There is a strategic focus on custody, including arrangements for diverting the most vulnerable from custody. There are arrangements to ensure custody-specific policies and procedures protect the well-being of TACT detainees.


1.1 There is effective leadership by the Chief Officer Group which communicates a clear focus on safeguarding vulnerable people in custody and promotes the safe and respectful delivery of custody under both TACT and PACE.

Indicators (what we expect to see)

  • The Counter Terrorism Network has objectives in relation to the diversion of vulnerable adults and children away from custody which are promoted and monitored.
  • There is an effective management structure that ensures appropriate policies and procedures for the end-to-end custody process are in place under both TACT and PACE, are fully implemented and are reviewed regularly to ensure compliance with PACE Code H (Terrorism) and relevant human rights standards. Policies and procedures are accessible and staff understand them.
  • There are sufficient resources to carry out the TACT custody functions to ensure the safety and well-being of detainees. TACT custody suites are staffed with personnel who are trained, with the right skills and security clearance, who understand how to respond to detainees and whose training needs are assessed, met and evaluated to perform the requirements of the role.
  • Services provided externally to support TACT custody are appropriately vetted, monitored and scrutinised to hold providers to account.

1.2 There is an evident and effective focus on the protection of children and vulnerable adults. In particular: the best interests and welfare of children are promoted and safeguarded and where possible this avoids their criminalisation; the welfare of vulnerable adults is promoted and safeguarded.

Indicators (what we expect to see)

  • Safeguarding of children is embedded at a strategic level, supported by clear policies and procedures specific to the needs of children. Custody officers and staff are trained to recognise children who have been groomed for terrorism and to understand the need to safeguard and promote the best interests and welfare of children. They are supported to do so in the context of TACT.
  • Staff are provided with training and awareness of human trafficking, sexual abuse (including exploitation), extortion and grooming. All staff are alert to the signs that a detainee has potentially been a victim of trafficking, sexual abuse or grooming, know how to report it and do so appropriately.
  • The relevant Force area has a robust safeguarding policy for vulnerable adults which is informed by the underlying five principles of the Mental Capacity Act 2005: a presumption of capacity; the right for individuals to be supported to make their own decisions; that individuals must retain the right to make what might be seen as unwise decisions; best interests; least restrictive intervention.


1.3 Performance management data supports the safe delivery of TACT custody.

Indicators (what we expect to see)

  • Data are routinely collated (including custody throughput, demographics, adverse incidents, strip-searching, complaints and use of force), analysed to identify trends, and used to inform organisational learning and improve outcomes for detainees.
  • The Force has mechanisms in place to assure itself and the public that the use of force in relation to detention and custody is strictly necessary, safe and proportionate for TACT detainees.
  • Quality assurance processes promote the safe and respectful treatment of detainees and continuing professional development of staff.
  • Effective mechanisms are in place to learn from adverse incidents and to identify and share good practice within and across police forces and partnerships.

1.4 The Force is meeting its obligations under the Equality Act 2010 and the public sector equality duty. The Force promotes respect for people from all backgrounds and with diverse needs, and raises awareness of the discrimination that can be faced by particular groups.

Indicators (what we expect to see)

  • All staff are trained in and aware of the public sector equality duty under section 149 of the Equality Act 2010 and the protected characteristics. The Force collates adequate evidence to understand the impact of their decisions on those categories covered by the Act and take appropriate steps to ensure the duty is complied with.
  • There is effective and regular monitoring in place, including but not limited to analysis of data on custody throughput by ethnicity, religion and mental health.
  • Regular equality impact assessments are conducted across detention and custody operations. They include an element of external challenge and are published and used to develop improvement action plans.
  • A race and religion equality governance and accountability framework is established, linked to the Force’s risk register, which includes: collection of core data sets by ethnicity and religion as above, including strip-searching/use of force; arrangements for periodic reviews of the data with the Force’s Independent Advisory Group and/or relevant local community groups; plans to make improvements to practice where this is identified as being necessary; appropriate leadership and governance structures to oversee and make sure the improvements are carried out.
  • Where staff come across unfair or discriminatory treatment they are able and required to take action in challenging, eliminating and reporting it.
  • Results of race and religion equality monitoring, and any other monitoring required by protected characteristics, are communicated to all staff and staff understand how they can implement and monitor appropriate action.
  • Staff have been trained in recognising and meeting the needs of people who have one or more of the protected characteristics under the equality legislation. There are policies and procedures in place to ensure staff understand their obligations under the Equality Act 2010.

1.5 The Force facilitates access as required for effective external scrutiny.

Indicators (what we expect to see)

  • The Force responds to issues and complaints raised by Independent Custody Visitors (ICVs). This includes dealing with immediate complaints and issues raised during visits.
  • ICV feedback is used appropriately by the Force and there are regular and formal opportunities for the scheme to raise issues with senior officers.
  • The Force has an effective mechanism in place to facilitate the Independent Reviewer of Terrorism Legislation.


1.6 Partnership arrangements effectively support the identification and management of risks to the welfare of vulnerable detainees (including children) in TACT custody.

Indicators (what we expect to see)

  • There is constructive engagement with all relevant partner agencies (including appropriate adult services, ICVs, relevant safeguarding bodies, health care providers and commissioners, local authorities, youth offending services, escort providers, immigration authorities, the ambulance service, the Independent Reviewer of Terrorism Legislation and the terrorism liaison group at Westminster Magistrates Court) to support the safe and respectful delivery of custody. Outcomes can be clearly demonstrated.

Human rights standards

In relation to expectations 1.1–1.6: Human rights standards require that all places of detention are managed to ensure that detention is prescribed by law and that detainees’ human rights are respected, protected and fulfilled. That means that the humanity and inherent dignity of each and every detainee is recognised in policy and practice, that vulnerable detainees are identified and safeguarded and that managers ensure that all staff have the requisite knowledge, aptitude and skill to perform their duties so as to be human rights compliant. A child (any person under the age of 18 years) must be treated as vulnerable by reason of age and their best interests remain a primary consideration. See ECHR 2, 3, 5; ICCPR 10(1); ICESCR 12(1); CERD 2, 5, 6; CAT 10, 11, 12, 13, 16; OPCAT 19, 20, 21, 22; BOP 1, 4, 5, 7, 9, 29; PPMI 1, 2, 20; CCLEO 2, 3, 6, 7; BPUFF 1, 15; DEDRB 2; DRM 4; DHRIN 5. In relation to children specifically see CRC 3, 19, 24, 33-37, 40.