Gwent PEEL 2018
How legitimately does the force treat the public and its workforce?
Gwent Police requires improvement at treating the public fairly and on behaving ethically and lawfully. It is good at treating the workforce fairly.
The force recognises the importance of working closely with communities. Officers and staff understand how important it is to treat people with fairness and respect. However, frontline officers and staff varied in their knowledge of unconscious bias.
The workforce understands how and when to use force and stop and search. The force needs to improve how it monitors the use of stop and search and use of force.
Gwent Police needs to do more to ensure all members of its workforce are appropriately vetted for the posts they hold. It also needs to monitor people who apply to see if they belong to certain protected minority groups.
The force needs to improve how it spots and manages risk of corruption. It also needs to make sure it has enough people and resources to do this work.
Gwent Police is good at treating its workforce fairly. This question was not subject to detailed inspection in 2018/19, and our judgment from the 2017 legitimacy inspection has been carried over.
To what extent does the force treat all of the people it serves with fairness and respect?
Areas for improvement
- The force should ensure that appropriate members of its workforce receive training in, and understand, unconscious bias.
- The force should ensure it monitors a comprehensive set of data on its use of force to enhance its understanding of fair and effective use of this power.
- The force should ensure it monitors a comprehensive set of data on its use of stop and search to enhance its understanding of fair and effective use of these powers.
We set out our detailed findings below. These are the basis for our judgment of the force’s performance in this area.
Treating people fairly and respectfully
Force leaders are good at understanding the importance of engaging with the people they serve and treating them with fairness and respect. There is a joint engagement and communications strategy between the force and the police and crime commissioner. This sets out how they intend to communicate and engage with communities and key interested parties. This is covered in the ‘Planning for the future’ section of this report.
Force policies and procedures explain the importance of fair decision making and treating the public with respect. Training for officers and staff also reinforces the importance of fair decision making.
Gwent Police has several different channels it uses to engage with the public. Social media provides an alternative way for people to contact the force. A positive action outreach worker does engagement activities with diverse communities in Gwent. This include activities with BAME elders’ groups and people in places of worship, colleges, local authorities and sports clubs.
The force has also engaged with community partners. For example, officers joined a We Are Wales interfaith event. At the event, the force asked for feedback on what deters victims of hate crime from reporting it.
Gwent Police is keen to hear from residents about the issues they would like to see prioritised where they live. In May 2019, the neighbourhood teams in each local authority area sent out a short survey on social media. The survey asked for residents’ views on their top policing priority. Links were also posted on partner organisations’ websites.
A total of 1,378 people took part in the survey and 140 said they wanted to work with police and partner organisations to manage their own community issues. Priorities varied for each local authority area. Each priority will be addressed through the newly formed community safety partnership in each of the five local authority areas.
The force encourages local people to get involved in local crime prevention. Gwent Police has continued to expand its focus around the citizens in policing programme. The force has police cadets actively working with local policing teams in Gwent communities. There are mini-police schemes in schools (aimed at 9–11 year olds) where the force is building trust and resilience in some of its most deprived primary schools.
Some officers we spoke to understood unconscious bias and the importance of effective communication skills when working with the public. This understanding varied across the force.
The force has given training to officers on unconscious bias. But it seems not to have had the impact the force hoped. It is also unclear if appropriate staff have received training. This is an area that needs to be addressed. The force needs to assure itself as to who has been trained and then be assured officers and staff understand the importance of making fair and impartial decisions when working with the public.
Gwent Police needs to improve the extent to which it understands how force is being used.
Gwent Police gives training and guidance on the use of force. Most officers and staff understand how to use it fairly. Since our 2017 inspection, there has been a significant drive to ensure officers are completing use of force forms. There has been a significant improvement in compliance.
This information complies with National Police Chiefs’ Council (NPCC) recording standards, and the force submits relevant data in line with national requirements. This was an area for improvement in our last inspection, which the force has met.
While some local supervision takes place, this is limited and there is reliance on central monitoring as to whether staff complete use of force forms. The force is in the process of moving this responsibility back to local supervisors. This should ensure officers get feedback on their use of force, rather than just on whether they have completed the form correctly.
The force considers use of force at the quarterly operational tactics meeting chaired by a superintendent. The meeting considers how often force is used, the age of the person involved and the types of force used, along with injuries to officers, any complaints received and (more recently) ethnicity. However, this information is not detailed or broken down so the force can get a thorough understanding of how force is used.
There was no evidence of the meeting conducting a review of officers and teams who frequently use force, or of injury rates. Therefore the force is not systematically monitoring or managing the appropriate and inappropriate use of force.
The force is aware that it needs to improve how it monitors use of force. So far, its focus has been on changing the meeting structure. It also needs to develop more comprehensive data and information to consider at the meeting.
The quarterly legitimacy scrutiny panel gives the force external scrutiny on use of force and stop and search. It is co-ordinated by the office of the police and crime commissioner and considers use of force and stop and search at alternate meetings. Members are independent and drawn from the force’s independent advisory group and ethics committee. They represent a diverse range of the community and have appropriate training to carry out their role.
For the first part of the meeting, they review body-worn video for the use of force or stop and search encounters along with the relevant form. In the second part, they review all forms and a report summarising the use of force or stop and search. This report could be expanded to include similar information that we recommend is considered at the force’s internal meetings.
They then give feedback to the force through a report. The report is considered at various internal groups and published on the police and crime commissioner’s website.
External scrutiny of stop and search and viewing body-worn video were areas of improvement for the force in the last inspection, which the force has met. The force publishes an infographic on use of force on its website, featuring key data.
Using stop and search powers
Gwent Police needs to improve the extent to which it understands how stop and search powers are being used.
We found that the workforce understands the ethical use of stop and search and, in the main, supervision is taking place. The force has provided training to ensure officers understand how to use the power fairly and respectfully. This was an area for improvement in our last inspection, which the force has met.
We reviewed a representative sample of 345 stop and search records to assess the reasonableness of the recorded grounds. We found that 77 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.
Monitoring of stop and search is similar to use of force. It is considered at the operational tactics meeting. The monthly equality and diversity group (chaired by the head of equality and diversity) also considers ethnicity.
These meetings consider a range of data and information such as volume, purpose, object and outcome of searches by age and ethnicity. They also consider how the force monitors complaints. But the data is not comprehensive and the force may be missing opportunities to understand how stop and search is being used, or if it is being used effectively and fairly.
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). Also, it isn’t clear that it 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. The force has carried out some recent work to understand disproportionality in its stop and searches, but it lacked detailed analysis. We reviewed the force’s website and found no reference to analysis carried out to understand and explain the reasons for disparities or any subsequent action taken.
The force is aware that it needs to improve the monitoring of stop and search. As mentioned above, it is taking action. Prior to the commencement of our inspection fieldwork, the force had taken the decision to use the operation tactics meeting to consider all aspects of stop and search in future, as it has recognised that more detailed monitoring is required.
As mentioned above, the legitimacy scrutiny panel gives external scrutiny of stop and search.
The force runs a ‘ride along’ scheme. This allows the public to patrol with officers to better understand how stop and search is used. The force gives feedback from the public to local teams.
In May 2019, the force attended a local leisure centre where they carried out a question and answer session on stop and search with members from the local community. Many were from a BAME background.Summary for question 1
How well does the force ensure that its workforce behaves ethically and lawfully?
Areas for improvement
- The force should ensure all staff have received at least the lowest level of vetting clearance for their roles, including those in designated posts, ensuring it is fully compliant with the national vetting guidelines.
- The force should monitor vetting decisions to identify disparities and disproportionality (e.g. BAME groups), and to reduce them where appropriate.
- The force should ensure its anti-corruption strategic threat assessment and control strategy are regularly refreshed using local and national data, and are subject to effective governance arrangements.
- The force should ensure that its counter-corruption unit:
- has sufficient capability and capacity to gather, assess and develop information about corruption risks effectively; and
- has full information technology monitoring to effectively protect information in its systems.
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
Gwent Police is good at maintaining an ethical culture. But it needs to do more to ensure all members of its workforce are appropriately vetted for the posts they hold.
The force’s leaders promote the importance of the Code of Ethics. They do this, for example, by publishing a Friday blog post on the force’s intranet and by reminding people at meetings about high standards of ethical behaviour. The force reinforces these expectations during staff training.
The force’s policies and procedures incorporate the Code of Ethics. Each is assessed for its equality impact to ensure it is fair. We found that the workforce understands the importance of the Code of Ethics well.
Gwent Police has a well established ethics committee that includes representation from independent members. The workforce can refer ethical dilemmas to the committee easily using the intranet. The force makes changes as a result.
Examples include a review of uniform policy, and whether the force’s mobile devices should be used for personal use. The committee also provides chief officers with its views in a report after each meeting. However, knowledge of the committee’s work varied among officers and staff. The force could promote its existence more widely.
We also found that ethical discussions with supervisors did not happen consistently. Encouraging these discussions will highlight the importance of ethical decision making and support organisational learning and continuous improvement.
The force would benefit from this because it has a strong commitment to learning through experience, rather than blaming staff for mistakes. This reflects Gwent Police’s open and transparent culture.
During the last inspection, we considered how much the force was developing and maintaining an ethical culture through effective initial vetting. We found that the force was not complying with all aspects of the national vetting standards.
We noted that the force has not achieved our 2016 recommendation that, within two years, all members of its workforce should have received the lowest level of vetting clearance for their roles.
The force vets new recruits to the correct standards. However, it doesn’t routinely ensure that people who move to different posts hold the right level of vetting clearance for their roles.
During our fieldwork, we found that 90 percent of the workforce hold the correct level of vetting for their designated posts. The force has taken steps to stop members of the workforce from moving to higher-risk posts until they are re-vetted. But there are times when people are required to do roles at short notice without having the right level of vetting clearance. Then, the force needs to use an effective risk management process authorised at a senior level that includes a clear reason for the decision.
Gwent Police doesn’t routinely monitor vetting decisions to evaluate how they may affect recruiting diverse groups. This means the force is missing opportunities to identify potential disparities in its decisions relating to people from under-represented groups, such as people with BAME backgrounds. The force told us it has plans to address this.
The force complies with its obligations to provide details to the College of Policing for the barred and advisory lists. This prevents people who have left the service under investigation, or who have been dismissed, from re-joining or working in law enforcement.
Gwent Police uses effective channels for clarifying and reinforcing acceptable and unacceptable behaviour. Also, for learning lessons from the causes and results of local and national misconduct cases.
The force produces a newsletter called the Professional Standards Department Times. It includes case studies and best practice from the Independent Office for Police Conduct (IOPC) and its own investigations.
The professional standards department gives 60-second video briefings about risks to integrity. This includes reporting requirements relating to business interests and notifiable associations, and the harm caused to vulnerable people by staff who abuse their position.
During our inspection, we tested how far the workforce appreciated these risks. We found that officers and staff clearly understood the consequences of not following the expected standards of behaviour. This shows the force’s approach is effective.
Gwent Police takes steps to identify and manage internal corruption risks. However, its ability to identify and respond to these risks is restricted. That is because it can’t monitor all its ICT systems and the capacity of its counter corruption unit (CCU) is limited.
The force has completed its counter-corruption strategic threat assessment and control strategy. But the strategy doesn’t meet the force’s needs because it leaves out information about areas of the force where corruption threats are higher.
The force would benefit from more analysis of local cases, to allow greater comparison between local and national corruption threats. Its control strategy needs to specify measures the force is taking to respond to corruption threats and who is responsible for them. More effective governance will allow the force to evaluate its progress better.
The force draws together different sources of information to assess corruption risks. It responds to them using different tactics and techniques.
For example, it does ethical interviews with officers and staff and it makes referrals to debt management agencies based on its assessment of a person’s vulnerability.
The force has used information from different sources to prepare a risk matrix to identify employees most at risk of corruption. This is a new process.
The force says it will use this matrix at a tactical meeting bringing together representatives from different departments to review information and take action in a structured way. This will help it support people who are most at risk of falling into corrupt practices.
The workforce has a good understanding of the need to declare gifts and hospitality. The force has responded to a previous area for improvement by publishing the register of gifts and hospitality every quarter.
Officers and staff know they must declare business interests and reportable associations (people who might compromise their position). The professional standards department makes decisions on whether they should be authorised.
The force could be more proactive in how it monitors compliance with the above – especially those that are declined. It doesn’t check for compliance routinely or consistently. Information about business interests published on the force’s website also needs to be refreshed.
Gwent Police takes steps to assess and develop intelligence about corrupt behaviour. But insufficient capacity and capability in its CCU is making it less effective.
Our review of 60 case files confirmed that the force doesn’t always take enough action to follow up lines of enquiry in all cases. The CCU monitors open source and telecommunications data. It is unable to monitor the use of all its ICT systems.
A software update during summer/autumn 2019 was planned to increase its ability to do this. The force is carrying out a review of the CCU’s capacity and capability to find out how it can monitor all intelligence more effectively in the future.
The force promotes its whistleblowing and anonymous reporting systems to its workforce. It runs two confidential reporting systems that enable officers and staff to report wrongdoing. These are the independent Safecall service and a confidential online messaging system.
We found the workforce had confidence using these systems and saw them as anonymous. The force takes effective action to support people who report wrongdoing. It has appointed several wellbeing ambassadors who give staff extra welfare support.
Gwent Police has developed links with partner agencies that support vulnerable people, including vulnerable crime victims. Since 2017, the force has given presentations about corruption risks to agencies that support victims of domestic abuse and those supporting people with drugs and alcohol problems. But the force needs to do more to reassure itself about the effectiveness of these links. It can do this by continuing to raise awareness about the significant harm caused by officers and staff who abuse their position for a sexual purpose.
The force has adopted the NPCC’s strategy to respond to the problem of police officers and staff who abuse their position for a sexual purpose. It recognises this behaviour as serious corruption and refers cases to the IOPC.
The force submitted a plan in 2017 to address the 2016 national recommendation on abuse of position for a sexual purpose. But it hasn’t yet met it. Issues with the CCU and monitoring ICT systems, as mentioned above, are still risk areas.
Reassuringly, the force has acted to ensure that its workforce is aware of the problem of abuse of position for a sexual purpose by providing training. It publicises cases to demonstrate how it deals effectively with this type of corrupt behaviour.
The force had one other area for improvement in 2017. This was to ensure it has force-specific literature in police stations and other public places on how to make a complaint in line with IOPC guidance. This has been met.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.
However, Gwent Police had three areas for improvement in the 2017 legitimacy inspection. These were:
- The force should review how high potential members of the workforce are selected for leadership development. This has been met.
- The force should take steps to ensure selection and promotion processes are transparent to improve the perception of fairness of officers and staff. This is being progressed.
- The force should continue to develop an effective system for managing individual performance to improve the perception of its value by officers and staff. This is being progressed.