Cambridgeshire 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, we reviewed a representative sample of 100 stop-and-search records to assess the reasonableness of the recorded grounds. We found that 91 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.

The force met the recommendations as they were set out in 2017, but improvements to effective practice means there is more it can do now. It should monitor 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 establish 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 found no obvious mention of analysis it had carried out to understand and explain reasons for disparities or any subsequent
action taken.

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 our fieldwork, we spoke to many officers and staff in different ranks, roles and parts of the force. Every member of the workforce we spoke to was clear about the importance of ethical behaviour and spoke confidently of the need to ‘do the right thing’. They demonstrated a practical understanding of their responsibility to act ethically and showed confidence in both their supervisors and the procedures for challenging and reporting unprofessional conduct.

The deputy chief constable oversees the ethics, equality and inclusion group. Its meetings feed information into the tri-force BCH board, which maximises learning across the three forces. Local policing commanders discuss ethics as a standing agenda item at their meetings. We saw examples where officers and staff had challenged masculine cultures, fairness in promotion processes and use of force in a healthcare setting. The force has branded its guidance to officers and staff in line with the Code of Ethics and the chief constable reinforced this during workshops to evaluate the LPR.

The force has a culture of learning. It takes a proportionate approach to misconduct and gives due consideration to severity and learning opportunities. One example concerned inappropriate access to force systems following the arrest of a celebrity. It took swift action and used the opportunity to educate those concerned. This was proportionate and reinforced a culture of learning and openness.

A PSD scrutiny panel encourages honesty and openness and provides the force with opportunities to improve. The panel is a diverse group of people from professional, academic and community backgrounds. The panel examines:

• use of force;
• stop and search;
• decision making in misconduct; and
• how well the force educates others to understand and spot the signs of corruption.

This level of scrutiny encourages improvements in the force and helps it demonstrate integrity to partner organisations and marginalised communities. The force shares its anti-corruption policy with partner organisations and evaluates the training it provides. The head of the PSD gave us examples that showed the force seeks good practice from outside the service, including the construction industry, and through its links with the professor of ethics at the University of Hertfordshire.

A BCH tri-force vetting department completes workforce vetting checks. The force doesn’t yet fully comply with all elements of national vetting standards. This is largely due to extensive recruitment across the three forces. However, a recent restructure has created more efficient processes and more vetting capacity. The department reduced its backlogs from 18 percent in April 2019 to 16.7 percent in May 2019, which is encouraging, given that the force also recruited an additional 40 staff that month. It takes its vetting responsibilities seriously and has routinely carried out more extensive pre-employment checks than had been required, including social media and drug testing of new recruits. It suitably vets all people in designated posts – that is, those that need a higher level of vetting because of the nature of their work. We are satisfied that chief officers frequently monitor plans and will act to ensure full compliance.

The College of Policing requires the force to create Flagstone records to update barred and advisory lists. These lists prevent people who have left the service under investigation, or whom the force has dismissed, from re-joining or working in law enforcement. The force routinely complies with this requirement.

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

Senior leaders in the PSD meet regularly with other heads of departments to discuss officers and staff who may be at risk of corruption, and use learning from cases they have investigated. They frequently brief all officers and staff to reinforce and clarify unacceptable standards. To maximise the reach and effect, the head of professional standards has carried out face-to-face surgeries with officers and staff across the three forces to debunk myths and provide openness about professional standards investigations, ethics and culture. This included a four-hour workshop on predatory behaviour. These sessions have begun to clarify understanding among the workforce. Across the tri-force area, 77 staff have volunteered to become PSD champions in their own departments. The force initially trialled use of champions within the Special Constabulary and found it to be effective.

The three forces have recently introduced 60-second professional standards briefings, which are pop-up bulletins that appear when officers and staff first logging on to force ICT systems. The intention is to use known and credible champions to promote learning among colleagues and cement ethical discussions. The BCH forces have agreed to use a rolling programme of interns in the PSD. They will work alongside policing supervisors to support this approach and carry out evaluations.

Conventional monitoring of ethics and standards through annual PDRs also includes an integrity health check. This is a document that guides managers through a checklist with officers and staff that includes standards, gifts and hospitality, notifiable associations and business interests. However, there is no current process to record responses and compliance. The BCH forces also commission the University of Durham to carry out workforce surveys. The latest survey, in May 2019, sought the views and perceptions of officers and staff on clarity, ethics and leadership.

During our fieldwork, we spoke with officers and staff and examined how the PSD communicates the outcomes of misconduct cases to improve their understanding. They make good use of the force intranet, Nimbus, and have access to an extensive range of useful guidance. They get information from Shield, the PSD publication that communicates information and outcomes. They also read force bulletins and chief officer blogs.

Most officers and staff said they had received some level of training, whether through e-learning or direct training, to recognise unconscious bias. Although they said they felt confident in challenging unacceptable behaviour – one member of staff provided an example about reference to sex industry workers – they also said they hadn’t received any recent training on abuse of authority for a sexual purpose. They did consider their senior leaders to be positive role models, however, and said there was greater openness in decision making, such as in promotion processes. We also noted that the PSD shares its severity assessments, which it uses to risk assess the severity of complaints and determine proportionate management.

Tackling corruption

The force is good at identifying and tackling corruption. It has assessed the threat of corruption and developed a counter-corruption control strategy. It uses information held about officers and staff well, to identify those potentially at risk of corruption, and is effective in taking steps to intervene. Force briefings to champions are beginning to improve the understanding of the wider workforce and highlight important concerns. This shows that the force doesn’t wait to react to intelligence, but, instead, takes good steps to prevent corruption.

Supervisors conduct integrity checks during annual performance reviews and, through these, staff know they must declare any business interests. Recent force communications have also reinforced awareness of notifiable associations and abuse of position for a sexual purpose. We saw an example where one member of staff sought guidance from PSD on a notifiable association. That approach was met with practical advice and support.

The force acknowledges that current staffing levels are only enough to deal reactively with incoming intelligence, with limited capacity for proactivity. However, departmental leaders have applied for additional staff to proactively monitor the force’s extensive range of ICT systems. We saw that the force uses effective techniques to follow up intelligence and investigate cases. It routinely monitors staff use of data, including hand-held devices, for evidence of misuse. We reviewed a sample of intelligence reports and investigations linked to corruption and the force had taken appropriate action in all cases.

As well as its own confidential reporting line, the force makes use of Crimestoppers to deal with anonymous reports made by the public. It handles material appropriately and makes mandatory referrals to the Independent Office for Police Conduct, which confirms that, when necessary, its guidance is sought on less clear cases.

A corruption prevention officer has been in post for two years and works with other managers to target presentations at new recruits as well as mid-service officers who haven’t received recent training. The prevention officer has also trained representatives of partner organisations to look for signs of potential abuse of position for a sexual purpose. They trained Cambridgeshire IDVAs in September 2018 and have given presentations to community groups and a private business that works with vulnerable young people. We reviewed a sample of investigations into this type of behaviour and found the force had dealt with each one appropriately.

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