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Greater Manchester PEEL 2018


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

Last updated 01/05/2019

Greater Manchester Police is good at treating the public and its workforce legitimately.

In our previous inspection, we judged Greater Manchester Police as good at treating the public fairly and this grading is carried forward.

Greater Manchester Police is good at behaving ethically and lawfully, but we found some areas for improvement. It should ensure it has an official process for staff to raise ethical questions.

It should make full use of the software it has to monitor IT systems to protect its data and prevent computer misuse.

It should ensure its wider workforce is trained in awareness of abuse of position for sexual purpose and its impact on the public.

The force is good at treating its workforce fairly, but we found some areas for improvement. The workforce is confident in the grievance process. But the force doesn’t deal with grievances in a timely manner. It has improved in this since 2017, and improvement must continue.

We saw that the force was working to improve its personal development review (PDR) process. This was an area for improvement in 2017, and the process still has gaps. We look forward to seeing the process fully implemented, used effectively and monitored force-wide.

In 2017, we also recommended improvements to the talent management system. The force has reviewed it, but it relies on the PDR process mentioned above. So, the force may not be providing fair opportunities for its entire workforce. This is an area for improvement.

Questions for Legitimacy


To what extent does the force treat all of the people it serves 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. However, we reviewed a representative sample of 297 stop and search records to assess the reasonableness of the recorded grounds. We found that 86 percent had reasonable grounds recorded. Therefore, about six in seven stop and search encounters have reasonable grounds recorded. 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). It also isn’t clear that the force 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 found no mention of analysis the force had carried out to understand reasons for disparities or explain subsequent action taken.

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 it has a process for the workforce to refer and discuss ethical concerns.
  • The force should ensure its anti-corruption unit 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.
  • The force should improve its workforce’s knowledge and understanding of the abuse of position for a sexual purpose.

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

The force is good at developing and maintaining an ethical culture. It has senior representation on the Greater Manchester Combined Authority ethics committee, independently chaired by the Bishop of Manchester. This operates at a strategic level and provides advice on ethical considerations and policy to the force – for example, the use of body-worn video. On inspection, we found that officers and staff feel comfortable raising matters with their supervisors, but most did not have regular discussions with their line managers about ethical dilemmas. Officers and staff were not aware of how they could raise ethical concerns internally. The force may wish to consider the development of an internal mechanism for reporting ethical dilemmas affecting the workforce.

In 2017, we found that Greater Manchester Police had backlogs in the vetting of officers and staff to national required standards. This year, we were pleased to find that all officers and staff had been vetted, and there was no backlog at the time of inspection. This means the force has fully addressed our national recommendation from 2016 and has robust systems in place to manage its vetting requirements for the future, broadly consistent with authorised professional practice guidelines . It is proactive in managing forthcoming vetting renewals, with a four-week lead period for completion, to minimise future lapses in vetting status.

The force considers disproportionality in its vetting arrangements and advises the College of Policing as required through barred and advisory lists, to ensure that corrupt staff don’t re-enter policing. However, during pre-inspection fieldwork we identified six cases of vetting failures for staff members. Four of these six were individuals from under-represented groups. This means that the force may not be acting in line with vetting decisions in some circumstances. It should satisfy itself that, in future, all appointments are made based on valid decision making and vetting outcomes.

We found that the force has established an organisational learning board, so it can learn from serious case reviews, coronial findings and reported misconduct. We were pleased to see that officers and staff felt there was a shift towards a learning culture rather than a blame culture within the force.

The force uses a variety of methods to reinforce standards of behaviour and share misconduct outcomes. These include senior leader road shows and publication through internal intranet and local bulletins. The officers and staff we spoke to were aware of outcomes and behaviour being reinforced in this way. This means the force can be confident that officers and staff understand the sanctions for poor behaviour.

Tackling corruption

Greater Manchester Police is good at managing organisational corruption risks. The force has a local strategic counter-corruption threat assessment and control strategy. However, during our inspection we found that the force doesn’t make full use of the information it holds on employees to identify those in danger of becoming a corruption risk and doesn’t hold meetings to discuss intelligence received about its workforce. Using this information would make the force better able to put in place interventions to support its people.

The force has a well-developed database where business interests are recorded, including those that have been refused and those that have ceased. Notifiable associations and inappropriate associations are combined under one category within the force’s iBase database. This makes it difficult to determine whether inappropriate associations are an issue for the force, and we raised a concern about some corruption intelligence recording criteria. We found that the force does use a matrix to evaluate the risk from notifiable associations which is effective, and the policy itself appears to be well used by the workforce. We found that high-risk and critical notifiable associations are revisited by the anti-corruption unit (ACU), but business interests that have been refused on the grounds of force integrity are not routinely reviewed. This means that the force may not understand the wider impact, and it may wish to consider the benefits of regular reviews of business interests.

At the time of our inspection, we found 28 entries on the gifts and hospitality register for the previous five-month period, which appeared low for a large force. We were able to clarify that, due to the overwhelming public response to the Manchester Arena attack in 2017, a decision had been taken to cease the requirement to report gifts offered by the public. When speaking with the workforce, we found there was some confusion about the current policy and reporting requirements, but staff would seek advice. The force may wish to provide clarity to officers and staff about the current policy and action they need to take when offered gifts or hospitality.

Although the force has invested in software which can be used to fully monitor all its IT systems, at the time of the inspection this was not being fully used. The force has assured us that, with the implementation of iOPS in early 2019, this issue will be resolved. But it remains a risk. The force currently uses its IT monitoring capability in criminal cases on the authorisation of a senior officer, rather than proactively looking for such data breaches. It makes decisions on the proportionality of monitoring in relation to any investigation and is not looking to change its approach. With full use of this technology, it could protect the data held within its systems and identify computer misuse.

Greater Manchester Police has a confidential reporting system provided through Crimestoppers. Staff can also report concerns by telephone, using a confidential recording facility within the ACU. We found there was some uncertainty as to the availability of these reporting mechanisms among some of the workforce. This means that not all staff may be raising concerns about standards of behaviour. The force may wish to consider how the workforce’s understanding of these systems is reinforced, to be confident that any concerns are fully reported.

The force has a well-resourced ACU with dedicated intelligence and investigative resources and equipment. During our ACU file review, we found there were only six out of 60 examined cases in which we considered other tactics might have been used to undertake more effective investigations. Initial grading and assessment of intelligence follows authorised professional practice guidance and is categorised in accordance with national corruption categories. Corruption intelligence is only accessible on computers within the ACU. We found the system to be up to date and well managed, and data fully searchable. For those cases we examined in the ACU file review, all that should have been referred to the Independent Office for Police Conduct (IOPC), due to the nature of the investigations, had been correctly referred. This means there is every likelihood that corrupt activities within the force will be identified and fully investigated.

The force recognises the abuse of position for a sexual purpose as serious corruption, and this is reflected in the force’s local counter-corruption strategic threat assessment. We found during our file review that all relevant cases were appropriately referred to the IOPC. The force is taking steps to address this area by providing briefings to its employees and has adopted the National Policing Counter-Corruption Advisory Group strategy. This has also been addressed through the deputy chief constable’s leadership visits to districts, and professional standards branch road shows which have taken place across the force. The force has also provided awareness to its partners involved in dealing with vulnerable members of the public, to enable recognition within the community.

During our inspection, we found some staff were aware of recent cases publicised in the media and through the force’s intranet. Some supervisors we spoke with had also received briefings to assist in identifying the warning signs. However, we found little evidence to show that the wider workforce had received awareness training, and officers and staff had limited knowledge of this concern. The force needs to consider how it can improve staff understanding of the importance of abuse of position for a sexual purpose and its impact on the public.

Summary for question 2

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


Areas for improvement

  • The force should improve how it manages grievances, so that it provides timely outcomes for officers and staff.
  • The force should ensure its process for assessment and development of officer and staff performance is fully implemented, used effectively and monitored force-wide.
  • The force should have a talent management system that is consistent, fair and accessible to all the workforce.

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

Improving fairness at work

The force is working well to improve fairness at work. It uses a range of methods to engage the workforce and seek feedback. These include senior leadership meetings and station visits, one-to-one appointments, staff forums, focus groups and the staff survey. The force also takes a ‘you said, we did’ approach to inform its workforce of action that has been taken. Since 2016, as a result of staff feedback it has taken steps to improve, with software technology and the consideration of the criteria requiring sergeant attendance at sudden deaths as examples. It has also undertaken consultation with staff about the pending merger of crime investigation and public protection investigation units across the force.

This year, the force has seen an increase in participation in the staff survey to approximately 51 percent of the organisation, compared to 34 percent in 2016. This was balanced across police officer, staff and PCSO roles. We also received positive feedback that the special constabulary feels engaged by the force, and special constables were also encouraged to participate in the staff survey, enabling them to raise their specific concerns.

The force conducted 170 feedback sessions with staff between August and October 2018 to share the survey results. These sessions also enabled it to identify from the workforce other reasons for stress. Further engagement with the workforce has taken place through the development of a video presentation, local communication and engagement information packs for branches and districts, and the development of plans to support implementation of changes. The force plans to focus on the workplace stresses it has identified. It has also recognised the sergeant rank as a priority, as these are important leaders within the force. This approach means that it can show it responds to the concerns raised by its workforce.

We examined a sample of grievance files during pre-inspection fieldwork. We found that, although the grievance policy and procedure reflected Advisory, Conciliation and Arbitration Service (Acas) guidance and codes of practice, grievances were not always being dealt with in a timely fashion. Of the ten files examined, eight had encountered unacceptable delays, including allocation to a grievance manager for investigation, and delays in reports being sent from Greater Manchester Shared Services to HR. Six of the ten files took up to 14 months to complete, for cases that were not considered complex. Some files also had closure reports missing. This means that, although officers and staff we spoke to during our inspection were aware of the grievance procedure or knew where to find it and would feel confident to use it if they needed to, the force can’t be confident that grievances are dealt with effectively.

The force recognises these issues and reviewed the grievance process in 2017 and again in early 2018. As a result, it has made changes to its processes. We examined four additional files during our inspection fieldwork and found the force now provides central oversight of grievances, and advice is given by HR managers. We also found evidence of chase-up emails to staff to support timeliness and consistency in process, with improved completion of closure forms. However, we also found some cases still showed a delay in identifying managers to deal with grievances, contacting the complainants and completing investigations. Overall, the force needs to continue its efforts to improve the management of grievances.

We found that the force analyses its data to identify and address any adverse impact and disproportionality in selection processes and misconduct investigations. It understands the number of applicants for selection with protected characteristics and the respective pass rates in those processes. It gathers data on the potential for any adverse impact in misconduct investigations and has found little disproportionality. It also takes steps to raise awareness within the organisation. We found some staff were aware of road shows and emails to encourage applications from under-represented groups for specialist roles such as firearms, as well as the personal development action learning sets (PeDALS) programme. The PeDALS programme provides professional development for black, Asian and minority ethnic (BAME) staff seeking promotion. The force has updated its promotion processes and removed the need for supervisor support. Staff we spoke to believe the new processes to be fair and open. The force is exploring the potential to work with the Metropolitan Police Service to attract further BAME candidates as direct entry recruits. This shows that it is taking some steps to make the workforce more diverse and representative of the people it serves.

Supporting workforce wellbeing

The force has a wellbeing board chaired by the assistant chief officer, and a strategy that supports force activity. It has allocated an additional £1m over a three-year period to provide a centrally co-ordinated wellbeing service to enhance capacity, with an established project overseen by the wellbeing board. We noted within the FMS that since 2017, Greater Manchester Police has made progress with the establishment of the wellbeing services unit. We were pleased to find that six of the seven wellbeing liaison officers are now in post, as well as 60 volunteer wellbeing single points of contact across the force.

The force uses a range of preventative measures to support wellbeing. It subscribes to a 24-hour employee assistance programme, which offers advice and access to counselling and support to the workforce. The force’s occupational health provision includes a registered mental health nurse and offers support for cognitive behavioural therapy and psychiatric services, which means that it can prioritise mental as well as physical health. The force is aware that the demand for wellbeing services has increased and has looked to other forces and agencies to understand what works. It is a member of the Blue Light Framework and Oscar Kilo, the wellbeing website for emergency services.

The trauma risk management process (TRiM) is well established and has given valuable support to those staff affected by the Manchester Arena attack and other incidents. The force has increased the number of TRiM practitioners from 16 to 31, with budget provision to train an additional 16 people across the organisation. The force offers access to a range of wellbeing workshops and therapies for staff. However, we found that the pressures on neighbourhood patrols to meet demand may limit access for some staff. Within the control room, we found there is a clear strategy to address wellbeing improvement with a focus on physical, social, psychological and environmental wellbeing. The control room has an identified lead and a volunteer wellbeing team to support activity.

As part of the newly promoted sergeants’ training course, first-line managers are given a half-day session on managing attendance and wellbeing, and have been issued with a guide to support them. The force should ensure training is provided to existing managers.

The force has a wellbeing panel which meets regularly to review referrals made to occupational health, including those referred for support because of complaints and misconduct. However, we found that the department may not be meeting all demands consistently, as currently it also manages medical assessments for new starters. This means those staff needing access to occupational health assessment and support may not be seen swiftly when recruitment is taking place. With the ambitious plans to recruit officers over the next few years, this may become even more acute. We are aware that further funding has been requested to help build capacity for planned recruitment numbers and the force is looking to outsource the recruitment requirements to address this. At the time of inspection there were no backlogs in referrals, but demands were not being met consistently, and confusion over accessing services may be resulting in reduced demand. The average waiting time from referral to appointment was several days to see a nurse, one to two weeks for physiotherapy, and approximately three weeks to see a doctor.

We also found the number of occupational health referrals to be among the lowest per headcount of forces across England and Wales. We received some feedback that officers and staff felt accessing occupational health support was difficult, and there was confusion among staff about whether they could self-refer. This means that staff who require support from the force to return to work may not receive it when it is needed most and may be absent from work for longer. The force told us that staff can self-refer for occupational health support. There are defined criteria to enable those people who have been involved in a traumatic incident, are the subject of misconduct, or are believed to be a victim or perpetrator in domestic abuse incidents to self-refer. The force should consider providing clear guidance to staff and supervisors about accessing occupational health services and the support available through other means – for example, the employee assistance programme. Officers and staff in high-risk roles don’t currently receive mandated appointments with the welfare team. The force has acknowledged this and is putting annual one-to-one meetings in place to address this.

Greater Manchester Police has a sickness rate in line with the rate experienced by forces across England and Wales, with approximately 2.7 percent of police officers absent at any one time. The force is taking steps to address sickness absence with a project that has seven themes for improvement: leadership culture and behaviour, communication and raising awareness, prevention, education and training, learning from others, force data, and performance management and reporting. The force monitors absence data and produces reports which line managers can access online.

One area in which the force has acted to improve sickness involves the implementation of Operation Ergo, which includes a shift pattern change for neighbourhood patrol officers. The shift pattern allows for a regular team meeting to discuss performance and wellbeing. It also builds capacity for training days to reduce the need to take shift staff away from responding to calls for service. It is anticipated that these will help reduce sickness absence. Operation Ergo is currently in place within Oldham, Tameside and Rochdale, with other force areas due to be working the new pattern by May 2019. HMICFRS understands that the force has implemented the new working pattern in March 2019, ahead of expectations.

Managing performance and development of officers and staff

In our 2017 legitimacy report, we identified an area for improvement which centred on the implementation and monitoring of the effectiveness of the revised PDR process. The force has introduced the new PDR for police officers. It intends to improve on the current police staff assessment process by rolling out a comparable process for staff in 2019, but its format is not yet agreed. We found there is limited oversight of the PDR process and no central monitoring of uptake of PDRs and the quality of their completion. During reality testing, we found that many officers we spoke with did not have a current PDR with identifiable objectives. Some were not having formal monthly one-to-one conversations with their line managers about performance. Most staff we spoke to felt able to raise issues directly with their supervisors outside a one-to-one meeting, but recognised that these conversations were unlikely to be documented. Supervisors commented on the lack of training and understanding about how to complete PDRs for staff, and not having time to do them. We also found little evidence to show that the force was addressing under-performance. This means that it is unable to formally support the performance and development of all staff or make the most of their contribution.

The force needs to take steps to provide further PDR training to supervisors, ensure PDRs are being completed, and monitor the effectiveness of the process. This should help ensure that all individuals are provided with support and development in the workplace, and under-performance is identified and appropriately tackled.

We identified a second area for improvement in 2017, relating to improving awareness of the talent management process and increasing confidence and participation in the scheme. We found that the force has reviewed the talent management process and there is a structure in place. However, this is accessed through completion of a PDR, and is only for officers rather than all staff. With the inconsistencies in the take-up of the PDR process across the force, Greater Manchester Police can’t be confident that it supports the talent management process and provides fair opportunities to all.

We were pleased to receive positive feedback about the changes to the promotion process. The force now produces a four-year timetable for promotion boards. All boards are staffed by independent assessors, and applications are anonymised throughout selection. Most officers stated that perceived barriers, such as supervisor support, had been removed. Mentors are available for those seeking promotion, and we found processes are now based around the national competency and values framework. Staff believed them to be fair and transparent. They now receive an information pack, feel informed at the start of the process and receive feedback at its conclusion.

Summary for question 3