Security clearance processes improvement review-implementation report

Report: 7
Date: 8 December 2005
By: Commissioner

Summary

This report:

• provides the first update on the Security Clearance Processes (also known as vetting) Implementation Plan (SCPIP) and the progress being made in delivering each of the recommendations; and
• informs the Planning Performance and Review Committee (PPRC) of the wider vision for vetting resulting from the MPS Service Review and the new work being conducted by Detective Chief Superintendent (DCS) Flower who has been tasked to scope the establishment of a unified vetting command.

A. Recommendation

That 

1. progress in implementing the original SCPIP be noted;
2. the four recommendations be agreed as completed; and
3. the proposed amendment to the scope and reach of the SIR detailed in paragraph B8 of this report is approved.

B. Supporting information

1. Work commenced on the Service Improvement Review (SIR) of security clearance processes in July 2004. The MPA PPRC approved the project initiation document in September 2004 that culminated in the final report and improvement plan being approved by the PPRC in March 2005.

2. Vetting is a series of checks carried out when a person applies to join the MPS as an employee, or a contractor, or when someone seeks appointment to a sensitive post within the service. Its aim is to protect the MPS from persons and organisations, both internal and external, who may cause harm to it or expose it to unacceptable risk. Vetting seeks to balance timeliness, risk and cost.

3. The SIR was prompted by concern that the time taken to complete vetting was reducing local effectiveness, whilst units waited for new employees to join, and created costs due to the effect of prospective employees taking up offers of alternative employment whilst they waited for vetting clearance.

4. The review identified five units in the MPS as being involved in vetting in its wider sense and included the vetting functions of the Character Enquiry Centre (CO4) and the Royalty Protection Unit (SO14).

5. However, the main focus of the review featured the roles of the Personnel Security Group (PSG) and Special Branch (SB) because of their involvement in the vetting of MPS employees and contractors.

6. Among the SIR’s fourteen recommendations was the long-term aim of amalgamating all MPS vetting units into one MPS Vetting Command within the Directorate of Professional Standards.

7. It should be noted that the original review was undertaken in 2004 and the subsequent MPS Service Review, DPS Review and the terrorist incidents in July 2005 have changed the original vision and have impacted on the timescales set within the SIR.

8. As a result of the MPS Service Review DCS Flower has been appointed to scope the feasibility of amalgamating the following units under one command:

• DCC8 (8) - Personal Security Group.
• S012 - Special Branch security vetting.
• SO14 - Royal Household Vetting.
• CO4 - National Intelligence Service.
• SCD10 (5) Police National Computer.

9. It is anticipated that DCS Flowers’ report will be completed by the end of January 2006 and presented to MPS Management Board for their decision as to whether a unified ‘Character and Information Services Command’ should be formed. This is a departure from the SIR’s original vision.

10. Appendix 1 relates to the status of each SIR recommendation.

11. The following ten recommendations from the SIR are ongoing:

12. Recommendation 1: (Overarching) The creation of a single MPS vetting unit and that this unit should sit within the DPS, combining the functions of all current vetting units under one head, working to a common policy and set of standards, supported by a robust, integrated Information Technology (IT) infrastructure. This recommendation is in progress and is now the basis for the new work of DCS Flower

13. A phased approach is planned to allow the PSG to takeover the administrative functions of SB relating to the Counter Terrorism Check (CTC). (Recommendation 1.1). Delays also resulted from the unavailability of suitable accommodation, integration of IT and training/accreditation courses for the PARASOL system as a result of operation Theseus.

14. The amalgamation of SO14 with the PSG (Recommendation 1.2) cannot progress until agreement is reached between the Royal Household and MPS emanating from the Butler-Sloss review. SO2 Business Support is leading on behalf of the MPS to identify the Royal Household’s vetting requirements and a joint protocol is being developed between the parties.

15. An IT working group has been implemented to oversee all aspects of delivery. (Recommendation 1.3).

16. Identifying whether it is appropriate to incorporate the functions of CO4 vetting units into the MPS vetting unit (Recommendation 1.4). DCS Flower is considering this within his remit resulting from the MPS Service Review.

17. Recommendation 2: The MPS Vetting Board should revise Policy and Standard Operating Procedures, by June 2005, so that personnel will not require National Security Vetting clearance if this cannot be justified, taking into account Cabinet Office, Home Office and Association of Chief Police Officers (ACPO) policy.

This recommendation in progress

18. This issue is being taken forward at ACPO level working groups to determine what impact the recently produced Cabinet Office guidelines will have. In light of the terrorist incidents, there is reluctance by the MPS to be out of sync with established national protocols.

19. There has been a 26.1% workload increase Full Year To Date (FYTD). These increases relate to Non Police Personnel (Contractors), Special Constabulary and Police and Community Support Officers (PCSOs). ‘Live Cases’ currently stand at 2,800. Changes made to MPA/MPS contracts have had an impact in this area.

20. In October 2004, the number of ‘Live Cases’ stood at 3,200. Therefore the figure of 2,800 cases needs to be seen in the context of a 26.1% increase on top of an already high volume of work. The PSG is becoming more efficient. The MPS anticipates that the increased workload will stabilise around the 19% mark.

21. The MPS intends to move from a position of a slavish compliance to ACPO vetting procedures to a position of ensuring that vetting checks are targeted on the key risks and vulnerabilities within the MPS. Proper risk assessment is needed in order to achieve this and to make sure that resources are not wasted carrying out unnecessary checks.

22. The result should be fewer, better targeted checks. Recommendations have already been made in relation to Non Police Personnel (Contractors), which is under DCS Flower’s consideration. A similar process is being applied to Recommendation 6 (Residency criteria).

23. Recommendation 3: A pilot process to test the viability of granting interim clearances should be developed by June 2005. Whilst ‘prima facie’ this would appear to be a good idea, it comes with significant practical hurdles, not least of which is the employment status of any individual engaged in such a way and whether the service could dispense with them if adverse information came to light.

24. It must also be recognised that once an individual has unsupervised access to the MPS they will have the opportunity to do harm to the service that may go undetected. If they are employed in the ‘evidence chain’ there will almost certainly be very real difficulty with court appeals and possible claims of a miscarriage of justice if previously undeclared information comes to light.

25. MPS Standard Operating Procedure 17 has been implemented to deal with granting interim clearances on an urgent/exceptional basis. A discussion paper has also been completed relating to adopting a more flexible approach to vetting Contractors. This coupled with other changes to vetting of overseas candidates will, it is anticipated, result in a quicker vetting process.

26. Recommendation 4: Changes are made, by March 2006, to the way the current Management Vetting (MV) process is carried out.

This recommendation is complete

27. Although completion date was set at March 2006 it was brought forward owing to delays being experienced in other areas of the SIR. The recommendation was supported by seven sub-recommendations.

28. Mandatory interviewing has now ceased and discretion is being applied by Senior Vetting Officers (4.1), clear and effective feedback is being provided (4.2), posts have been designated as MV (4.3), staffing levels have been increased (4.4), 2 staff are now present at interviews (4.5), specific caseworkers are now appointed to be a single point of contact (4.6) and MV staff have undertaken interview training (4.7).

29. Recommendation 5: The MPS Vetting Board to determine, by March 2006, the extent to which Special Branch database checks should be carried out.

This recommendation in progress

30. This recommendation will be achieved by the sub recommendations: 5.1 (checking of SB databases), 5.2 (assessment of how robust the SB system is) and 5.3 (checking of external forces SB databases).

31. The SB assessment is complete and is due to be considered by the MPS Vetting Board.

32. Recommendation 6: That further work is done by PSG, by July 2005, to prepare an MPS proposal about more flexible application of residency criteria, for discussion with key external stakeholders such as the Cabinet Office, Home Office, ACPO and the Security Service.

This recommendation in progress.

33. The MPS should comply with the national vetting standards agreed by ACPO. As a result of recommendation 6 the MPS sought legal advice regarding the four options highlighted within the SIR.

34. Discussions continue within ACPO Vetting to decide if and how the national policy can be brought in line with, or closer to, the standards set by the Home Office Circulars and the Cabinet Office manual.

35. To consult other stakeholders MPS members of ACPO Vetting placed the matter before the Advisory Group on National Recruiting Standards (AGNRS). The AGNRS believe that the policy is being applied too rigidly and a more commonsense approach is required.

36. The deadline set, June 2005, was neither achievable nor realistic given the complexities involved. Agreement is sought to extend the deadline for completion until 16 December 2005.

37. Recommendation 7: That the MPS agrees a Service Level Agreement (SLA) with the Security Service, by June 2005, for its input into the vetting process.

This recommendation in progress

38. This recommendation remains in progress. Delays occurred due to the new appointment of the Head of External Vetting in July, the London terrorist attacks that resulted in prioritisation of Security Service tasks and the need to await the outcome of the Cabinet Office review of vetting, which was published in October 2005.

39. During discussions with the Security Service an additional improvement opportunity was identified. The Security Service agreed to second a suitably vetted MPS employee within their unit to prioritise MPS referrals. The MPS employee has been identified and will shortly commence his secondment. The working arrangements will be contained within the SLA.

40. As a stopgap pending the recruitment of an MPS employee, the MPS identified a suitably qualified contractor to work exclusively on MPS referrals for the last six months. The MPS currently has the quickest turnaround of vetting referrals of any organisation within the UK.

41. Recommendation 8: The MPS should, by June 2005, request written confirmation from the Security Service of the precise difference in approach followed for checking against surnames of overseas origin and why this approach is taken.

This recommendation in progress

42. Contact has been established and written confirmation will be forthcoming once the Security Service is in receipt of advice from their legal department.

43. Recommendation 9: An Implementation Team, made up of representatives from the Business Groups affected, is set up, by April 2005, to progress the short-term recommendations and create a more detailed implementation plan.

This recommendation is complete.

44. An Implementation Manager was appointed and an implementation team from PSG, SO12, SO14 and CO4 was formed. They were supported by the appointment of Change Managers responsible for: personnel, IT, accommodation and PSG. A corporate governance chart has been published.

45. An implementation plan supported by an action based template covering each area of the Change Managers responsibility has been published. Project Highlight reports are submitted to the MPS Vetting Board and a Risk Register is maintained by the Implementation Manager.

46. It is anticipated that the implementation plan will be subsumed within the wider vetting remit of DCS Flower.

47. Recommendation 10: Overseeing the implementation of the recommendations from the MPS Inspectorate, MPA Internal Audit and Thematic Report on Race and Diversity, should fall to the MPS Vetting Board from April 2005.

This recommendation is complete.

48. A gap analysis has been undertaken and outstanding actions have been incorporated within the action based templates for progression by the Change Managers.

49. Recommendation 11: The MPS Vetting Board should identify, by July 2005, any recommendations from the Commission for Racial Equality (CRE) report, which relate to vetting and ensure any implications for the MPS are taken into account.

This recommendation in progress.

50. The Directorate of Professional Standards (DPS) has recruited a new Diversity Coordinator. Recommendation 11 is being progressed albeit at a delayed pace. The delays are a consequence of the new coordinator prioritising his work to ensure that other milestones set by the DPS review and Service Review are met.

51. The Coordinator has met with the Head of PSG and the implications discussed. This recommendation is expected to be complete by December 2005.

52. Recommendation 12: The MPS Vetting Board considers, by July 2005, how traces found during employment vetting searches can be fed back to Home Forces.

This recommendation in progress. Due to an oversight by the Implementation Manager, the action was only allocated in October 2005.

53. Recommendation 13: ICG undertakes work, starting in April 2005, to address problems 2 and 3 identified during the review.

This recommendation in progress.

54. Owing to the realignment of the ICG this work is in the process of being handed over to the DPS. It will become an integral part of this improvement plan.

55. Recommendation 14: A comprehensive system is developed, by June 2005, for monitoring the performance of the vetting process, using the existing process maps and taking into account the costs and benefits of collecting the data.

This recommendation is complete.

56. A new management information system has been implemented. It now provides an accurate picture of workloads, predicts trends, monitors performance and identifies blockages within the vetting process.

C. Race and equality impact

All equality implications were fully evidenced within the original ICG SIR final report. No new issues with regards to equality have been identified.

D. Financial implications

1. All financial implications are evidenced within the ICG SIR final report previously provided to the PPRC meeting. There have been no amendments to those figures.

2. As the scope and scale of DCS Flower’s amalgamation study becomes clearer a revised financial plan will be presented to the PPRC.

E. Background papers

None

F. Contact details

Report author: Detective Chief Superintendent Phil Flower

For more information contact:

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

List of abbreviations

• ACPO – Association of Chief Police Officers
• AGNRS - Advisory Group on National Recruiting Standards
• CRE – Commission for Racial Equality
• CTC – Counter Terrorism Check
• DCS – Detective Chief Superintendent
• DPS – Directorate of Professional Standards
• FYTD – Full Year To Date
• ICG – Internal Consultancy Group
• IT – Information Technology
• MPA – Metropolitan Police Authority
• MPS – Metropolitan Police Service
• MV – Management Vetting
• PCSO – Police and Community Support Officer
• PPRC – Planning, Performance and Review Committee
• PSG – Personal Security Group
• SCPIP – Security Clearances Implementation Plan
• SB – Special Branch
• SIR – Service Improvement Review
• SLA – Service Level Agreement

Appendix 1: SIR Recommendations status

SIR Action	Task	Working Group lead	Due by	STATUS	Notes
1.1	Combining the CTC administrative functions of PSG and SB Vetting Units	PSG	June 2005	RED	The timescales set were unrealistic due to the requirement to train and select staff to use the PARASOL IT system. A phased approach will result in this recommendation being achieved by Feb. 2006
1.2	Ensuring that those checked by SO14 are done so to MPS Standards	Awaits	March 2006	GREEN	Agreement has yet to be reached between the MPS & Royal Household regarding their vetting requirements and protocols
1.3	Developing the current IT systems to prepare for the future	IT	After March 2006	GREEN	IT WG has been implemented to oversee the IT user requirement
1.4	Identifying whether it is appropriate to incorporate the functions of CO4 vetting units into the MPS vetting unit	VWG	March 2006	GREEN	Options paper completed. DCS Flower considering options in light of the MPS Service Review
1.5	Considering the potential for combining the SC vetting functions of PSG and SB vetting unit and whether this should be incorporated into the MPS vetting unit.	Awaits	After March 2006	GREEN	Awaits allocation
1.6	Considering the potential for incorporating the DV function of SB vetting unit into the MPS vetting unit	Awaits	After March 2006	GREEN	Awaits allocation
2	MPS Vetting Board should revise Policy & Standard Operating Procedures so that personnel will not require National Security Vetting clearance if this cannot be justified, taking into account Cabinet Office, Home Office and ACPO policy	PSG	June 2005	RED	Refer to paras. 18-22 within PPRC paper
3	A pilot process to test the viability of granting interim clearances should be developed by June 2005	PSG	Jan. 2006	GREEN	SOP17 implemented to grant interim clearances
4	Changes are made to the way the current management vetting process is carried out	PSG	March 2006	GREEN	Completed
4.1	Mandatory interviewing is discontinued and discretion applied by senior vetting officers	PSG	March 2006	GREEN	Completed
4.2	MVU to produce clear & effective feedback	PSG	Nov. 2005	GREEN	Completed
4.3	Designate posts for MV	PSG	March 2006	GREEN	Completed
4.4	Increase staffing levels within MVU	PSG	August 2005	GREEN	Completed
4.5	Ensure that 2 staff are present during MV interviews	PSG	Nov. 2005	GREEN	Completed
4.6	Appoint specific caseworkers & single point of contact	PSG	Sept. 2005	GREEN	Completed
4.7	MVU staff to receive interview training	PSG	March 2006	GREEN	Completed
5	MPS Vetting Board to determine the extent to which SB database checks should be carried out	Awaits	March 2006	GREEN	Awaits allocation
6	PSG carry out further work to prepare an MPS proposal about more flexible application of residency criteria	PSG	July 2005	RED	Refer to paras. 32-36 within PPRC paper
7	MPS agrees a SLA with the Security Service for its input into the vetting process	VWG	June 2005	RED	Refer to paras. 37-39 within PPRC paper
8	MPS to obtain written confirmation from the Security Service of the difference of approach for checking against surnames of overseas origin	VWG	June 2005	RED	Security Service await legal advice before providing written response to the MPS
9	Form an implementation team from business groups affected and create an implementation plan	VWG	June 2005	GREEN	Completed
10	Oversee the implementation of recommendations from previous inspections	PSG	June 2005	GREEN	A gap analysis has been completed & outstanding actions have been incorporated within the action-based templates for implementation by Change Managers
11	Identify any recommendations from the CRE report which relate to vetting & incorporate within vetting response	VWG Diversity Coordinator	July 2005	RED	Refer to paras. 49-50 within PPRC paper
12	Consider how traces found within employment vetting searches can be fed to Home Forces	VWG	July 2005	RED	Due to an oversight by the Implementation Manager, this action was allocated in October 2005 to the VWG.
13	ICG undertakes work to address problems 2 & 3 identified during review	ICG	June 2005	RED	This recommendation was originally to be taken forward by the ICG. However, owing to the ICG’s realignment this recommendation will become an integral part of this improvement plan. A handover is being arranged. Owing to the MPS Service Review ICG has not progressed this recommendation in any meaningful way.
14	Implement a comprehensive management information system	PSG	August 2005	GREEN	Completed.

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