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Vetting good practice: clarification interviews and predicting demand

HMICFRS published eight vetting inspections last week.

Essex Police and Lancashire Constabulary have each been graded as "good" by HMICFRS on their vetting arrangements. 

As of November 2022, Essex Police had 6,294 officers, special constables, police staff and PCSOs - of which 33 did not have the correct level of vetting for their role.

HMICFRS determined the force had a “good awareness” of these cases – some related to expired vetting while others had recently taken a post which required a higher level of vetting.

Meanwhile, at the time of Lancashire’s inspection it was in the process of transferring vetting records from a paper-based system supplemented by spreadsheets through to a new IT system (due to be used from January 2023).

Of Lancashire’s 6,309 officers, specials, staff and PCSOs, 56 were in post without the correct level of vetting because it had expired. There was “awareness” of these cases and reminders had been sent.

Both forces’ vetting units were described as “effective” at predicting future vetting demand and both had increased staffing numbers to meet Uplift increases. The two vetting managers keep records of predicted recruitment dates along with the expected number of joiners through Uplift one year in advance.

Essex will use overtime to meet high demand while Lancashire uses both overtime and employ agency staff.

Although Authorised Professional Practice allows forces to accept vetting clearance for transferees if it is less than a year old, both forces re-vet all transferees as well as those who have left the service and want to rejoin.

Essex has a “three-tiered approach” to vetting decisions – where there is no adverse information clearance is granted, where there is adverse information the team leader will make the decision and record rationale and where there are more serious concerns the Force Vetting Manager will make the decision (and record rationale).

The force has further introduced a decision making template which other FVUs in the southeast are now adopting.

Interviews are also used to clarify written responses in vetting applications.

Meanwhile, Lancashire has a system whereby vetting researchers conduct enquiries and present the results to three dedicated decision-makers, with the FVM reviewing all refusals. They also conduct interviews to clarify written responses as well as consult with staff associations and seek advice from a PSD advisor where there are cultural considerations.

The two forces will further use “risk mitigation measures” to support vetting decisions – including restrictions on postings and monitoring of social media activity.

Lancashire's FVU meets weekly with the counter-corruption unit (CCU) where they consider the monitoring of vetting applications' use of force IT systems to manage potential risks. 

Lancashire’s HMIC report did not contain sections on information and data protection nor tackling potential corruption.

However, the inspectorate has urged Essex to review its CCU staffing levels to ensure there are sufficient resources.  

Due to resources – very few cases were investigated completely by the CCU, but were handed over to the PSD when further investigation was needed. The CCU has recruited a new prevention and engagement lead and, at the time of the report, was actively recruiting four further prevention staff.

The force has an anonymous confidential reporting line and received 132 reports between January 1 2020 and November 2022.

Of 60 reviewed corruption files – there were two cases where no further action was taken, which may have resulted in “missed opportunities”. The CCU was found to have responded effectively in the remaining 58.

HMICFRS sets out: “Until the engagement and prevention team referred to earlier in this report are in post, the existing specialist CCU resources can’t focus sufficiently upon corruption investigations. This is a risk to the force.

“The force should improve how it collects, assesses, develops, and investigates counter-corruption intelligence by ensuring that its counter-corruption unit has sufficient resources and suitably trained staff to meet demand and allow for proactive intelligence collection.”

A total of eight forces had vetting inspections published last week. They included North Wales, Gwent, Cleveland and Staffordshire – all of which were graded as “adequate”.

Common areas for improvement included having sufficient staff in the vetting unit (North Wales, Cleveland and Staffordshire) as well as actions following identification of concerning adverse information. Forces were advised that in this case all vetting decisions should be supported with sufficiently detailed written rationale (North Wales, Cleveland, Gwent) and that effective risk mitigation stategeies are implemented (Gwent).

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