Suffolk 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.

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

Suffolk Constabulary continues to develop and maintain an ethical culture. Its policies and procedures take account of the Code of Ethics. Generally, the workforce has a good understanding of the code, and of expected standards of professional behaviour. All promotion processes include questions based on ethical issues. The strategic equality and ethics board, which includes attendees from external partner organisations and workforce support groups, discusses ethical issues. The force also has a joint integrity board with Norfolk Constabulary.

The workforce can raise ethical dilemmas directly with senior officers through the force’s ‘challenge mat’ process. But the force could do more to publicise these methods and better share lessons learned with the workforce. When mistakes are made, senior leaders have worked hard to develop a culture of learning rather than blame.

The force is following the new Vetting Code of Practice and authorised professional practice. It manages all current vetting requests, whether for starters or internal postings, in an effective and timely way. The force meets its obligations to give details to the College of Policing for its barred and advisory lists, so that people who have left the service under investigation, or through dismissal, can’t re-join any force or otherwise work in law enforcement.

The head of the professional standards department (PSD) reviews disparities in vetting decisions, including refusals for black, Asian and minority ethnic applicants. These refusals are discussed at the PSD’s fortnightly tactical tasking meetings. The force has a small number of refusals, which the head of the PSD reviews directly. The force knows it should work to improve the quality of the data and information it holds about applicants’ protected characteristics. The PSD and human resources are working to improve matters.

Suffolk Constabulary did not meet our national recommendation for all forces to make sure that officers and staff had the minimum level of vetting required in their role by December 2018. However, its vetting backlog of 11 percent is lower than the England and Wales rate of 13 percent. The vetting unit for Suffolk Constabulary is run jointly with Norfolk Constabulary, but collaboration between the two separate units has caused some problems in terms of data quality and recording. This has resulted in the unit having a historical backlog of vetting records that are out of date and need to be reviewed and/or deleted (for example, when a person has resigned or moved from a staff to a police officer role). The force now knows how many outstanding records exist and is working through them. This has been a challenge because of the level of resources available, but the vetting unit has gained some extra staff.

The force has taken steps to mitigate the risk this poses by prioritising those in higher-risk posts and reviewing compliance with PSD policies. The force also monitors this risk as part of its organisational risk register procedure.

The force clarifies and reinforces standards of professional behaviour through its intranet, as well as poster campaigns and presentations to the workforce. The PSD has a communications plan with a specific focus each month. This is designed to continually improve the workforce’s understanding of professional standards. However, the awareness of integrity policies and procedures, such as declaring business interests, was mixed across the workforce.

The PSD has a quarterly newsletter, called ‘Lessons Learned’. The newsletter highlights issues of misconduct and breaches of the standards of professional behaviour, and ways in which the workforce can learn from them.

The force publicises the outcomes of serious complaints and gross misconduct investigations on the intranet. The workforce’s awareness of these publications was inconsistent. However, there was a clear understanding of the consequences of not following the Code of Ethics or standards of professional behaviour.

The force publishes limited information to the public about the outcomes of serious misconduct cases. It could use this opportunity more effectively to reassure local communities that it is effectively tackling unacceptable standards of behaviour, and to encourage the public to report any concerns they may have around this issue.

Our 2017 legitimacy inspection contained two areas for improvement.

First, in line with the Independent Police Complaints Commission (IPCC) guidance, the force was to improve the quality and timeliness of its updates to complainants, including matters of misconduct. (The IPCC became the Independent Office for Police Conduct [IOPC] in January 2018.)

During the current inspection, we spoke with a regional officer from the IOPC. The force is now complying with its guidance on the timeliness of managing complaints and mandatory referral criteria.

Second, the force needed to improve its workforce’s understanding, so that the force could identify, and respond appropriately and at the earliest opportunity to, reports of discrimination.

Supervisors now get clear advice on this matter from the intranet. The PSD reviews, records and refers all allegations to the IOPC, when required, and investigators receive a copy of the IOPC guidance. The PSD oversees investigations and advises when needed. We are satisfied that the force has made suitable progress in addressing these two areas for improvement. 

Tackling corruption

The force has an effective joint counter-corruption strategic threat assessment and control strategy in place with Norfolk Constabulary. This has been refreshed recently. The threat assessment identifies key vulnerabilities, trends and emerging threats. It does not include drug use or supply as a category for analysis, but the control strategy identifies this as an intelligence gap for the force.

The force reviews notifiable associations effectively to identify individuals who may be susceptible to corruption. The force carries out reviews more often on individuals who are perceived to be of greater risk. We consider this good practice. The ACU has recently introduced a process to review refused business interests after three months. The number of cases is small, and the force is using the reviews to see how effective it is.

The annual PDR includes an integrity checklist. Supervisors were using this consistently to discuss standards of professional behaviour with staff. However, the PSD does not routinely monitor the checklist. Doing so may assist the force to identify those members of staff who may become a corruption risk. Support is available to identified officers and staff and includes early interventions, such as debt counselling. These interventions aren’t monitored or evaluated, however. The force should consider doing this, to be sure that these services are effective in preventing potential corruption.

The limited capacity and capability of the force’s ACU means its ability to do proactive work is restricted. But if a concern is raised that requires a reactive approach, the force can quickly obtain support locally to deal with it. The ACU effectively manages the information and intelligence it receives. However, the way it records this intelligence doesn’t always align with nationally recognised categories. The result is that it may be difficult to identify and analyse trends in corruption issues. The force should review the initial classification process within the ACU.

The force now has software for real-time monitoring of its ICT systems, including those on mobile devices, besides its standard auditing capabilities. This was being rolled out across the force. The force is aware that live-time ICT monitoring could potentially increase demand on the ACU, which has little scope to take on proactive work. The ACU’s capacity was reviewed at the end of 2018, as part of the force’s outcome-based budgeting process. Agreement was reached to fill a vacant post. The head of the PSD and deputy chief constable closely and regularly monitor the impact on resources of ICT monitoring software.

The force has effective links with organisations that support vulnerable victims. It has a particularly innovative scheme to support victims of abuse of position for a sexual purpose. A dedicated member of staff from Victim Support works with victims throughout an investigation, at any hearing or court appearance and beyond. This support is available for victims in both criminal and misconduct cases. The support helps to prepare the victims to give the best evidence possible. Such cases are more likely to reach a positive conclusion. We consider this to be a positive approach to supporting vulnerable victims.

Confidential processes exist to effectively report wrongdoing. Officers and staff have a good understanding of how to do this and are generally confident that they can do so anonymously. They felt that they could approach the PSD if they had serious concerns and would be content to contact staff within the department directly to discuss them and seek advice.

The force views abuse of position for a sexual purpose as serious corruption. This is the main priority in its counter-corruption strategic threat assessment. It refers all cases appropriately to the IOPC. The workforce has a good understanding of abuse of position for a sexual purpose.

Recently, the force ran a campaign to refresh the workforce’s awareness of developing inappropriate relationships with victims of crime. The ACU has also given supervisors individual training on identifying the early signs of abuse of position for a sexual purpose – and on what to do if they recognise such signs. The force has put this plan into practice in response to our 2016 national recommendation about the abuse of position for a sexual purpose.

The only outstanding action is to start to implement a plan to make sure that effective ICT monitoring tools, and resources to use these, are in place. The force was rolling out monitoring software during our fieldwork and is reviewing its impact on resourcing within the ACU. It should be possible to close this action and sign off the plan as completed in mid-2019.

This question was not subject to detailed inspection in 2018/19, and our judgment from the 2017 legitimacy inspection has been carried over.