020/2014: Retrospective vetting of all NYP staff and officers – 05 December 2014
Retrospective vetting of all NYP staff and officers whilst also considering current resourcing of the vetting unit and charging for contractor vetting.
Executive Summary and recommendation:
This decision notice has been rendered necessary as a result of two main developments:-
a) October 2015 the new network for the Police service (PSN(P)) will be introduced, there will be a requirement for forces to ensure that their members are vetting cleared to a certain standard and analysis has revealed that 468 individuals will need to achieve vetting clearance by October 2015 in order for NYP to be compliant in this regard.
b) By the end of 2014 it is anticipated that the long awaited vetting Code of Practice (administered by the College of policing) will be introduced. This Code of Practice will require all forces to ensure that a retrospective vetting regime is operated so that all officers and police staff achieve the current standard of vetting clearance applicable to their respective roles.
In addition to these two main developments the NYP vetting unit has effected process reengineering to allow the previous service level agreement for recruitment which required vetting processes to be completed within 37.5 days to be reduced to 21 days, thus ensuring that recruitment of officers and police staff is as speedy and as smooth as possible.
During the recent National Vetting Conference (14th October 2014), the ACPO Lead for vetting, ACC Jelley emphasised the importance and greater emphasis that was being placed on vetting. It is also relevant to note that the Vetting Code of Practice is the second code which will be published by the College of Policing (with the Code of Ethics being the first). This decision notice has been written in order to provide the Police and Crime Commissioner with information to allow her to consider the requirements of the vetting unit, in light of new developments nationally.
The purpose of this decision notice is in three parts:
1) To gain agreement for the instigation of the retrospective vetting programme. And to ensure that the required level of resources is allocated to undertake the work in a timely fashion
2) To begin charging for contractor vetting, thus generating an income for North Yorkshire Police.
3) To continue to employ two vetting admin clerks in order to amend the vetting unit SLA from 37.5 days to 21 days (halving the SLA from 6 weeks to 3 weeks)
Police and Crime Commissioner decision: Approved
Signature: 
Date: 05 December 2014
Title: Police and Crime Commissioner
Part 1 – Unrestricted facts and advice to the PCC
1. Introduction and background
The North Yorkshire Police Vetting Unit was established in 2006. Prior to this time, no officially recognised vetting was undertaken on individuals joining North Yorkshire Police, in line with other forces – only basic checks were undertaken at the time an individual joined. North Yorkshire Police are compliant with ACPO National Vetting Policy and undertake vetting to the prescribed level. In order to ensure full compliance and to minimise any risks to North Yorkshire Police and the public, the Retrospective Vetting Programme aims to ensure that 100% of individuals who work for North Yorkshire Police have nationally recognised Police Vetting. Currently only 63% of individuals who work for North Yorkshire Police have sufficient vetting (as mandated by ACPO National Vetting Policy).
| Total members of NYP (not including volunteers) | Total not vetted to current standards | % not vetted to current standards |
| 2894 | 1062 | 37% |
i) Retrospective Vetting and the ACPO National Vetting Code of Practice
On the 24th September 2014 a full staff list was obtained from NSPIS and compared with the vetting system Corevet. This data shows that there are currently 1,062 members of North Yorkshire Police who have no ACPO recognised vetting status. The code of practice is currently being consulted on, however, when it is published, the compliance of police forces will be subject to HMIC inspections. If North Yorkshire Police do not undertake the retrospective vetting of their staff, NYP will fail an HMIC inspection. Although there is no required-by date, a plan will need to be in place in order to achieve 100% compliance and this may need increased resource within the vetting unit.
ii) Comparative position with other forces in the North East Region:
Of the seven forces within the ACPO number 2 region only one force claims to have vetted more than 60% of it’s members.
iii) – Retrospective Vetting and the PSNP Project
The Public Service Network (Police) will be live in October 2015 .Clarification of the vetting requirement of the PSN(P) has been obtained and on the 22/09/14 there was an update via POLKA which stated the following:
“Vetting requirement within PSN customer IA conditions: Policing has robust vetting policies in place. Although some personnel who were in post before the ACPO vetting policy was introduced may not have undergone a similarly robust vetting process (particularly in respect of identity checks). Some forces have advised NPRIMT that, although there is a low risk, they are uncomfortable in confirming full compliance with the vetting requirement within the PER.1 PSN customer IA conditions. Retrospective vetting of personnel would be expensive and resource intensive so NPIRMT raised this with Cabinet Office PSN (on behalf of policing). The result is that NPIRMT has successfully negotiated an agreement that forces implement policies in line with the ACPO vetting policy and will not need to undertake any retrospective vetting of personnel to comply with this requirement. Please contact the NPIRMT if you have any queries” (PSNP Programme Update September 2014, Page 4)
The above would appear to state that as long as the force is currently compliant with ACPO National Vetting Policy that retrospective vetting is not required. New data has been obtained from NSPIS from the 24/09/14. This states that of the 1,062 individuals who have no vetting clearance (this figure does not include volunteers), 594 joined NYP before the vetting policy was published and have not moved within the organisation, retrospective vetting will not need to be undertaken on them. This leaves 468 individuals who may require vetting before October 2015.
There are currently 1062 staff who are not vetted to current standards (not including volunteers) within North Yorkshire Police (data correct as of the 24/09/14)
| Total Staff | 2894 | |
| Total Staff not vetted to current standards | 1062 | 37% |
However, 594 of these individuals joined NYP pre 2004 and have not moved roles since – this indicates that they will not need vetting for the PSN(P)
| Staff who joined pre 2004 and have not moved roles | 594 | 56% |
| Staff who joined pre 2004 and have moved roles since that date, this also includes staff who joined since 2004 | 468 | 44% |
| 1062 |
v) Charging contractors for vetting
The recovery of base line costs for police services must be considered to ease the impact on the reduced budget of North Yorkshire Police, and charging for the vetting of third parties is an area of potential cost recovery that can create cashable efficiency savings for the force, whilst in part contributing to the maintenance of a professional vetting service.
A total of 508 individual and chargeable NPPV cases were received in the 9 months to September 2014. – £26,255 in revenue would have been generated (267 NPPV1 applications at £35 each, 158 NPPV2 applications at £70 each and 39 NPPV3 applications at £150 each)
The Force is currently absorbing the cost of vetting, observing the traditional view that this is an internal process aimed at protecting the security of North Yorkshire Police. Some Forces are now adjusting this stance and take the view that it is justifiable to create income generation for their forces to offset the costs associated to the non police vetting process.
It has been identified that certain contract service providers are benefiting directly by police vetting of their own employees. Research with a number of forces identified a trend with contractors to request vetting for more staff than they need to support their contract, which they are using to improve their own resilience and even potentially using the police service as their own free employee screening service. In addition, the presence of police accredited vetting and existing police contracts help companies promote services to other businesses in pursuit of future contractual opportunities.
Initiating a charging system may make service providers re-think their resource strategy in support of our contracts if they have to pay for security clearances for their staff. In addition, it may have an impact on numbers that the Vetting Unit are expected to check with the added effect of reducing the overall scale of NPPV
There are at least eight Forces which charge for NPPV vetting.
Additionally, available information indicates that Humberside Police have received a large number of requests to accept North Yorkshire Police vetting from their contractors. They have queried whether North Yorkshire Police is to charge in the future and to confirm that each force accepts the vetting carried out by the other.
N.B There is no intention to charge individuals who wish to volunteer for or be employed by North Yorkshire Police. There is also no intention to charge partnership schemes such as the Watch schemes, mountain rescue services etc.
v) Amendment of the vetting unit SLA to 21 days for recruitment.
North Yorkshire Police Vetting Unit was subject to a Service Review in 2012 where a number of issues were identified. Concerns were raised particular to the perceived length of time of the vetting process. In order to alleviate these concerns and ensure that vetting could be completed in a timely manner, which was agreeable to NYP, a prototype process was developed. This process reengineering would amend SLA’s from 37.5 days to 28 days and was dependent upon the employment of an administrative support officer. Since December 2013 the vetting unit has employed 2 Vetting Admin Clerks who are agency staff, this has actually led to the average SLA for vetting applications reducing from 37.5 days to 21 days. In order to amend the vetting SLA, the continued employment of the 2 vetting admin clerks and amending their roles to permanent instead of agency is requested. This will effectively half the vetting unit SLA from 6 weeks to 3 weeks for all internal recruitment. The SLA for contractors will remain the same (at 37.5 days).
vi) Vetting Health Checks on internal Movers
This necessary activity can be undertaken if the additional resources requested in this decision notice are agreed
vii) The College of Policing Vetting Code of Practice and Annual Aftercare on high level clearances
This necessary activity can be undertaken if the additional resources requested in this decision notice are agreed
2. Matters for consideration
2.1) Retrospective Vetting
In order to complete the requirements of the Retrospective Vetting Programme it will be necessary to employ additional resources within the unit. In the period 01/10/2012 – 31/08/14 (22 months) the two vetting administrators have completed 985 internal vetting cases. This equates to 45 per month (or 22.5 per administrator).
Based on the above calculation:
Two additional administrators could complete 1080 vetting cases in 24 months (2 years)
2.2) Amendment of the roles of the vetting admin clerks, from agency to fixed term contract.
i) Amendment of Vetting Unit SLA – For Recruitment
In order to amend the Vetting Unit SLA’s for recruitment from 37.5 days to 21 days, it is requested that the two agency roles which are currently authorised up to the end of March 2015 are amended to permanent or fixed term contracts.
ii) Vetting Code of Practice
This necessary activity can be undertaken if the additional resources requested in this decision notice are agreed
iii) Vetting Renewals for existing staff
This necessary activity can be undertaken if the additional resources requested in this decision notice are agreed
2.2 Charging Contractors for vetting
Costing exercises have been undertaken in other forces which do not deliver full cost recovery and only pass a proportion of the expense to the third party. This sends a key message to customers that the Force is not operating the scheme for profit and that customers are asked to make a reasonable contribution for service.
The cost recovery is based on the impact of work involved in the data collection analysis and assessment and should be aimed at providing a consistent and reasonable return of the actual cost involved. The focus should be on the actual time staff spend undertaking the work process rather than based upon the time taken to produce a security clearance which may differ significantly dependant on individual circumstance
It has been suggested that this will result in suppliers inflating their tender costs as a result of the implementation of charges, particularly if the charges were significant. Consultation with Norfolk Constabulary in relation to this indicates that there is no evidence of any impact on tender costs in the full two year period since the charges were implemented for NPPV. Indeed in the current climate there is no reason to suppose competition to win contracts will change how companies tender, and more competition may even result.
Of the 585 NPPV applications processed in January – September 2014 (not including volunteers), 508 were chargeable and would have generated a revenue of £26,255 for North Yorkshire Police.
3. Other options considered, if any
There are three other options, regarding resourcing the vetting unit, to be considered:
1) To maintain the status quo, without the continuing employment of the two temporary vetting admin clerks (contracted up to the end of March 2015). The risk to North Yorkshire Police with this option is the inability to comply with the Code of Practice and the consequential potential failing of an HMIC inspection. North Yorkshire Police will not be able to realise the income generation from NPPV vetting and the retrospective vetting programme will not be able to be undertaken (thus causing a potential problem regarding North Yorkshire Police’s connection to the PSN(P).
2) Not to employ any additional Vetting Administrators but to maintain the employment of two temporary vetting admin clerks. This option will allow for the amendment of the vetting unit SLA to 21 days, however, the vetting unit will not be able to complete Retrospective Vetting in order to comply with the Vetting CoP and the requirements of the PSN(P).
3 (i) To employ two additional Vetting Administrators for two years which would enable the completion of retrospective vetting for all members of North Yorkshire Police.
(ii)To maintain the employment of the temporary vetting admin clerks to enable the vetting unit to halve the vetting unit SLA, to complete aftercare (to ensure compliance with the Vetting CoP) and to manage the increased workload involved in vetting renewals
4) There are two options to be considered regarding charging for contractor vetting:
i) To approve a charging model for the initial and renewal vetting of Non-Police Personnel
ii) To continue to provide a free vetting service for all Non Police Personnel Vetting processes
Preferred Options – Options 3 and Option 4 (i).
4. Contribution to Police and Crime Plan outcomes
The Retrospective Vetting Programme would facilitate the achievement of two of the four policing priorities namely “protect vulnerable people” and “focus on prevention and early intervention”.
The increased resourcing of the vetting unit would ultimately lead to a reduction of recruitment timescales, thus contributing to the achievement. of all three of the corporate priorities namely “transforming the organisation”, “people first” and “partnerships and commissioning”.
The vetting unit would be in a position to comply with the Vetting CoP (implementation date December 2014) which will be inspected against by the HMIC
1. Consultations carried out
UNISON have been consulted and have indicated that they are content at this stage to support the concept of retrospective vetting on the understanding that any procedure relating to this and detailing what happens if an individual fails vetting is agreed with them.
The Police Federation have been consulted and are content to support the retrospective vetting of all police officers.
2. Financial Implications/Value for money
Chief Constables Chief Finance Officer Comments:
Based on the information provided in the Decision Notice, I have calculated the following financial implications:
| £’000 | ||
| Annual income | 52.0 | |
| Annual staffing costs: | ||
| 2.00 fte Vetting Admin clerks made permanent | 41.6 | |
| 2.00 fte Vetting Administrators (full time) | 51.2 | |
| 92.8 | ||
|
Net costs years 1 and 2 |
(40.8) |
|
| Net income year 3 onwards | 10.4 | |
These net costs/net income will impact on the bottom line.
3. Legal Implications
Having read this report and having considered such information as has been provided at the time of being asked to express this view, the Acting Force Solicitor and Head of Legal Services is satisfied that this report does not ask the PCC for North Yorkshire to make a decision which would (or would be likely to) give rise to a contravention of the law.
Consideration of current employment contracts and procedures with regard to retrospective vetting should be agreed with staff associations as noted by Unison in their consultation above.
4. Equality Implications
As the proposal will look at vetting individuals who joined NYP pre 2004 as well as those individuals who do not hold the right level of vetting, it may be that the ages of those to be vetted are slightly higher than the average age in force. However, this is as a result of the date at which formal vetting was introduced and those who joined post 2006 have been vetted to the correct level. This activity therefore will bring parity for all parties as far as vetting status is concerned.
5. Human Resources Implications
The 3 main elements for consideration within these proposals provide a sound solution to changing and increasing demands being placed on the organisation in terms of network security and enhanced guidance and Codes of Practice for vetting. They provide a cost recovery option for the increasing demands placed on the team and also enhance the recruitment vetting service level agreement which shortens recruitment timescales and improves applicant experience. With regard to the first element – retrospective vetting, it is understood that the required consultation has already taken place with UNISON. The second element – charging for contractor vetting, will provide a funding stream to support some of the costs incurred in this increasing area of business. The third element – embedding the Vetting Admin Clerks into the business on a fixed term basis, supports the process reengineering work that has already proven effective and provides the support to reduce the recruitment vetting SLA.
People considerations would include continued consultation and dialogue with UNISON with regard to retrospective vetting. Also the appropriate employment contract management through fixed term contracts that shown a direct link to this specific piece of work. It is also noted that whilst there may be a perception of a reducing level of recruitment being required in the future this is counteracted by the developing flexible resource pool that is being developed within the organisation.
Public Access to information
The Police and Crime Commissioner wishes to be as open and transparent as possible about the decisions he/she takes or are taken in his/her name. All decisions taken by the Commissioner will be subject to the Freedom of Information Act 2000 (FOIA).
As a general principle, the Commissioner expects to be able to publish all decisions taken and all matters taken into account and all advice received when reaching the decision. Part 1 of this Notice will detail all information which the Commissioner will disclose into the public domain. The decision and information in Part 1 will be made available on the NYPCC web site within 2 working days of approval.
Only where material is properly classified as restricted under the GPMS or if that material falls within the description at 2(2) of The Elected Local Policing Bodies (Specified Information) Order 2011 will the Commissioner not disclose decisions and/or information provided to enable that decision to be made. In these instances, Part 2 of the Form will be used to detail those matters considered to be restricted. Information in Part 2 will not be published.
Is there a Part 2 to this Notice – NO (please delete as appropriate)
If Yes, what is the reason for restriction –
Originating Officer Declaration
Author name: Rhiannon Wright
Collar number: 005331
| Name (Collar Number) | Date of completion (√) | |
| Head of Department
has reviewed the request and is satisfied that it is correct and consistent with the NYPCC’s plans and priorities. |
Steve Read
006574 |
03/11/14 |
| Legal Advice
Legal advice has been sought on this proposal and is considered not to expose the PCC to risk of legal challenge or such risk is outlined in Part 1 or Part 2 of this Notice. |
Jane Wintermeyer 3840 |
11/11/14 |
| Financial Advice
The CC CFO has been consulted on this proposal, for which budgetary provision already exists or is to be made in accordance with Part 1 or Part 2 of this Notice. |
Jane palmer 4364 | 20.11.2014
|
| Equalities Advice
Either there is considered to be minimal impact or the impact is outlined in Part1 or Part2 of this Notice. Author to complete as Equalities matters are mainstreamed within departments. |
Rhiannon Wright 005331 |
04/11/14
|
| HR Advice
HR advice has been sought in relation to any people related matters
|
004647 Rosie Holmes |
20.11.2014
|
| I confirm that all the above advice has been sought and received and I am satisfied that this is an appropriate request to be submitted for a decision
Signature |
- Published on