Bedfordshire PEEL 2018

This question was not subject to detailed inspection in 2018/19, and our judgment from the 2017 legitimacy inspection has been carried over.

However, Bedfordshire Police had an area for improvement in the 2017 legitimacy inspection: we said the force should ensure that its data for use of force (including body-worn video footage) is monitored by an internal and external group to provide oversight.

During our inspection fieldwork, we assessed this area for improvement and found that the force has clear plans to establish an internal scrutiny group. This will be comprised of officers from different departments. But the force has no firm plans to implement an external group, which would give greater transparency and varied challenge. We will monitor the force’s activity in this area in the coming year.

Additionally, we reviewed a representative sample of 100 stop and search records to assess the reasonableness of the recorded grounds. We found that 82 percent of those records contained reasonable grounds. Our assessment is based on the grounds recorded by the searching officer, and not the grounds that existed at the time of the search.

In our 2017 legitimacy report, we recommended that all forces should:

• monitor and analyse comprehensive stop and search data to understand reasons for disparities;
• take action on those; and
• publish the analysis and the action by July 2018.

We found that the force has complied with some of this recommendation. But it doesn’t identify the extent to which find rates differ between people from different ethnicities and across different types of searches (including separate identification of find rates for drug possession and supply-type offences). Additionally, it isn’t clear that it monitors enough data to identify the prevalence of possession-only drug searches or the extent to which these align with local or force-level priorities.

We reviewed the force’s website and were pleased to find a report of a review of black, Asian and minority ethnic searches setting out analysis that the force had undertaken in attempting to explain the reason for the disproportionality rate. However, this did not include analysis on find rates, nor was there mention of action the force intended to take.

We set out our detailed findings below. These are the basis for our judgment of the force’s performance in this area.

Maintaining an ethical culture

During fieldwork, we spoke to many officers and staff in different ranks, roles and parts of the force. Without exception, every member of the workforce was clear about the importance of ethical behaviour. Many said that the code of ethics was an important resource for them. Staff had a positive view of their supervisors as sources of ethical guidance and support for them. They also regarded senior leaders in the force as ethical role models. The workforce showed a good working knowledge of ethics and their duty to report business interests, notifiable associations, and gifts and hospitality.

The ethics, equality and inclusion group offers strategic governance. If staff members encounter an ethical dilemma, they can refer it to the regional ethics committee.

This committee is available to members of all seven regional forces. Members of the committee offer ethical advice, with support from an academic expert in ethics. Staff we spoke to were generally unaware of the committee, but it was only established in January 2019. We will monitor how the force promotes the committee to its staff.

The force’s sergeants and inspectors spoke positively about the professional standards department (PSD). There was consensus that the force encourages a ‘no blame’ culture, where mistakes can be learned from. There was a clear focus on prevention by the PSD. This takes the form of prominent reminders in shared spaces (such as canteens) and staff training. The PSD evaluates the training that it offers. It also seeks good practice from outside the service. This includes the construction industry and ethics departments in local academic institutions.

In 2017, we identified an area for improvement: we said that the force should improve the quality and distribution of its printed information about how to make a complaint, in line with the Independent Office for Police Conduct (IOPC)’s statutory guidance. The force has now updated this material and distributed it to enquiry offices. We saw the updated material. It was clear and prominently displayed. It also meets the public’s needs.

A collaborated, tri-force vetting department completes workforce vetting checks. In 2017, we identified an area for improvement and said the force should have a credible plan to comply with all aspects of the national vetting standards by December 2018, in line with a national HMICFRS recommendation from 2016. The force does now have a credible plan. But it doesn’t yet comply with all elements of national vetting standards. This is largely due to extensive recruitment across the three forces. The situation is improving, however: in January 2019, 77 percent of staff in Bedfordshire Police had sufficient security clearance. By the end of June 2019, this figure had increased to 83 percent. As a result of a recent restructure of responsibilities, the force has assigned a further six posts to vetting checks.

Although the force does take its vetting responsibilities seriously, we researched a small sample of designated posts that require the highest level of vetting because of the nature of their work. Some staff weren’t sufficiently vetted. We are satisfied that chief officers frequently monitor plans, and will act to ensure that full vetting compliance is met. But the force should reassure itself that staff in designated posts have the correct level of current vetting.

All forces need to understand whether people’s ethnic background disproportionately affects the results of vetting checks. Bedfordshire Police does monitor and scrutinise these outcomes, which senior staff check for any learning or bias. Vetting officers routinely attend recruitment events to offer the best advice and guidance to potential applicants.

We spoke with staff and examined how the force communicates outcomes from misconduct cases to improve its own understanding. Staff were aware of Shield, the professional standards publication that contains information and lessons learned from local and national cases. The force’s intranet was an important form of guidance, and the main source of updates about recent misconduct outcomes.

Recently, the head of the PSD carried out face-to-face sessions with staff of Bedfordshire Police, as well as Cambridgeshire and Hertfordshire constabularies. The aim was to offer useful information about professional standards investigations, ethics and culture. The sessions included a four-hour workshop on sexually predatory behaviour in the workplace. These sessions have supported understanding among staff. Across the tri-force area, 77 staff have volunteered to become PSD champions in their own departments. The champions are intended to be local points of contact for officers and staff who want to access professional standards information.

Tackling corruption

The force is good at identifying and tackling corruption. It has a local strategic counter-corruption threat assessment that meets its needs. This assessment identifies the force’s priorities as sexual misconduct, vulnerability and disclosure of information. However, the force doesn’t explicitly identify the associated control measures for each of these priorities (for example, the proposed intelligence, prevention, enforcement, communication and engagement activity to counter each of the identified threats).

The force’s use of proactive tactics in tackling corruption is limited because of resources. But it does use the information it holds about its employees to identify staff who may become a corruption risk to the force. This information includes staff with high overtime or mileage claims, or credit card usage. The force also considers other data relating to sickness absence, complaints and misconduct. But the force doesn’t discuss these indicators at a single meeting, where it could make decisions based on the intelligence and agree consistent actions.

The force consistently records comprehensive information for all gifts and hospitality. It publishes the register for the whole workforce annually, and its own policy requires publication of chief officers’ data every quarter. The force also has a business interests policy and register. But it doesn’t routinely review rejected applications. It should address this issue to make sure that staff are abiding by the decisions. The force has conversations about integrity with the workforce during annual performance reviews. As a result, staff have a good knowledge of their obligation to declare a business interest. However, the force’s own assessment is that it needs to improve compliance with its professional development review (PDR) process. There is work in progress with the human resources function, including a new PDR ICT system, to make supervisors more accountable.

The force acknowledges that current staffing levels are good enough to deal reactively with incoming intelligence, but that there is only a limited capacity for proactivity. It hasn’t made use of intrusive, covert tactics as part of its investigative response for several years.

The force has the capability to monitor all its ICT systems and the data contained within them. But it doesn’t make proactive use of its ICT monitoring software to check that employees’ use of the data within their systems is appropriate and lawful. The strategic assessment outlines plans for more proactive scanning (for example, in relation to staff who exhibit sexually predatory behaviour). But the force doesn’t yet have these plans in place to help identify those staff.

The force has developed good links with external agencies that support vulnerable people. Since June 2018, the force has given presentations to a range of partner agencies that support refugees and victims of domestic abuse, as well as to drug and alcohol-related support agencies.

The force has confidential reporting systems so that staff can report internal wrongdoing. These comprise a direct telephone line to the counter-corruption unit and an email inbox. The force also uses the Crimestoppers system to allow colleagues to submit intelligence anonymously. During our fieldwork, the force handled this material appropriately.

In 2017, we identified an area for improvement: we said that the force should ensure that all allegations that meet the mandatory criteria for referral to the IOPC are so referred, and that it updates witnesses and subjects regularly. This is no longer a concern. The force has links with IOPC counterparts and meets them regularly. The force also dip-samples cases, to make sure that referrals have been made. And the IOPC confirms that, when necessary, the force seeks its guidance about more complex cases.

The force recognises the abuse of position for a sexual purpose as serious corruption. This is reflected in the force’s local counter-corruption strategic threat assessment, which identifies this issue as the main corruption threat facing Bedfordshire Police.

In 2017, the force submitted a plan to address our 2016 national recommendation regarding the abuse of position for a sexual purpose. It hasn’t yet fully implemented this plan, because of the counter-corruption unit’s lack of resources. And some Bedfordshire Police staff told us they are yet to receive training on identifying the signs of abuse of position for a sexual purpose.

This question was not subject to detailed inspection in 2018/19, and our judgment from the 2017 legitimacy inspection has been carried over.

However, Bedfordshire Police had two areas for improvement in the 2017 legitimacy inspection. The first identified a need for the force to ensure that the grievance process complies with the Advisory, Conciliation and Arbitration Service codes of practice and guidance, particularly relating to timescales, records, audit trail, updates and support to witnesses and staff who have lodged grievances.

We reviewed a selection of grievance files. They showed that the force dealt with all but two of these grievances effectively, giving regular updates to witnesses and staff, and completing the grievances within the recommended timescales. This was partly due to the efforts of the human resources team in monitoring and (when necessary) chasing progress in individual cases, to make sure that the force dealt with them promptly and to the required standard.

The second area for improvement identified that the force should make sure that it develops and supports its supervisors and managers to conduct fair, effective and consistent assessments that support continuing professional development and manage poor performance, including establishing an effective quality assurance process.

The force has made some progress in this respect, but its work isn’t complete. In July 2019, the force was due to introduce its new PDR framework (‘my conversation’). This new framework contains a second line manager’s quality assurance, and emphasises the need to address staff performance, development and wellbeing. We will monitor the implementation of this new approach.