSP as serious corruption. In the counter-corruption STA and control strategy, the force lists APSP as one of the main threats it faces.

We found the ACU records these cases correctly. It consistently refers them to the IOPC.

Of the 60 ACU corruption intelligence files we reviewed, 12 related to APSP. We found all these cases had been handled well.

The force told us the ACU and PSD routinely provide training 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. The force told us that, at the time of our inspection, 91 percent of its personnel had completed it.

Surrey 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 Surrey Police