Hampshire PEEL 2018
How legitimately does the force treat the public and its workforce?
Hampshire Constabulary is good in the way it treats the public and its workforce.
The workforce is good at behaving ethically and lawfully. The force continues to develop and maintain an ethical culture. Policies and processes align with the code of ethics. The workforce clearly understands the principles of the code. But the force should make sure the work of its ethics committee is more widely known about. It should also make sure officers know how to raise ethical dilemmas with the force.
Standards of professional behaviour are regularly reinforced and clarified on the force’s intranet and in messages from senior leaders. Cases of misconduct and breach are published in a quarterly newsletter. This shows how officers and staff can learn from them. Members of the public who have made a complaint to the force are now given a copy of their recorded complaint.
The force has an effective counter-corruption strategy. Members of the workforce know they can report wrongdoing in confidence and know how to do it.
The force uses the information it holds on its workforce to identify people at risk of corruption. This means it can intervene early. It also monitors whether officers and staff comply with their decisions about notifiable associations or business interests. It has realistic plans in place to make sure that it will very soon be able to automatically monitor all IT systems to identify potentially corrupt behaviour.
The workforce generally has a good understanding of abuse of position for a sexual purpose but not all staff and supervisors could recall their training. The force has good links with organisations that support vulnerable people but should make sure these relationships are effective.
In 2017 we judged Hampshire Constabulary to be good at treating both the public and its workforce fairly.
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, there is an area for improvement identified from this inspection:
- The force should identify and put in place training provision for independent advisory group (IAG) members designed to ensure that they have all the relevant knowledge required to perform their role.
During our fieldwork we investigated the progress the force has made in this area for improvement.
Since our last inspection there have been several training events for members of the IAG. Members are now more aware of features such as the use of force, stop and search and critical incidents. This is positive since these are the areas of police activity that IAG members are likely to give an independent perspective on.
We also reviewed a representative sample of 122 stop and search records to assess the reasonableness of the recorded grounds. We found that 84 percent had 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 national 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.
The force has complied with some of this recommendation. But it doesn’t identify the extent to which find rates (the rate at which officers find what they are looking for) differ for people from different ethnic backgrounds and for different types of searches (including separate identification of find rates for drug possession and supply-type offences). It isn’t clear that the force monitors enough data to identify the prevalence of possession-only drug searches or how far they align with local or force-level priorities. The force has plans to develop richer data sets, in pursuance of our 2017 recommendation, which have been delayed due to technical difficulties with some elements of its stop and search ICT programme.
We reviewed the force’s website and found no clear mention of analysis it had done to understand and explain disparities, or any subsequent action taken.
How well does the force ensure that its workforce behaves ethically and lawfully?
Areas for improvement
- The force should take steps to make sure that the work of the ethics committee is more widely known, and that officers and staff are aware of how to raise ethical issues within the force.
- The force should ensure that it builds more effective relationships with the individuals and organisations that support and work with vulnerable people.
- 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
Hampshire Constabulary continues to develop and maintain an ethical culture. Its policies and procedures take account of the code of ethics. All new staff are given training about the code of ethics and the annual performance review contains a reminder about the code. We found that the workforce has a clear understanding of the code, and of the standards of professional behaviour. Senior managers are seen as ethical by the workforce. They promote ethics through personal example and messages to staff.
The force has an ethics committee to consider ethical issues, with representatives from across the force and from staff associations and external members. Despite the work of the committee being publicised through a force-wide journal, not many staff know about it. There is little discussion about ethical issues in the workplace. On most occasions we were told that ethical dilemmas would be discussed with line managers if the need arose. This is very limiting as it means that ethical issues aren’t explored widely, or even not at all if they are about a person’s supervisor.
Senior leaders have worked hard to develop a culture of learning rather than blame when mistakes happen. Most staff we spoke to felt that they would be supported by the force if they made an honest mistake. Supervisors have been given a decision-making tool by the professional standards department to help guide them towards dealing with mistakes in the most suitable way. Lessons learnt from misconduct enquiries are shared with the workforce through the professional services department’s quarterly newsletter, Reputation Matters. Members of staff who we spoke to during our fieldwork told us that the force has effectively communicated information about lessons learnt and the outcomes of misconduct cases to them.
The force follows the new vetting code of practice and Authorised Professional Practice. It manages all new vetting requests, for new starters and internal postings, effectively and quickly. It can identify disparities in vetting decisions, including refusals for BAME applicants. But it didn’t meet our national recommendation that, by December 2018, forces make sure officers and staff have the minimum level of vetting needed for their role. Its vetting backlog in December 2018 was only 3 percent, with no backlog in vetting at the time of our fieldwork.
The force meets its obligations to provide details to the College of Policing for the barred and advisory lists. These lists prevent people who have left the service under investigation, or been dismissed, from re-joining or working in law enforcement.
The force clarifies and reinforces standards of professional behaviour regularly through items on its intranet and messages from senior officers. Officers and staff are aware of Reputation Matters. This reports cases of misconduct and breaches of the standards of professional behaviour and shows how the workforce can learn from them.
The professional standards department has worked hard to raise awareness of acceptable behaviour. It gives briefings to supervisors and then checks that supervisors have passed the information on to their staff. The force publicises the outcomes of serious complaints and gross misconduct investigations through its intranet. We found that all staff had a clear understanding of the consequences of not following the code of ethics or standards of professional behaviour.
Our 2017 legitimacy inspection contained an area for improvement for Hampshire Constabulary. This was that it should give each person who had made a complaint to the force a copy of their recorded complaint. It should also improve the quality and speed of its updates to complainants. We found that the force has fully addressed this issue. During the inspection we spoke to a regional officer from the Independent Office for Police Conduct (IOPC) who is pleased with how the force deals with misconduct.
Hampshire Constabulary has an effective counter-corruption strategic threat assessment and control strategy in place. The threat assessment identifies the main vulnerabilities, trends and emerging threats. There are confidential processes for reporting wrongdoing and supporting members of the workforce who use them. Officers and staff have a good understanding of how to do this and are confident that they can do so anonymously. The force has made progress towards achieving the national recommendations we made in 2016 about the abuse of position for a sexual purpose.
It uses the information it holds on its workforce to identify those at risk of corruption and it can intervene or start investigations early. The registers of notifiable associations, business interests and gifts and hospitality are completed well. The force monitors compliance with its decisions about business interests and notifiable associations.
The force can check what records have been accessed on important IT systems. Some monitoring systems are automated, but at the time of the inspection it couldn’t routinely monitor the use of all its IT systems to identify potentially corrupt behaviour. It has purchased a new software monitoring system which will allow it to automatically monitor all its systems. This will be fully installed and operational by autumn 2019.
IT monitoring could increase the demand on the anti-corruption unit (ACU) if fully used. So, two extra ACU posts have been agreed as part of this year’s force budget. This is important as during our inspection we reviewed how well the force had previously investigated corruption-related intelligence. We found that sometimes investigations had been concluded before all enquiries were done. On other occasions, poor record keeping made it difficult to see what action had been taken and would hinder a proper assessment of any subsequent connected intelligence. This suggests that the force doesn’t have enough resources in its ACU, especially around expertise and supervision.
We were told by the force that these problems were recognised before our inspection and improvement measures had been put in place. Measures include:
- introducing better supervisory oversight of counter corruption investigations in the ACU;
- making sure that all supervisory posts in the ACU are occupied by substantive rank holders; and
- appointing a new detective inspector to provide additional supervision.
The force believes that these measures have addressed the issues we identified. We will monitor progress in this area in future inspections.
Abuse of position for a sexual purpose is viewed as serious corruption and the force usually refers cases to the IOPC. During our review we found some cases hadn’t been referred and we have brought this to the attention of the force. We are now confident that the force will in the future refer these types of cases.
The workforce has a good understanding of abuse of position for a sexual purpose. They have had training, received briefings from the professional services department and seen publicity about misconduct cases of this type. Supervisors have been trained about the warning signs of this sort of behaviour among their workforce. Not all staff and supervisors, however, could recall this training when we asked them about it, so it may need refreshing.
The force has developed links with organisations that support vulnerable people. This is important because frontline staff in these organisations can give early indications of officers who abuse their position for a sexual purpose. So far there has not been any intelligence about this sort of activity from these organisations. The force should consider any further steps it could take to build its relationships with such staff. It should make sure that they have the necessary awareness of both what this behaviour looks like and where in the force it can be reported.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, there were two areas for improvement identified from this inspection:
- The force should ensure that it has effective systems in place and monitors these as to how well and consistently its performance development review (PDR) system is used across the force.
- The force should review how high potential members of the workforce are selected to ensure it is consistently fair and objective.
During our fieldwork this year we checked what progress the force has made in these areas for improvement.
It has made good progress in both. A new PDR system has been introduced that is linked to the force’s approach to conducting regular one-to-one interviews between supervisors and their workforce. It is a simple one-page document that supports the PDR interview areas by checking personal wellbeing, goals, acceptable behaviour and essential training. The proportion of staff with an up-to-date PDR is 70 percent.
Improvements in how high-potential members of the workforce are selected are described earlier in this report. All routes into the talent pool are open and accessible to all qualifying staff.Summary for question 3