A report into the effectiveness of vetting and counter-corruption arrangements in Cumbria Constabulary

About us

His Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS) independently assesses the effectiveness and efficiency of police forces and fire and rescue services, in the public interest. In preparing our reports, we ask the questions the public would ask, and publish the answers in an accessible form. We use our expertise to interpret the evidence and make recommendations for improvement.

Introduction

Vetting, IT monitoring and counter-corruption: requires improvement

In September 2021, HMICFRS changed the way it reports on how effectively forces managed vetting and counter-corruption.

Previously, we inspected these areas as part of our police effectiveness, efficiency and legitimacy (PEEL) programme and provided our findings in the inspection report.

The new arrangements mean we will inspect each force separately to PEEL, although we will continue to use the same methods and produce a report containing our findings, graded judgments and any areas for improvement or causes of concern. The report will be accessible via a web link from the most recent force PEEL report.

In December 2021, we conducted our inspection of Cumbria Constabulary, examining the effectiveness of the force’s vetting, IT monitoring and counter-corruption. We briefed senior personnel in the force at the end of the inspection.

This report sets out our findings. It includes areas for improvement identified at the time of the inspection, which we recognise the force may have already addressed.

How effectively does the force vet its officers and staff?

The force’s overall understanding of the workforce’s vetting status is not effective. The force vetting unit (FVU) system doesn’t link to its human resources (HR) system. As a result, it can’t automate the notification process between the FVU and HR teams for people leaving, joining or moving within the organisation. Instead, it must do this manually. This means the vetting team may sometimes be unaware of personnel moving within the force. And it means the HR team may be unaware of what vetting clearance individuals have.

The force doesn’t have a system to ensure it periodically renews vetting clearances in line with the Authorised Professional Practice (APP) on vetting. It isn’t confident that all staff are appropriately vetted.

The force was planning to put in place a vetting management IT system in early 2022. In preparation for this, it started the process of transferring vetting records from its manual system on to the new IT system. This revealed a small number of people who had not been vetted. At the time of our inspection, the force was carrying out work to identify any further gaps.

We found that the force has identified designated posts that need enhanced management vetting. But it doesn’t have a consistent process for informing the FVU when personnel move into all those designated posts. Nor does the force have access to accurate information identifying who currently occupies posts that need enhanced vetting. A recent force restructure has increased the number of designated posts and the FVU couldn’t be sure if officers and staff in these new posts held the required level of vetting.

The FVU used to be part of the former Criminal Records Bureau. As such, it retains several legacy roles, such as:

• conducting checks for the public protection unit and firearms licensing;
• back-record conversion for the Police National Computer; and
• adding Police National Computer warning signals.

Some 25 percent of the team’s work isn’t related to vetting. As a result, the FVU doesn’t have enough resources to match demand.

The force isn’t fully compliant with the APP on vetting. For, example, it doesn’t complete vetting interviews regularly. And when it does complete them, it doesn’t always record notes. Improving and achieving full compliance would inevitably increase workloads and need additional resources.

The force carries out annual reviews of vetting files for personnel. In the latest review, it found some files needed renewing. It also makes monthly schedules in order to meet deadlines. And in weekly meetings, it has identified upcoming demand for vetting new recruits. This is because of the Police Uplift Programme.

At the time of our inspection, the force knew of several people who didn’t have the right level of vetting for their role. We found that the force didn’t know about the true scale of demand for vetting, and it hadn’t yet developed a credible plan to understand and deal with it.

The force doesn’t monitor vetting decisions for any disproportionality, and we found no evidence of the force analysing potential disproportionality. For example, it doesn’t analyse the proportion of rejections for applicants with a particular protected characteristic compared to the proportion of rejections for a control group (without that protected characteristic). As a result, the force has no way of understanding the reasons for any disproportionality, so it isn’t taking any action to address it.

In our 2016 report PEEL: Police legitimacy – An inspection of Cumbria Constabulary we raised vetting as an area for improvement, stating:

“The constabulary should ensure that it complies with all aspects of the current national guidelines for vetting.”

Similarly, in our 2017 report PEEL: Police legitimacy (including leadership) – An inspection of Cumbria Constabulary we raised vetting as an area for improvement, stating:

“The constabulary should ensure that its plan to comply with all aspects of the national vetting standards, in line with HMICFRS’ nationwide recommendation in December 2016, is credible and will be achieved by December 2018.”

Then in our 2019 PEEL spotlight report Shining a light on betrayal: Abuse of position for a sexual purpose we made a national recommendation stating:

“All forces that are not yet doing so should immediately comply with all elements of the national guidance on vetting. By July 2020, all forces that haven’t yet done so should vet all personnel to the appropriate standard. Forces should also have a clear understanding of the level of vetting required for all posts, and the level of vetting held by all their officers and staff. Forces should make sure all personnel have been vetted to a high enough level for the posts they hold.”

Cumbria Constabulary has previously shown some progress, but we found it still needs to improve the management of its vetting. As a result, we have identified this as an area for improvement.

How effectively does the force protect the information and data it holds?

The force doesn’t have an effective way of monitoring its IT systems and remote devices to identify improper use. Its capability is reactive only and limited to auditing its email system. The force can’t monitor other IT systems or handheld devices.

At the time of our inspection, it had recently approved the purchase of established IT monitoring software, which was due to be introduced in the early part of 2022. But we found that the force didn’t appreciate the increased demand full IT monitoring would generate. And it didn’t have plans in place to deal with this.

The force does recognise the risk associated with using encrypted apps on force devices, so it doesn’t allow this. It has a clear policy and guidance on the use of social media and has communicated these to the workforce.

In our 2016 report PEEL: Police legitimacy – An inspection of Cumbria Constabulary we identified IT monitoring as an area for improvement, stating:

“The constabulary should ensure that it has the capability to monitor all its computer systems to identify risks to its integrity.”

Similarly, in our 2019 PEEL spotlight report Shining a light on betrayal: Abuse of position for a sexual purpose we made a national recommendation, stating:

“Where forces are yet to implement an effective ICT monitoring system that allows them to monitor desktop and handheld devices, they should do so as soon as reasonably practicable.”

How well does the force tackle potential corruption?

The force doesn’t have a current counter-corruption strategic threat assessment (STA), even though it has previously had one. Similarly, it doesn’t have an associated counter-corruption control strategy and action plan. Instead, the force uses both the national and north-west regional STAs to set its priorities. These STAs are based on STUDIOS (sexual misconduct, theft, unauthorised disclosure of data, drugs, inappropriate/notifiable associations, organised crime infiltration/corruption and social media). So force analysis of counter-corruption intelligence isn’t localised or bespoke. We were disappointed to find that Cumbria didn’t contribute to the 2020 north-west STA. The STA is an important part of understanding the threats locally, regionally and nationally. We strongly encourage the force to complete an annual STA.

The force doesn’t correctly categorise corruption intelligence in line with the APP on counter-corruption (intelligence). The force has its own set of 23 intelligence categories, only some of which correlate with the national APP on corruption categories.

We reviewed 60 corruption intelligence case files. In most cases, the counter-corruption unit (CCU) responded effectively. We found three cases in which the force’s limited auditing capability meant it didn’t progress some specific types of audits that may have helped. The force uses an array of techniques to develop and investigate corruption-related intelligence. We found no evidence of the force proactively collecting intelligence or using covert tactics.

At the time of our inspection, the force considered staffing levels in the CCU to be adequate. But it conceded that it sometimes had to pass intelligence development packages to the professional standards department to continue investigations. And although the force was planning to introduce IT monitoring software in early 2022, we found no evidence or acknowledgement of the extra resourcing it would need to effectively exploit it.

The force recognises it hasn’t yet developed effective working relationships with external organisations that support vulnerable people. Its early efforts were frustrated by the pandemic. The force was reinvigorating this work when we visited.

CCU staff have developed and presented training to raise awareness of abuse of position for a sexual purpose indicators, and to signpost reporting processes should concerns arise. The workforce recognises that abuse of position for a sexual purpose is serious corruption.

In our 2018/19 report PEEL: Police effectiveness, efficiency and legitimacy – An inspection of Cumbria Constabulary we identified areas for improvement, stating:

“The force should ensure that its counter-corruption unit:

• has enough capability and capacity to counter corruption proactively and effectively; and
• continues to build effective relationships with individuals and organisations that support and work with vulnerable people.”

Similarly, in our 2019 PEEL spotlight report Shining a light on betrayal: Abuse of position for a sexual purpose we made national recommendations, stating:

“By April 2020, all forces that haven’t yet done so should:

• record corruption using the national corruption categories;
• produce a comprehensive annual counter-corruption strategic threat assessment, in line with the authorised professional practice; and
• establish regular links between their counter-corruption units and those agencies and organisations who support vulnerable people.”

“By April 2020, all forces that haven’t yet done so should make sure they have enough people with the right skills to look proactively for intelligence about those abusing their position for a sexual purpose, and to successfully complete their investigations into those identified.”

The force still needs to improve its recording of corruption-related intelligence. We have identified this as an area for improvement.

The force also needs to improve its proactive capability and the links between its CCU and organisations that support vulnerable people. Accordingly, the following remains an area for improvement.

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A report into the effectiveness of vetting and counter-corruption arrangements in Cumbria Constabulary