Cheshire 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.

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

Maintaining an ethical culture

Cheshire Constabulary has a newly formed strategic plan for 2019/20 in which it clearly sets out its values as being:

• respect;
• integrity and transparency; and
• fairness.

When we inspected, the code of ethics was displayed prominently throughout the constabulary. Policies we examined contained equality impact assessments. As part of its promotion processes, potential leaders are required to demonstrate competence in managing situations involving ethical problems.

The leadership has set out a people promise behavioural framework. This focuses on leading, supporting, developing, and an open and healthy culture.

In the past 12 months, the force leadership has dealt with the challenges of a high-profile court case with one of its officers convicted of a serious sexual offence while on duty. They have worked internally to raise the profile of abuse of authority and encourage ethical reporting, and externally through transparent communications with the public of Cheshire to provide reassurance.

A professor of ethics from Chester University advises the ethics panel. Ethics meetings can be called as issues arise. Staff and the PCC can propose issues to be considered and this is advertised on the intranet. However, we found virtually no knowledge of the ethics panel among the workforce we spoke to. The constabulary should increase the awareness and effectiveness of the ethics panel and its procedures. This will make sure ethical dilemmas are raised and that what has been learnt is passed on to the workforce.

Most staff we spoke to had regular conversations with their supervisors, but it was rare to have ethical issues built into this. We found no monitoring of the annual integrity health check that should be completed between individuals and supervisors. It should work with its professional standards department (PSD) to make improvements. However, we were given some examples where officers have challenged the perceived standards of other officers.

We were pleased that most of the workforce we spoke to considered that the constabulary now has an open learning, rather than a blame, culture. The PSD shares an open learning policy, which is positive. The PSD has completed an area for improvement we identified in 2017. It has improved the information provided to complainants and the recording of complaints.

The constabulary complies with the National Vetting Code of Practice and authorised professional practice (APP) when recruiting. This includes contractors and volunteers. But it doesn’t monitor vetting decisions to identify disparities (e.g. BAME groups). As a result, it doesn’t act to reduce them where appropriate. This is something it needs to consider.

The constabulary fulfils its requirements to check whether anyone it intends to employ is on either of the barred or advisory lists held by the College of Policing. It complies with APP direction in relation to the barred and advisory lists, both checking incoming personnel and ensuring those dismissed are placed on the appropriate lists.

The constabulary has not achieved our 2016 recommendation that, within two years, all members of the police workforce should have received at least the lowest level of vetting clearance for their roles. Progress since 2016 can only be described as slow.

There are backlogs in the vetting renewals and reviews of current staff as the unit focuses on new recruits. During our inspection, we identified outstanding vetting for 35 officers and 355 police staff. These backlogs highlight the need to review the vetting unit’s resilience and effectiveness.

The constabulary has effective channels for clarifying and reinforcing acceptable and unacceptable behaviours. Learning is included in newsletters, intranet updates and weekly orders. This includes learning from national events and incidents.

A communications strategy was launched following a serving police constable being convicted of a serious sexual offence while on duty. Details of misconduct cases are shared so the workforce understands the consequences of not meeting the expected standards of behaviour.

We found that staff regularly used constabulary policy to record gifts and hospitality. Most staff we spoke to understood that these needed to be reported, but not what to do if gifts were declined. The workforce would benefit from the integrity policies being shared and clarified. We discovered some uncertainty about gifts reporting procedures and what exactly was a notifiable association.

Tackling corruption

The constabulary is generally good at managing organisational corruption risks.

We found the strategic counter corruption threat assessment to be fit for purpose, and it had a related control strategy. But the threat assessment could be more localised.

The documents outline the main control strategy areas and related intelligence, enforcement and prevention priorities. But there were no ownership or timescales attributed to the activity that would take place as a result.

The constabulary makes good use of the integrity registers, although it could do more to check compliance with decisions around both business interests and notifiable associations.

It doesn’t hold a formal proactive people intelligence meeting. But it does use local management interventions and the CCU conducts ethical interviews.

The constabulary is good at looking for and assessing intelligence about potential corruption. There is a confidential reporting system that is provided through ‘Crimestoppers’, which is available to staff and the public. Most of the workforce we asked about it considered it to be confidential.

The CCU has launched an awareness campaign which has increased reporting of integrity concerns. There is a well-used facility to report directly into the CCU. In 60 corruption intelligence cases we reviewed, more work could have been carried out in just five.

There are strong links with external groups who support vulnerable victims. CCU staff have given several presentations to social care and social workers. These have been provided at both managerial and practitioner levels. The abuse of position action plan explains the work carried out.

As well as the presentations, a handout outlines triggers for concern and signs to look for. This has been provided to external organisations. The constabulary can evidence several cases where referrals have been generated since these links were developed. This is encouraging.

The constabulary has invested in IT monitoring software. CCU staff are becoming increasingly experienced in using it. It was explained that this system can monitor all systems including hand-held devices and phones. But the CCU lacks the capacity to carry out more proactive work which is something it now needs to consider.

We examined the abuse of position action plan. The document is comprehensive and shows significant activity across all prescribed areas in the NPCC strategy. The constabulary has raised awareness among its workforce on this issue. It has trained supervisors in the signs to look for among staff. While awareness training was still under way, we were surprised to find many staff who hadn’t received any training on this issue. This included some in supervisory detective posts. The constabulary should continue its work to raise the profile of this among its workforce.

Corruption intelligence is held on a dedicated system. This is firewalled and only accessible on computers within the CCU. This was found to be up to date and well maintained by CCU staff. All the cases reviewed requiring referral to the Independent Office for Police Conduct were correctly referred.

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