Thames Valley 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

The code of ethics is important to the force’s leadership. The workforce believes that members of the leadership team act ethically. The chief constable chairs an ethics panel and ethical behaviour is well embedded in the force. During our fieldwork, we saw publicity about the code on display and heard that ethical considerations form part of all force training. This includes the discussion of ethical dilemmas.

In our legitimacy inspection in 2017, we said that there needed to be more external scrutiny of force policies and that there was lack of knowledge amongst staff about how to raise ethical issues. This year we found that the complaints integrity and ethics panel provides external scrutiny of all policies. This group advises the force on difficult ethical issues. We saw evidence of the positive contribution the panel makes in dealing with inquiries into historic child sexual exploitation and the detention of people suspected of carrying drugs within their body.

However, most staff are still unaware of how to raise ethical issues. There is little knowledge about the local ethics champions and boards the force has put in place. As a result, staff told us they would instead raise any ethical issues with their supervisor.

The head of the professional standards department has conducted awareness-raising campaigns about acceptable behaviour and publicises results and lessons learnt from misconduct investigations. The force complies with 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 while under investigation, or have been dismissed, from re-joining or working in law enforcement.

Almost all staff we spoke to told us that the professional standards department deals with misconduct in a fair way and that there is a culture of learning. Supervisors conduct an integrity health check as part of the annual personal development review process. This includes a reminder of the policies about accepting gifts and hospitality. As a result, we found that most staff had a good knowledge of these issues.

The force’s policy on receiving gifts and hospitality is based on the 2012 Association of Chief Police Officers (ACPO) guidance. But it doesn’t incorporate ACPO’s guidance that a cash gift shouldn’t be accepted unless it is a donation to a police-supported charity. The force needs to address this, as our review of the gifts and hospitality register identified an occasion where an officer had declared and been permitted to keep a cash gift. On another occasion, alcohol had been accepted, which is contrary to accepted practice in many other forces.

We found that not all staff fully understand what constitutes a business interest, and learnt that the force doesn’t require staff who own a property that they rent out to declare this as a business interest. We also heard that no follow-up checks take place when a business interest has been refused, unless specific intelligence is received.

The head of the professional standards department reviews disparities in vetting decisions, including refusals for BAME applicants. However, the force hasn’t completed our national recommendation from 2016 that all staff should have received at least the minimum standard of vetting by December 2018. It made the decision not to employ extra staff in the vetting department, preferring to invest these resources in frontline roles.

It has since employed more staff in the vetting department, meaning that all new recruits are being vetted as they join. However, at the time of our fieldwork, the force told us that there was a backlog of 840 staff (10 percent of the workforce) who have never been vetted and over 1,600 staff (20 percent of the workforce) who need further vetting. The force partially addresses this by making sure that all staff who move into high-risk posts have up-to-date vetting.

Tackling corruption

The force has a local counter-corruption threat assessment and control strategy. It has a well-resourced counter-corruption unit that takes robust action to deal with corrupt officers and staff. The workforce is aware that abuse of authority for sexual purpose is serious corruption and the force treats it as such. Ways to report misconduct confidentially are well used and staff have confidence in them. But the force needs to make more progress in how it identifies potential corruption at an early stage.

The counter-corruption threat assessment identifies the main issues that the force needs be aware of when identifying corrupt activity. However, it doesn’t specify clearly who is responsible for the actions it lays out or how they should be monitored. And it doesn’t draw together all sources of information, such as key locations or activities where corruption may occur, which could give an early indication of potentially corrupt activity and an overall picture of corruption risks. A more comprehensive threat assessment and strategy, which takes these factors into account, would help the force take a more proactive approach to identifying potentially corrupt activity at an early stage.

At the time of the inspection, the force couldn’t fully monitor all its IT systems to identify potentially corrupt use. The force has told us that it will resolve this issue during 2019. In collaboration with Hampshire Constabulary, it has purchased software that (from March 2019) will allow it to monitor the use of force IT systems by employees who are suspected of involvement in corrupt activity. This will be upgraded later in the year to allow overall continual monitoring of all force systems.

Officers and staff are aware that abuse of authority for sexual purposes is serious corruption. Most staff remembered completing a training course on this subject and had some knowledge of the signs and symptoms that would indicate that a colleague was involved in this sort of activity. The force has provided information to external organisations, such as women’s refuges, which may come across people who could be vulnerable to officers who abuse their position for a sexual purpose. This took the form of a letter raising awareness of the issue. The force hasn’t followed up this initial step and has not received any intelligence back because of this exercise. Again, this may mean that potentially corrupt behaviour goes undetected.

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