A report into the effectiveness of vetting arrangements in Northumbria 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

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.

Northumbria Police is adequate at vetting.

In May 2023, we inspected Northumbria Police to examine the effectiveness of the force’s vetting arrangements. We briefed senior personnel in the force at the end of the inspection.

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

Northumbria Police has been using an established vetting IT system for about 13 years. It doesn’t link with the force’s HR system. To overcome this, HR (which is known in this force as people services) provides individual email updates to the force vetting unit (FVU). These inform the FVU about any internal moves, promotions or people leaving the force.

Current vetting of workforce

The force told us that as of May 2023, it had a total of 6,226 police officers, special constables, police staff and police community support officers.

FVU administration staff monitor the vetting system to identify when renewals are due, prompting them to send out application documents. The force told us there were three people in post without recruitment vetting because their clearance had expired. The FVU was in the process of conducting the vetting renewals for these cases. The force also told us that an analyst in the professional standards department carries out a monthly process to compare vetting data and HR data. This helps the FVU to keep track of every individual’s vetting clearance level.

Demand and workload

The force has increased staffing levels in the FVU, but it still doesn’t have enough people to cope with current demand.

The FVU is prioritising recruitment vetting to support the Police Uplift Programme. But this means other FVU work, such as changes of circumstances and non-police personnel vetting (NPPV) applications and renewals, is being delayed. Some new FVU staff are still being trained, which is also contributing to delays.

The FVU predicts future vetting demand with HR. The force vetting manager maintains a plan of the number of officers expected to join through the Police Uplift Programme one year in advance. HR also gives the FVU details of other planned bulk recruitment processes. The FVU could improve its understanding of future demand by analysing this data alongside vetting renewal forecasts. This might allow it to bring some renewals forward, to create a more balanced workload throughout the year.

Northumbria Police grants 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 May 2023, it had 1,138 non-police personnel. FVU staff told us that 165 new NPPV applications and 72 renewals had been delayed, some by over 6 months.

The FVU has a robust process to immediately cancel vetting clearance if the contracting company doesn’t submit an NPPV renewal application. However, the force doesn’t have a consistent process to then make sure that building or IT access is also removed. This means some people who no longer hold NPPV clearance may potentially still have 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.

The force told us it has 558 designated posts. There are 1,445 people occupying these posts.

Generally, the force doesn’t move people into designated posts without making sure they have MV clearance. But the FVU told us that in the months before our inspection, due to demands on the vetting unit, 24 individuals were moved into designated posts without MV clearance. Three more members of police staff in a regional unit were moved into designated posts through the Transfer of Undertakings (Protection of Employment) Regulations 2006. We urge the force to make sure all 27 of these post‑holders are vetted to the correct level as soon as possible.

The force vetting manager decides whether any new posts created by HR should be included on the designated posts list. The force has recently reviewed the list. In this review, another 72 MV posts were identified. This means the 340 people occupying these posts now need MV clearance. The force told us that it hadn’t recorded this as a risk on its force risk register (a document where risks that might have a negative effect on the force are recorded and mitigated). The force should consider including this risk on its register.

Where MV is completed, the FVU carries out all the required minimum checks.

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.

Northumbria Police has chosen to vet all transferees and those people who have left the service and applied to re-join. The FVU requests a professional standards department 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 that they must notify the FVU of any change to their personal circumstances, for example, marital status, name changes or significant changes to personal finances.

In 2022, the force introduced an integrity health check questionnaire. It specifically asks people about any changes in their personal circumstances. At the time of our inspection, the force told us that 81 percent of the workforce had completed this questionnaire. The professional standards department recently sent a force-wide email reminding members of the workforce about their obligation to report changes. The force has also published guidance on its intranet.

Generally, we found the workforce has a good understanding of when to report changes in circumstances. When the FVU receives a notification, it carries out relevant enquiries to identify risks and decide if the person’s vetting status is affected.

If the change is only a change of address, the FVU doesn’t make enquiries. There is a locally managed ‘approval to reside’ procedure. This procedure requires the officer’s line manager to carry out checks on the new address before the officer moves into it. Due to demands on the unit, the FVU has delayed completing change of circumstances vetting enquiries. As a result, at the time of our inspection there were 288 notifications yet to be researched and assessed.

The professional standards department 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 well-documented case where the FVU revoked vetting clearance for an officer who had received a final written warning for dishonesty. The officer subsequently left the force.

Vetting decisions

Vetting researchers in the FVU conduct all necessary checks. They make the vetting decisions and record their supporting rationale. In more complex cases, they make a recommendation, but the vetting supervisor makes the final decision and records the rationale. We found a small number of cases where the head of vetting made the decision.

The FVU regularly carries out interviews to clarify written responses in vetting applications. The FVU supplies copies of the interview notes to the applicant, but only if specifically requested.

Risk mitigation measures

The force regularly uses risk mitigation measures to support its vetting decisions. This includes restricting where people can be posted, monitoring applicants’ social media activity, and regularly reviewing how applicants’ manage their finances.

The FVU sometimes consults with the counter-corruption unit and HR to decide if any risk mitigation measures may be suitable to help manage potential risks. But the force acknowledges it doesn’t have a robust process in place to make sure these risk mitigation measures are managed effectively.

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

Appeals and quality assurance

The head of vetting handles most appeals. On the rare occasions when the head of vetting made the initial decision, their deputy handles the appeal. We found an example of the deputy overturning one of the head of vetting’s decisions. But in the interests of transparency, we advise the force to consider appointing someone outside the FVU to handle appeals where the vetting manager was the original decision-maker.

The force has established a disproportionality panel to review all vetting refusals. But there is currently no process to quality assure vetting clearance decisions where the process has revealed adverse information about the applicant or their family and friends. The force is currently negotiating with other FVUs in the north-east police region to carry out quality assurance processes on behalf of each other in such cases.

Disproportionality

The vetting 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 records the results of all applications from people who declare a protected characteristic. The force monitors rejection rates and the reasons for rejection across a wide range of protected characteristics. More in-depth analysis of rejection cases may help the force to understand the reasons for any disproportionality and allow it to act on the information. We encourage the force to develop this work further.

Vetting file review

We reviewed 40 vetting clearance decisions from the preceding three years with a vetting specialist from another force. These files related to police officers and staff who had previously committed criminal offences or 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. In that case, the decision rationale didn’t take full account of all identified risk factors. This decision was made after the publication of our thematic report An inspection of vetting, misconduct, and misogyny in the police service. In that report we recommended that all vetting decisions (refusals, clearances and appeals) should be supported with a sufficiently detailed written rationale.

The FVU’s 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 that 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 Northumbria Police