Gloucestershire PEEL 2018
How legitimately does the force treat the public and its workforce?
Gloucestershire Constabulary’s leaders act as positive ethical role models.
Officers and staff understand the force’s values. Leaders use these values when they make decisions. There is an annual integrity check. The promotion process includes an assessment of ethical behaviour.
Leaders foster a no-blame culture that does not try to blame people for mistakes but instead learn from what went wrong. Officers and staff feel that the force supports them if they have made mistakes.
Although the force has vetted all officers and staff, it has a backlog of employees who have worked for the force for over ten years but whose vetting has lapsed.
The constabulary has not re-vetted them. This poses a considerable security risk.It has recruited more vetting staff to solve this problem.
The force has effective methods of telling all officers and staff about the standards of behaviour it expects. It manages and identifies any risks of corruption. But the counter-corruption unit does not have enough resources to monitor the workforce’s use of internet searches and social media, which presents a possible risk.
Officers and staff understand the harm caused by abuse of authority for a sexual purpose. The force has trained supervisors to recognise the warning signs of this type of serious corruption.
To what extent does the force treat all of the people it serves with fairness and respect?
This question was not subject to inspection in 2018/19, and our judgment from the 2017 legitimacy inspection has been carried over. However, we reviewed a representative sample of 182 stop and search records to assess the reasonableness of the recorded grounds. We found that 91 percent 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 elements of this recommendation. It monitors and analyses stop and search data to understand reasons for disparities. However, it does not identify the extent to which find rates vary between people from different ethnicities and across different types of searches (including separate identification of find rates for drug possession and supply-type offences). It also isn’t clear that the force monitors sufficient data to identify the frequency of possession-only drug searches or the extent to which these align with local or force-level priorities. We reviewed the force’s website, but were unable to find information, analysis of the reasons for the disparities or any explanation of action it may have taken to address the imbalance.
We will continue to monitor progress in this area.
How well does the force ensure that its workforce behaves ethically and lawfully?
Areas for improvement
- The force should ensure all officer and staff have at least the lowest level of vetting clearance for their roles and clear any backlogs, so it complies fully with the national vetting guidelines.
- The force should monitor its vetting decisions to identify disparities and disproportionality (e.g. BAME groups) and act to reduce them where appropriate.
- The force should ensure that its counter corruption unit:
- has enough capability and capacity to counter corruption effectively and proactively; and
- can fully monitor all of its computer systems, including mobile data, to proactively identify data breaches, protect the force’s data and identify computer misuse.
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
Leaders act as positive, ethical role models and reinforce the importance of the Code of Ethics and the standards of professional behaviour. Officers and staff understand the force’s values and ethics well. Leaders use these values and ethics when they make decisions. Chief officers set out clear expectations of workforce behaviour, and leaders are expected to act ethically and lawfully. The force uses the monthly force bulletin and the weekly chief officer blogs to promote these expectations. Both publications have a section produced by the professional standards department (PSD) which gives useful information about misconduct cases. The force has introduced a new personal development process. This includes an annual integrity check together with the expectation that supervisors use it to reinforce ethics and values. The force’s promotion process now includes an assessment of ethical behaviour. Supervisor training includes inputs about ethical leadership. Force policies and procedures about business interests and notifiable associations support an ethical approach, and the workforce understands expectations. The force reviews policies every year and sends them out to the workforce for consultation as part of the review process. The force reviews each policy to ensure that it complies with the Code of Ethics. It also assesses each policy to see how it affects equality, making sure that a policy does not discriminate against or disadvantage anyone. These measures mean that the force is more likely to be successful in maintaining an ethical culture.
The force has an ethics committee with an independent chair. There is a well-established process by which officers and staff can refer ethical dilemmas for discussion. The committee aims to raise awareness and promote good practice. It is open to the public and all attendees are invited to discuss ethical dilemmas in an open and accessible way. The committee shares learning and recommendations with the workforce. It publishes full meeting minutes on the force website and in internal bulletins, so both the public and the workforce can review decisions. The force governance board considers the ethics committee’s recommendations and has changed some policies and procedures as a result. Recent examples include the acceptance of alcohol as a gift under certain circumstances, and the abolition of the rule which said that male staff should wear ties when they were not in uniform.
The force encourages learning and engagement with the workforce. Force leaders promote a no-blame culture and encourage organisational learning. If there are things which the force needs to change, it will change them. Leaders aim to learn from mistakes, instead of blaming people for things which have gone wrong. The force holds a quarterly senior leadership forum which raises cultural and ethical topics and makes recommendations. Similar forums exist for officers below chief inspector rank and for police staff equivalents. This encourages openness and honesty. Officers and staff understand the standards of behaviour and feel that the force supports them if they have made genuine mistakes.
During the inspection, we considered the extent to which the force was developing and maintaining an ethical culture through effective initial vetting. We found that the force does not comply with all aspects of the national vetting standards. Employees are not routinely re-vetted, as they should be, ten years after their initial vetting. This means that the force is not aware of the security risks posed by those who have not been vetted. The force is in the process of re-vetting all officers and staff. During the inspection the percentage of the workforce without appropriate security clearance was 14 percent, which equates to approximately 300 officers and staff. This is a more recent figure than the one included in the legitimacy data section (which showed that 17 percent of the workforce had up-to-date security clearance, as at 1 April 2018). In 2016 we made a national recommendation that forces should ensure that by December 2018 all of their workforce have up-to-date vetting clearance. The force has not been able to comply this recommendation. This presents a risk to the force.
The force states that all members of its workforce have been vetted at some point. However, it acknowledges it has a backlog of employees whose vetting needs to be renewed where it has lapsed. The force re-vets all officers who have been promoted, as well as those who transfer from other forces. Overall, the force vets its officers and staff in accordance with the National Police Chiefs’ Council standard. The force is aware of those members of its workforce who do not hold the required clearance for their current roles and is addressing this. It uses a structured process for assessing and managing vetting risks. Various factors are used to decide how to prioritise vetting cases. These include the sensitivity of the role and, in the case of contractors, both the frequency of their contact with the force and the type of systems they may have access to. However, we found that the force is not considering the amount of time that has passed since an individual’s vetting lapsed when it prioritises cases. The backlog includes some people whose vetting expired over three years ago, and this presents a risk to security.
The force is taking positive steps to increase the capacity and capability of its vetting team. This includes the recruitment of additional vetting team members. This should increase the team’s ability to address the backlog. The force has an appropriate risk management process for cases where people need to take up roles at short notice without holding appropriate vetting. In such cases, the deputy chief constable reviews the circumstances and makes the decision whether or not to depart from established procedures. In making these decisions, the deputy chief constable completes a detailed form which includes an assessment of risk, together with the rationale supporting each decision.
During our inspection, we found that all people in roles that require a higher level of vetting had the required level of checks.
The force offers a good standard of vetting aftercare. It identifies those who need additional support because of vetting difficulties and helps them if it can. There were 40 cases where advice and assistance were being provided to people experiencing financial difficulties. Most cases require an annual review, although there is a small number of cases that are reviewed twice-yearly. The force has recently introduced counter-corruption checks as part of the review process. It does not, however, monitor vetting decisions about new recruits and BAME candidates to identify disproportionality. This means that the force is not being proactive in identifying potential barriers to recruitment.
The force complies with its obligations to give the College of Policing details of people for the barred and advisory lists. This helps to prevent people from re-joining or working in law enforcement when they have left the service under investigation or been dismissed.
The force has effective channels for clarifying and reinforcing acceptable and unacceptable standards of behaviour. The PSD takes a proactive approach to clarifying and reinforcing these standards. Staff from the PSD engage with officers and staff throughout the force to share learning. The counter-corruption unit (CCU) has developed a video which promotes high standards of behaviour; this has been distributed widely throughout the workforce. New recruits and recently promoted officers and staff are told about ethics and expected standards of behaviour. The force promotion process includes an assessment of ethical behaviours. The force publishes the findings of misconduct hearings on the intranet, and the learning from each case is reinforced in the chief constable’s blog and through PSD publications.
Gloucestershire Constabulary identifies and manages organisational corruption risks adequately. The force has produced both a counter-corruption strategic assessment and a control strategy, but it could improve the standard and content of both. These two products are subject to governance and review processes. The force uses the integrity register to record business interests and notifiable associations. Intelligence is developed to identify officers and staff who are at risk of becoming a corruption threat. The force assesses these risks and, where appropriate, puts support in place to help people and to mitigate the risk of corruption. However, we found little evidence to show that the force monitors and evaluates the effectiveness of such interventions.
During this inspection we reviewed 60 cases. We found that once the force had identified a potential problem, the assessment and development of intelligence was generally of a good standard. However, the CCU has insufficient resources to undertake proactive intelligence gathering. The force is currently unable to monitor the use of all its ICT systems routinely. This creates a gap in its anti-corruption capability. The force recognises that it has technical problems in monitoring IT, but systems limitations make it unclear when this can be rectified. The CCU does have the capability to monitor open source and social media, which includes internet searches.
Effective links exist with external agencies which support vulnerable victims of crime. The force has given presentations to statutory partners and a range of voluntary agencies, including the independent domestic violence advisers, to raise awareness of corruption and the abuse of position for a sexual purpose.
The force has adopted the National Police Chiefs’ Council strategy to tackle the problem of police officers and staff who abuse their position for a sexual purpose. The force recognises the abuse of position for a sexual purpose as serious corruption and this is reflected in its local counter-corruption strategic threat assessment. However, the force has only made limited progress on its plan to address our national recommendation about the abuse of position for a sexual purpose. The CCU lacks capacity, and its inability to monitor ICT systems remains a risk.
Reassuringly, our interviews with officers and staff showed that the workforce has a clear understanding of the harm caused by the abuse of position for a sexual purpose. The force circulates information and gives briefings to the workforce to reinforce
this message. Officers and staff are informed of the likely consequences if they develop inappropriate relationships with members of the public. Supervisors have been trained to recognise the warning signs that someone might be abusing their position for a sexual purpose. Effective, confidential reporting systems are available to staff through which they can submit information about corrupt behaviour.
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.