Staffordshire PEEL 2018

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 182 stop and search records to assess the reasonableness of the recorded grounds. We found that 74 percent 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 elements of this recommendation. It monitors and analyses stop and search data to understand reasons for disparities.

However, it does not identify the extent to which find rates vary 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 frequency of possession-only drug searches or the extent to which these align with local or force-level priorities. We reviewed the force’s website, but we couldn’t find information on, or analysis of, the reasons for the disparities or any explanation of action it may have taken to address the imbalance.

In our last legitimacy inspection of Staffordshire Police in 2017, we identified three areas of improvement.
These were:

• the way the force records and scrutinises use of force;
• how it promotes learning opportunities; and
• making sure all frontline officers have a thorough understanding of how to use all coercive powers fairly and respectfully.

Although not specifically inspected this year, we are pleased to report that the force has addressed these areas for improvement.

It has improved both its recording and scrutiny of use of all types of force. It has introduced a system to record incidents accurately. This allows the force staff safety steering group to review and scrutinise the use of force effectively.

Outside scrutiny is provided by both the Staffordshire Commissioner’s Office scrutiny group and at scrutiny panels in each of the local policing areas. This enables the force to identify trends and any learning opportunities to improve officers’ understanding and ensure that the powers are used fairly and respectfully.

The force has introduced specific learning modules to its officer safety training sessions. This includes the appropriate use of force and effective communication skills. The force highlights good practice and the footage from BWV is used to reinforce learning. The force also provides refresher courses for officers where a performance issue has been identified. 

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

Maintaining an ethical culture

Staffordshire Police’s leaders consistently promote the force’s values and the Code of Ethics. They are well understood by the workforce.

The chief constable and other members of the executive leadership team regularly give clear messages reinforcing the importance of high standards of ethical behaviour. The force uses its What if? and Crossing the Line campaigns to increase awareness of professional boundaries and threats to the workforce’s integrity. These campaigns refer directly to the Code of Ethics. High standards of behaviour are reinforced at training events and in communications published on the forces intranet. The workforce holds the chief constable and other senior leaders in high regard. They are visible, accessible and engage with the workforce well.

During our inspection, we examined how far supervisors and staff understand the Code of Ethics and the force’s values. They were able to describe the force’s expectations, their use of the national decision model and the importance of fairness and accountability in policing.

We identified strong examples of the workforce challenging and reporting inappropriate behaviour. The force gives good levels of support to those who are affected by the investigation of misconduct cases.

Despite the workforce’s appreciation of the principles of the Code of Ethics, we didn’t find examples of difficult ethical dilemmas being discussed among teams. Nor was there a strong level of awareness of how ethical issues could be raised, other than with local line managers.

The force does not use an ethics board. Its view is that enough alternative forums exist that provide opportunities where the workforce can refer difficult ethical issues.

These include ETAP and the strategic service improvement board. We acknowledge that these provide ways for referrals to be made. However, knowledge of their existence among the wider workforce was limited. The force could do more to communicate the results of their decisions. This will encourage more people to submit ethical dilemmas and support organisational learning and continuous improvement.

Staffordshire Police encourages learning through experience, rather than blaming and punishing people.

The chief constable provides clear messages about the importance of trust in policing and how the force is enabling supervisors to make decisions without referring to more senior managers.

We confirmed that the professional standards department (PSD) has a proportionate approach to handling complaints and conduct cases. They are assessed for seriousness and referred promptly to supervisors. This means minor underperformance issues are resolved more swiftly.

The force does not use a yearly performance appraisal system. Instead it relies on periodic ‘check in’ meetings between line managers and the people they supervise to discuss performance and wellbeing.

Complementing this is an annual integrity health check. This reminds officers and staff of their obligations to report business interests, gifts and hospitality, and associations with members of the public who could compromise their integrity.

However, we found that this is not being used consistently. The force is reviewing its approach. Reassuringly, we found that supervisors are vigilant to influences on wellbeing or integrity. Officers and staff have a thorough understanding of their obligation to tell the force of changes to their personal circumstances.

Officers and staff say the force will support them if minor mistakes are made in good faith. They explained the reasons for their decisions well. They apply the national decision model to ensure their decisions are accurate and they understand the standards of professional behaviour expected of them.

The force’s policies include references to diversity and have clear references to the Code of Ethics. This means the force is more likely to maintain an ethical culture, which will help communities have confidence in its legitimacy.

During our 2017 effectiveness inspection, we considered how far the force was developing and maintaining an ethical culture through effective vetting procedures. We found not all the workforce were vetted to national standards.

This time, we were pleased to find that the force has made considerable progress in this area. The force has ensured almost all the workforce has received at least the lowest level of vetting clearance for their roles. Twenty-two need to have their vetting refreshed.

The force reviews vetting decisions made by its vetting unit. These decisions are taken without information relating to protected characteristics (such as age, gender or disability). This reduces the chance of unconscious bias influencing the decision maker.

The unit’s manager consults with the force’s diversity and inclusion officer when making decisions. If cases are appealed, these are forwarded to the deputy chief constable for assessment. Vetting forms do not differentiate applicants who are of black, Asian or minority ethnic (BAME) backgrounds. So the force is unable to monitor the outcomes of its decisions to determine if under-represented groups are disproportionately affected by them.

The force meets its obligations to provide details to the College of Policing for the barred and advisory lists. These stop people who have left the service under investigation, or have been dismissed, from re-joining or working in law enforcement.

Staffordshire Police clarifies and reinforces standards of behaviour. The results and lessons learned from local and national cases are shared throughout the force. This includes specific messages given by the chief constable and emphasised in the weekly newsletter, The Beat, published on the force’s intranet.

The PSD shares information in a twice-yearly newsletter that describes the lessons learnt and outcomes of cases. 

The force makes easily accessible information about risks to integrity, including the reporting requirements relating to gifts and hospitality, available on its intranet. The PSD also provides input to all new police officers, police staff members and transferees about the expected standards of professional behaviour. This includes police cadets and volunteers.

During our inspection, we tested the workforce’s knowledge of risks to integrity. There was widespread appreciation of these risks and the consequences of not following expected standards of behaviour. This shows the force’s approach is effective.

Tackling corruption

Staffordshire Police takes steps to identify and manage internal corruption risks. However, its ability to identify and respond to these risks is limited because it cannot monitor all its ICT systems. Also, the capacity of its CCU is limited.

The force has completed a counter-corruption strategic assessment and control strategy. This influences the force’s management of corruption risks. But it would benefit from more analysis of local case studies, to allow greater comparison between local and national corruption threats.

We identified that the force draws together different sources of information to assess corruption risks. For example, data held on its registers of business interests and notifiable associations, to identify members of its workforce who are at risk of corruption.

This approach is mostly reactive. The force doesn’t hold a tactical meeting that regularly brings together representatives from different departments to review information and identify and track intervention measures in a structured way.

The force does use early intervention measures to prevent corrupt activity and support people. These measures include referrals to counselling and debt management services, and ethical interviews.

We reviewed 60 cases and found that the initial grading and assessment of intelligence did not consistently follow the APP guidance. Of the 60 items of intelligence we reviewed, 42 were not categorised in accordance with the national corruption categories. We also found that in a quarter of the cases some lines of enquiry were not pursued, and the force recorded insufficient rationale. However, from early 2019, the force has implemented a practice whereby all incidents are reviewed at detective inspector level prior to closure, to ensure rigour in the quality assessment process. The force has also implemented a review process to ensure all incidents are categorised in line with national corruption categories.

Given these practices are relatively new and not fully established we will revisit this in the future.

The force uses early intervention measures inconsistently. Further lines of enquiry, including ICT audits, would have been more suitable in some cases. However, the CCU has limited ability to monitor use of ICT systems, including hand-held and remote devices.

The force is working with its commercial ICT partner to identify the most suitable tool for mass auditing its systems. This will be an area of further scrutiny by us during future inspections. This is because the force faces challenges to ensure the capability and capacity of the CCU is sufficient to review intelligence and carry out effective investigations.

Reassuringly, the CCU can monitor social media and other public internet spaces. The force has started reviewing the structure of its PSD and CCU to determine how it can increase the CCU’s capacity.

The CCU has developed strong links with partner organisations who support vulnerable people, including victims of crime. We identified examples of serious misconduct reported to the force by partner organisations. This shows these communication channels are effective.

The force promotes its whistleblowing policies and anonymous reporting systems to its workforce. Officers and staff were aware of the ‘bad apple’ reporting line and email system – which they saw as confidential and anonymous – and were prepared to use it.

We also noted that the force’s ETAP provided the force with its independent views on how suitable these reporting systems are.

The force uses the NPCC 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 Independent Office for Police Conduct.

Staffordshire Police is experienced in identifying and pursuing people who abuse their authority. Because the force can’t monitor all its ICT systems effectively it hasn’t yet achieved our 2016 national recommendation relating to abuse of position. The CCU’s capacity to handle intelligence remains an area of risk for the force.
It recognises this.

The force acts to prevent inappropriate behaviour. The commitment shown by the CCU in engaging with the workforce using its Crossing the Line campaign videos, case studies and other material highlighting the harm caused to vulnerable people, is notable.

The workforce has a strong appreciation of the harm caused by this type of misbehaviour. Our reality testing confirmed that supervisors are vigilant to the warning signs that suggest someone may be abusing their position for a sexual purpose.

Officers and staff understand the serious consequences if they develop inappropriate relationships with members of the public. The force acts robustly in tackling people who abuse their position. This is shown by the way it handles misconduct cases over the longer term.

Senior officers comment explicitly on each case, describing the serious harm caused to victims and public confidence. The force actively publicises cases internally and externally to show how it deals effectively with this type of corrupt behaviour.

This question was not subject to detailed inspection in 2018/19, and our judgment from the 2017 legitimacy inspection has been carried over.There were no areas for improvement identified from this inspection.