HMICS Assurance review of vetting policy and procedures within Police Scotland

03 October 2023


Police Scotland’s vetting unit comprises a committed and skilled team which works to a high standard and is determined to reduce risks to the organisation.

In a report published today, (Tuesday, 3rd October 2023) examples of good practice, training and a learning culture within the service’s vetting team are highlighted.

The report from HM Inspector of Constabulary in Scotland also identifies gaps in the vetting system, some examples of poor decision making and makes a number of recommendations on how risk can be better managed.

The HMICS Assurance review of vetting policy and procedures within Police Scotland is part of a wider thematic inspection of organisational culture within Police Scotland which HMICS is presently undertaking. Due to the importance of vetting and its current high profile, it was agreed this separate review should be expedited to consider the quality of vetting.

HM Chief Inspector of Constabulary in Scotland, Mr Craig Naylor, said: “Vetting is an integral part of the process to identify individuals who are unsuitable to work within policing. A thorough and effective vetting regime is vitally important to assess a person’s integrity and it reassures the public appropriate checks have been carried out on those who are placed in a position of trust.

“There is no doubt the public’s confidence in and the reputation of policing has been damaged by officers who have behaved inappropriately and broken the law. Significant steps have been undertaken following recent high profile cases in England to ensure that officers and staff have been checked and any risks identified, highlighted and managed appropriately.

“Losing intelligence to terrorists or serious organised criminals is a threat which Police Scotland rightly takes seriously but exposing a vulnerable person to an individual who wishes to harm them is, to me, abhorrent and steps need to be taken to provide assurance that the protection of the vulnerable is prioritised."

Mr Naylor’s first recommendation in his report urges the Scottish Government to legislate to ensure there is a minimum level of vetting for all officers and staff within Police Scotland and to enable the Chief Constable to dismiss anyone who cannot maintain suitable vetting.

“Vetting should not be viewed in isolation or as a standalone process and must be part of an overall system to identify and manage potential risks posed by officers and staff. By its very nature, vetting is a snapshot in time and no regime, however rigorous, can ever guarantee a person will not go on to become a risk. Where these risks cannot be managed, it should be possible to remove that individual from their role or, if necessary, from the service” added Mr Naylor.

Prior to the creation of Police Scotland the vetting was varied, inconsistent and not always recorded effectively. No check nor review of officers and staff employed by the legacy forces was carried out when the new organisation began and some have no vetting record.

Nor is it mandatory for vetting to be repeated beyond that which is required on recruitment to Police Scotland, something which HMICS considers to present a significant risk. It believes all personnel should be re-vetted at least every 10 years and the introduction of an annual integrity review, at which any change of personal circumstances could also be noted, would go some way to identify risks which require to be addressed.

“Currently there is no clear process for anyone working within Police Scotland to advise the service of a significant change of personal circumstances, nor of a conviction. There may be situations where they are unable to maintain their vetting clearance and, as a consequence, it should be withdrawn or suspended.

“Our view is vetting clearance should be reviewed following misconduct proceedings to ensure any new risk is considered” said Mr Naylor.

Certain critical posts within Police Scotland which entail a higher level of access to intelligence, information or working with vulnerable people require an enhanced form of vetting, known as management vetting. Management vetting is renewed every seven years but HMICS found the list of designated posts had not been revisited since 2013 and the criteria for a post being classed as one is not always met.

When vetting is refused there is an appeal process and during its inspection, HMICS identified a disproportionate number of cases where the appropriate refusal of vetting has been overturned and clearance granted. Whilst these were historical cases, HMICS brought these cases to the attention of the Force Vetting Manager and the Anti-Corruption Unit Detective Superintendent so they could assess the risk and whether the clearance was still appropriate.

Police Scotland has indicated it will randomly review recruitment vetting of three to five percent of its personnel. While HMICS considers there may be some merit in this, it wants priority to be given to assurance that all officers and staff have at least recruitment vetting, a plan is in place to renew it every 10 years and annual integrity reviews are held.