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1.
ACPO Professional Standards Conference 2008
2. Introduction & Housekeeping
John Feavyour
Deputy Chief Constable
Cambridgeshire Constabulary
3. Health & Safety Announcements
4. Overview of Day 1 & Introduction to Day 2
John Feavyour
Deputy Chief Constable
Cambridgeshire Constabulary
5. Session Four
‘Vetting – The Ongoing Challenge’
6. ‘Vetting – Risk Management In Action’
Simon Cole
Assistant Chief Constable
Hampshire Constabulary
7. Implications of Getting It Wrong
Home office strikes Ł8m deal to transport illegal immigrants with man jailed for murder plot
Headline front page story in the Daily Mail Monday 2nd June 2008
Story Details:
The department failed to make checks on former police officer Mark Ayres.
Although he had been released early, his 13-year-sentence still had two years to run when Government agreed for his handling the deportation of illegal immigrants.
Ayres changed his name after leaving jail. As Mark Andrew Heaver, he was convicted of arranging for two men to stab and beat 33-year-old Michael Donovan to death at his Merseyside home while his wife and children slept upstairs.
Ayres, who joined Thames Valley police from school but left after only 18 months, founded ITA in January 2006.
they decided there was no need to look at the background of ITA's bosses, who had no contact with immigrants. They simply ran Criminal Records Bureau checks on the 50 guards.
False claims in Ayers's CV - that he reached the rank of major after serving with the Royal Marines and the Special Boat Service - also went unnoticed.
In 2006, five Nigerian illegal immigrants were found working at the Home Office as cleaners.
Shadow Home Secretary David Davis asked: 'Are they satisfied their vetting procedures pose no risk?'
Headline front page story in the Daily Mail Monday 2nd June 2008
Story Details:
The department failed to make checks on former police officer Mark Ayres.
Although he had been released early, his 13-year-sentence still had two years to run when Government agreed for his handling the deportation of illegal immigrants.
Ayres changed his name after leaving jail. As Mark Andrew Heaver, he was convicted of arranging for two men to stab and beat 33-year-old Michael Donovan to death at his Merseyside home while his wife and children slept upstairs.
Ayres, who joined Thames Valley police from school but left after only 18 months, founded ITA in January 2006.
they decided there was no need to look at the background of ITA's bosses, who had no contact with immigrants. They simply ran Criminal Records Bureau checks on the 50 guards.
False claims in Ayers's CV - that he reached the rank of major after serving with the Royal Marines and the Special Boat Service - also went unnoticed.
In 2006, five Nigerian illegal immigrants were found working at the Home Office as cleaners.
Shadow Home Secretary David Davis asked: 'Are they satisfied their vetting procedures pose no risk?'
8. National Vetting Strategy Procedures, Protocols & Practices
Linking ACPO & National Vetting Infrastructure
Commitment to Integrity & Prevention of Corruption
Focal Point for Guidance
Delivery Plan
Now approved by CC West;
The Vetting Portfolio will provide a strategic overview concerning all elements of National Security Vetting and Police Vetting including procedures, protocols and practices. This will involve the creation of a links between all ACPO portfolios and National Vetting infrastructures to ensure synergy in ACPO response and approach when developing national policy.
The Police Community is committed to the maintenance of the highest levels of honesty and integrity, and to the prevention of; corrupt; dishonest; unethical or unprofessional behaviour. The joint ACPO & ACPOS National Vetting Policy for the Police Community will support that commitment by creating an understanding of the principles of vetting in the police community, thereby establishing uniformity in vetting procedures.
The vetting portfolio will act as a focal point for guidance on vetting decisions, and on contractual and legal developments, together with advice on other emerging issues. This will include the development of a delivery plan for Vetting. Governance of the portfolio will be provided by the ACPO Professional Standards Committee within the Workforce Development Business Area.Now approved by CC West;
The Vetting Portfolio will provide a strategic overview concerning all elements of National Security Vetting and Police Vetting including procedures, protocols and practices. This will involve the creation of a links between all ACPO portfolios and National Vetting infrastructures to ensure synergy in ACPO response and approach when developing national policy.
The Police Community is committed to the maintenance of the highest levels of honesty and integrity, and to the prevention of; corrupt; dishonest; unethical or unprofessional behaviour. The joint ACPO & ACPOS National Vetting Policy for the Police Community will support that commitment by creating an understanding of the principles of vetting in the police community, thereby establishing uniformity in vetting procedures.
The vetting portfolio will act as a focal point for guidance on vetting decisions, and on contractual and legal developments, together with advice on other emerging issues. This will include the development of a delivery plan for Vetting. Governance of the portfolio will be provided by the ACPO Professional Standards Committee within the Workforce Development Business Area.
9. Structure of Vetting Portfolio.
No click throughs on this slide
Structure of Vetting Portfolio.
No click throughs on this slide
10. National Vetting Working Group
Membership of the group:
Regional Vetting Reps
Scottish Representation through ACPOS
National Police Improvement Agency
Centre for Protection of National Infrastructure
ACRO – ACPO Criminal Records Office
Serious and Organised Crime Agency
Cabinet Office
Home Office
Police Federation / Unison
ACPO Personnel
11. Current Levels of vetting - Force Vetting
Authentication – Confirms ID and allows access to Confidential and occasional secret
Recruitment Vetting – Background checks, Criminal Convictions, financial and Employment References
Enhanced Vetting – This will be superseded by 2 new levels. Management Vetting - access to secret and occasional access to top secret
Enhanced Management Vetting regular access to Top secret
Non Police Personnel Vetting - A means to ensure persons other than police staff have been assessed for reliability and integrity. Serves to reduce risk of loss of sensitive assets.
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AUTHENTICATION- Authentication whilst, not a formal security clearance, underpins all levels of Force and National Security Vetting. Authentication is used to confirm an individual’s identity, nationality, employment eligibility and residency qualification.
It allows long term, uncontrolled and frequent access to government protectively marked assets up to CONFIDENTIAL and occasional access up to SECRET.
It does not allow access to Police protectively marked assets, or unescorted access to any Police premises.
RECRUITMENT VETTING (RV)-
There are no national guidelines in respect of police staff recruitment.
the vetting criteria for the recruitment of police officers, has been extended to include persons applying for police staff vacancies.
RV should include Background checks, Criminal Conviction checks, financial checks and Employment references. (It should be noted that RV checks are shared by both Vetting Units and Recruiting/HR departments).
completion of RV allows regular access to CONFIDENTIAL and occasional access to SECRET police and government assets.
The 3 year ‘Residency Criteria’ will be expanded upon later.
ENHANCED VETTING (EV)-
Under the new Policy currently under consultation this will be replaced by 2 new levels
Management Vetting and Enhanced Management Vetting
The purpose of ‘Management Vetting (MV) and Enhanced Management Vetting’ (EMV) is to provide a means of ensuring that persons serving in ‘designated posts’, which are those with access to sensitive police information, intelligence, financial or operational assets, have been assessed as to their reliability and integrity. The procedure therefore serves to reduce the risks of unauthorised disclosure, or loss of, sensitive police assets.
It is recommended that all persons with long term, frequent and uncontrolled access to SECRET, and occasional access to TOP SECRET police assets, should hold MV clearance. Those who require regular and uncontrolled access to TOP SECRET police assets should hold EMV clearance.
NPPV-
provides a means of ensuring that persons other than police officers, police staff, including PCSO’s and members of the Special Constabulary, having physical or remote access to police information, intelligence, financial or operational assets have been assessed as to their reliability and integrity. The procedure serves to reduce the risks of unauthorised disclosure or loss of sensitive police assets. There are four level of NPPV Level 1, 2, 3 and 4
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AUTHENTICATION- Authentication whilst, not a formal security clearance, underpins all levels of Force and National Security Vetting. Authentication is used to confirm an individual’s identity, nationality, employment eligibility and residency qualification.
It allows long term, uncontrolled and frequent access to government protectively marked assets up to CONFIDENTIAL and occasional access up to SECRET.
It does not allow access to Police protectively marked assets, or unescorted access to any Police premises.
RECRUITMENT VETTING (RV)-
There are no national guidelines in respect of police staff recruitment.
the vetting criteria for the recruitment of police officers, has been extended to include persons applying for police staff vacancies.
RV should include Background checks, Criminal Conviction checks, financial checks and Employment references. (It should be noted that RV checks are shared by both Vetting Units and Recruiting/HR departments).
completion of RV allows regular access to CONFIDENTIAL and occasional access to SECRET police and government assets.
The 3 year ‘Residency Criteria’ will be expanded upon later.
ENHANCED VETTING (EV)-
Under the new Policy currently under consultation this will be replaced by 2 new levels
Management Vetting and Enhanced Management Vetting
The purpose of ‘Management Vetting (MV) and Enhanced Management Vetting’ (EMV) is to provide a means of ensuring that persons serving in ‘designated posts’, which are those with access to sensitive police information, intelligence, financial or operational assets, have been assessed as to their reliability and integrity. The procedure therefore serves to reduce the risks of unauthorised disclosure, or loss of, sensitive police assets.
It is recommended that all persons with long term, frequent and uncontrolled access to SECRET, and occasional access to TOP SECRET police assets, should hold MV clearance. Those who require regular and uncontrolled access to TOP SECRET police assets should hold EMV clearance.
NPPV-
provides a means of ensuring that persons other than police officers, police staff, including PCSO’s and members of the Special Constabulary, having physical or remote access to police information, intelligence, financial or operational assets have been assessed as to their reliability and integrity. The procedure serves to reduce the risks of unauthorised disclosure or loss of sensitive police assets. There are four level of NPPV Level 1, 2, 3 and 4
12. Current Levels of vetting National Security Vetting
Counter Terrorist Check (CTC)
Security Check (SC)
Security Check Enhanced (SC Enhanced)
Developed Vetting (DV)
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COUNTER-TERRORIST CHECK (CTC)-
Counter Terrorist Checks are carried out to prevent those who may have connections with terrorist organisations, or who may be vulnerable to pressure from such organisations, from gaining access to certain persons, premises and information, that could be exploited to further the aims of a terrorist organisation.
CTC clearance, on its own, does not allow access to, knowledge or custody of, protectively marked government or police assets. CTC clearance is required for all police officers, members of the Special Constabulary, Police Staff, including PCSOs and Force Support Officers, and non-police personnel whose work involves proximity to public figures who are assessed to be at particular risk from terrorist attack, or who have access to premises, information or material assessed to be of value to terrorists.
The weaknesses of CTC as a blanket check are covered later in the HO 54/2003 slide
SECURITY CHECK (SC) - SC clearance is required for those individuals who are to be employed in posts, which involve long-term frequent and uncontrolled access to SECRET government assets, and require occasional access to TOP SECRET government assets and information.
This process includes a check with CPNI, examination of finances and a non-step down/standard PNC check
SECURITY CHECK ENHANCED (SC (Enhanced) - SC (Enhanced) is identical to the above with additional financial checks and is specific to those individuals who have access to STRAP material.
DEVELOPED VETTING (DV) - Developed Vetting (DV) is designed for those individuals who have long-term frequent and uncontrolled access to TOP SECRET government assets and for individuals, while not in such a post who will be in a position to, directly or indirectly, bring about the same degree of damage.
This process costs forces Ł928.25 (source: DVA figures 01/08/07) for a DV, Ł661 for a standard DV review and Ł316.08 for each additional interview
This level of vetting includes a robust examination of finances, interviews with referees, checks with CPNI and checks of departmental records. It has been identified earlier that much of the work conducted under this vetting level is conducted by Police Vetting Assets. This check is primarily aimed at addressing counter terrorism concerns within the agreed GPMS (Government Protective Marking Scheme).
For DV’s, a ‘review’ should be carried out initially at 5 years and thereafter, at a minimum, every 7 years. However, any level of clearance may be reviewed at an earlier stage if adverse information comes to light relating to the subject, or there is a material change in and individual’s personal circumstances.
Main Reason for Refusal
Convictions 40.1%
Residency 11.4%
SB - CTC 0.2%
Intelligence LIO, MCRAC) 20.5%
CRIS 4.6%
Candidate Family Members 7.6%
Complaints & Discipline System 2.4%
Finance Issues 11.3%
Other (DVLA, Military, RMS) 1.9%
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COUNTER-TERRORIST CHECK (CTC)-
Counter Terrorist Checks are carried out to prevent those who may have connections with terrorist organisations, or who may be vulnerable to pressure from such organisations, from gaining access to certain persons, premises and information, that could be exploited to further the aims of a terrorist organisation.
CTC clearance, on its own, does not allow access to, knowledge or custody of, protectively marked government or police assets. CTC clearance is required for all police officers, members of the Special Constabulary, Police Staff, including PCSOs and Force Support Officers, and non-police personnel whose work involves proximity to public figures who are assessed to be at particular risk from terrorist attack, or who have access to premises, information or material assessed to be of value to terrorists.
The weaknesses of CTC as a blanket check are covered later in the HO 54/2003 slide
SECURITY CHECK (SC) - SC clearance is required for those individuals who are to be employed in posts, which involve long-term frequent and uncontrolled access to SECRET government assets, and require occasional access to TOP SECRET government assets and information.
This process includes a check with CPNI, examination of finances and a non-step down/standard PNC check
SECURITY CHECK ENHANCED (SC (Enhanced) - SC (Enhanced) is identical to the above with additional financial checks and is specific to those individuals who have access to STRAP material.
DEVELOPED VETTING (DV) - Developed Vetting (DV) is designed for those individuals who have long-term frequent and uncontrolled access to TOP SECRET government assets and for individuals, while not in such a post who will be in a position to, directly or indirectly, bring about the same degree of damage.
This process costs forces Ł928.25 (source: DVA figures 01/08/07) for a DV, Ł661 for a standard DV review and Ł316.08 for each additional interview
This level of vetting includes a robust examination of finances, interviews with referees, checks with CPNI and checks of departmental records. It has been identified earlier that much of the work conducted under this vetting level is conducted by Police Vetting Assets. This check is primarily aimed at addressing counter terrorism concerns within the agreed GPMS (Government Protective Marking Scheme).
For DV’s, a ‘review’ should be carried out initially at 5 years and thereafter, at a minimum, every 7 years. However, any level of clearance may be reviewed at an earlier stage if adverse information comes to light relating to the subject, or there is a material change in and individual’s personal circumstances.
Main Reason for Refusal
Convictions 40.1%
Residency 11.4%
SB - CTC 0.2%
Intelligence LIO, MCRAC) 20.5%
CRIS 4.6%
Candidate Family Members 7.6%
Complaints & Discipline System 2.4%
Finance Issues 11.3%
Other (DVLA, Military, RMS) 1.9%
13. Synergy between Force and National Security Vetting? Much of the work conducted in some fields of National Security Vetting stems from local checks at a Force level using Police held data
Checks of Identity, employment history, nationality, residency qualification and unspent criminal conviction form the baseline of all NSV and Force Vetting.
Is there an over reliance on CTC Check?
What Does a Negative Check actually mean?
Public Perceptions of Security Service Checks
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1 What is the real difference between NSV and Force Vetting.
2 One would rightly assume that NSV checks will have far more depth and scrutiny level attached, yet these checks are carried out using information largely already held on police databases.
3 Is there an over reliance on CTC – What does it actually tell us, why are so many roles subject to it. This has broad reaching consequences in terms of costs of conducting the checks, the level of resources within the shared service providers, backlogs and the actual peace of mind for an organisation that this ultimately delivers.
4 What does a negative check really mean – does no trace to the security services assume a person is of little or no risk?
5 Public Perceptions of security service checks at a higher level working with data only held by them Versus reality
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1 What is the real difference between NSV and Force Vetting.
2 One would rightly assume that NSV checks will have far more depth and scrutiny level attached, yet these checks are carried out using information largely already held on police databases.
3 Is there an over reliance on CTC – What does it actually tell us, why are so many roles subject to it. This has broad reaching consequences in terms of costs of conducting the checks, the level of resources within the shared service providers, backlogs and the actual peace of mind for an organisation that this ultimately delivers.
4 What does a negative check really mean – does no trace to the security services assume a person is of little or no risk?
5 Public Perceptions of security service checks at a higher level working with data only held by them Versus reality
14. A New Vetting World Revised National Vetting Policy
ACPO Policy and cross portfolio dialogue
Cost and resource effective vetting of the extended police family
Uniformity in development of memorandum of understanding with partners
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Policy Thanks to the hard work of a number of colleagues within the Force Vetting Officers Advisory Group and the National Vetting Working Group, a complete redraft of the national policy has been produced and consultation is now underway.
Thanks to:
Alan McCawley (Met)
Bob Lane (Warwickshire)
Carol Benton (Lancashire)
Jonathan Gupta (Staffordshire)
Stewart Finlayson (Strathclyde
Cross Portfolio issues Vetting portfolio not considered in the many cross portfolio issues, vetting is not considered in terms of cost, resource implications, demand upon Force Vetting staffing levels and aftercare.
Key systems and access
Extended Family e.g. Community Safety Accreditation, is a CTC check necessary. Risk averse v Risk management
MOU CPS, Audit commission, Highways agency. etc
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Policy Thanks to the hard work of a number of colleagues within the Force Vetting Officers Advisory Group and the National Vetting Working Group, a complete redraft of the national policy has been produced and consultation is now underway.
Thanks to:
Alan McCawley (Met)
Bob Lane (Warwickshire)
Carol Benton (Lancashire)
Jonathan Gupta (Staffordshire)
Stewart Finlayson (Strathclyde
Cross Portfolio issues Vetting portfolio not considered in the many cross portfolio issues, vetting is not considered in terms of cost, resource implications, demand upon Force Vetting staffing levels and aftercare.
Key systems and access
Extended Family e.g. Community Safety Accreditation, is a CTC check necessary. Risk averse v Risk management
MOU CPS, Audit commission, Highways agency. etc
15. Residency Criteria Current Issues:
HR concerns
Implications on conditions of employment
Ability to have a workforce representative of the community, recruitment and retention of hard to reach groups.
Checkable History
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The 3 year ‘Residency Criteria’ remains an area of current debate between the vetting and HR communities. This area of development and future debate has been redefined as the need for a checkable history which satisfies the current vetting policy and recruitment criteria, whilst ensuring the high standards of pre-employment checks are maintained. ACRO are an active participant in this area of future development.
IMPLICATIONS ON CONDITIONS OF EMPLOYMENT – Career Breaks, etc.
Fairness?
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The 3 year ‘Residency Criteria’ remains an area of current debate between the vetting and HR communities. This area of development and future debate has been redefined as the need for a checkable history which satisfies the current vetting policy and recruitment criteria, whilst ensuring the high standards of pre-employment checks are maintained. ACRO are an active participant in this area of future development.
IMPLICATIONS ON CONDITIONS OF EMPLOYMENT – Career Breaks, etc.
Fairness?
16. Home Office Circular 54/2003National Recruitment Standards – Eligibility criteria for police recruitment and consistent recruitment practices CTC Check
Is it fit for purpose?
ACPOS Position
Aftercare issues
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HOC 54/2003 gives guidance on eligibility criteria for police recruitment and covers criminal convictions, financial checks, checks on persons who have lived abroad through to whether someone has tattoos or can swim or not.
Straight lift from HOC 54/2003;
Forces need to carry out recruitment vetting procedures on all applicants to determine an applicant’s suitability to have access to sensitive and classified material and to ensure that counter terrorist checks are made. This guidance applies to all applicants (including UK nationals who have been living abroad) and should be read and sit alongside national security and force vetting policy and procedures and the recent Home Office Circular 6/2003 on nationality.
Counter Terrorist Checks are carried out to prevent those who may have connections with terrorist organisations, or who may be vulnerable to pressure from such organisations, from gaining access to certain persons, premises and information, that could be exploited to further the aims of a terrorist organisation.
Fit for Purpose
ACPOS moving away from blanket CTC check to a risk based approach to role and access level
It should be noted that ACPOS have recently decided to move away from this blanket CTC requirement to one which is centred on a role/risk based approach. This ACPOS decision is supported by the Cabinet Office, a decision which the Cabinet Office would like to see replicated for Police Forces in England and Wales. CTC includes a CPNI (Security Service) and PNC check but does not include, as standard, any local force checks such as PSD/Force Intelligence.
Aftercare practicality and checking of pre 2003 employees and the management of issues relating to personnel effected.
Is 10 years to bigger gap?
4 headlines will appear on click
HOC 54/2003 gives guidance on eligibility criteria for police recruitment and covers criminal convictions, financial checks, checks on persons who have lived abroad through to whether someone has tattoos or can swim or not.
Straight lift from HOC 54/2003;
Forces need to carry out recruitment vetting procedures on all applicants to determine an applicant’s suitability to have access to sensitive and classified material and to ensure that counter terrorist checks are made. This guidance applies to all applicants (including UK nationals who have been living abroad) and should be read and sit alongside national security and force vetting policy and procedures and the recent Home Office Circular 6/2003 on nationality.
Counter Terrorist Checks are carried out to prevent those who may have connections with terrorist organisations, or who may be vulnerable to pressure from such organisations, from gaining access to certain persons, premises and information, that could be exploited to further the aims of a terrorist organisation.
Fit for Purpose
ACPOS moving away from blanket CTC check to a risk based approach to role and access level
It should be noted that ACPOS have recently decided to move away from this blanket CTC requirement to one which is centred on a role/risk based approach. This ACPOS decision is supported by the Cabinet Office, a decision which the Cabinet Office would like to see replicated for Police Forces in England and Wales. CTC includes a CPNI (Security Service) and PNC check but does not include, as standard, any local force checks such as PSD/Force Intelligence.
Aftercare practicality and checking of pre 2003 employees and the management of issues relating to personnel effected.
Is 10 years to bigger gap?
17.
THE TIMES
Monday, June 2 2008
ISA Story from THE TIMES Monday 2nd June 2008ISA Story from THE TIMES Monday 2nd June 2008
18. Independent Safeguarding Authority The Independent Safeguarding Authority (ISA)
Created to help prevent unsuitable people from working with children and vulnerable adults.
Regulated Activity
Current interpretation of the regulations could indicate that all Police Officers and a large number of police staff members will become the subject of ISA regulation.
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1 ACPO recognises that any steps that can be reasonably taken to safeguard the vulnerable in our society should be supported. However, the ISA consultation paper has raised a number of concerns which require clarification and further definition. The financial implications of complying with these obligatory regulations for the Police service nationally cannot be understated.
2 Regulated and controlled activity – clarification required2 headlines will Appear on click
1 ACPO recognises that any steps that can be reasonably taken to safeguard the vulnerable in our society should be supported. However, the ISA consultation paper has raised a number of concerns which require clarification and further definition. The financial implications of complying with these obligatory regulations for the Police service nationally cannot be understated.
2 Regulated and controlled activity – clarification required
19. Independent Safeguarding Authority List 99, POCA and POVA
Cost balanced against compliance
Cost of this compliance has not yet been stated but under the widest interpretation of the regulations this could cost the police service in excess of Ł7 million for police officers alone
Every Child Matters
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List 99, POCA & POVA issues within this, costs of registering staff
What is List 99?
List 99 is a secret register of men and women who are barred from working with children by the Department of Education and Skills (DfES). More than 80 years old, it is maintained by the Children's Safeguards Unit of the department and contains the names, aliases, dates of birth and national insurance numbers of all those forbidden to work with children in schools, social work and voluntary settings.
POCA& POVA
Protection of Children Act List. This is a list, managed by the Department for Education and Skills (DfES) on behalf of the Department of Health (DH)
The Protection of Vulnerable Adults (POVA) scheme was introduced in July 2004. At the heart of the scheme is the POVA list. This is a list, managed by the Department for Education and Skills (DfES) on behalf of the Department of Health
There is a statutory duty on providers of care to check if an individual is included on the POVA list. Referrals and checks made against the POVA list identify those people who are banned from working in a care position with vulnerable adults.
When an employer asks for a criminal records check for a position that involves working with vulnerable adults, then if the above conditions are met then the disclosure process will include a check against the POVA list.
In some circumstances, in order to meet the regulations covering minimum staffing levels, an employee may need to start before the results of a check are known
Cost v compliance 7 million estimate of cost to regulate police service
Every Child Matters puts an obligation on all organisations whose work can contribute to public protection work, including social services, a duty to co-operate and share information and support the creation of a national service framework for children. ISA are currently liaising with the Department for Children, Schools and Families to seek reconciliation between the requirements that they have under the Safeguarding Vulnerable Groups Act 2006 and the obligations within Every Child Matters. The result of that liaison has huge implications for the Service.
ISA – Meeting in London Soon3 headlines will Appear on click
List 99, POCA & POVA issues within this, costs of registering staff
What is List 99?
List 99 is a secret register of men and women who are barred from working with children by the Department of Education and Skills (DfES). More than 80 years old, it is maintained by the Children's Safeguards Unit of the department and contains the names, aliases, dates of birth and national insurance numbers of all those forbidden to work with children in schools, social work and voluntary settings.
POCA& POVA
Protection of Children Act List. This is a list, managed by the Department for Education and Skills (DfES) on behalf of the Department of Health (DH)
The Protection of Vulnerable Adults (POVA) scheme was introduced in July 2004. At the heart of the scheme is the POVA list. This is a list, managed by the Department for Education and Skills (DfES) on behalf of the Department of Health
There is a statutory duty on providers of care to check if an individual is included on the POVA list. Referrals and checks made against the POVA list identify those people who are banned from working in a care position with vulnerable adults.
When an employer asks for a criminal records check for a position that involves working with vulnerable adults, then if the above conditions are met then the disclosure process will include a check against the POVA list.
In some circumstances, in order to meet the regulations covering minimum staffing levels, an employee may need to start before the results of a check are known
Cost v compliance 7 million estimate of cost to regulate police service
Every Child Matters puts an obligation on all organisations whose work can contribute to public protection work, including social services, a duty to co-operate and share information and support the creation of a national service framework for children. ISA are currently liaising with the Department for Children, Schools and Families to seek reconciliation between the requirements that they have under the Safeguarding Vulnerable Groups Act 2006 and the obligations within Every Child Matters. The result of that liaison has huge implications for the Service.
ISA – Meeting in London Soon
20. Raising The Standard Click one displays graphic
Click two displays lift texts from Sir Ronnie’s report
Raising the Standard is the HMIC thematic inspection on professional standards.
Particular emphasis on vulnerability to corruption and information leakage.
Vetting a key underpinning principle of the issues.
Click one displays graphic
Click two displays lift texts from Sir Ronnie’s report
Raising the Standard is the HMIC thematic inspection on professional standards.
Particular emphasis on vulnerability to corruption and information leakage.
Vetting a key underpinning principle of the issues.
21. Raising The Standard The major threats identified in respect of professional standards were information leakage, in particular using intelligence or information for personal gain or passing it on to associates; infiltration of the organisation, which is an increasing threat in the ever-widening ‘police family’
Click one displays graphic
Click two displays lift texts from Sir Ronnie’s report
Raising the Standard is the HMIC thematic inspection on professional standards.
Particular emphasis on vulnerability to corruption and information leakage.
Vetting a key underpinning principle of the issues.
Click one displays graphic
Click two displays lift texts from Sir Ronnie’s report
Raising the Standard is the HMIC thematic inspection on professional standards.
Particular emphasis on vulnerability to corruption and information leakage.
Vetting a key underpinning principle of the issues.
22. Raising The Standard
In view of the threats, it is vital that all forces review their operational security arrangements, to ensure integrity and confidentiality of sensitive information. It is also important that a similarly thorough review is undertaken of the arrangements for staff vetting and identification of potential staff vulnerabilities.
These activities represent key measures in preventing and identifying corruption or vulnerability Click one displays graphic
Click two displays lift texts from Sir Ronnie’s report
Raising the Standard is the HMIC thematic inspection on professional standards.
Particular emphasis on vulnerability to corruption and information leakage.
Vetting a key underpinning principle of the issues.
Click one displays graphic
Click two displays lift texts from Sir Ronnie’s report
Raising the Standard is the HMIC thematic inspection on professional standards.
Particular emphasis on vulnerability to corruption and information leakage.
Vetting a key underpinning principle of the issues.
23. Raising The Standard Recommendations and Suggestions This HMIC Review required the creation of vetting units within forces and called for ACPO PSC to review vetting databases. The work of these units will be interlinked with the Vetting Transformation Programme
Recommendation 5
Ensure that FVO’s are being consulted during the establishment of local and National threat assessments for their own respective forces
Recommendation 11
Chief officers should carry out an analysis of current vetting structures within their force and, where gaps exist, move towards being fully compliant with ACPO’s vetting policy no later than April 2007.
Suggestion E
In view of the forthcoming force restructuring, before any further police funds are spent purchasing vetting databases that may prove to be incompatible, the ACPO PSC should carry out a review of vetting databases. Any review should take into account the feasibility of a national product.
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24. The Future Fingerprints & DNA
Vetting Transformation –Third shared service provider for police vetting
Consultation and ratification of National Vetting Policy
National Vetting Officer
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Fingerprints & DNA
Requirement that fingerprints & DNA are taken of all Police Officers and Police Staff prior to attestation/employment. Subject to speculative search prior to placement on elimination database.
Implications of Cost involved to the service, finance, resource and logistics
VT – Importance of the results of the MPS proposal to the way forward
Consultation of the new policy – including HR world re issues of checkable history, fingerprints & DNA of police officers.
Business Case for National Vetting Officer. A need for a single point of contact to bring together and drive forward the change process, The Role is crucial for the delivery of Vetting Transformation.
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Fingerprints & DNA
Requirement that fingerprints & DNA are taken of all Police Officers and Police Staff prior to attestation/employment. Subject to speculative search prior to placement on elimination database.
Implications of Cost involved to the service, finance, resource and logistics
VT – Importance of the results of the MPS proposal to the way forward
Consultation of the new policy – including HR world re issues of checkable history, fingerprints & DNA of police officers.
Business Case for National Vetting Officer. A need for a single point of contact to bring together and drive forward the change process, The Role is crucial for the delivery of Vetting Transformation.
25. The Future Development of Performance Framework for vetting community
Working with ACRO – International Issues
Collaboration with relevant ACPO portfolios to deliver unambiguous guidance that provides direction and a clarity of purpose. Ensuring an effective vetting process that is cost effective, resource efficient and proportionate to risk.
3 headlines appear on click
Performance Framework
An effective framework to be developed, this will be determined by the National VT structure
ACRO
Checkable history, the use of shared criminal records and intelligence from abroad
ACPO Cross portfolio dialogue
Vetting should not be an afterthought of other portfolios. Encouraging greater consultation to ensure that appropriate levels of vetting are resource efficient and proportionate to risk.
Doesn’t stand alone … link to National Picture
3 headlines appear on click
Performance Framework
An effective framework to be developed, this will be determined by the National VT structure
ACRO
Checkable history, the use of shared criminal records and intelligence from abroad
ACPO Cross portfolio dialogue
Vetting should not be an afterthought of other portfolios. Encouraging greater consultation to ensure that appropriate levels of vetting are resource efficient and proportionate to risk.
Doesn’t stand alone … link to National Picture
26. What Can You Do? Engage In Consultation Process
Work with and fully engage your vetting units
HMIC Professional Standards Template
Fully consider Vetting
27.
Refreshment Break
Scandinavian Ballroom Foyer
28. ‘Vetting Transformation’
Michael Shryane
Senior Policy Advisor
Cabinet Office, Security Policy Division
29. Overview Roles and responsibilities
Cabinet Office priorities
Key Challenges for the Police Community
Questions
30. Roles and responsibilities Cabinet Office:
Intelligence, Security, Resilience Group
Security Policy Division
Departments (PUSs and Ministers)
Departmental Security Officers (DSOs)
Wider national security vetting community
Home Office:
CONTEST Strategy – Office for Security and Counter Terrorism (OSCT)
Security Service:
Centre for the Protection of National Insurance (CPNI)
31. Cabinet Office Personnel Security Priorities 1 Recruitment Controls
Baseline Personnel Security Standards (BPSS)
Rebasing National Security Vetting
Proportionate
Targeting (added value)
Best use of limited national security resources
32. Cabinet Office Personnel Security Priorities 2 Ongoing Personnel Security Management
Checks are valuable but a snapshot in time
Maintaining currency
Vetting Transformation
Quicker
Smarter
Cheaper (more efficient)
33. Challenges for the Police Community Determining National Security Vetting requirements, particularly application of the Counter Terrorist Check (CTC)
Joint working in support of the Vetting Transformation Programme
Delivering an effective holistic protective security regime (including personnel security measures) that protects police assets and enable partnership working with other organisation and agencies
34. Contact Details Michael Shryane
Cabinet Office, Security Policy Division
26 Whitehall
London
SW1A 2WH
0207 276 5644
michael.shryane@cabinet-office.x.gsi.gov.uk
35.
Interactive Exercise
36. ‘Management Vetting and Aftercare’
Bob Varey
Chief Superintendent
South Yorkshire Police
37. Management Vetting Designed to provide a means of ensuring that persons serving in ‘designated posts’ have been assessed as to their reliability and integrity
Designated posts are those with access to sensitive police:
Information
Intelligence
Financial or Operational assets
38. Designated Posts These are the more sensitive posts within the Police Service, such as:
Special Branch Officers
Intelligence Officers
Financial Investigators
The posts ‘designated’ for higher clearances will be Force specific
39. What’s Involved? Usual systems checks i.e. PNC, non-conviction databases
Professional Standards ‘health check’
Thorough investigation of financial circumstances
Line Manager reports
Occupational Health reports
40. Why Do It? Requirement of the National Intelligence Model (NIM)
Will give an assessment of the individual’s suitability
Developed to ‘plug gaps’ in National Security Vetting
Requirement for regular access to SECRET Police material
Pre-requisite to SC Clearance
Requirement for designated posts
41. MV versus SC SC involves a check against the PNC for the subject
Subject, partner & parents are checked against National Security databases
A Credit Reference Check
Does this give reassurance to the Police Service to the required level?
42. MV versus SC SC does not take all police information into consideration
Only takes ‘relevant’ PNC convictions into account
‘Relevant’ convictions are those relating to honesty / integrity offences and other matters which may prejudice the National Security i.e. extremism
43. MV versus SC SC does not take non-conviction information into account i.e. custody records, intelligence etc.
44. MV, SC & GPMS SC will give regular, frequent & uncontrolled access to SECRET Government assets
SC does not take into consideration areas identified in Police Strategic Threat Assessments
MV will give regular, frequent & uncontrolled access to SECRET Police assets
Will enable access up to CONFIDENTIAL Government assets
45. Future of MV Revised Vetting Policy introduced new level of vetting Enhanced Management Vetting (EMV)
Will be prerequisite to DV clearance
Includes all stages of MV with additional checks and most stages of DV
Will enable regular, frequent & uncontrolled access to TOP SECRET Police assets
46. Why Have EMV? DV clearances are currently contracted out
The Police Service is not provided with any information resulting from DV enquiries
DV is a lengthy and costly process
EMV should lead to cost savings due to majority of enquiries being completed in house
47. Aftercare Any level of vetting clearance is based on a snap shot in time
It assesses an individual’s suitability for vetting clearance at that moment in time, based on all available information
Personal circumstances can, and will, be subject of significant change
Such changes can affect suitability to maintain vetting clearance
48. What’s Involved Periodic (recommended to be annual) assessment to ascertain if there are any changes
Self Declaration
Line Manager’s comment
Reassessment of clearance
49. Why Do It? Personal circumstances will change over time
Gives continued assurance as to suitability to maintain clearance
May uncover ancillary issues i.e. misconduct offences the Force is not aware of
50. Managing Failures Were retrospective vetting is conducted and the individual fails, need to consider:
Risk to individual
Risk to Force
Risk to public
Decision must be made on a case by case basis, taking all relevant factors into consideration
51. Summary of Morning Session
John Feavyour
Deputy Chief Constable
Cambridgeshire Constabulary
52.
Lunch
Phileas Fogg Restaurant
53. Session Five
‘Managing People – Local Solutions’
54. ‘Public Trust – Hard to Win, Easy to Lose’
Nick Hardwick
Chair
Independent Police Complaints Commission
57. What the public gets British Crime Survey (2006/07):
64% very dissatisfied with how their complaint was dealt with
58. How the public want low level complaints resolved….
59. … and what they want the IPCC to do
60. How the IPCC is responding Stock take:
“Fix the problem not just the blame”
61. How the IPCC is responding Corruption:
Intelligence Unit
RIPA Powers
IPCC Director Lead
IPCC Report Line Intelligence Unit
The IPCC has established an Intelligence Unit with all the requisite security features (SENTINEL SECRET network, Brent faxes/phone/video-conferencing facilities, secure safes ad so on).
The Intel Unit is establishing liaison points in all PSD Intel Units across E&W, to ensure the proper dissemination of intelligence that comes to the IPCC's attention through investigations.
RIPA powers
We have full RIPA powers for the prevention and detection of crime, as well as the more recently added power of Article 2(b) investigations following death (irrespective of if the investigation is of a criminal nature).
We also have skilled staff across the IPCC from varied backgrounds
IPCC Director Lead
The IPCC have a Director with lead responsibility for corruption and we are working together with ACCAG to widen the existing protocol between the IPCC and Anti-Corruption Units so that the IPCC can offer a greater degree of support and oversight for what can be resource-intensive and at times politically sensitive work. The protocol will allow our Senior Investigators (and Intel Unit where appropriate (need to check with PG if IU was included next week) to be included in covert referral processes, and will allow us to increase our oversight and independence in key cases. All of our Senior Investigators are highly experienced investigators (and are undertaking a covert corruption skills refresher courser later this year).
The IPCC is looking to expand its work in corruption and covert investigations. We will be looking to work closely with forces to assist them in tackling this area of work. We are also exploring the possibility of modes of understanding with other LEAs such as SOCA to provide assistance to future managed covert enquires and in time, we will be looking to be able to run independent covert investigations.
IPCC Report Line
We have set up a Report Line which is dedicated to police officers an police staff wishing to report concerns of any wrongdoing or malpractice within their place of work.
The reasons for the IPCC’s increasing involvement in this area of work are:
to provide assistance and support to forces;
To fulfil our remit to ensure independence in the system; and
To meet the very reasonable public expectation that serious corruption matters will have independent oversight – and in the more serious cases, direction and control. Intelligence Unit
The IPCC has established an Intelligence Unit with all the requisite security features (SENTINEL SECRET network, Brent faxes/phone/video-conferencing facilities, secure safes ad so on).
The Intel Unit is establishing liaison points in all PSD Intel Units across E&W, to ensure the proper dissemination of intelligence that comes to the IPCC's attention through investigations.
RIPA powers
We have full RIPA powers for the prevention and detection of crime, as well as the more recently added power of Article 2(b) investigations following death (irrespective of if the investigation is of a criminal nature).
We also have skilled staff across the IPCC from varied backgrounds
IPCC Director Lead
The IPCC have a Director with lead responsibility for corruption and we are working together with ACCAG to widen the existing protocol between the IPCC and Anti-Corruption Units so that the IPCC can offer a greater degree of support and oversight for what can be resource-intensive and at times politically sensitive work. The protocol will allow our Senior Investigators (and Intel Unit where appropriate (need to check with PG if IU was included next week) to be included in covert referral processes, and will allow us to increase our oversight and independence in key cases. All of our Senior Investigators are highly experienced investigators (and are undertaking a covert corruption skills refresher courser later this year).
The IPCC is looking to expand its work in corruption and covert investigations. We will be looking to work closely with forces to assist them in tackling this area of work. We are also exploring the possibility of modes of understanding with other LEAs such as SOCA to provide assistance to future managed covert enquires and in time, we will be looking to be able to run independent covert investigations.
IPCC Report Line
We have set up a Report Line which is dedicated to police officers an police staff wishing to report concerns of any wrongdoing or malpractice within their place of work.
The reasons for the IPCC’s increasing involvement in this area of work are:
to provide assistance and support to forces;
To fulfil our remit to ensure independence in the system; and
To meet the very reasonable public expectation that serious corruption matters will have independent oversight – and in the more serious cases, direction and control.
62. Challenges for the future 1. Fix the problem not just the blame
2. Keep it local
3. Make it simple
63. ‘Delivering Outrageous Sanctions’
John Feavyour
Deputy Chief Constable
Cambridgeshire Constabulary
64. Spectrum of Misconduct
65.
Jane Stichbury
HMIC
66. The Conference
The Frontline Supervision Thematic
The HMIC Inspection
Timings
Collaboration
67. Closing Address
Paul West
Chief Constable
West Mercia Constabulary
68. 3 Key Challenges How are you going to ensure an understanding of the threat to your Force from corruption and resource the required capability and capacity to tackle it?
Does your Force have an effective vetting strategy incorporating pre-employment, in-service and “aftercare” arrangements?
Is your Force ready to implement the new misconduct arrangements and what ideas can you contribute to the IPCC stock take of the complaints system?
69.
ACPO Professional Standards Conference 2008