A report into the effectiveness of vetting and counter-corruption arrangements in Nottinghamshire Police
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 questions on behalf of the public 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: good
In September 2021, HMICFRS changed the way it reports on how effectively police forces manage 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 March 2022, we inspected Nottinghamshire Police to examine the effectiveness of its vetting processes, IT monitoring and counter-corruption. Senior officers in the force were briefed at the end of the inspection.
This report sets out our findings. It includes an area 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?
We found that Nottinghamshire Police has a vetting management IT system and periodically reviews all clearances in line with Authorised Professional Practice on vetting.
The force maintains a spreadsheet which records month-by-month when renewals for recruit vetting or management vetting are due. The force vetting unit (FVU) plans ahead and sends relevant documentation and reminders to officers and staff. We examined a ‘chaser list’ that demonstrates the force makes sure staff submit requests for review and renewal. We sampled vetting data held by the FVU and found all officers and staff had the correct level for their role.
The FVU has sufficient resources to meet normal demand. Its workload is managed on a spreadsheet within the vetting management IT system. This identifies current cases allocated to vetting assessors, but we found a small number of unallocated cases. We also found a larger number of management vetting annual reviews that had been paused to enable the FVU to meet the demands of the Police Uplift Programme. The senior vetting assessor sets target completion dates for vetting each batch of new recruits.
The FVU assesses future demand by obtaining advance warning of planned training courses linked to designated posts. It also gathers information about other training events publicised on the force intranet, recognising this would generate additional work. Human resources (HR) and the FVU held regular meetings about recruitment to help predict future demand.
The head of the professional standards department and the force vetting manager reviews the list of designated posts annually. The review had been completed in January 2022, when a total of 1,472 individuals held designated posts requiring enhanced management vetting. The force couldn’t confirm how many different roles had designated status as the FVU had instead broken the information down by department, officer and staff. We inspected the designated post list, which is maintained on a spreadsheet. We found a manual review would be required to categorise the 1,472 posts into their individual role types and the force hadn’t done this. We encourage the force to complete this piece of work to gain a full understanding of the number and type of designated posts it has.
We found the FVU was compliant with all the minimum checks for management vetting in line with Authorised Professional Practice, including open-source intelligence and line manager endorsements. Where relevant, it conducted interviews with management vetting applicants or their current and former supervisors, usually to clarify any anomalies or issues raised.
The force’s vetting management IT system doesn’t link to its HR system. The FVU and HR produce a weekly current position statement. This provides the FVU with the most up-to-date information on staff leaving, retiring and moving to designated posts. However, there had been several occasions where staff had started in a designated post prior to the conclusion of the management vetting process.
The FVU collates monthly data in relation to vetting decisions for applicants with protected characteristics. It doesn’t analyse this data to identify any disproportionality or understand the reasons for it. For example, it doesn’t analyse the proportion of rejections for applicants with a particular protected characteristic compared to a control group without that characteristic. As a result, the force has no means of understanding the reasons for any disproportionality and therefore no action is being taken to address it. We identify this as an area for improvement.
Areas for improvement
The force should introduce a system to monitor and respond to disproportionality in its vetting decisions.
How effectively does the force protect the information and data it holds?
We found that Nottinghamshire Police has the ability to monitor all its IT systems. During our review of potential corruption intelligence, we saw some effective use of IT monitoring software. However, the counter-corruption unit (CCU) mainly undertakes monitoring on an intelligence-led basis rather than a widespread proactive approach.
Monitoring of mobile devices started in November 2021. However, the force did not know to whom each of its phones was allocated. Its ability to monitor mobile phones has been limited because of transferring to a different operating system and mobile phone contract. The force has introduced a new attribution process in which devices are linked to email addresses, and users must physically accept prompts before phones can be activated. We strongly urge the force to ensure it knows to whom each device is allocated.
The force recognises the risk associated with the use of encrypted apps on force devices and doesn’t allow them.
How well does the force tackle potential corruption?
We found that Nottinghamshire Police has a current counter-corruption strategic threat assessment, which it completes annually to identify corruption risks faced by the force.
The STA and associated control strategy identified three priorities, namely disclosure of information, inappropriate associations and sexual misconduct.
However, the CCU doesn’t share the STA with the wider workforce and doesn’t publicise the corruption priorities. The CCU shares some data at superintendent level and uses the information at tasking meetings, but generally corruption-related priorities are circulated within the CCU. This is a missed opportunity. Other forces have circulated a redacted version of the STA to its workforce.
The force correctly categorised all 41 items of corruption intelligence we reviewed in line with national standards.
Since our last inspection in 2018, the CCU had increased in size and had sufficient staffing levels. We saw some examples of proactive intelligence development using IT monitoring and proactive system audits. The force will be able to do more proactively as its IT monitoring capability matures and compatibility issues with other force systems are addressed. The force was aware of this and had recently increased its analytical and investigative resources, which should enable it to be more effective in this area.
The force recognises abuse of position for sexual purpose as serious corruption and the CCU has provided the workforce with relevant training, including presentations, e-learning and bespoke training for senior leaders.
The CCU has also presented training on abuse of position for sexual purpose to charities and other outside agencies who support vulnerable people. However, we were told that less intelligence had come from external agencies during the pandemic because training had been provided online rather than in person. The force recognises that it needs renewed emphasis on building these relationships and generating increased referrals.