Nottinghamshire PEEL 2018
How legitimately does the force treat the public and its workforce?
Nottinghamshire Police is good at treating the public and its workforce legitimately.
It is good at behaving ethically and lawfully. But it needs to improve how fairly it treats its workforce.
The force has leaders who are good role models. Officers and staff understand the standards of behaviour the force expects. But it would be good if it had a separate forum where staff could refer ethical dilemmas. The force has vetted its workforce and makes sure vetting decisions are fair. It deals with corruption threats well. But is should make sure the action it takes to reduce corruption is working. The force may be missing opportunities to identify and deal with corruption, due to staff shortages in the specialist unit. It needs to develop better links with other organisations to encourage information sharing.
The force hasn’t made much progress in how it deals with potential unfairness at work. It doesn’t have a consistent way of dealing with workforce concerns. But it is improving its understanding of workforce wellbeing and is taking action to improve this. It reviews a range of 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. In particular, it 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.
The force is good at increasing the diversity of its workforce. It attracts new recruits from groups that aren’t well represented and is good at making sure they remain with the force.
In 2017, we judged Nottinghamshire 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 effectiveness inspection has been carried over. However, we reviewed a representative sample of 97 stop and search records to assess the reasonableness of the recorded grounds. We found that 96 percent had 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 most 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 doesn’t identify the prevalence of possession-only drug searches or the extent to which these align with local or force-level priorities.
We reviewed Nottinghamshire Police’s website and found that the force publishes comprehensive stop and search data, including analysis carried out to understand reasons for some, but not all, of the disparities.
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 that its counter-corruption unit:
- 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
- builds effective relationships with individuals and organisations that support and work with vulnerable people.
Maintaining an ethical culture
Nottinghamshire Police leaders are positive ethical role models. They continue to reinforce the Code of Ethics and the expected standards of professional behaviour. The force sends round guidance and advice to officers and staff using a combination of intranet articles and the chief constable’s fortnightly video blog. The workforce demonstrates a good understanding of the expected standards.
The DCC chairs an organisational risk, learning, standards and integrity board that monitors standards of behaviour. This includes force-level data on complaints, employment tribunals and workplace fairness concerns. Members discuss ethical dilemmas in an open and honest way. But we were disappointed to find that the force doesn’t have a separate forum to which staff can refer ethical dilemmas. This would provide the workforce with the support they need to make difficult decisions. Supervisors clearly explained to us how they gave messages to staff, and staff explained the process they follow to raise any problems.
All policies and procedures reflect the Code of Ethics and are subject to an equality impact assessment . This means that the force is likely to be successful in further developing and maintaining an ethical culture.
In our 2017 legitimacy report, we recommended that the force should review its plan to ensure that, by April 2018, it had achieved vetting clearance for all those people that it was required to clear. We are encouraged to find it has made significant progress to meet the national vetting deadline. It has cleared all backlogs and established processes for enhanced vetting. We checked a large number of posts that required a higher level of vetting and were pleased to find that everyone currently working in those posts had the required vetting. Our assessment is that the force is now compliant with the vetting requirement.
The force monitors the results of its vetting decision making to identify any disparities. It reviews vetting for new recruits, including those who are black, Asian and minority ethnic (BAME), to monitor the reasons for rejections. The force considers cases on an individual basis. It finds solutions to overcome vetting barriers wherever possible. For example, it allowed a recruit to move address when an extended family member with convictions lived at the same address.
The force complies with its obligations to provide details to the College of Policing for the barred and advisory lists. These prevent people who have left the service under investigation, or whom the service has dismissed, from re-joining or working in law enforcement.
The force has good ways of reinforcing and clarifying acceptable and unacceptable behaviours. The PSD has carried out face-to-face briefings with officers and staff, during which it asks them to assess an incident of alleged misconduct. In most of the sessions, staff and officers assess the incident at a higher level than the PSD. The intention is to reduce any misunderstandings and start further conversations between staff and their line managers.
The force publishes findings of misconduct hearings on its intranet, but this information needs updating. The PSD page on the intranet has a library of policies. The PSD also uses the rolling banner on the force system to promote awareness of current issues. The chief constable often reinforces this through his blog. The force emails important news directly to individual officers.
The workforce views the PSD positively. The PSD takes a proactive approach to reinforcing and clarifying acceptable and unacceptable behaviours. The department makes regular visits across the force area to engage with the workforce to support and share learning. Examples include a series of briefings about the force anti-corruption policy where it shares case outcomes at team meetings, and one-to-ones to reinforce standards of behaviour.
The force has an effective counter-corruption strategic assessment and control strategy. Both are subject to governance and review processes. The force makes good use of the integrity registers for notifiable associations and business interests, and has developed a matrix to assess the risk posed by reported notifiable associations. This assists it in identifying those of greatest risk to its integrity.
The force uses information to identify officers and staff who are at risk of becoming a corruption threat. It currently focuses this information on complaint data, but intends to expand this to include other organisational data. It puts early interventions in place to assist individuals and mitigate the risk of corrupt activities taking place in the force. However, it doesn’t routinely evaluate these interventions. It determines success by whether or not the individual reappears on the list. The force may wish to address this potential gap, as it includes other sources of information from which to build an evidence base of effective intervention tactics.
The counter corruption unit (CCU) isn’t staffed well enough. The number of staff working within the CCU has reduced in the last year. This reduction limits the extent of proactive work done to develop information. Our review found that the unit could have completed more work, in some cases. As a result, the force may be missing opportunities to identify and deal with corrupt officers and staff. It has recognised the need to invest in the CCU and has approved a business case to review the CCU’s capability to increase the number of staff.
The force demonstrates a commitment to having the necessary arrangements in place to monitor its handheld and remote devices, so that it can check that officers and staff aren’t misusing them. It moved to a new device-monitoring provider this year, which caused some technical problems with the existing security software. The provider has developed a solution, which it is currently testing before full monitoring resumes. In the meantime, the force is monitoring devices by auditing the individual systems.
As part of monitoring corruption, the force has yet to develop effective links with external organisations who support vulnerable victims of crime. The CCU has spoken about this to local safeguarding boards across the force area to update senior partners. However, it accepts that it needs to do more to fill this gap and make sure that other organisations are comfortable passing information to the police. The unit currently relies on informal relationships with safeguarding partners to do this.
The force has adopted the national strategy in relation to police officers or staff who abuse their position for a sexual purpose. It views this as serious corruption. The force is good at dealing with abuse of position for a sexual purpose and refers all cases to the Independent Office for Police Conduct (IOPC). Those we spoke to during our inspection had a good understanding of this type of abuse. The force has given most supervisors additional guidance on the warning signs to look for. We found examples of the force identifying such cases from reviewing its own data. This suggests the workforce has developed a good level of awareness. The force has clearly 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 improve how it manages and monitors individual performance, supporting its supervisors in conducting fair and effective assessments. Performance development reviews need to be consistently and fairly applied across the entire organisation.
- The force should have a talent management system that is consistent, fair and accessible to all the workforce.
Cause of concern
We are concerned that Nottinghamshire Police does not consistently support the wellbeing of its workforce. The force has a wellbeing strategy in place, but has not made enough progress to promote it and create a culture where wellbeing is prioritised. As a result, the force is not giving consistent and effective support to all its workforce.
To address this cause of concern, we recommend that within six months the force should:
- Put a communication plan in place to raise awareness of the wellbeing strategy across the workforce. This plan should ensure that all staff and officers have access to information.
- Ensure that all current supervisors are trained to recognise warning signs and are aware of the early intervention options available so that they can give appropriate support and prevent wellbeing concerns escalating.
- Ensure that it has an evaluation process in place to determine what interventions work. This should include a way to provide the learning to supervisors. It should also include a way to assess the views of the workforce on whether their wellbeing needs are being prioritised and appropriate support is available for them.
Improving fairness at work
Nottinghamshire Police has made limited progress since last year in how it identifies and improves potential unfairness at work. Leaders need to do more to seek feedback and challenge from all parts of the workforce. The force conducted the last staff survey in 2016 and has plans for another in spring 2019.
The force conducts exit interviews with members of staff who leave the organisation. But we found limited evidence of line managers conducting regular one-to-ones with staff. Officers and staff we spoke to had little knowledge of the process to raise ideas or problems other than to speak to their line manager. The force acknowledges this. It plans to make the most of the opportunities presented by the recent changes to the force intranet to raise awareness of existing systems. Staff association representatives meet with chief officers quarterly at the strategic leadership board to discuss workforce problems and feedback.
During our inspection, the most significant workforce concern was resourcing levels. The force has responded positively to this. Officers are pleased that it has reversed the decline in police officer numbers. However, this has affected police staff, who are anxious about potential consequences and planned redundancies. Staff we spoke to said they were unwilling to apply for lateral job opportunities due to financial barriers. They explained that they had to start at the entry point of a pay grade when changing roles, even if that meant a reduction in salary. Some senior leaders we spoke to acknowledged this.
Nottinghamshire Police’s approach to dealing with grievances and workforce concerns is inconsistent. There is little understanding of the grievance policy across the workforce. This policy includes the use of a standard form to report a grievance. But our file review showed that officers and staff report grievances by using free-text emails, Word documents or PDFs. This means there is no consistent way for grievances to be submitted, recorded and tracked.
Line managers are unclear about their responsibilities. This means there is not enough effective oversight to ensure that managers complete investigations in accordance with the recommended ACAS (Advisory, Conciliation and Arbitration Service) guide and the Code of Practice. The force was due to review its grievance policy in September 2017, but has not done this. The policy would be better if it had more consistency and structure, as well as a better focus on the needs of the individual and wider organisational effect of unfair practice or treatment. The force has responded to our findings. It is reviewing the policy and is taking action to address the lack of workforce understanding.
The force has a developing understanding of what affects the perception of fairness and respect. It analyses some data to support this understanding. The DCC chairs the organisational risk, learning, standards and integrity board. This is a forum for thematic and departmental leads to discuss important areas and identify any emerging opportunities and risks. A senior HR business partner attends this meeting and provides an overview of the fairness at work process. However, officers and staff we spoke to weren’t aware of any changes that had resulted from them raising problems. The force should ensure it has an overview of all concerns to guarantee it appropriately addresses the problems that matter most to the workforce. Equally important, it should communicate its response to all staff.
Nottinghamshire Police has good processes for increasing the diversity of its workforce. The force has a proactive approach and uses staff association representatives to attend events with prospective applicants from less-represented groups. As a result, 38 percent of applicants to the PCDA scheme, and 21 percent of successful candidates, come from BAME backgrounds. This is a much better result than with traditional methods of police recruitment. The force is working with the College of Policing to ensure all assessment processes minimise unconscious bias. The force understands the importance of addressing potential disproportionality in the retention and progression of BAME officers and staff. It offers mentoring and coaching that focus on promotion processes. This approach includes training in unconscious bias.
The force has a good record of retaining those officers and staff with protected characteristics, and BAME officers and staff are not disproportionally subject to complaint or misconduct allegations. The force recognises that it could still do more to improve diversity within its senior ranks.
Supporting workforce wellbeing
Nottinghamshire Police continues to develop its understanding of workforce wellbeing, but the workforce isn’t fully aware of the force’s plans. The DCC chairs a quarterly health and wellbeing board, which has active participation. The force has reintroduced local-area welfare meetings and staff and officer association welfare groups to improve the understanding of and approach to wellbeing.
Officers and staff viewed these meetings as a positive step but told us that more focus was required to identity organisational and individual problems earlier. It is clear that the force understands the importance of workforce wellbeing. Its wellbeing activities include:
- an annual staff seminar;
- mindfulness training;
- Connect 5, a mental health training programme targeted at public protection staff; and
- adoption of the Blue Light Wellbeing Framework.
However, many officers and staff we spoke to agreed that wellbeing relies more on the actions of individual line managers. We found occasional examples of missed opportunities to support staff, due to supervisors not recognising welfare problems. The force launched its wellbeing strategy during our inspection. This will give momentum to force wellbeing, but it is too soon to see any noticeable benefits or influence across operational policies or processes. This is an area for improvement.
The force is improving its understanding of the threats to the wellbeing of its workforce. It undertakes some analysis of management information, such as workforce sickness and assault data, to identify and understand patterns and trends. Analysis of sickness data can give an indication of whether there are problems relating to wellbeing within a police force. It is encouraging that the force has a lower absence rate for police officers and staff than the England and Wales rate. Supervisors understand their role in maintaining contact with team members absent from work, whatever the reason.
In our 2017 legitimacy report, we said the force should prioritise workforce wellbeing and make sure staff receive their entitled leave and time off. During fieldwork, all staff agreed that they didn’t have difficulty with their direct supervisor authorising time off. Supervisors we spoke to explained that they found HR systems and processes hard to navigate. The force isn’t able to supply data about the number of rest days owed to or taken by officers, but is working to improve this.
The force is taking some action to improve the wellbeing of its workforce. It plans to refresh the wellbeing section of the intranet to increase its visibility and accessibility. Effective preventative measures exist, and some supervisors recognise individual warning signs and intervene early to prevent problems from escalating. However, the force doesn’t routinely evaluate supervisors’ interventions for effectiveness. Nottinghamshire Police makes a higher number of referrals to occupational health services than the England and Wales rate. Officers and staff told us that the occupational health support provision is adequate, with swift and effective contact following referral.
Managing performance and development of officers and staff
Nottinghamshire Police is partially effective in managing the performance and development of its workforce. As we found in 2017, performance development reviews (PDRs) are mandatory, but not seen as useful or effective by most staff unless they are seeking promotion. Many staff have one-to-one meetings with their line managers, but they are neither frequent nor regular. The workforce does not see performance management as a priority and there is limited oversight of PDR processes. Consequently, 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 an individual’s performance review. It has made little progress since our last report and this remains an area for improvement.
We found an inconsistent approach to identifying talent in the force, either externally or 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. The force supports the direct entry scheme, but there haven’t been any suitable candidates in the last two years. It continues to explore this method of attracting talent to the organisation.
The workforce views the annual officer promotion processes as fair. Regular processes mean individuals can plan how they will collate their evidence and receive support to do so. The involvement of the Police Federation in promotion processes up to and including the rank of superintendent offers a high degree of openness, fairness and credibility with the workforce. This is a positive step. Overall, the workforce generally values the current arrangements for selecting leaders and perceives them to be fair.Summary for question 3