Lincolnshire Police needs to improve integrity arrangements to maintain public confidence

In a report into the effectiveness of integrity arrangements in Lincolnshire Police, His Majesty’s Inspectorate of Constabulary and Fire and Rescue Services (HMICFRS) graded the force ‘adequate’ in its vetting of police officers and staff but said it ‘requires improvement’ in both tackling counter-corruption and upholding professional standards.

HMICFRS found that the force’s vetting unit and its HR department work together effectively to predict demand of vetting applications. This includes monitoring the progress of all recruitment and promotion processes and new applications.

However, inspectors said effective risk mitigation strategies must be followed if any adverse information is identified, to reduce any potential risks to the force.

The force takes steps to improve the workforce’s awareness of the expected standards of professional behaviour. But HMICFRS said that the force needs to improve its processes for the collection, sharing and evaluation of organisational learning relating to the standards of professional behaviour. For example, investigators rarely record learning from cases, and data collected by the professional standards department doesn’t include all complaints. This means the force is missing opportunities to identify and act on trends, address concerns and make improvements.

HMICFRS said the force’s initial handling of complaints and conduct matters does not always comply with statutory guidance. There is a lack of oversight of the complaints dealt with, making it difficult to comment on the fairness and consistency of decision-making in certain cases. The force also needs to improve the level of service it provides to complainants.

His Majesty’s Inspector of Constabulary, Roy Wilsher said: “Public interest in police behaviour is high. There is an increased focus from the Government and police on improving vetting, challenging misconduct and tackling corruption.

“This in turn, increases the demand on those working in force vetting units, professional standards departments and counter-corruption units. Their work is essential to make sure the right people join the police service, and all officers and staff continue to work with integrity.

“Lincolnshire Police manages its vetting workload well, effectively managing and predicting demand. While it has effective governance in its professional standards department and the standard of its corruption investigations are good, improvements are needed here.

“For example, the force’s counter-corruption control strategy is missing some significant control measures we would have expected to see.

“It also needs to improve how it responds to complaints and conduct allegations and assess some of its vetting arrangements.

“We will continue to monitor the force’s progress.”

Lincolnshire Police’s Chief Constable Paul Gibson said: “We accept the findings of this report and that there are some areas where we need to improve, but we’re confident that the action plans we have implemented will work at pace towards achieving these.

“The inspection found that that our vetting is good, we are dealing with the small amount of corrupt officers and staff, our investigation into complaints is thorough and proportionate, and we have good investigation standards and good supervision when it comes to counter-corruption. These are the areas that matter most to the public because if were falling in these areas of work this is where they would most feel the impact.

“We will of course look at the areas where we need to improve and make sure we act on recommendations, but I’m pleased to see that the inspection team found some areas of good practice where we have effective processes and practices in place, are complying with Authorised Professional Practice (APP), and are providing a good service to the public we serve.

“We continue to invest in vetting, challenge misconduct, and tackle corruption so that we can continue to deliver the highest possible standard of policing to communities in Lincolnshire.”

Regarding the vetting grading of ‘adequate’, Mr Gibson said: “As pointed out by inspectors, our vetting is of a good standard. We have invested in this area as we understand the importance of ensuring that we maintain the highest standards of integrity within our people – both those who join us and those who already work with us.

“Vetting is an ongoing exercise, whether you’ve worked for Lincolnshire Police for ten days or ten years. The report notes that all staff have relevant vetting for their role, that teams share information appropriately, and that the Vetting department is managing demand well, with no backlogs.

“This is integral to maintaining a police force made up of staff who will display the high professional standards of behaviour that are required to work in the privileged position of police officer or member of police staff.”

Identifying areas of improvement, the HMICFRS report said the force should support all vetting decisions with a sufficiently detailed written rationale; that effective risk mitigation strategies should be implemented, and that there should be more specific reference to the vetting APP and the NDM when recording rationales.

Mr Gibson added: “In relation to the identified areas for improvement, I am confident that our action plan is addressing the need for a more detailed written rationale in those relevant cases.”

The HMICFRS inspection team graded professional standards as ‘requires improvement’, with the report stating that the Force needs to improve processes for collecting and sharing organisational learning, improve on using opportunities to act upon trend and address concerns, deliver more training to staff on professional standards, and better use of Centurion. Centurion is the system is used for case recording, management, and process control of Police data relating to professional standards. It also identified a lack of auditable supervision and decision making.

Many of its observations focused on the force’s use of the Centurion – the system used for case recording, management, and process control of police data relating to professional standards – which was not being used to its full potential.

Following the inspection, the force said it has invested in upgrading the system to the latest version and has ensured all staff within the PSD (Professional Standards Department) have received training bespoke to their roles.

The force said it accepts the comments regarding organisation learning, which was again linked to a lack of training and efficient use of the Centurion system. Both individual and organisational learning is now recorded onto this system, which is reviewed and disseminated monthly with an action tracker in place to ensure effective governance.

“The inspection team’s observation about a lack of auditable decision making also refers specifically to the use of Centurion. While the report acknowledged that the governance and structure of the department was good and that matters were being handled in a fair and consistent way, this was not being replicated within the Centurion system. This was because of a previous lack of awareness and training, which has now been rectified,” said Lincolnshire Police.

“This area for improvement has been subject to an action plan within the department that has focused on greater use of the system, and in particular the recording of decisions, rationale, and supervision of investigations.”

Mr Gibson said: “We accept that we can do more in capturing some of the learning from cases and investigations and have plans in place to address this. We have already invested heavily in Centurion and are confident that we can now illustrate that investigation plans, supervisory oversight and decision making are recorded on the system. The PSD team has also addressed specific points such as the recording of the progress of investigations, which is now being done to a high standard.

“It’s encouraging to see that the inspection team found that our staff are confident to approach our PSD if they have concerns to raise and that there are a number of ways in which they can do this.

“We have focused on the culture within our organisation, and it is pleasing to see the positive findings in this respect. We are also pleased to see that the inspection team found that our investigations into complaints and conduct matters are mostly ‘thorough and proportionate’. Where there are identified areas for improvement, such as improving our wider organisational learning, our analysis of complaints issues for themes and any potential areas of disproportionality and our supervision of investigations, we have put steps in place to ensure that these improvements are now being implemented.”

While the HMICFRS inspection team graded counter-corruption arrangements as ‘requires improvement’, it acknowledged that the department lacked the resourcing capacity to undertake actions that were routinely being completed by larger forces.

“It suggested, however, that the department should make efforts to address these. It raised several issues with the format of the department’s strategic threat assessment, suggesting a number of ways that this could be improved. These have been taken on board and included the latest strategic threat assessment that was published following the HMICFRS visit,” said Lincolnshire Police.

“The report suggested that the Force should implement regular People Intelligence meetings, this was accepted and has now formed part of the departmental improvement plan.

“It also commented on a lack of resources and suitably trained ones, which were contributing to an apparent lack of proactivity and external work to highlight the risks of Abuse of Position for Sexual Purpose with partner agencies. The force is looking to see how it can effectively meet this demand considering the ongoing financial challenges and resourcing implications.”

As part of the ongoing plan to improve PSD, Lincolnshire Police said resource has been dedicated to looking at several processes highlighted in the HMICFRS report. This includes creating several standard operating procedures to address issues such as touchpoints within the complaint handling process, more effective use of forms and letter templates and more timely recording of complaints and referrals to the IOPC.

Mr Gibson said: “It’s encouraging to note that the team recognised that our Anti-Corruption Unit is an experienced crime-focused team, and that the standard of investigation is good. This provides good levels of assurance in support of our determination to ensure that corrupt people do not have a role within our organisation. We note the areas that the team have identified for improvement, and we are already addressing them through our improvement plan.”