A report into the effectiveness of integrity arrangements in Sussex 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 Sussex 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	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

Sussex 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

The JFVU provides the vetting function for both Sussex Police and Surrey Police. The JFVU uses the latest version of a vetting IT system, which it first introduced in Sussex in about 2006.

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 changes.

The JFVU and HR have recently introduced a process where the two departments can access a shared Microsoft Teams channel. They each 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

Sussex Police told us that, as of 21 October 2024, it had a total of 5,605 police officers, special constables, police staff and police community support officers.

The force told us that there were 181 personnel who don’t hold current vetting or the right level of vetting for their role. At the time of our inspection, there were 53 people in force whose vetting had expired. This meant they didn’t hold a valid vetting clearance for their role. The oldest one expired on 10 June 2024. Of these, 35 were in posts designated for a higher level of vetting, management vetting (MV). A further 128 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. This is a risk recorded on the force’s risk register. The force vetting manager (FVM) closely monitors vetting workloads and reports weekly to the PSD senior management team. Since March/April of 2024, vetting demand has been outstripping the JFVU’s capacity. To address this, the force recently recruited a further five vetting caseworkers. The JFVU now has 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 the productivity of the JFVU for several months.

The JFVU manages renewals on the vetting IT system. At the time of our inspection, the force had a workload of 1,178 applications awaiting processing. The force acknowledged that it isn’t taking effective steps to prioritise higher-risk cases within this workload. 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 received any additional training for this role and don’t have access to the corruption-related intelligence held by the ACU. The JFVU told us this additional workload is having an adverse impact on the unit’s ability to meet day-to-day vetting demand. In most forces, vetting units don’t have these extra responsibilities. We urge both forces to reconsider the allocation of this work, particularly as we found staff in the ACU duplicate some aspects of the notifiable association process.

The JFVU and HR work together effectively to predict demand. The 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. But 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. The JFVU has granted this clearance to 2,976 people in Sussex. At the time of our inspection, 20 contractors had expired vetting. All 20 were being re‑vetted. The oldest case dates to 8 August 2024.

Departments that have responsibility for contractors inform the JFVU when they are no longer in contract. The JFVU then reviews their vetting status. If the JFVU removes vetting or it expires, it tells the relevant department to cancel the individual’s access to police premises, and the IT department to remove their access to 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 the 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. It tells 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 891 designated posts and maintains a list of them. There are 1,625 people in these posts. When HR creates a new post, the vetting manager determines if MV is necessary and updates the designated posts list. The force last reviewed its designated posts list in June 2024.

Sussex Police isn’t managing its MV process effectively. Until recently, the force was allowing some individuals to take up a designated post without the JFVU granting MV clearance. The JFVU told us it has now agreed a process with HR to make sure that this will no longer occur.

The JFVU told us there are 163 people who are in a designated post without MV clearance. Of these, 35 had expired MV vetting. And the force had placed 128 people in designated posts without granting them MV. But the force doesn’t have a full understanding of the risks associated with having this many designated postholders without MV clearance. For example, the JFVU couldn’t readily provide us with additional information about these posts. We asked which roles the people occupied or for how long they had been in post without MV. But the JFVU couldn’t tell us.

The force should make sure it has an effective process to give continued assurance that designated postholders always have the requisite 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.

Sussex 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 intelligence from the anti-corruption unit, from all forces in which the individual has previously served.

Sussex Police 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.

If an officer who wants to transfer from Sussex 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 has used force-wide communications and publishes reminders of this in the PSD publication.

The force now requires all its police personnel to complete an annual integrity review. This review includes any changes of circumstances. The force told us that 73 percent of the workforce have now completed the annual integrity review.

When members of the workforce report changes of circumstances to the JFVU, it makes vetting enquiries. This is to identify risks so it can decide if the person’s vetting status is affected.

The force told us there were 319 change of circumstances notification reports in the JFVU workload awaiting risk assessment. The oldest of these arrived in the JFVU on 23 July 2024.

We spoke to some officers and staff. Individuals we spoke to were aware of the requirement to report changes of circumstances.

Misconduct vetting review

The PSD informs the JFVU of all misconduct meeting or misconduct hearing outcomes. The JFVU 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 2 years preceding our inspection it had completed 38 post-misconduct reviews. The force showed us an example of a police staff member who received a final written warning after being arrested for stalking and harassment. The JFVU reviewed the individual’s vetting and imposed a postings restriction as an additional risk mitigation measure.

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. They 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 when the case is complex. The FVM doesn’t usually make initial vetting decisions. The head of vetting is the decision-maker for post-misconduct reviews.

In other respects, 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 referred 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 case file review, we found five cases where the applicant wasn’t interviewed when it would have been beneficial. This would have helped decision-makers clarify details 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

Sussex 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 risk 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. The force has very recently shared the contents of this assessment with vetting decision-makers in the JFVU. This is in line with the vetting APP. The force should continue to do this annually, so that vetting decision-makers stay up to date with the force’s main corruption threats.

Vetting appeals

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

When an external candidate submits an appeal, it is sent to the appeal officer who is the FVM, unless they participated in the original refusal decision. In these cases, the head of vetting becomes the appeal officer.

For internal candidates who have their vetting refused or revoked there is an appeal panel. 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.” During our vetting files review, we found evidence that the HR representative on the panel has in the recent past been directly involved in vetting appeal decisions. The involvement of the HR manager in the panel’s decision-making in this way is contrary to the Vetting Code of Practice. The JFVU showed us a guidance document the force has prepared to clarify the role of the HR representative as being purely advisory. But, at the time of our inspection, the force hadn’t issued the guidance. The force should take steps to make sure its vetting appeals process complies with the Vetting Code of Practice and APP.

Quality assurance

Sussex 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 of its vetting caseworkers. The FVM dip samples three cases per supervisor. This can include both approvals and rejections. The head of vetting quality assures the FVM’s appeal decisions.

This process appears to be effective. It helps the JFVU to give feedback to decision‑makers. The force told us of examples where it had overturned clearance decisions following these quality assurance checks. Previously the selection of cases to dip sample was random. But, as the JFVU provides vetting for two forces, it has recently adjusted its dip sampling to make sure there is equity in the quality assurance process across both. 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 analysed the vetting data. The force race board reviewed this analysis. The JFVU has attended a community leaders forum to explain the force’s vetting arrangements.

At the time of our inspection, 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 at the time of our inspection 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 22 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 17 of the force’s decisions. But in the remaining five cases the recorded rationale didn’t consider all identified risks or relevant risk mitigations. For example, there were three cases where the force didn’t obtain all available information before reaching a vetting decision. In these cases, the force didn’t consider all risks or relevant risk mitigation. We also saw two post-misconduct review decisions where the force hadn’t fully considered the risk or mitigated it when the individual was granted continued vetting clearance.

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

Sussex 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

Chief officers demonstrate and clearly communicate the expected standards of behaviour to the workforce. The force publishes leaders’ blogs on themes such as integrity and racism and those staff we spoke to found the content informative, interesting and thought provoking.

The deputy chief constable holds a virtual fortnightly forum in which senior leaders discuss themes including integrity and professionalism. Recent examples were attendance management and the importance of keeping in touch with those on sick leave.

The deputy chief constable also meets with all probationers during their initial training weeks. And the PSD provides training to probationers, including on their first day and twice before they patrol independently. The training emphasises that officers hold a role with extensive powers, which comes with a responsibility to exercise them in a professional manner.

The force provides as needed integrity and professional standards training to new police staff on joining the organisation. However, the training it provides isn’t as developed as that given to new police officers.

The PSD also gives training to transferees. This includes material on notable complaint and conduct cases and advice on how to report wrongdoing.

All newly promoted sergeants and inspectors receive formal training on the standards of professional behaviour. This is to outline to supervisors what their responsibilities are and to help equip them with the skills and knowledge to maintain professional standards within their teams. The PSD also attends continuing professional development events for local supervisors to reinforce this learning. These include training on the Police Race Action Plan and how to put it into practice.

The PSD works with a dedicated member of the force’s communications team. They co-ordinate PSD messaging and share it with the workforce via email or intranet publication. However, it is unclear whether the process around what to publish is sufficiently structured. And it is not clear whether it actively takes account of all available learning.

The force publishes the outcomes of gross misconduct cases on its intranet. Members of the workforce we spoke to were aware of this and could describe the identified learning. For example, the use of force, making inappropriate comments, and the unauthorised access of information.

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

Sussex Police hasn’t formally evaluated how well its workforce understands the standards of professional behaviour.

However, it tries to determine this in informal ways. These include, for example, changes in the volume of requests for advice, referrals following the publication of learning and reporting individual changes in circumstances.

The force checks and reinforces the standards of professional behaviour during its annual performance and development review process. Additionally, as part of the promotion processes, the force often assesses candidates against a professional standards scenario.

The PSD continually works with managers in local divisions and departments to provide bespoke information on emerging complaints and conduct trends. The PSD can interrogate the data and information it collects down to individual employee level. This means the force can use targeted interventions to enhance understanding and improve standards. For example, the PSD was receiving specific report types relating to one department. The PSD investigated these and as part of the resolution, recommended bespoke departmental training.

Organisational learning

Sussex Police doesn’t have a clear process for the collection and sharing of PSD‑related organisational learning.

There is a joint Surrey and Sussex organisational learning board. Sussex’s own culture and standards board underpins this. The Sussex deputy chief constable chairs both. Agenda items include complaint and conduct data, updates from the Ethics Committee, and progress on national learning including the Baroness Casey Review and the Angiolini Inquiry. Both boards identify and assign key learning at a strategic level, but this doesn’t appear to consistently reach the wider workforce in Sussex.

Independently from the force’s learning boards, the PSD identifies and shares learning to the wider workforce. However, this is also not consistently received, understood, and acted upon at a local level.

We believe there are opportunities for the force to improve these processes so that 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 has oversight of PSD performance through a series of governance and assurance meetings which senior PSD managers attend.

There is a scheme of delegation which sets out decision-making responsibilities within the PSD. There are six appropriate authorities. Primarily, the three detective inspectors lead on initial assessments, and one detective chief inspector carries out final determinations. The deputy head of PSD also carries out some gross misconduct final determinations to ease workload pressures at this stage.

The PSD public confidence team deals with complaints resolution and handling. There are six established full-time posts. However, at the time of our inspection, there was one vacancy, and the force had moved one postholder to help a volume crime investigation team outside PSD. This has contributed to a backlog of complaints. At the time of our inspection more than 300 complaints were awaiting allocation, the oldest was logged 6 weeks prior.

The force told us that approximately 25 percent of all logged complaints are typically allocated to divisions and departments outside PSD. Sussex Police has limited capacity outside PSD to deal with these complaints. This affects the quality and timeliness of local complaint handling.

Timely resolution of complaints is key to maintaining public confidence, so this is a concern. As such, the PSD has recorded the demand on the public confidence team on its risk register. The PSD has introduced a new triage process to speed up the allocation of complaints based on the threat, harm and risk posed. But capacity is still key to a longer-term solution.

The PSD investigators told us there was enough capacity for them to carry out their roles. Having a dedicated PSD meetings and hearings officer further helps with investigative capacity. Workloads were varied but investigators described them as high but manageable.

We found that in our review of conduct cases, some matters that the PSD were investigating and allocating resource to were low level performance issues. We encourage the force to empower supervisors to address these locally before considering referral to the PSD.

Training and experience within the professional standards department

The force recognises PSD as a complex, specialist policing field and has appointed senior leaders within PSD with considerable senior detective, operational and public order command capability. This affords the PSD visibility and credibility outside the department.

All appropriate authorities have completed the relevant College of Policing endorsed training course, except for one, for whom the course is scheduled.

All PSD investigators have been on their College of Policing endorsed course. Those joining the unit receive training at the earliest opportunity. All investigators are either professionalising investigations programme (PIP) level 1 or 2 trained. All supervisors are PIP 2 trained apart from the public confidence team inspector who is working towards it. The force provides ongoing training, including material from its solicitors and the Independent Office for Police Conduct (IOPC), covering a range of topics such as how to carry out investigations and what to include in an outcome report and letter to complainants.

The force should continue to develop formal induction training for new PSD starters. We understand that this is at an early stage of development and appears to be something that the PSD workforce would welcome. The department has previously created very detailed process maps for conduct and complaint investigations. But PSD officers and staff we spoke to hadn’t seen them.

The public confidence team sergeant trains new divisional and departmental supervisors to effectively deal with complaints allocated to them. Despite this, the PSD has identified issues with the quality and consistency of locally handled complaints, such as with the content of outcome letters. The public confidence team inspector identifies repeat themes and provides these to local leads at monthly meetings to promote improvements.

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 the force website, contact centre and the IOPC website. It also gets complaints by direct reporting to officers or staff, the enquiry office, or the office of the police and crime commissioner.

Sussex Police is inconsistent in its compliance with the IOPC statutory guidance in its logging and initial handling of complaint and conduct cases.

The majority of complaints the force receives are dealt with by the public confidence team. In some cases, the PSD passes complaints to divisions for them to locally handle. These will either be those suitable for service recovery or those which can be handled otherwise than by investigation. They generally involve matters that need enquiries which the public confidence team can’t easily make.

Locally based chief inspectors oversee the handling of these complaints. The PSD told us they stay engaged with local divisions and departments offering an advice and quality assurance service. The public confidence team detective inspector maintains a central overview of these cases on Centurion, chairing a meeting with local leads to offer support and maintain timely progress.

At the time of our inspection, there was a considerable backlog of complaints awaiting allocation. The PSD has introduced a triage system to make sure it promptly allocates cases needing priority action. Many of the complaints the force receives would ordinarily be deemed suitable for dealing with outside Schedule 3. The IOPC expects the force to deal with such complaints in a timely manner. At the time of our inspection, this was a challenge for the force.

We reviewed 10 complaints that the force resolved outside Schedule 3. We found the force’s decision to do this was suitable in all of them. However, the sample reviewed showed that in less than half the cases, the complaint handler hadn’t contacted the complainant to fully understand their complaint. There was a correlation between this and the complaint handler also not making basic enquiries.

The PSD doesn’t record complaints as soon as possible once it identifies that it should record an allegation under Schedule 3. In 7 out of 20 complaints we reviewed, the force recorded them on Centurion within 1 to 2 working days. In 10 out of the 20 cases, it took more than 9 working days to record the complaint.

The force needs to make quicker decisions about how to handle complaints. In 19 out of 20 cases we reviewed, the force took longer than 14 days to make the handling decision. However, the way the force handled the complaint was correct in all cases we examined. In 13 of 20 cases, the PSD made relevant enquiries with other areas of the force before making this decision. The PSD documented its handling decision‑making rationales in 16 out of 20 complaint cases. The four cases where it hadn’t documented rationales, the force handled them otherwise than by investigation.

The PSD is responsible for all complaints with discrimination allegations. It asks for guidance from the force race equality network for relevant complaints. This occurs at appropriate stages of the complaint, including the initial assessment.

Initial handling of conduct matters

The PSD records conduct matters within a suitable period after it comes to its attention. Statutory guidance states the force should do this as soon as practicable. In 14 out of 20 cases we reviewed, the force recorded the matter within 1 to 2 working days. It recorded the remaining six within three to eight working days.

The force correctly handled conduct matters in 17 out of 20 cases we reviewed and did so in a timely manner. In 13 out of 20 conduct cases, the PSD made a handling decision within 1 to 2 working days. However, in 2 cases, it took more than 14 working days to make a handling decision. In 17 out of 20 cases, the PSD made relevant enquiries with other areas of the force before making this decision.

In 15 out of 16 cases that needed a severity assessment, the appropriate authority’s initial severity assessments were reasonable and proportionate. In most cases there was evidence of the appropriate authority reviewing these as the case progressed.

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 our case file review, we identified one case that needed a mandatory referral to the IOPC. The force had correctly identified and referred this. In addition, during our fieldwork, we also observed the PSD’s weekly meeting where the PSD referred a complaint of abuse of position for a sexual purpose (APSP) to the IOPC the same day.

In 9 of the 40 cases we examined, there was an allegation of police criminality. These included a potential offence of misconduct in public office under common law. And other offences contrary to the Perjury Act 1911, and the Serious Crime Act 2015. The investigator acknowledged that a crime may have been committed and recorded it on Centurion in seven of these cases. The two cases where the force didn’t acknowledge it was in relation to a sexual touching offence and a data protection offence.

It may, in some cases, be proportionate to deal with a matter as internal misconduct rather than as a crime. But the force should document a clear rationale for this decision.

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.

We found the public complaints process on the force’s website to be accessible and user friendly. There are links throughout the website directing users to the correct sections.

People complaining through Single Online Home, by phone and in person, have opportunities to use language line, forms in other languages, and in Braille.

We found no evidence of any specific force initiatives to make sure its complaints system is accessible to harder-to-reach groups. People in these groups may be less trusting and need reassurance that the force will consider their complaint fairly and deal with it appropriately.

Sometimes, public complainants require additional support during the complaints process. For example, where they have a disability such as a visual impairment. We found that the force doesn’t consistently support complainants who may need assistance. Of the 20 Schedule 3 complaint cases we examined, complainants may have required additional support on 3 occasions. The force identified the need for additional support in one of them. We didn’t see evidence of the force providing additional support on any occasion. Two of the complainants in these cases were experiencing mental health issues and the other was a male who was the victim of domestic violence.

The force should make sure that it consistently considers the needs of complainants, records this, and provides it where necessary.

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.

Sussex Police documents its PSD complaints and conduct processes from initial handling, through investigation to conclusion. These process maps are very detailed. They encourage compliance with relevant legislation, identify who is responsible for what and when, and highlight timescales. The maps cover initial handling, through investigation to conclusion. But not all PSD officers and staff we spoke to had seen them.

During our casefile review, we found that the force consistently investigates complaints to an acceptable standard. This was true in all four complaints that were subject to an investigation. We found the outcomes of these to be reasonable and proportionate.

However out of 16 misconduct investigations, the force didn’t complete 6 to an acceptable standard. The issues we identified included not following all reasonable lines of enquiry, a lack of engagement with interested parties, and minimising concerning behaviours.

In the five cases where the force didn’t follow all reasonable lines of enquiry, three related to domestic violence matters. The PSD followed up minimal, if any, misconduct lines of enquiry once the force had concluded the criminal investigation. The force didn’t adequately review the evidence in the criminal case to determine whether misconduct proceedings were justified. Instead, it took the closure of the criminal case to be a closure of any potential misconduct also, despite the burden of proof being different. The PSD told us that it had recently adopted a more thorough approach to reviewing potential misconduct aspects where the criminal investigation has ceased.

We found the PSD didn’t always prepare terms of reference and investigation plans. Nor did it always document its decision-making and rationale. In our case file review of 20 complaint and conduct investigations, we found that the force had completed terms of reference in 16 of the 20 cases. And that it had recorded and provided reasons for its decision-making in 17 of the 20 cases.

However, the PSD had prepared an investigation plan in only 6 of the 20 cases. We made a recommendation relating to investigation plans in our 2022 national report, ‘An inspection of vetting, misconduct, and misogyny in the police service’. Sussex Police has still not implemented this recommendation.

We also found in our case file review that investigators weren’t always allocating their time proportionately to the highest priorities. For instance, we saw a case of a member of the workforce shopping during duty time that was given as much investigative priority, time and effort as, for instance, cases involving alleged criminality. PSD supervisors and managers should be overseeing such investigations and monitoring the proportionality of the response.

The PSD resolved 16 out of 20 complaint cases otherwise than by investigation, which we found to be a proportionate approach. Of these cases, complainants exercised their right to review in eight. The review body partially upheld one due to an administrative issue.

The PSD is inconsistent in how it records the reflective practice review process against officers on Centurion. In our case review, the force resolved four cases relating to public complaints this way. However, the PSD didn’t record the reflective practice review process on Centurion against the correct officer. Whereas the force recorded it correctly in seven out of eight misconduct cases.

Additionally, we found the PSD is storing case documents in multiple locations and has no consistent approach to recording progress entries. There is no defined naming convention for documents or regular use of the investigation tab. There are clear opportunities for the force to standardise the use of Centurion to assist supervisors and auditors.

The force told us it had a process for supervisors to review investigations. There are 28-day reviews by a sergeant and 90-day reviews by a detective inspector. There is also a diarised four-weekly PSD supervision meeting to review significant cases. However, in our case file review we only found evidence that regular, meaningful supervisory oversight occurred in only 8 out of 20 cases.

In sub judice cases where there is a criminal matter linked to a misconduct investigation, the force has a long-established documented process to assist decision‑making. The PSD expects its investigators to always look for opportunities to progress conduct matters while not prejudicing the criminal case. The PSD gave us an example where an officer had been arrested for possessing indecent images of children. It was arranging with the criminal team to use a small number of the images to start misconduct proceedings. However, some members of the workforce we spoke to expressed frustration about the delays encountered in cases considered sub judice. And that a perception exists that the force is risk averse in progressing such cases.

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.

Sussex Police did consider the welfare of accused police officers and staff. But the support it gave to those making internal conduct allegations and to witnesses was less formalised.

Sussex and Surrey Police have a joint approach to providing welfare support to officers. There is a joint 17-page guidance document for those performing the roles of welfare officer and secondary welfare officer.

Sussex Police appoints a welfare support officer to people who are the subject of a misconduct or complaint investigation. The force completes a duty of care risk assessment form which informs the level of support required. And it makes referrals to other services and agencies where appropriate. The force will form a gold group for more serious cases where welfare will be a specific consideration.

However, there are opportunities for the force to improve how the provision of welfare officers works in practice. There is no face-to-face training for welfare officers, only the guidance and a video. There is no oversight of how many times welfare officers meet with accused individuals, nor is the quality of any meetings monitored. The force doesn’t have a central register and doesn’t monitor how many cases a welfare officer is involved in. The force uses good welfare officers to such an extent that it becomes a burden for those individuals. We urge the force to take steps to improve the selection, training and oversight of welfare officers.

While the force provides officers and staff under investigation with welfare support it isn’t as definitive for those making allegations. The force has already identified this as a significant gap and is addressing it.

PSD investigators have monthly meetings with their supervisors to discuss workloads, welfare issues, and their objectives.

Suspension and restriction of members of the workforce

During our inspection, we checked whether the force documented its decisions about the suspension or redeployment of the accused person during an investigation. And we examined whether the force was using accelerated procedures appropriately.

Sussex Police doesn’t have a specific policy on the suspension and restricted duties of police officers. But it provides guidance to officers and staff within a wider document covering many aspects of a PSD investigation.

The force has produced a duty of care risk assessment for those facing a gross misconduct investigation, a criminal investigation or those it has suspended from duty. The force has also produced a comprehensive guidance document for individuals it has suspended or restricted while facing a misconduct investigation.

We carried out a casefile review of 14 relevant cases. In all of these, the force considered and documented suspension or restriction considerations appropriately.

The PSD told us it works collaboratively with other departments regarding the redeployment of restricted officers. It also considers vetting requirements in connection with this.

The deputy chief constable authorises all suspensions and reviews these every 28 days. At the time of our inspection the force had suspended 23 individuals.

Some members of the workforce told us there is a perception the force uses suspension too readily. They told us this has a negative effect on workforce confidence, given that investigations are often lengthy.

Sussex Police uses accelerated procedures where appropriate in misconduct cases. This is so police officers appear quickly before the chief constable who can dismiss them if appropriate, where there is incontrovertible evidence of gross misconduct. The force told us that from 2021 to the time of our inspection, it had carried out 18 accelerated misconduct hearings (AMH). But only one since the beginning of 2024. The force recognised there may be opportunities to use AMH more effectively. And that, at the time of our inspection, it uses AMH only where the case and evidence is incredibly straightforward. This means the force is potentially retaining officers longer than necessary at continued cost to the taxpayer. It also has a negative effect on the accused officer’s welfare.

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 in 19 out of 20 complaint cases that we felt the force provided an acceptable standard of service. This applied for cases dealt with by investigation or otherwise than by investigation.

But the force could improve its initial handling of public complaints. As stated previously, the force is delaying the recording of complaint cases and its initial handling decisions. We found that in 10 out of 20 cases we examined, the force took more than 8 working days to record them. And in the 4 cases requiring an investigation the force took more than 14 working days to make the handling decision. However, we found evidence that where complainants engaged with the investigation, the force provided them with regular and meaningful updates.

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

During the same period, the IOPC reviewed three 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 for Sussex finalised 216 reviews during that same period. It found the outcome that wasn’t reasonable and proportionate in 30 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

Sussex Police shares relevant information between departments and has an established process for doing so.

The PSD holds a weekly meeting, attended by vetting, ACU, public confidence team, HR, media and legal services, to discuss relevant cases and share information.

The force also has a well-established monthly people intelligence meeting. The head of PSD chairs this meeting, and people from vetting, HR, ACU, PSD and representatives from divisions and departments attend. This meeting considers officers and staff that pose the greatest risk. We saw that the meeting raised a significant number of actions (130 in 2024). The force circulates the meeting agenda in advance which includes a review of previous actions. We observed good discussion, exchange of information and collaboration between various departments. Topics covered ranged from sexual misconduct concerns, financial vulnerability, business interests, notifiable associations and employment tribunal issues.

The PSD told us it led on the introduction of ‘the problem oversight group’. This is attended by PSD, HR, and learning and development representatives to oversee The Police Regulations 2003 Regulation 13 procedures. The group covers cases being considered for the Regulation 13 process and shares relevant information. The group aims to make sure that Regulation 13 is applied fairly, especially in cases involving protected characteristics.

The culture and standards board meets quarterly. Relevant heads of department, including from PSD and employee relations/people services, attend. This meeting discusses trends from complaints and conduct cases. It also covers any national learning, for example recommendations from the Baroness Casey Review and the Angiolini Inquiry. The aim of the board is to prevent poor behaviour and promote professionalism by sharing learning.

In our review of complaint and conduct files, we found that the force, in most cases, did consider relevant information prior to making its handling decision.

The PSD regularly notifies the FVU of the outcome of misconduct proceedings so the force can review the individual’s vetting status.

The consideration of relevant information

In our case file review, we saw evidence that in most cases 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

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.

Sussex Police has produced a seven-page scheme of delegation document dated May 2024. In this document the force outlines the required decision-making authority level from the rank of police inspector or police staff equivalent upwards. It includes the provision for an assistant chief constable or above to chair an AMH.

To encourage consistency, fairness, and proportionality across initial assessments and final determinations, the force has introduced a quarterly appropriate authority continuing professional development meeting. This helps learning and discussion between the appropriate authorities on significant, discrimination and linked complaint and misconduct cases.

The force doesn’t carry out any formal analysis to establish if there is any disproportionality (across the nine protected characteristics) within its investigations and decision-making. To fully understand whether disproportionality exists, the reasons for it, and to address it, the force should carry out detailed analysis across the nine protected characteristics.

The force told us it is trying to understand the reasons behind disproportionality. The PSD consults with diversity networks for advice and guidance at decision-making stages. In addition, the force has an ongoing programme to review disproportionality regarding all the protected characteristics. It has reviewed vetting, and it will consider PSD investigations next.

However, throughout our interviews, focus groups and reality testing, we spoke to members of the workforce who believed that there was other disproportionality in decision-making and outcomes. They believed, through what they had heard, that there was disproportionality between the treatment of police officers and staff. And they felt that the force doesn’t consistently hold police officers accountable for their behaviour in a way that is proportionate and fair, especially in relation to more senior officers. Some members of the workforce stated that recent misconduct investigations lacked transparency. They said this undermines the credibility of the system.

The force told us it is taking steps to manage misinformation and had introduced a rumour control function within the force intranet. Members of the workforce can submit what they have heard, and the force provides an accurate response. The force has introduced this to help the workforce understand the proportionality and consistency in misconduct decision-making.

We urge the force to consider other urgent steps it could take to improve the workforce perception, trust, and confidence in the way it deals with complaint and misconduct matters.

Tackling potential corruption

Sussex 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

Sussex 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 a dedicated IT auditor. The auditor has identified the key processes needed to effectively audit the access of data across all the force’s IT systems. The IT auditor makes sure that all ACU staff can use these processes during their investigations. And the force told us it was working on a project to further develop its IT monitoring capabilities, with a scheduled ‘go live’ date in March 2025.

The force told us that it had identified the need for a second ACU systems auditor. The force plans to increase the ACU’s establishment accordingly. However, it has yet to fill the vacancy. This has affected the ACU’s capacity to carry out routine proactive IT audits. By not proactively monitoring activity on mobile and desktop devices, the force may be missing opportunities to identify potential misuse including improper contact with vulnerable victims.

The force uses its IT monitoring capability to enhance its anti-corruption investigations and to monitor personnel when intelligence shows they may pose a higher risk. The ACU identifies these individuals through analysis of intelligence reports, and in response to information from public complaints and reports of misconduct. A single point of contact within the ACU 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.

The Sussex Police ACU is involved in the procurement of new IT systems. A senior business partner from the ICT 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, the ACU auditor regularly tests the force’s auditing capability and reports 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 about 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.

Sussex Police can identify which members of the workforce are accessing different IT systems. The ICT department maintains a register identifying all mobile devices and to whom they are issued. ACU staff have access to this register. During our inspection, we found that this 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 inspection, Sussex Police’s IT monitoring software has overcome this.

Sussex Police permits the use of encrypted apps on its devices, and the ACU routinely monitors all workforce communications on these apps. However, as encrypted apps are constantly being updated, the force will need to satisfy itself that its monitoring remains effective.

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 public engagement, but they must use them professionally and securely. The corporate communications team must approve all new force accounts and maintains oversight of 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 showed 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

Sussex Police carries out only limited activities to routinely look for corruption-related intelligence. The force told us this was due to a lack of capacity within the ACU.

The force told us it does, however, carry out random drug testing. It has carried out 164 tests since 2023.

The force uses both an anonymous confidential reporting line, Breaking the Silence, and the national Crimestoppers integrity line. Between January 2022 and December 2022, it received 163 reports via Breaking the Silence, 223 in 2023 and 212 reports from 1 January 2024 up to the date of our inspection, 21 October 2024.

We examined 60 corruption intelligence files. In 15 of these cases, we found police personnel directly reported corruption-related intelligence to the ACU. A member of the public had made a report in nine cases. We only found one case that was the result of proactive intelligence work. Further sources of corruption-related intelligence included external agencies, 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 APSP because they don’t involve the public shouldn’t be recorded as APSP.

We found Sussex Police correctly categorises all corruption-related intelligence in line with the counter-corruption APP.

Identifying corruption threats

Counter-corruption strategic threat assessment

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

Sussex Police has produced a comprehensive counter-corruption STA. It identifies the force’s main corruption risks, for example sexual misconduct (including APSP), disclosure of information and computer misuse, and substance misuse. It identifies two emerging threats: length of service; and theft and fraud.

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.

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 using the 4P approach under the headings, prevent, prepare, pursue and protect. The control strategy identifies who has responsibility for each of these actions. So the force can hold individuals to account for completion of this work.

Implementation plan

The force should consider in detail each corruption threat identified in the STA and control strategy. It should address each threat within set timescales, through an implementation plan. The force has a current implementation plan. The plan covers all corruption threats identified in the STA, and some other commonly encountered corruption threats. Each action within the plan has a single point of contact nominated within the ACU.

However, during our inspection, we found the ACU wasn’t carrying out some significant actions it had identified in its control strategy. The force told us that ACU staff don’t have the capacity to complete them. Senior managers said they have no oversight of the implementation plan. The force isn’t using the STA, control strategy and implementation plan effectively to address corruption threats. We encourage the force to adjust its control strategy measures to focus activity on the specific threats, which it has identified through the STA process.

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.

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

When it identifies an individual 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 members of the workforce pose. The attendees at the meeting discuss each case, then agree a risk mitigation plan. The ACU is responsible for implementing the plan and keeping written records of the action it takes.

In many forces, the PSD has a daily tasking meeting to discuss complaints and conduct matters that have been reported in the preceding 24 hours. Sussex Police has chosen to hold its tasking meeting on a weekly basis. We would encourage the force to make sure its tasking meeting structure supports the timely exchange of information between PSD, ACU and the JFVU.

Partnership working to identify potential corruption

The ACU hasn’t established working relationships to build trust with external agencies and organisations. This would support vulnerable people and others who may be at risk of abuse by police personnel. The force is missing opportunities to safeguard potential victims. And it is missing opportunities to gather corruption-related intelligence about the potential sexual abuse of vulnerable people by police personnel.

Further, the ACU hasn’t provided any recent training on APSP to external agencies, such as sex worker support services, drugs and alcohol services and mental health charities. It last did so in 2023. Maintaining professional relationships with such agencies and providing them with regular training would help them to understand the warning signs and how to share information with the ACU.

This was a recommendation in our 2022 national report, ‘An 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. But, given the length of time that has elapsed and the relative ease of addressing this issue, this isn’t acceptable.

Despite this, during our file review, we found three examples of intelligence reports from agencies the force works with relating to suspected corruption.

Managing corruption threats

Intelligence development

We reviewed 60 corruption intelligence files. In 52 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 eight cases. These cases included three reports of sexual misconduct and five reports relating to unlawful disclosure of information. The ACU uses investigation plans. But we found that sometimes these missed some lines of enquiry, which would have been reasonable for the investigation to follow.

The force correctly identified the reports of sexual misconduct as APSP. But worryingly, it had finalised these cases before concluding all reasonable lines of enquiry.

Only one of the cases we reviewed resulted from proactive intelligence collection. As we described earlier, the ACU isn’t making effective, proactive use of IT monitoring and other intelligence collection methods.

Corruption investigations

Of the 60 corruption intelligence files we reviewed, 24 resulted in an anti-corruption investigation. We found the standard of investigation was good in 21 of these cases.

However, in three further cases related to APSP, we found shortcomings. In all three cases, the force closed the investigation before making all relevant enquiries. Further, Sussex Police should have referred these cases to the IOPC. But in each case the force hadn’t done so. In one case, the force allowed the police officer concerned to resign while under investigation. It then closed the case. That investigation should have continued.

Overall, it is disappointing to find that the force hadn’t taken all the appropriate steps to fully develop the intelligence or investigate the matter in 11 out of 60 corruption-related cases. This is a higher proportion of cases than we see in most other forces. The force could have avoided this with better use of investigation plans and more effective supervisory oversight of the cases.

We made recommendations relating to the quality of corruption-related investigations in our 2022 national report, ‘An inspection of vetting, misconduct, and misogyny in the police service’.

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 that individual poses. 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 people on the matrix. It then carries out a risk assessment to categorise the level of risk posed. The force records actions to investigate or mitigate the risks. Generally, we found good oversight of these cases. But we also found that the force could improve the matrix by incorporating additional factors to determine the level of risk. We understand the force now intends to develop its use of the matrix in this way.

During our inspection, we found the ACU dealt with most sexual misconduct-related intelligence effectively using its risk matrix. However, there was one case where an officer should have been assessed and included in the register but wasn’t.

Capacity and capability to investigate corruption

The ACU is a small team of experienced intelligence officers, investigators, a systems auditor, an analyst and a researcher. All ACU investigators have completed the College of Policing silver or bronze counter-corruption course. Police officers and staff within the ACU have a range of experience and skills. Some of them have backgrounds in protecting vulnerable persons, serious and organised crime investigation and intelligence. The ACU investigates all cases of corruption.

Staffing levels in the ACU don’t meet current demand. The force told us that due to this lack of capacity, ACU staff can’t look proactively for corruption. The force has recorded this as a risk on the force risk register. We have already noted that the ACU doesn’t have the resources to carry out the actions identified in its control strategy and implementation plan.

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 identified one case where the force was missing an opportunity 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. Our inspectors examine policies in:

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

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

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

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

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 aspects of these policies are managed by the JFVU rather than the ACU.

Notifiable associations

The force could improve some aspects of its process to manage notifiable associations.

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 staff record the type of association, frequency of contact and level of criminality. JFVU staff then use a matrix to grade the association based on the perceived level of risk. If the risk is assessed as low, the caseworker makes the vetting decision without any observations from the ACU.

Having completed the risk assessment, the JFVU then refers all notifiable associations to the ACU. ACU staff routinely carry out a further risk assessment process. As the ACU has access to a wider range of intelligence sources, it may identify additional risks. This process involves duplication of effort; the force carries out two separate risk assessments for each notifiable association. The first review carried out by the JFVU isn’t necessary. In most forces, the ACU manages notifiable associations.

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

ACU staff record all notifiable associations on a register. They then take appropriate action to minimise any risks. ACU staff audit force IT systems in all cases to identify any systems misuse. Supervisors in the ACU review cases graded as medium or high risk and send an update to the JFVU.

In cases where the staff member has made the disclosure themselves, ACU staff inform the individual’s supervisor of the association. They also tell the supervisor about any restrictions which they have applied to manage the risk.

At the time of our inspection, the JFVU received 1,144 notifiable association reports. These consisted of 43 high-risk cases, 75 medium and 1,026 low.

Business interests

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

The JFVU has responsibility for managing business interest applications for the force. The workforce can submit business interest applications to the JFVU via an online form. JFVU staff record these onto the vetting IT system.

JFVU caseworkers will only consider applications if the officer or staff member has a current performance development review. They must also have no misconduct issues, satisfactory attendance, and approval from their line manager and departmental head. The business interest policy requires officers and staff to declare voluntary work. The JFVU caseworkers authorise business interests. If there are any concerns, a JFVU supervisor will make the decision.

There is no ACU involvement in the authorisation process. So the force doesn’t consider any intelligence held by the ACU before it authorises a business interest. This isn’t an effective process to make sure that the force only grants an authorisation when it is appropriate. Corruption-related intelligence held by the ACU should inform every business interest authorisation decision.

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

The JFVU caseworkers meet regularly with the ACU to discuss business interests. The ACU will carry out checks to make sure the officer or staff member is complying with a refusal decision.

Local supervisors are responsible for monitoring compliance with any conditions imposed.

At the time of our inspection, the force had authorised 920 business interests. In the 12 months preceding our inspection, the force had rejected 19 applications.

The JFVU reviews business interest authorisations every 12 months, and every 3 years for voluntary work. The JFVU also reviews any business interest authorisation for police personnel who submit a change of circumstances notification.

Gifts and hospitality

The JFVU keeps records 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. Staff within the JFVU decide whether it is appropriate to accept the benefit. We found that the document used to record this decision was unduly complex and time consuming. We suggest that the force reviews this.

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 such cases correctly. But as we have already outlined, it isn’t consistently referring them to the IOPC.

Of the 60 ACU corruption intelligence files we reviewed, 11 related to APSP. We found only five cases had been handled effectively. As we described earlier, in the other six cases relating to APSP we found shortcomings in either the development of the intelligence, or the investigation. The force closed each of these cases before it had made all relevant enquiries. For instance, the force didn’t review body-worn video footage from previous incidents or carry out a full IT systems audit. The force should immediately implement measures to improve this.

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

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

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A report into the effectiveness of integrity arrangements in Sussex Police