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Cumbria PEEL 2018


How legitimately does the force treat the public and its workforce?

Last updated 01/05/2019

Cumbria Constabulary is good in the way it treats the public and its workforce.

The constabulary is good at treating the public fairly. Senior leaders make sure officers and staff understand the importance of fairness and respect when dealing with the public. Neighbourhood teams engage with communities to understand their problems and keep them updated about actions. Schemes such as the mini-police in schools help to improve understanding.

Officers and staff are trained to use force and stop and search powers appropriately. Frontline staff use body-worn video cameras, giving extra reassurance that they act professionally. Internal scrutiny of these powers ensures they are being used properly. The constabulary publishes data for the public. But there could be better external scrutiny.

The workforce is good at behaving ethically and lawfully. Policies and processes align with the Code of Ethics. The workforce understands the principles of the code. But the constabulary should improve how it discusses ethical dilemmas with the workforce.

All officers and staff are vetted to the correct level, with minimal backlogs.

The outcomes of complaint and misconduct investigations are published. This ensures lessons are learned about acceptable standards of behaviour.

The constabulary has a good capability to tackle potential corruption. But it needs to improve its ability to gather intelligence proactively.

Officers and staff have a good awareness of the problem of abuse of position for a sexual purpose. They have been trained to look for warning signs.

In 2017 we judged Cumbria Constabulary as good at treating its workforce fairly.

Questions for Legitimacy


To what extent does the force treat all of the people it serves with fairness and respect?


Areas for improvement

  • The force should ensure effective external scrutiny of its use of force.
  • The force should ensure effective external scrutiny of its use of stop and search powers.

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

Treating people fairly and respectfully

The senior leadership team has worked hard to develop a culture of learning and development within the constabulary, based on the ethos of treating everyone with fairness and respect.

The constabulary has a clear mission “to deliver an outstanding police service to keep Cumbria safe”. How it will achieve this is explained succinctly in the constabulary’s ‘plan on a page’. This outlines its values, main policing services, approach to providing those services, and how the constabulary will change to meet future challenges. Although few officers and staff mentioned the plan explicitly, they did show a good understanding of the plan’s principles. And they showed us they understood the importance of treating the public with fairness and respect.

All new and revised policies are subject to external scrutiny by the ethics and integrity panel. This ensures they reflect the values of treating people fairly and with respect. Internally, equality impact assessments help to ensure that all policies, procedures and training courses have due regard to legal responsibilities and constabulary values.

The constabulary has established effective channels to engage with local communities and respond to their needs. These include face-to-face meetings between neighbourhood teams and residents. The constabulary also makes good use of a range of social media. Local Facebook chat groups help neighbourhood teams to identify and respond quickly to local concerns. For example, at the time of our inspection the Carlisle Facebook group had 317 active members. As a result of comments posted about mobile phone use when driving and anti-social parking, neighbourhood officers and police community support officers were able to respond swiftly to public concerns. Afterwards they reported back to the Facebook group. It is also used to publicise events and campaigns, such as road safety. For those who don’t use social media, neighbourhood teams offer leaflets and focus on face-to-face community engagement.

We found the external neighbourhood web pages were generally up to date and reflected local concerns and action taken. Following public consultation in 2017, the public wanted a newsletter as their main communication with the constabulary, followed by social media. In response, the constabulary introduced a newsletter and reports that it has already about 4,000 people signed up to receive it. Through the constabulary website the public can also sign up to receive email updates on local issues.

The constabulary is using both traditional and new ways of involving people in crime prevention activity. It is reviewing its approach to the special constabulary to attract the right people with the right skills in the right areas. It uses cadets and volunteer schemes.

The constabulary reports that the mini-police scheme has been particularly successful with over 25 schools and 538 children engaged in activities. It makes good use of this scheme as an indirect way of encouraging engagement. It focuses on those communities which have traditionally had less confidence in the police.

We saw good examples of initiatives to re-engage communities that have felt they have not had the level of service they expect. The introduction of the Farmwatch scheme with good neighbourhood policing support is an example. Neighbourhood teams attended events such as farmers’ markets and livestock auctions and listened to farmers’ concerns. They acted on their concerns and worked together with the farmers to develop a plan which met their needs. This was valued by farmers who had become disaffected with the constabulary response to dealing with rural crime.

The constabulary tries to engage with those people and communities who are less likely to have contact with the police. A diversity channel on Twitter focuses on the various strands of diversity. It encourages those who are facing any type of crime to report it. The constabulary is working to make sure that it serves the public fairly. Most of the workforce we spoke to had either had or were about to receive unconscious bias training. The aim is to help the workforce understand the effect of unconscious bias on their working lives, to work towards eliminating discriminatory behaviours and to make the constabulary a more diverse, inclusive and productive place to work.

Community work in the Kirby Stephen area has successfully addressed the concerns of local people following the Appleby Fair. During this annual fair 10,000–15,000 English, Welsh, Romani, Scottish and Irish gypsy Roma travellers gather to buy and sell horses, meet with friends and relations, and celebrate their culture.

The constabulary is considering innovative ways to develop closer working with communities. The ‘connected communities’ pilot is an integrated approach to understanding communities’ needs. It uses joint problem solving to work with the community in meeting those needs. We are interested to see how this develops.

Using force

Cumbria Constabulary provides effective initial training and annual refresher training to officers and staff about the appropriate use of force. The constabulary regularly reviews and updates its training courses so that they reflect any changes to legislation, policy or process. Changes to policies and procedures are communicated through the internal website’s ‘need to know’ link.

All officers and staff we spoke to showed a good understanding of their powers and the tactics available. They could tell us about the principles of legality, proportionality, respectfulness and fairness as their main considerations in using force. They showed a good knowledge of the requirement to complete use of force forms on their handheld devices.

The constabulary has addressed the area for improvement from our 2017 legitimacy inspection in respect of the use of body-worn video. Officers understand the benefits and now use it regularly in interactions with the public. Among the workforce there is a positive view of the benefits of using body-worn video cameras.

Since April 2018, the constabulary has significantly reduced the backlog of officers waiting for refresher training. It has focused on frontline officers and is now reducing the backlog of officers in other roles. Officers and staff spoke positively about the quality of this training to prepare them to deal with a broad range of situations.

The constabulary still complies with all the National Police Chiefs’ Council’s use of force recording criteria, apart from the ability to record use of force in public order incidents. We noted this in our 2017 legitimacy inspection. The constabulary has not made progress. Officers still can’t access the reporting forms for use of force in public order incidents. The constabulary is aware of the problem and is in the process of renegotiating an ICT contract that will ensure all appropriate reporting forms are available to officers on their hand-held devices.

There is a robust internal monitoring and scrutiny framework to oversee the appropriateness of the use of force. The constabulary monitors and analyses a broad range of data and uses it to improve the way in which force is used. For example, a review of data showed that officers were selecting other tactics rather than using their PAVA incapacitant spray. This reluctance to use PAVA was leading to an increase in injuries to officers and offenders. The training syllabus was revised to improve decision-making on its use. Consequently, the number of injuries has reduced.

Scrutiny of body-worn video footage by inspectors and the business improvement unit gives added reassurance about its appropriate use. The unit conducts a monthly dip sample of use-of-force forms and body-worn video footage. They give feedback to officers and also submit a report to the use-of-force board. This means that the constabulary can act on anything needing a more co-ordinated, constabulary-wide response.

The ethics and integrity panel recently did a dip-sample of body-worn video footage. They found that officers were highly professional in the use of force and their communication. The constabulary told officers about this positive feedback.

The constabulary is open with the public about its use of force. It publishes the data on its public-facing website. Although there are internal groups monitoring use of force, there are limited external scrutiny arrangements. After an external review the constabulary implemented recommendations and changes to improve the quality of recording of the use of force. There are plans to involve further the ethics panel in considering some future elements of the use of force, such as spit guards.

The constabulary’s geography makes it difficult to adopt traditional methods of external scrutiny, such as a single constabulary-wide use-of-force external scrutiny panel meeting. The constabulary should consider the different methods of public engagement. And it should consider how technology could help.

Using stop and search powers

Our inspection found that all frontline officers are trained in the use of stop and search and have a good understanding of their powers. They receive regular updates of changes in policy or legislation through briefings, ‘need to know’ internal website updates or the best use of stop and search newsletter. Despite this level of understanding, several officers had not used their powers of stop and search for a considerable length of time. Some told us they were too busy for proactive work. Others lacked confidence in using the powers.

Within the constabulary there is again extensive internal scrutiny of stop and search. We reviewed a representative sample of 100 stop and search records to assess the reasonableness of the recorded grounds. We found that 93 percent had reasonable grounds recorded. Our assessment is based on the grounds recorded on the record by the searching officer and not the grounds that existed at the time of the search.

The business improvement unit scrutinises every form and gives feedback to officers through their supervisors, either positive or developmental. The unit collates the findings of scrutiny and provides monthly performance information to each area superintendent in their ‘Quality Counts’ performance pack.

The community safety department presents a quarterly performance report on the overall use of stop and search powers to the local policing and specialist capability board. The report draws out learning points and officers can access them on the constabulary ‘need to know’ intranet page.

The rigorous scrutiny arrangements provide appropriate assurance that powers are not abused, and also help to ensure that lessons are learned and good practice is highlighted. For example, the scrutiny identified that officers were unclear on the use of stop and search based on the smell of cannabis. The constabulary gave amended training to all frontline officers to ensure a more consistent understanding. Officers we spoke to who had completed this training explained the issue clearly to us.

However, an unintended consequence of this high level of oversight and governance is that there is little involvement from first-line supervisors in directly monitoring their own staff’s use of stop and search. The constabulary may be losing an opportunity for supervisors to be more actively involved in supporting and assisting their staff in the proper use of their powers. The constabulary recognises this and hope that its new performance information system will provide better data for supervisors to identify those staff who may need additional support.

There are more formal external scrutiny arrangements for stop and search than for use of force. There is an external stop and search scrutiny panel, with a remit to review a sample of stop and searches that have been carried out. The panel reports to the strategic independent advisory group. However, membership numbers are low despite constabulary efforts to increase them. As with the use of force panel, the constabulary finds it hard to recruit and keep a diverse membership that reflects its communities. Members have not had any formal training but are still confident to challenge the constabulary and have a good understanding of stop and search.

The constabulary makes good use of community forums, set up to deal with planned events, in seeking feedback on stop and search. During this year’s Appleby Fair, the constabulary shared and reviewed daily the use of stop and search tactics with the community adviser group. This ensured fair and appropriate use of the power and provided both greater understanding and reassurance in its use among the community.

As with use of force, the constabulary should consider how technology can help improve its external scrutiny arrangements for stop and 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 constabulary has partially complied with 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); and
  • prevalence of possession-only drug searches, and the extent to which these align with local or force-level priorities.

The constabulary has taken steps to comply with our 2017 national recommendation on publishing an explanation of any disparity in stop and search data. It has recently published on its website an explanation of disproportionality in the stop and search of black, Asian and minority ethnic (BAME) people. 

Summary for question 1

How well does the force ensure that its workforce behaves ethically and lawfully?


Areas for improvement

  • The force should ensure that its counter-corruption unit:
    • has enough capability and capacity to counter corruption proactively and effectively; and
    • continues to build effective relationships with individuals and organisations that support and work with vulnerable people.
  • The force should ensure it has an effective process for the workforce to refer and discuss ethical concerns.

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

Senior leaders in Cumbria Constabulary continue to promote the Code of Ethics through a variety of means. These include roadshows, an ‘ask the chief’ section on the internal website, supervisor briefings, intranet video briefings and leadership training. Officers and staff we spoke to during our inspection understood the principles of the Code of Ethics. Trainers running courses in, for example, mental health awareness, encourage ethical discussions as part of the learning.

The ethics and integrity panel reviews all policies to check that the Code of Ethics is the basis for policies and procedures. The principles of the code are integrated into the constabulary’s revised ‘plan on a page’. The workforce clearly has a better understanding of the importance of ethics than we found in our 2017 legitimacy inspection. But there was little mention of the ‘plan on a page’ during our reality testing. Senior leaders may wish to tell the workforce about it again in different ways. That way they can be confident everyone fully understands the central role the code plays in achieving the constabulary’s mission of “delivering an outstanding police service to keep Cumbria safe”.

While the ethics and integrity panel is able to provide robust challenge to senior leaders’ policies, decisions and actions, there is no established mechanism for the workforce to refer or discuss ethical dilemmas outside the training environment. Officers and staff can ring the professional standards department (PSD) on a dedicated number to seek advice and guidance on ethical dilemmas. But we found that this was not widely known or used by the workforce.

We found limited evidence of first and second-line managers having regular ethical discussions with their staff, either individually or collectively. The move to 15-week strength-based conversations with individuals, replacing the 15-week performance review, may improve the level of ethical discussion that takes place. Those people trained in the new approach spoke positively about the benefits. But because of the 15-week cycle, relatively few managers and staff have experienced the new strength-based conversation. The constabulary should consider how it can engage better with the workforce on ethical issues. This should make sure it continues to develop the culture that is integral to the success of the ‘plan on a page’ and Cumbria Vision 25.

We found that officers and staff are aware of the confidential reporting line to report wrongdoing. But not all were confident that it was truly anonymous. As part of its change programme the head of the PSD is implementing an action plan. This includes measures to improve the relationship between the PSD and the workforce.

In our 2016 national report about legitimacy we recommended that the workforce should all have received at least the lowest level of vetting by December 2018. The constabulary has worked hard to clear its vetting backlog. It is now compliant with our 2016 recommendation. The constabulary informally monitors all vetting decisions to work out whether there is any disproportionality in decision-making, for example in respect of people from a black, Asian and minority ethnic background. But this is still in the early stages and so there isn’t enough information to assess its effectiveness.

Cumbria Constabulary complies with most of the Authorised Professional Practice for vetting. But it does not complete Special Branch checks on some contractors who have only limited access to constabulary buildings, although we note that it does conduct some other security checks. During our inspection we reviewed the records of a sample of officers and teams in posts subject to enhanced vetting. All were vetted to the appropriate level and were well within date.

The constabulary has an effective mechanism for recording lessons learned and recommendations for improvement from other sources. Such recommendations come from serious case reviews, near-miss incidents and misconduct cases. The constabulary incorporates this organisational learning into its improvement plan. Managers in the relevant business area are given specific actions to implement based on this. The business improvement unit monitors progress monthly.

The constabulary highlights this organisational learning in briefings, the intranet and the PASS (people we know, areas we work, standards of professional behaviour, systems we use) newsletter. Most officers and staff we spoke to during our inspection knew of the PASS newsletter. And they knew about the reinforcement of standards through the ‘need to know’ briefing section on the intranet.

Officers and staff showed a good understanding of the expected standards of behaviour and their responsibilities concerning business interests, notifiable associations and gifts and gratuities. We reviewed the PSD page on the intranet and found that it had information on most areas of conduct. We understand that the web page is being reviewed in line with the PSD action plan. It will be relaunched with additional information available, such as tackling abuse of position for a sexual purpose.

The constabulary meets its obligation to record and share intelligence so that the College of Policing can keep up-to-date lists of people who have been subject to gross misconduct or other serious disciplinary matters. It complies with its obligation to notify the College of Policing for the barred lists of people who have been dismissed or resigned while under investigation for gross misconduct.

Tackling corruption

Cumbria Constabulary completes a strategic threat assessment for both corruption and wider PSD matters. It has a comprehensive control strategy which reflects this assessment and shows gaps in the constabulary’s understanding of corruption risks. The control strategy describes the intelligence, prevention, enforcement and reassurance/support priorities. These documents are reviewed every six months. The constabulary should consider developing this process further to profile corrupt officers, corruptors and any corruption hotspot locations.

The constabulary makes good use of information it holds on its workforce. This includes information it receives on business interests, gifts and gratuities and notifiable associations. The constabulary is good at responding to initial notification and intelligence in these areas. But it does not currently routinely and proactively monitor compliance with any decisions or conditions imposed.

It uses early interventions appropriately, including ethical interviews to resolve concerns and debt management referrals in financial difficulty cases. But it could do more to evaluate the effectiveness of such interventions.

The constabulary has good capability for monitoring its IT systems where it suspects there may be improper use. But this is confined to responding reactively to intelligence received. It could make greater use of its monitoring software to actively look for corruption risks. It could regularly check that officers and staff that have reported notifiable associations are not misusing systems.

The constabulary has begun developing links with external agencies, such as adult social care and the local child safeguarding board. This is supported by an email group for dissemination of appropriate messages.

It holds corruption intelligence locally on a dedicated stand-alone system which was recently upgraded. We found this to be up to date, managed well and the data fully searchable. During the file review we found several cases where potential development opportunities were not pursued. In some cases, this may have been a recording problem, but this was not the case in all instances.

The counter-corruption unit is small, so the constabulary has limited capacity to use covert investigative techniques. But we found the staff in the unit were aware of relevant tactics. We examined one case where the constabulary used covert regional resources to conduct a proactive and intrusive investigation. Of the 31 cases reviewed, five needed referring to the Independent Office for Police Conduct. All were referred appropriately. Four of the investigations reviewed needed referring to the local authority designated officer and this was completed in each case.

The constabulary is aware that it is reactive in its approach to counter-corruption at the moment. Although it does have the systems in place to be proactive, there are not enough staff within the counter-corruption unit to conduct proactive intelligence development. The PSD action plan includes a restructure of the department by revising processes, roles and responsibilities. Senior leaders have approved this and hope it will help to provide additional capacity.

Cumbria Constabulary is good at finding and tackling cases of abuse of position for a sexual purpose. It recognises this as serious corruption, and this is reflected in the constabulary’s local corruption strategic threat assessment. The constabulary’s response to the 2016 national recommendation plan on abuse of authority for sexual gain has been submitted.

The constabulary’s business improvement unit has governance over the implementation of the plan. It is part of the constabulary improvement plan. The head of the PSD provides monthly updates, so the plan stays on track. Good progress is being made on all actions within the plan.

Further work is needed, particularly in respect of proactive work to identify corruption risks. The constabulary needs to continue to develop partners’ awareness of abuse of position for a sexual purpose and provide information so any risks of this are identified quickly.

The constabulary offers effective material and briefings to raise awareness of the problem of abuse of position for a sexual purpose, including material on recognising the warning signs for supervisors and colleagues. The constabulary reports that over 1,200 officers and staff have attended PSD roadshow training events focusing on abuse of position for a sexual purpose and ethical behaviour. The chief constable has given a video briefing. And there has been a series of media campaigns.

Cumbria Constabulary conducted a benchmarking exercise to establish the levels of understanding of the workforce of abuse of position for a sexual purpose. After six months this had notably improved from 55 percent to 73 percent. During our inspection we spoke to officers and staff throughout the constabulary. All had a good knowledge of abuse of position for a sexual purpose and could describe the warning signs. Most said that if they had any concerns they would speak to their line manager in the first instance. The inclusion of integrity-related matters in the 15-week strength-based conversation between line manager and individual is an encouraging development. This should improve further the constabulary’s understanding of these matters. In future inspections we will examine how well the process is informing the constabulary’s response.

The constabulary has links with external partners, including adult and children’s services, charitable organisations and victim support services. Partnership events have raised awareness and encouraged the exchange of information and intelligence about abuse of position for a sexual purpose. The PSD action plan supports continued engagement, extending its reach to include agencies involved with sex workers and local gyms.

Summary for question 2

To what extent does the force treat its workforce with fairness and respect?


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