A report into the effectiveness of vetting arrangements in North Wales 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 an accessible form. We use our expertise to interpret the evidence and make recommendations for improvement.

1.  Introduction

Vetting: adequate

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 North Wales Police 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. 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

At the time of our inspection, North Wales Police had started the process of transferring vetting records from a manual to a new IT system. The new system doesn’t link with the HR system, but the departments work closely together. We saw several spreadsheets that HR sends to the force vetting unit (FVU) with information to help it manage vetting. This identifies renewals in advance, giving the FVU time to forward plan and send documents and reminders to officers and staff.

Current vetting of workforce

The force told us that as of September 2022, it had a total of 3,046 police officers, special constables, police staff and police community support officers.

The force told us there were 83 people (57 police officers, 25 police staff and 1 police community support officer) without the correct level of vetting for their role. This included 42 people whose vetting had expired. The force was aware of these cases and had sent reminders to the applicants.

Demand and workload

The FVU uses a series of spreadsheets to manage its workload. At the time of our inspection, the unit had 313 cases waiting to be dealt with. This includes new applications and renewals for both management vetting (MV) and recruitment vetting.

The force predicts future vetting demand by working with HR. The force vetting manager maintains accurate records with predicted recruitment dates and numbers for the Police Uplift Programme. The FVU and HR update this information and consider it alongside future vetting renewals. This helps with advance planning.

FVU staff told us their workloads are consistently high. However, this is being managed with temporary resources posted to the unit. The FVU has submitted a business case for additional resources to help transfer vetting records to the new IT system. Generally, the force is coping well with the demands placed on it by the uplift programme.

North Wales Police grants non-police personnel vetting (NPPV) clearance to contractors, volunteers and people who work in organisations that share police premises. It uses 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, 2 out of 126 non-police personnel were not vetted. The FVU isn’t consistently notified when contracts conclude, or people leave the contracted company. These people may still have vetting clearance and access to police buildings and IT systems.

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.

North Wales Police maintains a list of designated posts, but the FVU acknowledged it was incomplete. The force hasn’t reviewed the list regularly in line with APP. There are several posts with access to vulnerable people that the FVU has assessed should be on the designated post list, but they are not. The people in the posts don’t have the correct level of vetting for their role. The FVU has started to review these posts with relevant heads of department.

The FVU is notified three months in advance when MV renewals are due. This prompts the unit to send out renewal documents. But these aren’t consistently returned on time, and we found 22 people in designated posts with expired MV.

In addition, the FVU is often not notified before individuals are moved or promoted to designated posts, so they take up the role before being MV cleared. HR gives the FVU a monthly list which identifies these individuals, but only after they have moved. The force told us it had 41 members of its workforce in this position.

We reviewed a selection of MV cases. In each case the FVU had completed all the required minimum checks.

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.

North Wales 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. This includes updating the PSD intranet section with relevant guidance and providing training to new student officers.

The force intends to introduce a new performance review process in 2023. This will include a question about changes in personal circumstances. The FVU reported low numbers of notifications historically, but it now receives several each month. When it does, the FVU conducts vetting enquires to identify risks and to decide if the person’s vetting status is affected.

The FVU is aware of 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 force vetting manager has conducted these reviews in a small number of cases, but PSD doesn’t have a consistent process to notify the FVU of relevant cases.

Vetting decisions

There is a dedicated vetting decision-maker in the FVU. It is a temporary post, but the head of vetting is seeking funding to make it permanent. Researchers in the FVU complete all the relevant vetting enquires and make a recommendation in each case.

When the FVU is considering refusing clearance to an applicant who has declared a protected characteristic, the decision-maker refers the case with accompanying rationale to a panel for review and decision.

A principle of the Vetting Code of Practice is that: “Decision-making in respect of vetting clearance should be separate from, and independent of, recruitment and other human resources processes.” Both HR and recruitment sit on the panel in North Wales Police. If their role is purely to advise the panel, the risk of breaching this principle may be mitigated. However, the force should review their involvement.

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 applicants can be posted, monitoring their use of the force’s IT systems and regular reviews of how they manage their finances. The FVU and CCU work closely together when considering the use of IT monitoring to help manage potential risks.

The force produces a counter-corruption strategic threat assessment (STA) annually. This outlines the current threats facing the force. There is no established process for the CCU to share the assessment with the FVU. We encourage the force to make sure vetting decision-makers are fully aware of the current corruption threats.

Appeals and quality assurance

The head of the PSD or their deputy handles vetting appeals. In a small number of cases North Wales Police has used another force to conduct appeals on its behalf.

The panel that makes vetting decisions for applicants with protected characteristics contains the same people who handle appeals against refusal. This undermines the independence of the appeal process for these applicants.

Except for appeals, there is no process to quality assure clearance or refusal decisions. We encourage the force to address this, particularly where clearance has been granted despite adverse information being revealed about the applicant, family or friends.

Disproportionality

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

The force doesn’t monitor or analyse vetting decisions to identify disproportionality. For example, it doesn’t analyse the proportion of rejections for applicants with a particular protected characteristic compared to applicants without. As a result, the force has no way of understanding the reasons for any disproportionality, so it isn’t taking any action to address it. This is disappointing given we identified this as an area for improvement in our PEEL 2018/19 inspection.

Vetting file review

We reviewed 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. They included transferee and recruitment vetting decisions.

We agreed with all the force’s vetting clearance decisions, but in several cases the rationale contained insufficient detail. We encourage the force to make greater use of the National Decision Model and more explicit reference to risk factors outlined in the vetting APP. A quality assurance process would help the force make sure sufficient detail is recorded to justify its vetting decisions.

In some cases, the FVU didn’t record sufficient detail to explain why risk mitigation measures were considered necessary.

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A report into the effectiveness of vetting arrangements in North Wales Police