A report into the effectiveness of vetting and counter-corruption arrangements in Essex 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, in the public interest. In preparing our reports, we ask the questions the public would ask, and publish the answers in accessible form. We use our expertise to interpret the evidence and make recommendations for improvement.

1.  Introduction

Vetting, IT monitoring and counter-corruption: good

In September 2021, we changed the way we report on how effectively forces manage vetting and counter-corruption.

Previously, we inspected these areas as part of our police effectiveness, efficiency and legitimacy (PEEL) programme and provided our findings in the inspection report.

The new arrangements mean we will inspect each force separately to PEEL, although we will continue to use the same methods and produce a report containing our findings, graded judgments and any areas for improvement or causes of concern. The report will be accessible via a web link from the most recent force PEEL report.

In November 2022, we inspected Essex Police to examine the effectiveness of the force’s vetting, IT monitoring and counter-corruption arrangements. We briefed senior personnel in the force at the end of the inspection. It should be noted that we didn’t gather evidence during our inspection in relation to the wider culture of the workforce. We didn’t assess the overall leadership of the executive team and senior managers in setting expectations and standards across the organisation.

This report sets out our findings. It includes an area for improvement identified at the time of the inspection, which we recognise the force may have already addressed.

2.  How effectively does the force vet its 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 in the police service, as a police officer, special constable or member of staff. It sets out the minimum standards that should be applied for each clearance level. It also lists the minimum vetting checks that should be undertaken on the applicant, their family and associates. The APP has a large section providing guidance on assessing threat and risk in relation to vetting decisions.

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

Force vetting IT system

In 2020, the force upgraded its vetting IT system. Staff in the HR department have access to this system. HR provides the force vetting unit (FVU) with a series of regular and bespoke reports. These allow the FVU to track internal moves, promotions and people leaving the force. Furthermore, the IT system highlights vetting renewals four months in advance. This allows the FVU to plan and send relevant documentation to officers and staff.

At the time of the inspection, force vetting data was due to be uploaded onto the HR IT system before the end of 2022. This will help both vetting data and HR data to be viewed on a single system.

Current vetting of workforce

Essex Police told us that as of November 2022, it had a total of 6,294 police officers, special constables, police staff and police community support officers.

The force told us there were 33 people in post (22 police officers and 11 police staff) without the correct level of vetting for their role.

The force has a good awareness of these cases. Some relate to individuals whose vetting has expired. Others are posts that had recently been made designated posts, which require a higher level of vetting. In these cases, access to more sensitive data is restricted until the individual’s vetting application is approved and clearance given.

Demand and workload

The FVU uses a series of spreadsheets to manage its workload. At the time of our inspection, the force had 246 vetting applications yet to be dealt with.

The FVU is effective at predicting future vetting demand with HR. The force vetting manager (FVM) maintains records of predicted recruitment dates and the expected number of officers joining through the Police Uplift Programme one year in advance. The FVU considers this information alongside future vetting renewals to plan its work.

FVU staff told us their workloads are manageable. The force has increased staffing levels in the FVU to cope with additional demands from the uplift programme. Where necessary, the FVM uses overtime during periods of higher demand.

Essex Police grants non-police personnel vetting (NPPV) clearance to contractors, volunteers and people who work in organisations that share police premises. The force uses a combination of the FVU and the police national vetting service hosted by Warwickshire Police to carry out NPPV checks.

The force told us that as of November 2022, there were 1,018 non-police personnel. Of these, seven were not vetted. The force had risk assessed them and none had access to sensitive data.

The force has a good process to maintain accurate NPPV records. Nominated members of staff across the force are responsible for informing the FVU of any changes in non-police personnel. The FVM maintains a spreadsheet to manage this information. When the FVU is informed that a person is no longer contracted, their vetting clearance is cancelled and access to buildings and IT removed.

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 has designated 667 posts and maintains a list of them. The FVM has recorded a rationale for designating each post. When HR creates a new role, the FVM decides whether the post should attract a higher level of vetting. The force reviews the list of designated posts annually.

Generally, the force doesn’t allow people to take up a designated post before their MV clearance is granted. The FVU prioritises any new MV applications to make sure that posts can be filled without delay.

The FVU is notified four months in advance when MV renewals are due. We found there were 12 people in designated posts who didn’t have current MV. In seven of these cases the post had only recently been designated. The other five cases were all due to absence and had been risk assessed.

The FVU had completed all the required minimum checks in the MV cases we reviewed.

Transferees

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

Essex Police has chosen to vet all transferees and those who have left the service and applied to rejoin. The FVU requests a professional standards department (PSD) complaint and conduct history, as well as any counter-corruption unit (CCU) intelligence, from all forces in which the individual has previously served.

Change of circumstances

The force has taken steps to improve the workforce’s awareness that they must report any changes of personal circumstances, for example marital status, name changes or significant changes to personal finances.

PSD provides training to all new recruits, people being promoted and those moving to certain posts. The force’s personal development review (PDR) system, introduced in October 2022, include questions about risks, such as business interests. It specifically asks staff about any changes in their personal circumstances. The force told us that 94 percent of staff have completed their PDR.

On average, the FVU receives two notifications of changes in personal circumstance every day, suggesting the workforce has a good understanding of when to report these changes.

When it receives such notifications, the FVU conducts vetting enquires to identify risks and to decide if the individual’s vetting status is affected. The FVU requests that a new vetting form is completed if the changes are considered significant.

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

Vetting decisions

The force has a three-tiered approach to vetting decisions. If the vetting reveals no adverse information, the vetting researcher will grant clearance. Where there is adverse information, the team leader makes the vetting decision and records their rationale. In cases where there are more serious concerns, the FVM makes the final decision, also recording a supporting rationale.

The FVM has introduced a decision-making template to guide the FVU when processing vetting applications. FVU staff told us that they found this very useful when documenting their rationale for vetting decisions. The force told us that other FVUs in the southeast region are adopting this template.

The FVU regularly conducts interviews to clarify written responses in vetting applications.

Risk mitigation measures

The force regularly uses risk mitigation measures to support its vetting decisions. This includes restrictions on where people can be posted, monitoring applicants’ social media activity and regular reviews of applicants’ management of their finances.

The FVU refers some cases to the CCU to monitor individual’s use of the force’s IT systems to help manage potential risks. The force uses a diary system which prompts a check with CCU to make sure that agreed risk mitigations have been implemented. The FVU also informs line managers regarding any risk mitigations.

The force produces a counter-corruption strategic threat assessment (STA) annually. This outlines the current corruption threats facing the force. The CCU has shared both the force’s and the region’s STAs with FVU staff. This is in line with the vetting APP.

Appeals and quality assurance

The head of the CCU handles all vetting appeals. The FVM routinely examines all vetting refusals for quality assurance purposes. The force would benefit from also quality assuring vetting clearance decisions, particularly those where the process had revealed adverse information.

Disproportionality

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

The force maintains records of the results of all vetting applications from people who declare a protected characteristic, including religion, age, gender, gender reassignment, disability, sexual orientation, and ethnicity. Analysis of all vetting applicants between January and June 2022 showed no disproportionality in vetting refusals for people who had declared a protected characteristic.

The force assists applicants from an ethnic minority group by assigning a member of staff to support them through the vetting process.

Vetting file review

We asked a vetting specialist from another force to review 40 clearance decisions from the preceding 3 years related to police officers and staff who had previously committed criminal offences or that the force had other concerns about. The files included transferee and recruitment vetting decisions.

The vetting specialist agreed with all the force’s vetting clearance decisions. Decision‑makers are using the vetting APP and the National Decision Model to guide their decisions. They sometimes make explicit reference to them within their rationale. We saw evidence of the FVU using risk mitigation strategies in relevant cases.

3.  How effectively does the force protect the information and data it holds?

Lawful business and IT monitoring capability

The force can monitor all its IT systems across handheld, mobile and desktop devices. It proactively checks activity on mobile devices. This helps identify potential misconduct including improper contact with vulnerable victims or organised crime groups.

The force monitors people when intelligence shows they pose a higher risk of sexual misconduct. We also saw evidence of IT monitoring of people who were the subject of other corruption-related intelligence. However, the force needs additional resources to make full and effective use of its IT monitoring software. We urge the force to review its CCU staffing levels to make sure there are sufficient resources to meet demand.

There are strong links between the force IT department and the CCU during the procurement process for new IT systems. No new systems can be introduced to the force without the prior approval of the CCU. This ensures new systems include suitable auditing functions or other measures designed to prevent and detect misuse.

IT monitoring policy

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

Digital device management

The force can attribute all mobile devices issued to individuals across the workforce. Devices are issued to specific individuals. The lawful business monitoring policy stipulates that the primary purpose of the force’s ICT is for policing purposes and there can be no expectation of privacy if used for personal use.

Information security – encrypted apps

The force has a comprehensive social media policy and detailed guidance. Both documents have been circulated to the workforce. Encrypted apps aren’t permitted on devices.

PSD provides training and guidance to the workforce about the risks associated with the misuse of social media. Officers and staff we spoke to showed awareness of the force’s expectations of them. The force’s operational security manager has also provided extensive training to the workforce to highlight the threats from social media and encrypted apps.

4.  How well does the force tackle potential corruption?

Intelligence

Sources of corruption-related intelligence

The force has an anonymous confidential reporting line. Between 1 January 2020 and November 2022, it received 132 reports. There were:

• 61 reports in 2020;
• 44 in 2021; and
• 27 in 2022.

We examined 60 corruption intelligence files, of which 27 were reports from members of the workforce. We found two cases that were the result of proactive intelligence collection.

Police corruption categorisation

The force correctly categorises intelligence in line with the counter-corruption APP.

Partnership working to identify potential corruption

The force has developed working relationships with agencies and organisations that support vulnerable people. It plans to extend this to more organisations. To date, this work has been completed by CCU investigators. This has an impact on their ability to investigate corruption.

The CCU has recruited a new prevention and engagement lead. It is actively recruiting four further prevention staff. This means the force will have a greater opportunity to encourage partner agencies to report suspected abuse of position for a sexual purpose (AoPSP). We strongly urge CCU managers to ensure that new prevention staff prioritise the development of professional relationships with external agencies and organisations.

Identifying corruption threats

Counter-corruption strategic threat assessment

In June 2022, the force’s counter-corruption STA was published. The STA identifies the force’s main corruption risks. It also highlights emerging threats and some organisational vulnerabilities.

The force doesn’t publish the STA or communicate the corruption threats to the workforce. It provides some detail to departmental heads at quarterly meetings. However, we encourage the force to consider publishing an edited STA. This will give the workforce a better understanding of the force’s current corruption threats.

Counter-corruption control strategy

The force has a counter-corruption control strategy based on the 4P-approach (pursue, prepare, protect and prevent). It clearly sets out the priorities identified in the STA.

Implementation plan

Each of the corruption threats identified in the STA and control strategy are considered in detail within the force’s implementation plan. There is a designated person responsible for each task and clear timescales for completion. At the time of our inspection, the identified tasks were due to be completed by April 2023.

Managing corruption threats

Intelligence development

We reviewed 60 corruption intelligence files. We found two cases where the force chose not to take action. This may have resulted in missed opportunities to develop the intelligence further and mitigate corruption risks. In the other 58 cases the CCU responded effectively. The force used a variety of techniques to investigate and develop corruption-related intelligence. These investigations were well supervised.

We found two cases of proactive intelligence collection using the force’s IT monitoring system.

Identification of those who pose a corruption risk

The force holds people intelligence meetings when required for individual cases. The director of HR also chairs a force support forum, which includes at which the head of PSD, senior managers, HR, finance, legal services, and the training department. At the meeting, they share information about people with significant welfare concerns, helping to identify anyone who pose a corruption risk. The CCU uses a matrix to identify those people who pose a risk of AoPSP or sexual harassment in the workplace. It regularly monitors them, including IT auditing. The CCU creates an investigation plan for those assessed as being a higher risk. During our inspection, we examined the matrix and found it was well maintained. The force uses similar arrangements for individuals who pose other types of corruption risk.

Capacity and capability to investigate corruption

The CCU is a small team of experienced detectives and a crime analyst. The CCU develops potential corruption intelligence. When further investigation is required, the CCU hands over the investigation to the PSD. We found very few cases investigated wholly by the CCU. This is due to limited resources.

Until the engagement and prevention team referred to earlier in this report are in post, the existing specialist CCU resources can’t focus sufficiently upon corruption investigations. This is a risk to the force.

Furthermore, the CCU has secured funding for an additional intelligence researcher. This post will be dedicated to routine and IT monitoring. Senior officers in the CCU told us they intend to closely monitor their team’s workload. We agree this will be important to make sure the force is able to continue to manage its corruption threats effectively.

Specialist resources

The CCU including the senior management team are experienced in covert law enforcement. When required the force can access resources for covert investigations through the regional organised crime unit or the National Crime Agency.

Policies designed to prevent corruption

Clear and concise corruption prevention policies help to guard against corrupt activity, but can’t guarantee to prevent corruption, or in themselves stop corrupt practice. They provide guidance on how police officers and staff should behave. They should clearly state what is expected of members of the workforce 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 their policies in these areas:

• Notifiable associations: policies should 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. They should require the disclosure by officers and staff of such associations.
• Business interests: policies should state when the force should allow or deny officers and staff the opportunity to hold other jobs. They should explain how the force will manage the risks that arise when officers and staff are allowed to hold them.
• Gifts and hospitality: policies should cover the circumstances in which police officers and staff should accept or reject offers of gifts and/or hospitality.

We found Essex Police’s policies were comprehensive and reflect the APP guidance. Members of the workforce submit an online form if they have notifiable associations or business interests, or have been offered gifts or hospitality. We found the force was managing these processes effectively.

Sexual misconduct

The force recognises AoPSP as serious corruption. During the file review, we found the CCU consistently referred these cases to the Independent Office for Police Conduct.

We found the CCU routinely develops intelligence about sexual misconduct beyond the scope of the initial allegation. In each case, the CCU researches the person and assesses them against an AoPSP/sexual misconduct risk matrix. Where the CCU assessed the risk as low and the intelligence couldn’t be developed, we saw good use of early interventions through risk management meetings.

The force has introduced the College of Policing learning material for AoPSP as mandatory training. This is supported by poster campaigns, intranet articles and the publication of the outcomes of gross misconduct hearings. CCU has provided further training to line managers. We found a good knowledge of AoPSP across the workforce.

Members of the workforce who report sexual misconduct are offered support from the Police Federation at an early stage in proceedings. This means people may be more confident to report sexual misconduct.

Back to publication

A report into the effectiveness of vetting and counter-corruption arrangements in Essex Police