A report into the effectiveness of vetting arrangements in South Yorkshire Police
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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.
South Yorkshire Police is adequate at vetting.
In April 2023, we inspected South Yorkshire 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
In January 2023, the force vetting unit (FVU) introduced a new vetting IT system, but it doesn’t link with the force’s HR system. The head of the FVU attends the monthly workforce deployment board meeting. This helps the FVU to keep track of all staff moves and makes sure that it is updated on current staff postings and any need to review their vetting.
The FVU uses information collated from its vetting IT system to track vetting renewals. Forty-two days before their clearance expires, members of the workforce are sent a vetting renewal form to complete. This approach helps the FVU manage demand. However, we found that the FVU didn’t specify a timescale for returning the form. In some of the cases we reviewed, officers and staff hadn’t returned their vetting renewal forms before their vetting clearance had expired.
Current vetting of the workforce
South Yorkshire Police told us that as of April 2023, it had a total of 5,814 police officers, special constables, police staff and police community support officers.
The force told us there were 152 people in post without the correct level of vetting for their roles because it had expired. The vetting IT system easily identifies these cases. We found that in some cases, FVU staff could have done more to make sure staff returned their vetting forms promptly. This would help to prevent vetting clearance expiring.
Demand and workload
The FVU has a process to make sure that the most urgent applications are processed first. We found that the time it took the FVU to complete all vetting checks, from receipt of the application to finalisation, averaged 53 days.
The FVU and HR department work together effectively to predict demand. The force has increased staffing levels in the FVU to cope with additional demand from Police Uplift Programme recruitment. The force vetting manager (FVM) maintains a plan of the number of new officers coming through the Police Uplift Programme one year in advance. The FVU considers this recruitment information alongside future vetting renewal data so that it can plan ahead.
South Yorkshire Police grants non-police personnel vetting clearance to contractors, volunteers and people who work in organisations that share police premises. The force also uses the police national vetting service hosted by Warwickshire Police to vet some non-police personnel. The force currently has 1,463 people with non-police personnel vetting clearance.
The force has a robust system to cancel building or IT access when people no longer need clearance. But the FVU isn’t always notified when contracts end or when people have left contracted companies. As a result, it couldn’t tell us how many people still required this clearance to access police premises or force IT systems. We urge the force to introduce a process to make sure the FVU is always informed when non‑police personnel vetting clearance is no longer required.
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 a role requires working with vulnerable people is also a factor for the force 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 1,654 designated posts. It maintains a list of these. There are 2,500 people occupying these posts. When HR creates a new role, the FVM determines if MV is necessary. We found the designated posts list was last reviewed at the start of 2022. The force acknowledged that a further review of the list was necessary.
The monthly workforce deployment board meeting monitors all police officer and staff moves. Generally, the force doesn’t allow individuals to take up designated posts before MV clearance is granted. The FVU prioritises MV applications to make sure that posts can be filled without delay. At the time of our visit, 98 people whose vetting had expired were in MV posts.
We reviewed a selection of MV cases. Generally, the force had completed the required minimum checks. But in every case, the FVU hadn’t requested an endorsement from the applicant’s supervisor. It should have done this, in accordance with the vetting APP.
We urge the force to prioritise the renewal of the expired MV clearances and make sure that all the required minimum checks are carried out.
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.
South Yorkshire Police FVU pre-screens all applications from transferees and from people who have left the service and want to rejoin. This requires applicants to consent to the FVU having access to their professional standards department complaint and conduct history as well as any counter-corruption unit intelligence from all forces in which the individual has previously served.
Applicants won’t pass the pre-screening process if their complaint and conduct history is deemed unsuitable. The FVU informs the applicant’s force if this is the case. Where the application is progressed, South Yorkshire Police has chosen to vet all transferees, including those who have left the service and applied to rejoin.
Change of circumstances
The force has taken steps to improve the workforce’s awareness that they must notify the FVU of any change in their personal circumstances, for example, marital status, name changes or significant changes to personal finances.
In March 2023, the force circulated a reminder to staff via a prominent intranet bulletin. Following this, the FVU received over 350 notifications of a change in circumstances. Generally, the workforce understands when to report changes in circumstances.
When the FVU receives a notification, it conducts vetting enquiries to identify risks and decide if the person’s vetting status is affected. If required, it will carry out a full re-vet.
The FVU also completes vetting checks whenever an officer or member of staff is promoted, changes role or has been subject to a misconduct proceeding (even where the case isn’t proven).
In addition, the FVU reviews all recruitment vetting clearances every five years and all MV clearances every two years. It also reviews all student officers’ vetting clearance prior to their confirmation as constables. These reviews are in addition to those required by the vetting APP. The force conducts these reviews, as it believes that the current vetting renewal periods are too long. We believe that these additional reviews will help to identify any potential risks.
Vetting decisions
Staff in the FVU conduct all the necessary checks when a person requires vetting clearance. Where nothing of concern is identified, they will grant vetting clearance. When any intelligence or adverse information is identified, they send the file without any recommendation to the deputy FVM. The deputy FVM then makes the final decision regarding vetting clearance or rejection.
The FVM makes the decision regarding vetting clearance or rejection for all transferees.
The force interviews applicants if the vetting process identifies any issues that require clarification. The interviews are carried out in person. The FVU takes interview notes. It shares these notes with the applicants to make sure they are accurate.
Risk mitigation measures
In some cases, the force grants clearance despite the vetting process revealing adverse information about the applicant or their family or friends. When this happens, the FVU informs the counter-corruption unit. We found the force was consistently mitigating these risks, such as monitoring the applicant’s use of the force’s IT systems.
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 counter-corruption unit to share the STA with vetting decision-makers. We encourage the force to do this.
Appeals and quality assurance
The FVM handles vetting appeals. Where the FVM has granted vetting clearance following an appeal, this is considered by the head of the professional standards department.
Vetting clearances granted by the force vetting officers are routinely checked to make sure the minimum vetting enquiries have been carried out. However, there is no quality assurance process for vetting clearances granted by the FVM or their deputy. We encourage the force to introduce such a process.
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.
Since November 2022, the force has analysed the outcomes of all vetting applications from people who declare a protected characteristic. This analysis has identified that some applicants from multi-occupancy homes may be more likely to fail vetting clearance. Applicants who declare such circumstances are now offered an interview. This gives the force the opportunity to gather more information to help it decide whether to grant clearance.
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 that the force had other concerns about. The files included transferee and recruitment vetting decisions.
Generally, we found that the files were well managed and the initial decision-making had been well documented. But the vetting specialist disagreed with the force’s decision to grant clearance in two cases. In both cases, the initial decision had been to refuse clearance, but it was granted on appeal. The recorded rationale didn’t justify the appeal decisions that had been taken. They should. Both of these decisions predated our thematic report, An inspection of vetting, misconduct, and misogyny in the police service.
One of these cases involved a student police officer. After the routine review of their vetting clearance at the end of their probationary period, their clearance was removed. The officer was dismissed.
Where vetting clearance was granted to applicants with concerning adverse information, we found that appropriate risk mitigation was routinely applied.
Area for improvement
The force should improve its vetting arrangements to make sure that:
- it has a clear understanding of the level of vetting required for all posts and that all members of the workforce have been vetted to a high enough level for the posts they hold; and
- it has a clear understanding of the vetting required for all non-police personnel and that they are all vetted to a high enough level for their roles.
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A report into the effectiveness of vetting arrangements in South Yorkshire Police