Lincolnshire PEEL 2018
How legitimately does the force treat the public and its workforce?
Lincolnshire Police is good at treating the public and its workforce legitimately. It is good at behaving ethically and lawfully.
Its leaders are good role models. Officers and staff understand the standards of behaviour expected of them. But the force doesn’t have a separate forum where staff can discuss ethical dilemmas. Its approach could be strengthened by letting the workforce know the results of complaint and misconduct investigations.
The force has vetted its workforce. But it doesn’t have a process to make sure all vetting decisions are fair.
It deals with corruption threats adequately. But it should make sure there are enough staff in the anti-corruption unit. Staff shortages mean the force may be missing opportunities to identify and deal with corruption. It needs to build better links with other organisations to encourage information sharing.
The force is getting a better understanding of workforce wellbeing. It reviews data to understand patterns that might affect wellbeing. But it needs to help its managers spot the early warning signs.
It needs to get better at managing performance and development. This should help its managers carry out performance assessments that help identify and develop talent. It should also bring in a talent management system that is fair and open.
In 2017, we judged Lincolnshire Police as good at treating the public fairly.
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 sample of 206 stop and search records to assess the reasonableness of the recorded grounds. We found that 81 percent or 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.
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 monitor 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). Additionally, 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.
We reviewed the force’s website and found no obvious mention of analysis it had carried out to understand and explain reasons for disparities or any subsequent action taken.Summary for question 1
How well does the force ensure that its workforce behaves ethically and lawfully?
Areas for improvement
- The force should ensure it has an effective process for the workforce to refer, discuss and publish ethical issues.
- The force should monitor its vetting decisions to identify disparities and disproportionality (e.g. black, Asian and minority ethnic (BAME) groups), and act to reduce them where appropriate.
- The force should ensure it has a process for sharing outcomes of complaint and misconduct investigations with the workforce to develop organisation learning.
- The force should ensure it has enough capability and capacity to counter corruption effectively and proactively; 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 and build effective relationships with individuals and organisations that support and work with vulnerable people.
- The force should ensure it has enough capability and capacity to counter corruption effectively and proactively. The force should ensure it can fully monitor all its computer systems, including mobile data, to proactively identify data breaches, protect the force’s data and identify computer misuse. The force should build effective relationships with individuals and organisations that support and work with vulnerable people.
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’s leaders are positive ethical role models. They reinforce the Code of Ethics and the expected standards of professional behaviour. The workforce is aware of the standards and ethical behaviour expected. The deputy chief constable is the force lead for the Code of Ethics. Officers and staff are aware of this.
The force-level Ethics Board is independently chaired by a volunteer, a former public sector professional. The board includes external representatives, such as an independent advisory group member, force chaplain and a professor from Lincoln University. This approach brings a different and challenging perspective to the meetings. Members review policies and procedures, and discuss ethical dilemmas open and honestly. Force policies have been revised following review by this group.
In our 2017 inspection, we identified that the force should arrange for ethical dilemmas to be discussed. But we found that the wider workforce doesn’t routinely discuss these. And there isn’t a process for encouraging the workforce’s involvement in these discussions. This would give the workforce the support it needs to make difficult decisions. Some supervisors explained how they prompted such discussions in their teams. And staff explained the process they follow to raise any problems. But the force could do more to promote discussions among the workforce. This remains an area for improvement.
The force complies with the national Vetting Code of Practice. The force vetting policy exceeds the requirements of Authorised Professional Practice. It manages all new vetting requests effective and quickly. This is the case for both new starters and internal posts.
Only 1 percent of staff in the force aren’t vetted. Of the 34 other forces that supplied data, the Lincolnshire Police has the second lowest number. It gives details to the College of Policing for the barred and advisory lists. These prevent people who have left the service under investigation, or been dismissed, from re-joining or working in law enforcement. The force complies with the national vetting requirement.
All forces must understand whether people’s ethnic background affects vetting check results. The force doesn’t routinely monitor recruitment vetting decisions to identify disparities. And it can’t show that it makes sure that BAME groups, for example, are treated fairly in the vetting process. But we are reassured that, due to the small number of cases, each is reviewed by a senior officer.
The force has adequate ways of reinforcing and clarifying acceptable and unacceptable behaviours. Its publication The Standard clarifies and reinforces acceptable and unacceptable behaviours, and confirms what is good practice. It refers to the College of Policing guidance and Independent Office for Police Conduct (IOPC). Most officers and staff find this useful. They all understood the consequences of not following the Code of Ethics or standards of professional behaviour.
The force’s approach could be improved by passing the results of complaint and misconduct investigations to the workforce. The results of gross misconduct cases are not widely known or advertised to the workforce.
In our 2017 legitimacy report, we asked the force to offer more help and information to those who want to make a complaint. The force is addressing this area for improvement. This has included posters at front counters and a public information booklet. The booklet is easy to understand, and explains how to make a complaint and the process. We are satisfied that the force has made suitable progress in addressing this area for improvement.
The force has a counter-corruption strategic assessment and control strategy. This is subject to governance and review processes. The force could improve how it uses the information it has about its employees. This would help identify those at risk of becoming a corruption risk to the force. This would allow the force to intervene earlier to reduce the risk of corruption, while supporting any identified individuals.
The force uses integrity interviews to speak to employees when responding to information being reported to the professional standards department (PSD). But this tends to be reactive, after information is received, rather than proactive. The force may wish to address this.
The force uses the integrity registers for notifiable associations and business interests. During our inspection, we found that the workforce had a good awareness of this.
The ACU doesn’t have enough staff to assess, develop and deal with corruption-related information. Despite being able to audit some of its IT applications, the force can’t check all its IT systems. It is buying new protective monitoring software. But this won’t be in place until autumn 2019. Once installed, the force is confident that it will assure the workforce it is accessing systems for policing purposes only. We will revisit this area in future inspections.
As part of monitoring corruption, the force has developed limited links with organisations which support vulnerable people. The ACU has spoken to local safeguarding boards across the force area to update senior partners across other agencies. Work with Ugly Mugs – a national organisation which improves the safety of sex workers – and the University of Lincoln is raising awareness of the abuse of position for a sexual purpose. More needs to be done to make sure that other organisations are comfortable passing information to the police.
The force has a confidential reporting system to report wrongdoing, called Bad Apple. Officers and staff understand how to use this and are generally confident to do so.
During our inspection, we found people occasionally using the system incorrectly. Specifically, the type of issue being reported could or should have been dealt with by line managers. The force may want to remind the workforce of the system’s purpose.
We found that officers and staff felt they could approach the PSD if they had serious concerns. And that they would be happy to contact members of the department to discuss concerns and get advice.
The force adopts the national strategy where police officers or staff abuse their position for a sexual purpose. It views this as serious corruption. This is reflected in the force’s local counter-corruption strategic threat assessment.
The force generally refers cases appropriately to the IOPC. Staff have been given guidance and briefings in the form of 60-minute videos and a poster campaign. Leadership seminars for supervisors have reinforced the warning signs to look for.
During our inspection, we found that the workforce recognised that the abuse of position for a sexual purpose is a form of serious corruption and felt confident to raise concerns. The force has identified the professional boundaries expected and the likely outcomes should they be breached.Summary for question 2
To what extent does the force treat its workforce with fairness and respect?
Areas for improvement
- The force should ensure that it has effective processes in place to identify and understand the causes of potential disproportionality and to take effective action to address these causes in the:
- recruitment, retention and progression of its workforce; and
- treatment of officers and staff with protected characteristics, who are subjected to complaint and misconduct investigations.
- The force should ensure it has good governance arrangements to analyse a range of workforce data and information. This would help it identify the greatest threats to wellbeing, and take effective action to address them.
- The force needs a talent management system that is consistent, fair and accessible to all its 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’s leaders use many ways to get feedback from its workforce. Chief officers support and encourage this. Thirty-two percent of staff responded to a survey in June/July 2018. This is lower than a survey in December 2016, where 48 percent of staff responded.
During our inspection, officers and staff told us that common themes from the survey had been shared across the force. They also believed senior leaders were listening to their concerns. They are less clear on what is being done to address the issues. The force may want to update the workforce on its next steps.
The force carries out exit interviews with people who leave. But we found that not enough line managers had regular one-to-ones with staff. When they do take place, however, they include individual welfare discussions. We found that participation in formal debriefing after attending distressing incidents was common.
Officers and staff spoke confidently about the ways they could raise ideas or problems. They gave examples where they had been invited to try a different approach. Staff association representatives meet with chief officers regularly and are included in senior meetings to discuss workforce problems and feedback.
The force understands what affects the perception of fairness and respect. Data analysis supports this. But officers and staff we spoke to weren’t aware of any changes that had resulted from them raising problems.
The force should make sure it is aware of all concerns, to guarantee it addresses the problems that matter most to the workforce. It should also let the workforce know its response.
The force’s approach to dealing with grievances and workforce concerns is clear and well-publicised among the workforce. But our grievance file review showed that in too many cases the lack of speed in handling was a recurring theme.
Cases generally take too long to resolve. The force has responded to our findings. It is making sure that managers complete investigations under the recommended Advisory, Conciliation and Arbitration Service guide, and the code of practice.
The force is identifying and reducing disparities in workforce representation. A recent recruitment process resulted in the recruitment of six officers who have second languages.
The force understands the importance of addressing disproportionality. But it doesn’t have processes to carry out analysis to identify it. The force doesn’t routinely use information to understand disparities in its treatment of officers and staff subject to complaint and misconduct allegations. It gathers this information on an ad-hoc basis and relies on intelligence and knowledge within ACU and PSD to identify any issues.
The force has a good record of retaining those officers and staff with protected characteristics. It recognises that it could do more to improve diversity.
Supporting workforce wellbeing
In our 2017 inspection, we asked the force to review how senior management teams respond to and promote the benefits of wellbeing. During this inspection, we found that it had a clear and focused wellbeing strategy and delivery plan. The plan has four strands:
The plan includes a range of measures to support and improve the physical and mental wellbeing of the workforce. Measures include:
- fitness mentors;
- refurbished gyms;
- baby box scheme;
- plastic water bottles given to staff to help them stay hydrated; and
- two wellbeing days for each officer and staff member.
The two wellbeing days were welcomed by staff, although many didn’t fully understand why these were being allocated.
There are regular health checks for those working in more stressful roles. The force intranet gives information on what support is available and what has worked before. It is governed by the wellbeing board, and chaired by the chief officer team.
The workforce saw this as positive and praised the commitment of chief officers. However, staff told us that more focus was needed to identify organisational and individual problems earlier.
Some supervisors recognise individual warning signs and intervene early to prevent problems from escalating. But the force doesn’t routinely evaluate supervisors’ interventions for effectiveness. The force could do more to understand the underlying issues that cause workforce wellbeing concerns.
Staff said that wellbeing issues included:
- not being able to arrange annual leave easily;
- lack of follow-up on psychological review;
- heavy workloads;
- lack of training; and
- not feeling valued or listened to.
The force needs to better monitor and analyse management information in areas such as:
- absence rates;
- injuries on duty, including assaults on officers and staff;
- overtime; and
- time off in lieu.
This would help the force develop a better understanding of patterns and trends. It could then identify the greatest threats and risks to the wellbeing of the workforce, to tailor meaningful preventative measures. This is an area for improvement.
Analysing sickness data can give clues about whether there are problems relating to wellbeing within a police force. It is encouraging that the force has a workforce absence rate of 3.41 percent, compared with the England and Wales rate of 4.02 percent in the year to April 2019. Supervisors understand their role in keep in contact with team members absent from work, whatever the reason.
The force has recently changed the workforce referral process to gain access to occupational health support. Before, occupational health provision was given as a tri-force shared service with capacity limits placed on each force. The revised triage process has changed responsibility from the line manager to HR. We found that the general workforce and supervisors don’t understand the change in approach. The force may wish to raise awareness.
During our inspection, we were repeatedly told that occupational health support provision is adequate, with swift and effective contact following referral. We didn’t find evidence of delays in accessing treatment.
The force takes the wellbeing of the workforce seriously, and officers and staff are aware of the chief officer team’s commitment to health and wellbeing. But there is still more work to do.
Managing performance and development of officers and staff
The force is inconsistent in monitoring its workforce’s performance and development. Performance development reviews (PDRs) are mandatory. But most officers and staff don’t see them as useful or effective, unless they are seeking promotion.
Many officers and staff have one-to-one meetings with their line managers. But these aren’t frequent or regular. This means that the force can’t be confident it is tackling poor performance well.
The workforce doesn’t see performance management as a priority and there is limited oversight of PDR processes. The force doesn’t use PDRs to grade staff, identify talent, support career development or manage poor performance. Its expectations of what it wants from its leaders are rarely included as part of a PDR.
There is an inconsistent approach to identifying talent in the force, externally and internally. Beyond formal national schemes, such as Fast Track, the force doesn’t have a co-ordinated talent management programme to develop officers or police staff. This area needs attention.
The force supports the direct entry scheme to inspector. But there haven’t been any suitable candidates in the past two years. It continues to explore this way of attracting talent.
The workforce considers the officer promotion processes to be fair. Individuals can plan how they will gather their evidence and get support. During our inspection, officers told us that HR’s recent involvement in promotion processes is seen as positive. This makes the process fairer and more open. This is a positive step.
The workforce values the arrangements for choosing leaders. They are seen as fair. But the force could do more to identify barriers, and support and develop talent. The public will be better served by a police service that develops talent effectively, and is diverse and representative of local communities.Summary for question 3