Angiolini Inquiry update

At the earliest opportunity, and by September 2024 at the latest, police forces should ensure that they have a specialist policy on investigating all sexual offences, including so-called ‘non-contact’ offences, such as indecent exposure.

Sussex Police has appointed a lead for Non-Contact Sexual Offences who oversees guidance, best practice and is responsible for the force’s approach to investigating indecent exposure and professional implementation. As per the recommendation, we have updated our Serious Sexual Offences Policy to include ‘non-contact’ sexual offences. Whilst the guidance from the College of Policing advised to adopt Exposure and Voyeurism as ‘non-contact’ trigger offences, Sussex Police extended the adopted offences to also include Spiking, ‘Upskirting’ and Cyber Voyeurism. The policy links to our newly developed Non-Contact Sexual Offences Investigative Strategy.

By September 2024, the National Police Chiefs’ Council, in collaboration with all force vetting units, and building on the results of the recent data-washing exercise, should conduct a review of the circumstances of all allegations of indecent exposure and other sexual offences recorded on the Police National Database and the Police National Computer against serving officers. This is to identify, investigate and ultimately remove those officers found to have committed sexual offences from all police forces.

The force has reviewed all records of this nature that were located via the Police National Computer and the Police National Database and are satisfied that any traces have been reviewed accordingly. We extended this recommendation by completing keyword searches on our Vetting system to locate any matters that may not have been identified via the Historic Data Wash exercise. This extension to the review is ongoing.

With immediate effect, the College of Policing, in collaboration with force recruitment, should ensure that every new candidate applying to become a police officer in any police force undergoes an in-person interview and home visit. This should be designed to provide a holistic picture of the candidate and a better understanding of the candidate’s motivations for joining the police and their dedication to serving the public.

In particular, this should include the following:

1. An in-person interview with the candidate to ensure that face-to-face contact is made with the recruiting force before the vetting or onboarding of the candidate is progressed.
2. A visit to the residence of all new candidates. This should be used as another opportunity, in advance of vetting enquiries, to engage with the candidate, relevant family members or other occupants of the residence, wherever possible.
3. An integrity questionnaire, used as part of the in-person home visit, to explore fully the candidate’s personal attitudes and values, including increased scrutiny of the candidate’s motivations and suitability for joining the police.
4. Corresponding guidance and training for home visits must be developed to ensure that the visits will enable a better sense of the candidate’s character, rather than judge living arrangements or socio-economic status.

Sussex Police complete in-person interviews with all new recruits. Further guidance on home visits is awaited and, once available, requirements will be assessed to develop how this can be resourced and prepared. We are aware of a pilot currently underway in relation to this recommendation, which will help to inform practice once complete.

By June 2024, the College of Policing, in collaboration with force vetting units, should take further steps to prevent those unsuitable for policing from joining the policing profession. This should include further developing the Vetting Code of Practice, Authorised Professional Practice on Vetting, and other guidance on recruitment and vetting practices in order to prevent those who commit sexually motivated crimes against women and those otherwise unsuitable for policing from holding the office of constable. In particular, recruitment and vetting policy, processes and practices must be developed in the following areas:

1. Applicants should be required to undergo an assessment of their psychological suitability for the role (which is not just a questionnaire).
   
   Sussex Police are awaiting guidance from the College of Policing with regard to this aspect of the recommendation.
2. There should be more robust use of the Police National Database during vetting, including as a tool to reveal unreported adverse information about applicants to ensure that potential risks are not missed. In particular, the Database should be used when individuals attempt to move between forces.
   
   The Vetting unit in Sussex Police utilise the Police National Database for every stage of the vetting process; this includes, but is not limited to, new recruit applications, transferees, internal moves, renewals and other vetting applications such as personal circumstance updates.  
   
   
3. Any individual identified as having a conviction or caution for a sexual offence should be rejected during police vetting. This should be clearly outlined in the Vetting Code of Practice and reflected in the Authorised Professional Practice on Vetting, which should consider all contact and non-contact sexual offences.
   
   Sussex Police is compliant with this recommendation and reject all new applications which identify sexual offence convictions and cautions.
   
   
4. The Authorised Professional Practice on Vetting should be amended to make it clear that military and/or Ministry of Defence checks should be carried out on all applicants who have served as military reservists.
   
   Sussex Police conduct checks on all applicants disclosing military service including regular and reservist personnel.
   
   
5. There should be a fundamental review of the link between debt, mental health, vulnerability to corruption and suitability to be a police officer, to inform vetting decisions. Detailed consideration should be given to the amount of unsecured personal debt held by officers, and rules should be amended to mandate officers to report any significant changes in debt to vetting teams. In addition, the rules should require applicants and officers to provide further insight into their finances, including any payday loans, when requested during the vetting process.
   
   The Sussex Police Vetting Unit complete financial checks and research as part of the application process. The disclosure of debt by a Sussex Police employee was already a requirement under the national vetting policy; but specific discussions with employees regarding any debt management issues also now form part of our force-wide annual integrity reviews.  
   
   
6. There should be increased rigour in relation to checks for authorised firearms officers, to ensure that vetting standards are met, as well as the introduction of a psychological assessment and an appropriate process for seeking feedback from supervisors or line managers to determine suitability for the role.
   
   Sussex Police firearms officers are already subject to enhanced vetting which is completed prior to being released for any firearms course. Our ongoing commitment to this recommendation includes reviewing the application process to incorporate written commentary from supervisors regarding role suitability, as well as including external assessors during assessment days. Our existing mentoring scheme also offers further opportunities to identify those who may (or may not) be suitable for the role. Interview questions have and will continue to focus on the Code of Ethics and behaviours, as well as Equality, Diversity and Inclusion, to allow us to concentrate on culture change via those selected.
7. No police officer should be onboarded, even if only for initial training, before all vetting is complete. In addition, each officer’s force vetting should be completed before their National Security Vetting is initiated. All force vetting information should be passed to National Security Vetting officers for consideration

Sussex Police adopt this process.

By March 2025, the College of Policing, in collaboration with force vetting units, should take steps to improve the quality and consistency of police vetting decision-making. This should include encouraging the use of greater professional rigour and curiosity when investigating lines of enquiry, in order to prevent those who commit sexually motivated crimes against women and those otherwise unsuitable for policing from joining the policing profession. These steps should include the following:

• Recruiting forces should be able to request that unresolved allegations discovered during vetting processes be reinvestigated.

This would require a national agreement to ensure consistency across forces.

• In collaboration with the National Police Chiefs’ Council, a national vetting capability should be created, as an advisory function, to provide another layer of confidence in instances where complex vetting investigations and decisions are required. In such cases, forces should approach the national vetting function to seek proposed lines of enquiry and ensure that they are following an agreed, standardised approach when considering complex cases. This is national work that is ongoing, and we await further guidance.

• Consideration should be given during vetting to any information or intelligence about police officers being reported missing, regardless of how quickly such reports were closed.
  
  Any information or intelligence in relation to a missing police officer is identified and discussed within PSD daily. Sussex Police have created a missing persons flag within our vetting system which is added to an individual’s vetting record in the event of a missing episode.
  
  
• Forces must ensure that force vetting units are complying with and practising Section 6.2 of the College of Policing Authorised Professional Practice on Vetting (2021), which states that force vetting units “must record the results of vetting enquiries; the rationale for refusing, suspending, withdrawing or granting clearance, including with restrictions; and where adverse information has been revealed and considered”. This is to ensure that an audit trail is recorded to give the force confidence in decisions made at the time and to allow future vetting officers to constructively scrutinise vetting enquiries and outcomes.
  
  Sussex Police utilise a vetting decision template, based on the National Decision Model, to record vetting rationales for approved and rejected applications. Our decisions are recorded on the applicants vetting record, to allow for auditing opportunities. Sussex Police has an audit plan for in place to ensure consistent and appropriate decision making across vetting applications.

With immediate effect, all recruiting forces should have regard to the new Vetting Code of Practice, which requires the parent force to provide all relevant information requested about the transferee to enable an effective assessment of risk by the force conducting a full re-vet of the transferee.

Sussex Police is compliant with this recommendation, with an approved process for all out-of-force requests, which includes transferees.

By December 2024, the College of Policing, in collaboration with force vetting and recruitment units, should ensure that information-sharing practices, including data retention policies, are strengthened in order to prevent those who commit sexually motivated crimes against women and those otherwise unsuitable for policing from remaining in, or moving across, the policing profession. In particular, there should be a focus on the following information:

• Previous failures to achieve vetting should be recorded by all forces and flagged to recruiting forces. This should also trigger a re-vet with the current or recruiting force.

Sussex Police flag vetting failures appropriately on our vetting system to allow identification of these individuals. We are exploring the further use of intelligence systems to offer additional recording of failed/rejected vetting applications.

• A shared agreement should be made about the quality, relevant and necessary content, and sources of information that will be provided in a reference for a future force, also known as a ‘shared referencing protocol’, with directed questions that must be answered (for example, regarding any past disciplinary or honesty/integrity issues). Information to be shared as part of the protocol should be covered within the relevant forces’ fair processing notices. The protocol should apply to all transfers and applications to police forces from individuals in the uniformed services, including:
  • the Ministry of Defence (including the Army, the Royal Air Force and the Royal Navy, as well as their respective reserve forces);
  • fire and rescue services;
  • HM Prison and Probation Service;
  • other police forces
  • relevant government agencies, such as Border Force or Immigration        Enforcement.
• This is to improve forces’ access to – and ability to use – the totality of information they hold about officers in order to prevent, detect and deal with those likely to commit offences.

This requires negotiation nationally to agree an improved process for information sharing across relevant agencies.

• As per Recommendation 8(b), there should be expanded access to and use of the Police National Database, including as a tool for revealing relevant uninvestigated adverse information about officers.

The Vetting unit in Sussex Police utilise the Police National Database for every stage of the vetting process; this includes but is not limited to new recruit applications, transferees, internal moves, renewals and other vetting applications such as personal circumstance updates. 

• Any adverse information or intelligence (developed or otherwise) should be passed by the current Professional Standards Directorate to the receiving Professional Standards Directorate for any officers transferring. No decisions on their appointment should be made until that intelligence has been reviewed, recorded and closed and the vetting units have had time to consider it. If the recruiting force identifies adverse information as a result of the vetting process, this should be shared with the current force for consideration and potential action.

Sussex Police are compliant with this aspect of the recommendation, with an out-of-force enquiry process, which stipulates that all adverse information on an individual will be disclosed to the requesting force.

With immediate effect, police forces should convey to all existing and prospective officers and staff that they must be held to a higher standard of behaviour and accountability than members of the public, and that therefore their right to privacy can be fettered in certain circumstances. These circumstances include, but are not limited to: recruitment, vetting, aftercare, transfer, promotion, role change, returning to policing and maintaining standards. This is to ensure that members of the police are fully aware and accountable for the unique powers entrusted to them and the standards of professional behaviour they swear to uphold. Updated fair processing notices concerning changes to processing of personal data should be provided prior to any new processing taking place, including data-sharing.

Sussex Police updated our annual integrity review process to explicitly include the recommendation text and we have updated our training inputs for new recruits and supervisors. Sussex Police regularly communicate with the workforce via internal articles on the standards of behaviour; and the completion of Code of Ethics training packages is mandated across the force. Work is ongoing to explore how any new processes that use personal data differently will be considered by the force Data Protection Officer.

By December 2024, the College of Policing, in collaboration with all force vetting units, should develop a stronger approach to force vetting aftercare in order to monitor an individual effectively throughout their career with the police and be aware of any change in circumstances as soon as possible to ensure that potential risks/red flags are identified and assessed. In particular, that approach should include the following:

• Mandatory, randomised re-vetting should be introduced, as an additional layer to standardised vetting periods, for police officers and staff, akin to randomised drug-testing.
  
  Sussex Police awaited guidance via the publication of the new Vetting Authorised Professional Practice in December 2024 prior to considering what formal process should be adopted regarding randomised re-vetting. This work is ongoing, however employees are already re-vetted during the course of their career, such as via internal moves or via annual integrity reviews and personal circumstance changes. 
  
  
• In addition to police officers and staff being required to declare any material changes in their circumstances within a managed system, such as a human resources system, supervisors, or anyone with concerns relating to behaviour, welfare or performance, should report them to Professional Standards Departments at any point.
  
  Sussex Police share internal communications to the workforce, reminding them of the responsibility to disclose any change in personal circumstances. Manager appraisals and annual integrity reviews offer additional opportunities for those in supervisory roles to share information with our Professional Standards Departments. Sussex Police has multiple methods in place for employees to disclose concerns to the Professional Standards Department.
  
  
• Professional Standards Departments should systematically exchange relevant and necessary information with vetting and counter-corruption units to consider information disclosed by any individual, and any action necessary.
  
  This is already standard practice within Sussex Police.

With immediate effect, every police force should commit publicly to being an antisexist, anti-misogynistic, anti-racist organisation in order to address, understand and eradicate sexism, racism and misogyny, contributing to a wider positive culture to remove all forms of discrimination from the profession. This includes properly addressing – and taking steps to root out – so-called ‘banter’ that often veils or excuses malign or toxic behaviour in police ranks.

Sussex Police is fully committed to being an anti-discriminatory force. Discrimination, in any form, is incompatible with our values. We will take positive action to address any report where an officer or staff member is found to have breached these standards.

Sussex Police is committed to celebrating and fostering the diversity of our officers, staff, communities, and everyone we serve. We strive to create an inclusive environment where every individual is valued and respected, and potential and talent is supported and recognised. In line with this commitment, we oppose all forms of prejudice, discrimination, and inequality.

We are dedicated to creating an environment where discrimination is not tolerated, and where individuals affected by it are heard, supported, understood, and their lived experiences are acted on.

In pursuit of these goals, we have delivered further mandatory training for the whole workforce, vigorously promoted new internal channels for confidential reporting, published internally and externally our anti-racism commitment, and developed an employer brand that supports delivery of consistent messaging, engagement and training around the expected Standards of Professional Behaviour and Code of Ethics.

We are in the process of refreshing our network of independent community advisors, and using insight, to ensure we listen and learn from the experiences of marginalised communities, as well as from our own colleagues.

Actions speak louder than words and we will ensure our commitment is transformed into actionable, measurable change. Our dedication will be reflected not only in our words but in tangible actions that can be tracked and evaluated. We will be accountable for our progress.

With immediate effect, all police forces should take action to understand and confront the barriers that police officers and staff face when reporting sexual offences committed by a person that they work with or in the workplace. This is in order to encourage victims, who are also police officers or police staff, to come forward and submit complaints, as well as to identify and remove those who are not fit for service. To do this, forces should:

1. ensure, when a complaint is made, that sufficient and appropriate resources are dedicated to supporting the complainant, including maintaining anonymity where needed or requested, and ensuring an investigation is carried out as appropriate;
2. address cultural barriers to reporting, such as re-victimising complainants by labelling or treating them as ‘troublemakers’; and
3. provide dedicated reporting processes for women in police forces who experience inappropriate behaviour related to their gender.

The Sussex Police Professional Standards Department has dedicated officers for sexual misconduct matters and have increased the breadth and depth of experience in VAWG/Sexual offending through recruitment. Anonymity considerations are given to complainants; and access to specialist advice and support is provided through various staff and external networks as well as Welfare Officers. We monitor any culture of sexism and sexual harassment via an internal recording tool, which is used to share lived experiences. We are confident that the available overt and anonymous reporting mechanisms foster confidence in employee ability to disclose sexual misconduct, cultural issues, or sexual harassment. We also promote and encourage reporting via the newly funded national corruption hotline.