Vetting - Policy and Procedure

(06.01)

Author: / James Ferguson
Department: / Professional Standards Unit
Published:
Last Updated: / 01/12/06

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1

NOT PROTECTIVELY MARKED

POLICY

1.INTRODUCTION

1.1Statement of Intent

1.1.1Central Scotland Police has adopted the following policy to protect the safety, Integrity of the Force and minimise threats against it and members of the public. This policy will affect all employees, potential employee and members of the public working or visiting the force area. The vetting criteria for the recruitment of PoliceStaff are the same as that for Police Officers.

1.1.2The general purpose of the policy is to treat all affected persons in a fair, confidential and sympathetic manner throughout the entire procedure in accordance with exiting legislation relative to Diversity issues and European Convention on Human Rights. It requires applicants to and employees of Central Scotland Police to respond with integrity in the information that they divulge during the vetting process.

1.1.3The policy affects all persons who seek employment with the Force and also members of staff applying for promotion, specialist/designated posts or transfers to or from other Forces. (i.e. Police Officers, Police Staff,). Similar checks will also be conducted on Non-Police Personnel e.g. workmen who have unsupervised access to our premises and external IT contractors who have access to our Force IT systems, other agencies, contractors, volunteers and partnerships working within the Force Also affected will be members of the public with whom applicants associate when making application/being nominated for “designated posts” within the force.

1.1.4Persons who are admitted to Force premises, but who remain under constant supervision and are not permitted access to Force IT systems or protectively marked material need not be vetted. In these circumstances, existing procedures for the reception of visitors should apply

1.1.5Beneficiaries of the policy are all employees of Central Scotland Police and all members of the public who work, live or visit the force area irrespective of gender, sexual orientation, race, age, disability or religion.

1.1.6Responsibility for the policy lies with the Superintendent, Professional Standards Department, however, all staff should be aware of it's contents.

1.1.7The policy links to the force's existing Professional Standards strategy and to the longer-term strategic business plan in terms of improving the way the force works.

1.1.8The policy will be delivered in recognition of partnership organisations where appropriate

1.2Diversity

1.2.1Central Scotland Police is committed to providing a service that is fair, accessible and meets the needs of all individuals, regardless of race, age, gender, religion, disability or sexual orientation. This commitment is supported by standards set by:

  • Race Relations (Amendment) Act 2000
  • Disability Discrimination Act 1995; and
  • ACPOS Diversity Strategy

1.2.2With specific reference to the Race Relations (Amendment) Act 2000, this policy has been assessed as being of LOW relevance to race equality.

1.3Distribution/Publication

1.3.1Information contained within this document may be the subject of copyright. Further copying or reproduction of said material should be accurate and should identify, where known, the copyright holder of the information and acknowledge it's copyright status.

1.3.2This document is releasable in its current form in accordance with the Freedom of Information (Scotland) Act 2002.

PROCEDURE

2.VETTING PROCEDURES

2.1 Force Vetting

The purpose of Force Vetting is to protect all assets associated with the Force including physical, financial and intelligence. Force Vetting includes:

  • Recruitment Vetting
  • Specialist Post Vetting
  • Central Service Secondment Vetting
  • Force Promotion Vetting
  • Management Vetting
  • Non-Police Personnel Vetting.

2.1.2Vetting Checks will be conducted on all staff including:

  • Police Officers
  • Police Staff (including temporary and agency staff)
  • Community Wardens
  • Neighbourhood Wardens
  • Members of the Special Constabulary
  • Student Placements
  • Volunteers
  • Non Police Personnel who requires unsupervised access to police premises (i.e. electricians, joiners and other general contractors)

2.1.3.There are two types of vetting procedures in operation within the Force. These are Force vetting and National Security Vetting.

2.2Police Basic Check

2.2.1The Police Basic Check is the first step in carrying out Force Vetting and requires applicants to prove their identity, and to disclose Police warnings, cautions, convictions and 'spent convictions', under the provisions of the Rehabilitation of Offenders Act 1974, and Rehabilitation of Offenders Act (Exceptions) Order 1975, as amended.

2.2.2The Basic Check underpins the vetting processes which are carried out by the Force and comprises interrogation of the following database applications:

  • PNC
  • Criminal History System
  • Crimefile
  • Scottish Intelligence Database
  • Special Branch.
  1. These five database checks will always be carried out on the applicant and their family and third parties.

2.3Recruitment Vetting

2.3.1.Recruitment Vetting is carried out on:

  • Police Officers
  • Police Staff (including temporary and agency staff)
  • Community Wardens
  • Neighbourhood Wardens
  • Members of the Special Constabulary
  • Student placements.
  1. Appendix 'A' - Recruitment Vetting Guidelines lists a number of factors, which require to be considered when assessing suitability of an applicant.

2.4Criminal Associations/Third Party Vetting

2.4.1The requirement to declare previous convictions and/or cautions does not extend to applicants' families or other persons detailed on the application form. Notwithstanding this, checks will be carried out and an assessment made to determine if any issues exist which could place the Force at risk or potentially cause embarrassment or harm it's integrity and thus preclude the appointment of the applicant to Central Scotland Police.

2.5Residency

2.5.1.Applicants must have been resident in the UK for a minimum of three years prior to application. This enables meaningful checks to be carried out for their period of residency.

2.5.2The 'three year residency rule' relates not only to Foreign Nationals, but also to UK Nationals who have lived abroad for longer than a twelve-month period within the preceding three years. However, if the applicant is able to prove that they have been of good character whilst resident abroad, by producing a Police Certificate or similar document from the relevant authorities, discretion may be used. Each case will be examined individually.

2.6Transferees

2.6.1.Where an Officer serving with another Police Force indicates that they wish to transfer to Central Scotland Police, appropriate enquiries will be conducted with their parent Force. Checks will include:

  • Service history
  • Appraisal history
  • Sickness record
  • Complaints record
  • Misconduct record
  • Professional Standards information.
  • In the event that an Officer is subject of an ongoing complaint or ProfessionalStandards investigation, transfers between Forces may be deferred until enquiries are complete.

2.6.3Similarly, where an Officer from Central Scotland Police applies to transfer to another Force, reciprocal arrangements are in place.

2.7Rejoiners

2.7.1A rejoiner is any person who has previously been a member of a Police Force.

2.7.2Individuals should not be permitted to rejoin without consultation with the Force Vetting Officer, irrespective of the length of time absent from a Police Force. Individuals have no rights in respect of rejoining.

2.8Career Breaks

2.8.1Both Police Officers and Police Staff are able to take Career Breaks without having to resign from the Force. They will continue to be regarded as employed by Central Scotland Police and will therefore remain subject to Force Conditions of Service and Force Policies and Procedures.

2.8.2It is therefore important that any changes in personal circumstances, involvement in criminal proceedings or criminal convictions are reported to the Force. They will be required to sign a Declaration on their return, to indicate that they have not breached any of the conditions of their Career Break Agreement.

2.8.3A Police 'Basic Check' will be conducted prior to the individual's return to work.

2.8.4If the individual was resident out with the UK during their Career Break, consideration will be given as to whether enquiries with the appropriate authorities be conducted, to ensure they have not had any adverse contact with the Police there.

2.9Members of HM Forces

2.9.1Applications from Service Personnel can only be accepted if they have 12 months or less to serve before their discharge. Confirmation of their discharge date should be obtained.

2.9.2HM Forces assess conduct on a range of:

  • Exemplary
  • Very Good
  • Satisfactory (Army and Navy), Good (RAF)
  • Fair
  • Unsatisfactory.
  • Discharge Certificates for Service Personnel will normally be sufficient proof of good conduct if they are deemed as performing 'Satisfactory' or better.

2.9.4In addition, enquiries will be made with the Army, Navy or RAF to establish if the applicant had ever been subject of disciplinary action or investigated by the Service Police for any crime or offence.

2.9.5The Service Police have three levels of disposal for crimes and offences committed whilst serving with HM Forces:

  • Reported (to Court Martial Hearing or reported by Civil Police)
  • Admonishment (a finding of guilt but with limited or no penalties)
  • Of interest (linked with the crime or offence but either suspected with a lack of evidence or complaint withdrawn).

2.10Specialist Post, Central Service and Force Promotion Vetting

2.10.1Vetting checks will be carried out on all members of staff who:

  • Apply for Specialist Posts or Central Service Posts
  • Apply for the promotion process
  • Are nominated for ‘Temporary’ promoted positions.
  • A current Police Basic Check will be carried out on the applicant only, along with a check of the Professional Standards databases. These checks will ensure that the applicant is suitable to occupy that post and that there have been no adverse changes to their personal and professional circumstances.

2.11Management Vetting (MV)

2.11.1It is recognised that some posts (Designated Posts) offer individuals greater access to Force assets and more sensitive intelligence and as such individuals occupying these posts will be subject to more robust checks to ensure that the risk to the Force is minimised. MV has been developed to suit these needs.

2.12Designated Posts

2.12.1A 'Designated Post' is one where the opportunity for the compromise of sensitive Police assets is highest, and where there could be substantial risk of serious damage to the Force.

2.12.2Serious damage can be defined as:

  • Frustrating the prevention or detection of serious, organised or major crime
  • Frustrating the apprehension or prosecution of such offences
  • Causing significant financial loss to the Force
  • The inappropriate or unlawful awards of contracts, and
  • Otherwise adversely effecting the reputation or security of the Force.
  • In addition, post holders who have access to ‘Secret’ and Top Secret’ Police assets will also be subject to MV.

2.12.3The vetting procedures for MV will include the following checks:

  • Proof of identity and residence
  • Completion of a Personal Information Questionnaire
  • Completion of a Financial Questionnaire
  • PNC
  • CHS
  • SID
  • CrimeFile
  • Special Branch
  • Professional Standards databases
  • Personal File
  • Supervisors' references
  • Subject interview by Force Vetting Officer (onlyif necessaryand to clear up ambiguities and/or in the interests of the applicant).

2.13Factors which may lead to refusal, withdrawal or limitations of MV Clearance

2.13.1The existence of one of more of the following factors may lead to refusal, withdrawal or limitations of MV clearance:

  • Past infringement of security or Vetting Policy or procedures
  • Significant or repeated breaches of discipline
  • Providing false or deliberately misleading information, or omitting significant information from the vetting questionnaires
  • Unauthorised association with persons with previous convictions or reasonably suspected of being involved in crime
  • Criminal convictions
  • Substantial financial difficulties or debts
  • Compulsive drinking or gambling
  • Use of controlled, or abuse of prescribed drugs
  • Other conduct likely to lead to blackmail or compromise.

2.14Assessing the criteria for trustworthiness

2.14.1In making an assessment as to whether or not to grant vetting clearance, the following matters will be taken into consideration:

  • The level of access to intelligence assets (the higher the level of access, the more stringently the criteria will be applied)
  • The provenance of any adverse information obtained during the vetting process (for example it may be necessary to give greater weight to some factors than to others)
  • A careful assessment of the significance of any past conduct or circumstances will be necessary
  • Distinctions will be drawn between isolated or minor blemishes on an individual's record and information pointing to habitual or significant vulnerabilities.

2.14.2All circumstances will be assessed to reach an adequate level of assurance about an individual. Evidence gathered from other Forces who have had the MV process in place for several years indicates that very few persons are refused clearance, however, a number of persons have regular aftercare where a potential vulnerability has been identified. Where a risk has been identified or raised with the Force Vetting Officer, it can more often than not be managed satisfactorily.

2.15At present the role of Authorised Firearms Officer has been approved by the Force Policy Group as a Designated Post and will now fall to be Management Vetted.

2.16The Force has still to authorise a full list of designated postsand when confirmed these posts will be listed in Appendix ‘B’

2.17 A Management Vetting Pack and application form can be accessed from Word Templates.

3.Non Police Personnel Vetting (NPPV)

3.1NPPV relates to the vetting of persons other than members of the Force who require access to Central Scotland Police premises or to Central Scotland Police IT systems either on Police premises or by remote access. This includes a variety of contractors, volunteers, consultants, auditors and researchers.

3.2There are different levels of NPPV; dependent upon the access each individual will have to Force premises and to Force IT systems.

3.3Interpreters

3.3.1In terms of security risk, interpreters are in the unique position of having access to sensitive information and vulnerable individuals without effective verification of the accuracy of the interpretation at the time of interview. It is therefore important that they are included within the NPPV process. The list of approved interpreters is maintained by Alpha Translating Services and can be accessed via the Force Control Room.

4. Financial Checks

4.1Schedule 1 of the Police (Scotland) Regulations 2004, stipulates that, "A member of a Police Force shall not wilfully refuse or neglect to discharge any lawful debt."

4.2Basic financial questions are included in the Standard Police Application Form and the Personal Security Questionnaire completed by Police Staff. These questions seek to establish that the applicant has not been declared bankrupt or been subject of any Court Action or a Court Judgement in respect of debt.

4.3An applicant will not normally be considered for appointment if they have existing Civil Court Judgements outstanding against them, or have previously been declared bankrupt or subject of a Trust Deed and less than three years have elapsed since the bankruptcy or Trust Deed debts have been discharged. These criteria also apply to individuals who have been company directors when such debts existed in the name of the company.

4.4The Force will have the ability to carry out a Credit Reference Check on an applicant to ensure that they have disclosed all relevant information.

4.5The purpose of a financial check is to assess whether applicants are, or have been in financial difficulties, or show signs of financial irresponsibility to the extent they could become vulnerable to financial inducement. Applicants should normally be free from undischarged debt or liability and able to manage existing loans.

4.6With Management Vetting, the applicant detailing income and expenditure completes a full Financial Questionnaire. To assist the Force Vetting Unit assess financial vulnerability, a financial score sheet and assessment sheet may be used. Additional Credit Reference Checks may also be conducted. Where concerns are raised regarding an applicant's ability to manage existing debts they may be interviewed to resolve any ambiguities.

4.7Debt arising whilst in service will be managed sympathetically and may influence their deployment within the Force.

4.8All information received, either on Financial Questionnaires or through applicant interviews, is personal, highly confidential and will be treated as such. All information will be kept within the individual's personal vetting file and will be retained within secure cabinets for vetting purposes only.

5.National Security Vetting

5.1National Security Vetting is administered by the Scottish Executive Departmental Security and applies to individuals who occupy designated posts which, in the course of their work, give access to, knowledge or custody of sensitive Government information or other valuable Government assets which carry a

  • 'SECRET' or
  • 'TOP SECRET' protective marking.

5.2Categories of National Security Vetting include:

  • Counter Terrorist Check (CTC)
  • Security Check (SC)
  • Developed Vetting (DV).

5.3Counter Terrorist Check (CTC)

5.3.1Counter Terrorist Checks apply to all Police, Police Staff and Non-Police

Personnel who are authorised to take up posts which involve proximity to

public figures at particular risk of attack by a terrorist organisation, or which

give access to information or material assessed to be of value to terrorists.

5.4Security Check (SC)

5.4.1A Security Check (SC) is carried out on all individuals who require:

  • Long term, frequent and uncontrolled access to 'SECRET' Government assets, and
  • Occasional access to 'TOP SECRET' Government assets, or
  • Who are in a position directly or indirectly to bring about the same degree of damage as such individuals.

5.4.2The SC process includes a Government credit reference check. The Force relies on the SC process to provide additional assurance as to the reliability of those occupying sensitive roles, e.g. Special Branch and Counter Terrorist Security Advisor. Successful clearance to MV level is necessary for progression to SC vetting. A list of SC vetted posts is contained in Appendix 'B' (still to be agreed)