Management vetting update

Report: 8
Date: 10 November 2003
By: Commissioner

Summary

The aim of this report is to inform the Professional Standards and Complaints Committee of the developments within the Personnel Security Group (PSG) in relation to management vetting (MV), and, in particular, its background and current position.

A. Recommendation

That members note the report.

B. Supporting information

Introduction

1. MV was introduced into the MPS in 1998 as part of the ‘Corruption and Dishonesty Prevention Strategy’. The objective of MV is to protect the interests of the MPS, and the individuals who represent the Service, by ensuring that ‘designated posts’ are not filled by people about whom there are justifiable concerns that they may practice, or be vulnerable to corruption, dishonesty or unethical behaviour.

Main issues

2. A designated post is defined as one where opportunities for corruption are highest and there could be a substantial risk of serious damage to the Service were it occupied by a person who is corrupt, dishonest, unethical or vulnerable to any of these things.

3. The serious damage, which the process is intended to address, can be defined as:

• Frustrating the prevention or detection of serious, organised or major crime;
• Frustrating the apprehension or prosecution of such offenders;
• Significant financial loss to the Service;
• The inappropriate or unlawful award of contracts; and
• Serious damage to the reputation, integrity or security of the Service.

4. The criteria are intended to cover police, civil staff and contractor posts. The list of designated posts is being developed in full conjunction with those branches, departments and operational command units concerned; it is estimated there are around 1500 designated posts in the MPS.

Key areas of examination in management vetting

5. The enquiries made during MV aim to examine the following five aspects:

• Financial vulnerability;
• Inappropriate behaviour;
• Personal integrity;
• Vulnerability to improper pressure or influence; and
• Vulnerability through health or welfare conditions.

6. The process involves the completion of a MV questionnaire and medical questionnaire. The medical questionnaire is only interested in medical problems of a security-related nature and is viewed only by a health professional within the Occupational Health department within the MPS’ Human Resources (HR) Directorate. It concentrates on three key areas of medico-security vulnerability, namely:

• Drug and substance abuse;
• Alcohol abuse; and
• Serious psychological problems.

7. The number of ‘designated posts’ in the organisation is bound to fluctuate, as new posts are developed and old dispensed with. Advice from legal counsel indicated that there was no legal authority upon which to base a request for MV upon staff who were already in post. In view of this it was agreed that only new entrants to one of the identified ‘designated posts’ would be vetted.

8. Personnel Security Group (PSG) transferred from HR to the Directorate of Professional Standards in June 2003. This transfer is subject to an integration project, part of which is to re-examine the processes and policies relating to MV. It is anticipated that this will be completed by the end of the year. The primary ‘change considerations’ is around the potential to develop a more bespoke process which can identify other risk areas, for example domestic violence, child protection, race and diversity issues. Additionally, work is being conducted to scope the potential benefit of developing a ‘limited MV process’ which could be used as part of the quality assurance process for promotion to middle and senior police management posts.

9. The Management Vetting Scheme has been well received in the MPS and senior managers regularly liaise with the PSG to have new roles considered for MV status.

10. Association of Chief Police Officers’ (ACPO). ‘National Vetting Policy for the Police Community’ has been written and is in the final stages of approval with an expected publication date in the new year, which includes MV as already adopted in the MPS.

11. Since the first MV case on 12 March 1999, 405 cases have been dealt with by the Management Vetting Unit in the PSG. Over this period there have been five refusals and three appeals, one of which was successful.

12. Those that were refused were done so for the following reasons

• Associates 1
• Financial 2
• Lifestyle 2 (1 of which was successful on appeal)

13. A refusal to grant MV can only be made by the Head of the PSG, a Detective Superintendent, and were an appeal to be made, this would be dealt with by a Detective Chief Superintendent (Misconduct and Civil Actions Command) at stage 1. Stage 2 appeals are to an independent ACPO rank officer and Superintendent. A recent refusal is just about to proceed to stage 2.

14. MV is not part of the National Security Vetting process, although it is similar in some parts to the process of developed vetting (DV). DV has its focus upon access to ‘Top Secret’ governmental assets and matters of national security; it does not give sufficient assurance to address the identified risk profile for police ‘designated posts’.

15. The primary differences between MV and DV is that DV does not access all the police databases, including those within the DPS and the interview element is structured around risk to Government assets, whereas the MV interview is focussed upon corruption, dishonesty, associates and beliefs which are identified in the risk profile developed in respect of ‘designated posts’.

C. Equality and diversity implications

1. Guidance for vetting comes from the Cabinet Office. The Head of the PSG continues to work with the ACPO working party to develop the National Vetting Policy for the Police Community; this policy is being created to ensure compliance with Human Rights Act.

2. The MPA Internal Audit’s and the MPS’ recent Inspectorate reviews make no recommendations in this area, nevertheless equality and diversity implications in all PSG processes continue to be challenged to identify any possible areas of difficulty. Nothing has to date been identified that disproportionately disadvantages any group or community.

3. A work strand is in progress with the Community and Cultural Research Unit to develop protocols and processes to protect sensitive personal data to ensure confidentiality and engender confidence in MV for transsexual and transgender employees.

D. Financial implications

There are no financial implications directly linked to the information contained within this report.

E. Background papers

None.

F. Contact details

Report author: Detective Superintendent Dolden, MPS.

For more information contact:

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

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