A report into the effectiveness of vetting arrangements in Lancashire Constabulary

About us

His Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS) independently assesses the effectiveness and efficiency of police forces and fire and rescue services, 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: 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 September 2022, we inspected Lancashire Constabulary to examine the effectiveness of the force’s vetting 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.

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

At the time of our inspection, Lancashire Constabulary’s force vetting unit (FVU). managed its data using a paper-based system supplemented by spreadsheets. It had purchased an established vetting management IT system, which it planned to use from January 2023. The force had started transferring vetting records to the new IT system and mapped all its vetting processes.

The HR department provides the FVU with a series of reports each month. These allow the FVU to keep track of internal moves, promotions and people leaving the force.

We saw several spreadsheets containing information from HR that the FVU uses to manage its vetting. This process flags vetting renewals in advance. This helps the FVU to manage its workload and send relevant documentation and reminders to officers and staff.

Current vetting of workforce

Lancashire Constabulary told us that as of September 2022, it had a total of 6,309 police officers, special constables, police staff and police community support officers. The force told us there were 56 people (30 police officers, 24 police staff and 2 police community support officers) in post without the correct level of vetting because it had expired. The force demonstrated awareness of these cases and had already sent reminders.

Demand and workload

The FVU uses a series of spreadsheets to manage its workload. The force told us that the number of cases it handles per month has increased from 340 to 500. This includes new vetting applications, renewals and where it has been notified by a member of the workforce that their personal circumstances have changed.

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 data on future renewals, bringing some renewals forward to create a more balanced workload throughout the year.

The force has increased staffing levels in the FVU to cope with additional demands from the Police Uplift Programme. FVU staff told us their workloads are manageable. Where necessary, the FVM uses overtime and employs agency staff during periods of higher demand. Managers told us that in the months preceding the inspection, the time it took to finalise vetting cases had increased. And the number of expired vetting cases is slowly increasing from 0 in early 2022. The force monitors performance in this area during quarterly meetings with a chief officer.

Lancashire Constabulary 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 September 2022, it had 186 non-police personnel, of which 7 were not vetted.

The FVU collects data on a quarterly basis to check which non-police personnel still require vetting. This identified a small number of occasions when the FVU hadn’t been notified when contracts had concluded or people had left. They may still have had access to police buildings and IT systems. Their vetting clearance should have been cancelled and access 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.

Lancashire Constabulary told us it has 249 posts on this list, held by 692 individuals. The FVM decides if a post created by HR should be included on the designated post list monthly. The force has recently reviewed the list and the next review is scheduled for 2024.

Generally, the force grants MV clearance to police officers and staff before allowing them to start in a designated post. HR supplies the FVU with a list of all internal moves every month. This identifies those who have been moved into MV posts and those who no longer require MV clearance. The FVU compares this list against its vetting records to check that everyone occupying a designated post has the correct level of vetting.

Occasionally, individuals have been moved to a designated post prior to being given MV clearance. When this occurs, the FVU completes vetting enquiries to allow these individuals to remain in post. At the time of our inspection, there was only one person in a designated post waiting for initial MV clearance.

The FVU monitors when renewals are due and extracts data from HR reports at least three months in advance. But we found four people in designated posts whose MV had expired. We reviewed a selection of MV cases. In each case the FVU had completed all the required minimum checks.

In 2017, the force identified 33 different posts, occupied by 163 people, that involved increased access to vulnerable people or work with limited supervision and access to the public. The force hasn’t included them on the designated post list. The checks on these posts fall short of those required for MV, even though the force recognises the increased risk of sexual misconduct. We urge the force to reconsider MV for the posts, in accordance with the vetting APP.

Transferees

Vetting APP allows forces to accept 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 with a current vetting clearance.

Lancashire Constabulary 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 intelligence, from all forces in which the person has previously served.

Change of circumstances

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

Professional standards training is given to all new recruits, as well as those promoted or moved to certain posts, such as force control room staff. The force’s personal development review system, introduced in April 2022, includes questions about risks such as business interests. It specifically asks staff about any changes in their personal circumstances.

In August 2022, the deputy chief constable sent all officers and staff an email expressing the importance of reporting changes in circumstances. This prompted 300 notifications to the FVU.

The FVU receives up to 40 such notifications per month. This suggests the workforce has a good understanding of when to report changes in circumstances. When the FVU receives a notification, it conducts relevant enquires to identify risks and decide if the person’s vetting status is affected. If the change only relates to a change of address, the FVU doesn’t make these enquiries. This means some risks might not be identified.

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. We saw a case where the FVU revoked MV clearance for an officer who had received a written warning for dishonesty.

Vetting decisions

Vetting researchers in the FVU conduct enquiries and present the results to three dedicated vetting decision-makers. The FVM reviews all their refusal decisions.

The FVU regularly conducts interviews to clarify written responses in vetting applications. Staff associations are consulted and written notes from the meeting are shared with interviewees. Where there are cultural factors to consider, the force seeks advice from a PSD advisor. This is recorded on a form it has introduced and is used to inform the vetting decision.

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, meetings with the PSD advisor, and regular reviews of applicants’ management of their finances.

The FVU meets weekly with the counter-corruption unit (CCU). Together they consider the monitoring of vetting applicants’ use of the force’s IT systems to help manage potential risks.

The force uses a diary system that prompts the FVU to check with the CCU that agreed risk mitigation has been implemented.

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 in line with APP.

Appeals and quality assurance

The head of the PSD (or their deputy) handles vetting appeals. The FVM presents the appeal case to a panel convened to advise the head of PSD. The panel includes:

• head of PSD (chair);
• operational superintendent;
• member of the ethics committee;
• Police Federation representatives;
• trade union representatives; and
• members of various staff associations.

The appeal decision remains with the head of PSD, who records their rationale in each case.

The FVM routinely quality assures vetting refusals. It has very recently started to dip sample a small number of clearance decisions. This is likely to be more effective once it becomes an established and consistent process.

Disproportionality

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

The FVU maintains records of the results of all vetting applications from people who declare a protected characteristic and provides quarterly results for different religions, age, gender, gender reassignment, disability, sexual orientation and ethnicity.

The force analyses its vetting decisions to identify potential disproportionality. The analysis shows that applicants from ethnic minority groups and those who are Muslim are generally more likely to be refused vetting clearance compared to applicants from White backgrounds, or those who are Christian.

When the force reviewed the reasons for refusal, it identified that these applicants often failed because they didn’t disclose relevant information about friends and family. To address this, the force has prepared guidance for applicants including a video and a leaflet containing hints and tips for completing the form. These are used by the recruitment department and vetting officers during sessions with potential applicants from ethnic minority groups. It is too early to assess how effective these measures will be in addressing the disproportionality. The FVU would benefit from greater analytical support to gain further insight into its protected characteristic data.

Vetting file review

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

We agreed with almost all the force’s vetting clearance decisions. The decisions were well documented with suitably detailed rationale in all but one case.

Decision-makers use the vetting APP and the National Decision Model as guidance and sometimes refer to them in their rationale. More recent cases have greater levels of detail in the rationale and better consideration of identifying and managing risk. There is evidence the FVU is using risk mitigation strategies such as restrictions on where an applicant is posted, IT monitoring and regular review of applicants’ finances.

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A report into the effectiveness of vetting arrangements in Lancashire Constabulary