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Response to HMICFRS report:  Vetting and Counter Corruption Inspection

Dear Inspector / Minister,

As the Police and Crime Commissioner for Warwickshire (Local Policing Body), I am providing the following response to the Secretary of State for the Home Office, and His Majesty’s Inspectorate of Constabulary and Fire and Rescue Services (HMICFRS), in respect of the HMICFRS report ‘A report into the effectiveness of vetting and counter-corruption arrangements in Warwickshire Police’, which was published on the 21 September 2023. This action is pursuant to my obligations under Section 55(1) of the Police Act 1996.

Local Policing Body’s Comments

I welcome the report and thank HMICFRS for its inspection in April 2023 of Warwickshire Police’s vetting and counter corruption arrangements. This is a critical area of performance given its impact on police legitimacy and the importance of the force instilling trust and confidence in the communities that it serves. I therefore note the inspection’s assessment of the force’s arrangements in this regard as ‘Adequate’: “The force has demonstrated some of the characteristics of good performance, but we have identified areas where the force should make improvements.”

The matter of vetting is particularly relevant to Warwickshire Police given that force’s chief constable is the National Police Chiefs’ Council (NPCC) lead for vetting. In addition, Force Vetting Unit (FVU) provides the Police National Vetting Service by carrying out vetting enquiries and making vetting decisions for non-police personnel, such as contractors who operate in multiple forces across the UK. This service is also available to other forces allowing them to commission Warwickshire Police to manage their local non-police personnel vetting arrangements. Due to these national responsibilities, the Warwickshire Police FVU is far larger than FVUs in similar-sized forces.

The following extracts from the HMICFRS report highlight many areas of good practice, but it also recognises that there are areas where the force should improve: –

Scope of Inspection

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.

In April 2023, HMICFRS inspected Warwickshire Police to examine the effectiveness of the force’s vetting, IT monitoring and counter-corruption arrangements. It should be noted that HMICFRS did not gather evidence during the inspection in relation to the wider culture of the workforce. HMICFRS did not  assess the overall leadership of the executive team and senior managers in setting expectations and standards across the organisation.

How effectively does the force vet its officers and staff?

  • In March 2021, the force successfully applied for accreditation from the International Organization for Standardisation for the management of its vetting arrangements.
  • Warwickshire Police manages its Management Vetting (MV) processes effectively. It maintains a designated posts list. The FVU was confident that it had identified every role that requires MV.
  • Warwickshire Police has chosen to vet all transferees and those who have left the service and applied to rejoin. The FVU requests from all forces in which the transferee has previously served a Professional Standards Department complaint and conduct history, as well as any Anti-Corruption Unit (ACU) intelligence.
  • The force has taken steps to improve the workforce’s awareness in that they must report any changes in 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 staff about any changes in their personal circumstances. At the time of our inspection, the force told us that every member of the workforce had completed this questionnaire.
  • The FVU regularly conducts interviews to clarify written responses in vetting applications.
  • The force sometimes uses risk mitigation measures to support its vetting decisions. This includes restrictions on where people can be posted, checking their use of the force’s IT systems and regular reviews of applicants’ management of their finances.
  • The force produces an annual counter-corruption strategic threat assessment (STA) that outlines the current threats it faces.
  • The deputy chief constable handles vetting appeals.
  • Warwickshire Police’s FVU records the results of all applications from people who declare a protected characteristic. The force monitors rejection rates across a wide range of protected characteristics. It uses analytical tools to assess the data. At the time of our inspection, the force was still developing its analysis of disproportionality for rejected cases.

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

  • The force is in the process of purchasing IT monitoring software. At the time of our inspection, the force told us this had been delayed, but it expected the software to be installed imminently.
  • We examined 60 corruption intelligence files. We found effective use of reactive auditing in most cases. But the absence of an IT monitoring capability restricts the scope of some investigations.
  • Generally, the ACU has sufficient resources to meet current reactive demand. But the force acknowledges it will need more staff when it introduces its IT monitoring.
  • The force can attribute all mobile phones and tablets issued to people across the workforce.
  • The force has a comprehensive social media policy. It has shared it across the workforce. It provides guidance on the use of social media that includes the risks associated with its misuse. The policy reminds staff that they should have no expectation of privacy.

How well does the force tackle potential corruption?

  • We examined 60 corruption intelligence files and found that the confidential reporting line was an effective intelligence source. We also saw intelligence reported by colleagues, the public, the National Crime Agency, and line managers.
  • Warwickshire Police has introduced Operation Amethyst, which is an awareness-raising campaign focused on addressing both inappropriate and unacceptable behaviour within the force. As part of this, several people across the force have been given specific training so that members of the workforce and external agencies can report misconduct to them in confidence.
  • The force has developed working relationships with agencies and organisations that support vulnerable people, to help identify potential Abuse of Position for a Sexual Purpose (AoPSP).
  • The force has a current counter-corruption STA. It identifies the three main corruption risks facing the force and highlights emerging threats.
  • The force has a counter-corruption control strategy based on the national intelligence model’s prevention, intelligence, engagement, and enforcement format. It clearly sets out the force’s approach to counter the priorities identified in the STA.
  • The PSD meets monthly with local commanders. But the force doesn’t have an established people intelligence meeting attended by senior managers from local policing areas, HR, finance, legal services, and training.
  • The counter-corruption (prevention) APP sets out what policies forces should have and gives guidance on their content. We examined the force’s policies in these areas: i) Notifiable associations. ii) Business interests. iii) Gifts and hospitality. The force’s policies reflect APP guidance. But we did see some areas where they could be improved.
  • The force has delivered training on AoPSP for the entire workforce. The College of Policing training is mandatory for all staff. Training is also given to new recruits and new supervisors. The force supports this training with poster campaigns and intranet articles publishing the outcomes of gross misconduct hearings. We found a good knowledge of AoPSP across the workforce.

Areas for Improvement

  1.  The force should improve its vetting arrangements to make sure that:
    • when concerning adverse information has been identified during the vetting process, all vetting decisions (refusals, clearances, and appeals) are supported with sufficiently detailed written rationale; and
    • when granting vetting clearance to applicants with concerning adverse information, the FVU creates and implements effective risk mitigation strategies, with clearly defined responsibilities and robust oversight.
  1. The force should make sure it introduces IT monitoring so that it can monitor all use of its IT systems to support counter-corruption investigations and proactively gather intelligence.
  1. The force should improve how it collects, assesses, develops, and investigates counter-corruption intelligence by making sure that:
    • its annual counter-corruption STA and control strategy have an implementation plan with accountable action owners and that the force uses these processes to identify and manage corruption threats effectively;
    • its counter-corruption unit has sufficient resources and suitably trained staff to meet demand and allow for proactive intelligence collection; and
    • it carries out effective assessment and development of intelligence, including routine widening of enquiries into internal improper behaviour and checking of compliance when specific conditions are attached to notifiable associations and business interests.

Comments from the Chief Constable

“I am grateful to HMICFRS for visiting the force and completing a thorough inspection of our vetting and counter-corruption capabilities.  I thank the inspection team for the report and accept the findings – it is this scrutiny which helps us not only to drive improvements but also to ensure we provide the best possible service for people across Warwickshire.

I am pleased that the report has recognised much of the excellent work already going on in Warwickshire Police and that it acknowledges our commitment to improvement.  There are several areas in which we can improve as a force. Many of these have previously been identified by the force and we had already developed coherent plans to address them prior to the inspection team’s visit.

Each of the three Areas for Improvement (AFI’s) have been allocated to the Head of the force’s Professional Standards Department, and Head of Vetting, respectively for delivery.  Addressing specifically our current progress against each AFI:

AFI 1 (Vetting decisions):

All Case Officers receive comprehensive training, including the composition of rationales as per the Authorised Professional Practice. Applicants are provided with as much information as possible when refused vetting, including where a full rationale cannot be provided and reasons why not.  Decisions to grant vetting where adverse information has been found are subject to considered risk mitigation strategies, which are managed effectively and continuously.

AFI 2 (IT monitoring):

Lawful Business Monitoring was well on the way to implementation at the time of the inspection team’s visit in March 2023. It was fully implemented in July 2023, with the capability to routinely monitor all IT systems to a great level of detail. A robust policy is in place to inform and support the workforce, and we have a forward-facing process in place for onboarding all new applications and software as they are implemented into the infrastructure.

AFI 3 (Counter-corruption intelligence collection):

Existing and new measures in the force to tackle corruption include: –

  • A Counter-Corruption Strategic Threat Assessment tracker to drive activity, tackle threats, and provide accountability and reassurance.
  • ACU personnel uplift to consolidate investigative resilience and proactive capability.
  • Categorisation of corruption intelligence in accordance with NPCC categories.
  • A regular People Intelligence Tactical Meeting to ensure proactive monitoring of threats by allocated ACU case officers, and to manage wider risks.
  • A new risk matrix manages ongoing risk around abuse of position for a sexual purpose (APSP).
  • Investigation plans are routinely used to ensure all intelligence/evidential opportunities are explored.
  • ACU senior management meet monthly with area commanders to share intelligence and drive proactive investigation.
  • The Director of Enabling Services chairs a new Behaviour & Standards Board with senior managers across the force to ensure a joined-up approach and intelligence sharing.
  • ACU management and practitioners attend bespoke regional collaborative meetings where counter-corruption information is exchanged.
  • New entrants submitting pre-appointment business interests (BI) receive interim approval or refusal, which must then be further reviewed once posting / line management is confirmed. A new process and meeting structure monitors compliance with BI conditions and proactive monitoring of refused applications.
  • 100% completion rate of the Annual Integrity Health Check (AIHC) ensures the workforce is fully educated around their responsibilities and provides a further opportunity to check compliance.
  • Recent clarification around Notifiable Associations has seen a 40% (approximately) increase in submissions.
  • All new starters are issued with a handbook explaining policies and the purpose of them.

Scrutiny of HMICFRS recommendations and AFI’s in Warwickshire is robust. Oversight is provided at chief officer level in this instance through the force’s Legitimacy & Equality Board (chaired by an Assistant Chief Constable) and the Performance & Assurance Board (chaired by the Deputy Chief Constable). The Force Liaison Officer will work closely with HMICFRS to provide assurance around progress and compliance, through to final sign-off. I will of course keep the Police & Crime Commissioner up to date with our progress too.”

Comments from the local policing body on the CC’s comments

Chief Constable Tedds is supportive of the findings of the HMICFRS inspection and has provided her assurance that Warwickshire Police will continue to drive improvements in its vetting and counter corruption arrangements.

Progress will be scrutinised through the force’s governance arrangements and it is my expectation that the Areas for Improvement that were identified during the inspection will be fully completed to my satisfaction and that of HMICFRS. As I do in relation to all HMICFRS inspection reports, I will continue to ‘hold to account’ the Chief Constable in affecting these changes.

This response will be published on the website of the Warwickshire Office of the Police and Crime Commissioner (OPCC) in compliance with the requirements of the Police Act 1996.

 

Yours faithfully,

Philip Seccombe TD

Police and Crime Commissioner

6 October 2023