Vetting within the MPS

Report: 5
Date: 4 November 2010
By: Assistant Commissioner Specialist Crime on behalf of the Commissioner

Summary

This paper provides an overview of current vetting arrangements in the Metropolitan Police Service (MPS), including performance and quality assurance. An update on the recommendations of the MPA Vetting Audit on vetting is also provided.

A single vetting unit is now in place and a change management programme is underway to fully integrate all aspects of national security vetting within SCD26’s existing vetting operations.

Finally, the paper sets out how the Association of Chief Police Officers (ACPO) and the MPS continue to work on proposals to ensure compliance with the legislation for people working with children and vulnerable adults. The proposals include that those staff within designated roles be vetted to agreed standards every 3 years with annual checks against the Independent Safeguarding Authority (ISA) Barred Lists and Police National Computer (PNC) Impact Nominal Index (INI). Where appropriate, the MPS will refer incidents to ISA.

A. Recommendation

That

1. Members  endorse the developing approach.

B. Supporting information

Why we undertake Metropolitan Police Security Vetting

1. The MPS is committed to the maintenance of the highest levels of honesty and integrity, and to the prevention and disruption of dishonest, unethical and unprofessional behaviour. Vetting exists to protect the Service from persons and organisations, both internal and external, who may seek to harm it or expose it to harm through their own vulnerabilities. It assists in providing a safe working environment for personnel, in protecting the people of London, in protecting our information, safeguarding national security and plays a fundamental part in achieving an ethical and honest police service free from corruption.

MPS Vetting Unit

2. On 1 October 2010, the Vetting Unit, part of SCD 26, became responsible for performing all national security vetting and police vetting checks on behalf of the MPS. SO15’s National Security Vetting Unit (NSVU), who managed security checks (SC) and developed vetting (DV) applications, joined SCD colleagues who manage vetting for all new police officer recruits, specials, PCSOs and police staff, as well as contractor and management vetting and youth supervision checks. The unit is based at NSY. National security vetting functions were co-located with SCD 26 in 2009 in anticipation of this merger.

3. The decision to locate all vetting under the management of SCD26 was to improve performance; since SCD26 took responsibility for PSG in April 2007, performance against service level agreement targets has consistently improved and costs reduced. This improvement has been partly attributed to its strong linkage to the decision-making processes within the Disclosure Service. Further, this maintains vetting as independent of the recruitment and discipline processes.

4. Within SCD, the Vetting Unit will now focus on streamlining operations, removing duplication, improving performance and efficiency whilst ensuring consistency in approach and decision-making. Good practice will also be identified and shared across the unit. A change programme is now being put in place to fully integrate NSVU operations and will review the unit’s overall structure. All changes are due to be completed before the end of the financial year and will encompass policy review, business processes and operational improvements.

5. The operational improvements sought are:

• Ensuring there is a single vetting case management system.
• Implementation of a single performance framework with robust quality assurance processes underpinned by decision-making guidance for vetting officers.
• Removal of duplication created by having two vetting units
• Improved efficiency by ensuring police checks are completed in full before initiating Security Service checks.
• Proposing, in line with ACPO recommendations, more balanced levels of vetting
• Appropriate use of police staff rather than officers
• Ensuring no unnecessary contractor vetting occurs, in partnership with recruiting directorates.

6. These improvements will contribute to making significant progress against the MPA’s vetting audit recommendations. Please see Appendix 1 for progress to date on outstanding recommendations in the 2008/9 Audit Report.

7. Appendix 2 details the current 2010/11 budget for the Vetting Unit. The work undertaken by the National Security Vetting Unit will continue to be funded by the CT Grant and so is listed separately to MPS funded activity. Work is currently underway to transfer all NSVU budgets and equipment across to SCD 26.

Vetting performance

8. Until the merger, each unit independently managed performance in their respective areas. Steps are now being taken to create a single performance framework to ensure management information is collated consistently across all aspects of operations and monitored effectively. Further, full adoption of a single case management system will assist in managing performance at each stage.

9. The MPS requires 80% of counter terrorism check (CTC) cases to be completed within 35 calendar days. In the 2009/10 financial year 96% of CTC cases were completed within 35 calendar days with an average CTC now taking 19 days.

10. The service level agreement (SLA) for management vetting (MV) is to complete 80% of cases within 42 calendar days. In FY 2009/10, 83% of MV cases were completed within 42 days with an average check taking 30 days.

11. In September 2009, the NSVU introduced a more robust monitoring system for SC and DV cases. Current performance shows that DV applications are taking approximately 107 days to complete from receipt of application to clearance. SC applications take approximately 42 days to complete and since September 2009 approximately 84% of SC cases were completed within 42 calendar days.

12. The Vetting Unit undertakes all checks required for processing all types of vetting apart from national security checks and professional standards integrity checks. There is a requirement to liaise with the British Security Services for a national security check and a further integrity check with the Directorate of Professional Standards (DPS) Intelligence Bureau, as there is currently no direct access to their database. Typically, cases which breach our performance targets do so because they are complex and the security and/or DPS integrity checks take longer to complete, delaying the resulting process.

13. Appendix 3 includes details of vetting performance.

Quality assurance

14. Current quality assurance (QA) arrangements are based on the systems in place prior to the amalgamation. Work is underway to develop and implement a single, consistent and robust quality assurance process across the unit.

15. The NSVU apply a QA process to each application at various stages, to assess whether the vetting is required, whether the forms are correctly completed, and whether the NSVU pass/fail criteria have been correctly applied.

16. SCD 26 initially QA all vetting forms to ensure they have been completed accurately. Upon completion of all vetting checks a vetting officer will recommend whether an applicant fails or passes. This recommendation is reviewed by the senior vetting officer to ensure the recommendation complies with policy. Any decision to refuse an applicant will be further quality assured by a personnel security manager if an appeal is submitted. During the 2009/10 financial year, Personnel Security Group (PSG) identified a specific role to undertake a QA process on a selection of cases that have successfully completed vetting to ensure compliance with MPS policy. Personnel security managers are also required to dip sample vetting clearances each week. Work is currently being undertaken to implement a decision making framework to support staff in completion of vetting cases and the quality assurance process. We anticipate training and the implementation of this framework to coincide with the completion of the Vetting Policy Review.

Maintaining valid vetting clearances

17. Vetting essentially considers a snapshot in time and ACPO Guidelines and the National Security Framework set clear guidance on how often vetting clearances should be re-done. The timeframes are dependent on the type of vetting clearance required to perform a given role and on whether the individual is a direct employee or a contractor. (See tables 1 and 2 below).

Table 1 – Renewal timeframes for national security vetting and police checks for MPS Employees

18. Prior to their vetting expiration date, all officers and staff (via their HR Units) are issued with instructions to complete vetting forms for a vetting review. Resource issues mean that unreturned forms are not currently followed up. This is currently being addressed and a more robust policy and procedure is also being developed.

Table 2 – Renewal timeframes for police and national security vetting checks for contractors

19. Recently issued government guidance in August 2010 will increase the duration of a contractor CTC clearance from 3 to 5 years, bringing this in line with the duration of the other types of contractor vetting. Further, ACPO National Police Vetting Policy Guidelines issued in August 2010, have triggered a wider MPS policy review of vetting, including duration of vetting clearances for contractors. However, it is not anticipated that this will result in significant changes to policy.

20. The vetting expiry date is shown on contractors’ security passes and is linked to the access they may have to the FOUNDATION computer system. Any contractor with an expired security pass should be denied access to MPS premises. Upon expiry, if clearance is still required, new forms must be submitted and they are treated as a new vetting case.

21. As part of the vetting aftercare, employees and contractors are required to advise on any change in circumstances which might impact upon vetting. In addition, any adverse information that comes to light may trigger a vetting review.

22. It should also be noted that all officers and staff who are to undertake a new role under a different contract of employment are re-vetted to the appropriate level before their new contract of employment starts i.e. PCSOs applying to be police officers, staff applying for the Metropolitan Special Constabulary (MSC) and officers applying for the 30+ scheme or police staff posts.

Youth supervision

23. Currently the MPS undertake a youth supervision check on staff working within designated roles. This check is the equivalent of the CRB enhanced check, is valid for 3 years and is not transferable to another organisation. Details of the number of checks completed within the last 3 financial years are included in Appendix 3.

24. The designated posts are:

• Child protection
• School liaison
• Police cadets
• Youth offending teams
• Youth engagement officers

Independent Safeguarding Authority and Vetting and Barring Scheme

25. The Home Office suspended the Vetting and Barring Scheme (VBS) on 14 June 2010 to allow the government to re-model the scheme back to proportionate, common sense levels. Whilst this process takes place the MPS will continue with its existing youth supervision check.

26. Prior to the review, the MPS was awaiting confirmation on whether or not all police officers and staff would be subject to the scheme, or just individuals in designated posts. However, we have received indications that this is more likely to apply to individuals in designated posts.

27. In addition, an exemption from ISA registration fee and the associated fee had been agreed subject to police performing equivalent checks. This exemption is still likely to apply in any amended scheme that may be rolled out. However, this exemption does not cover offences and so it would be an offence for a police force to knowingly employ any barred person as a police officer (that is, in regulated activity), and an offence for a barred person to work or seek work in that capacity.

28. ACPO and the MPS have proposed that to comply with the exemption conditions, we complete the recruit vetting (RV) check and a check against the ISA Barred List prior to an individual commencing duties in a designated posts. In relation to staff already in designated posts at the start of the scheme, the MPS would have a three year period to vet these staff. This timeframe coincides with the renewal period of youth supervision checks.

29. The suggested posts that this would apply to are:

• Child protection
• School liaison
• Permanent custody officers
• Permanent custody staff
• Police cadets
• Youth offending teams
• Youth engagement officers

30. The ACPO proposal it to vet to a higher level than the ISA, who are only entitled to details of conviction, reprimand and cautions from the Police National Computer, plus local intelligence which the chief officer believes to be relevant.

31. Staff in these roles will be subject to a complete recheck every 3 years and an annual check against the Barred Lists and PNC and INI. Where appropriate, the MPS will refer incidents to the ISA.

32. Home Office advisers consider that the provision and use of barred list information for vetting purposes falls within the provisions of s50A of the Safeguarding Vulnerable Groups Act (SVGA). This is because checking the lists for those in a regulated activity would be done for the purposes of preventing the offences under the SVGA. In addition, this would ensure that barred persons cannot work as police officers. This provision is likely to be extended to constables, PCSOs and special constables, as these groups normally come into contact with and deal with the public, including vulnerable groups, in their everyday work. There is more difficulty in extending this to police staff, such as those undertaking clerical and support functions.

33. With regard to serving officers, the Police Service would be in the same position as any other employer, namely it would need to take action on any officer subsequently found to be barred and that officer would have to be removed from ‘regulated activity’. Otherwise both the individual and the employer would be committing offences. There is legal provision for this course in the SVGA.

C. Other organisational and community implications

Equality and Diversity Impact

1. It is vital that vetting decisions are made in a fair, proportionate and consistent manner. A review of vetting policy is currently underway for which there has been consultation with the staff associations. The project team held a vetting workshop with SAMURAI to discuss any issues or concerns they had with the vetting process. A full equality impact assessment is being undertaken as part of the review.

Consideration of MET Forward

2. The MPS vetting operation supports several aspects of MET Forward. Whether it be helping to ensure integrity, so that officers and staff can focus on keeping London safe through the work of Met Streets, or performing national security checks to enable officers to work on counter terrorism in MET Specialist, vetting is a vital function that ensures all MET people exceed the integrity standard the public rightly expect of officers. In addition, the current drive to improve efficiency and quality of service is in keeping with the theme of MET Standards.

Financial Implications

3. The initial focus of the merger is to streamline operations and there are no financial savings identified at the present time. The unit’s budget is provided at Appendix 2.

Legal Implications

4. The legal implications have been set out in the body of the report.

5. It is recommended that legal advice continue to be sought in respect of the proposal to amend the Safeguarding Vulnerable Groups Act 2006, and the Directorate of Legal Services are engaged to ensure the proposal to increase vetting checks of designated staff have no wider employment law related implications.

Environmental Implications

6. There are no environmental implications arising from this report.

Risk Implications

7. Vetting assists in providing a safe working environment for MPS personnel, in protecting the people of London, in protecting our information, safeguarding national security and plays a fundamental part in achieving an ethical and honest police service free from corruption. Ongoing work to ensure all employees and contractors hold a valid vetting clearance helps to mitigate the risk of individuals causing harm to the MPS.

D. Background papers

None

E. Contact details

Report authors: Ruth Child, Head of MPS Vetting, MPS

For information contact:

MPA general: 020 7202 0202
Media enquiries: 020 7202 0217/18

Send an e-mail linking to this page

Feedback