Vetting Policy - PD 130 - Lincolnshire Police

NOT PROTECTIVELY MARKEDLINCOLNSHIRE POLICEPolicy Document1. POLICY IDENTIFICATION PAGEPOLICY TITLE:VETTING POLICYPOLICY REFERENCE NO: PD 130 (9)POLICY OWNERSHIP:ACPO Commissioning Officer:Portfolio / Business-area Owner:Department Responsible:Senior Owner:Deputy Chief ConstableHead of Professional StandardsInformation Management UnitForce Vetting OfficerLinks or overlaps with other policies/strategies:ACPO National Vetting Policy for the Police Community 2012NPIA Circular 1/2010Government Protective Marking Scheme - PD 119MOPI policy - PD 118MOPI: Codes of Guidance 2010HR: Recruitment & Selection guidanceForce Security Policy – PD 55Cabinet Office Security Policy FrameworkData Protection Act and FOIAAlcohol, Drug and Other Substance Abuse – Pre employment Screening – PD 116POLICY EFFECTIVE DATE: SEPTEMBER 2014POLICY REVIEW DATE: SEPTEMBER 2015VERSION: DATE: REASON FOR ISSUE:4 Nov 11 Review5 May-12 Reviewed to align with strategic partner6 Jun-12 Annual review7 Aug 13 Annual Review8 Feb-14 Amendment to MoPI guidance reference- 1 -

NOT PROTECTIVELY MARKED9 Sept-14 Annual Review- 2 -

NOT PROTECTIVELY MARKED2. Legislative ComplianceThis document has been drafted to comply with the principles of the HumanRights Act.Public disclosure is approved unless otherwise indicated or justified.Adherence to this policy will ensure compliance with all relevant legislationand internal policies.3. POLICY STATEMENTS/INTENTIONS3.1 The principles and scope of the policyThe policy applies to all Police Officers, Police Staff, G4S Partnership Staff and allpersonnel contracted to work for Lincolnshire Police, Special Constables, volunteers,temporary personnel and trusted employees from agencies and organisations whoby the nature of their role may require access to Lincolnshire Police site, assets,systems and information. It is designed to provide clear guidance to the vetting levelsand procedures employed.The primary objectives are: To safeguard our information, operational and financial assets, To preserve the safety and welfare of our community and staff To maintain the safety and trust of the community we serve and those withwhom we work in partnership.It is intended that this policy will ensure consistency of approach and demonstratecompliance the ACPO National Vetting Policy for the Police Community 2012.3.2 The aim of the policyThe Force vetting policy is designed to provide additional assurances both topersons seeking recruitment to and those already working within the Force. A highlevel of integrity and honesty will ensure that new employees will not be a risk to theorganisation or national security and will reduce the risk of unauthorised disclosure ofinformation and other assets. The processes involved will take into account theHuman Rights Act 1998.The policy will also embed the Force Staff Charter of P.R.I.D.E. – Professionalism,Respect, Integrity, Dedication and Empathy. This will be achieved by providing clarityof the processes involved, consistency in their use, by reflecting the dynamic needsof the Force and by treating fairly those with whom the Vetting Unit comes intoprofessional contact.- 3 -

NOT PROTECTIVELY MARKED4. INTRODUCTION/LEGAL BASIS4.1 The origins/background informationLincolnshire Police is committed to the maintenance of high levels of honesty andintegrity and to the prevention and disruption of dishonest, unethical andunprofessional behaviour. A comprehensive and proportionate vetting strategy willassist the Chief Constable to maintain an efficient and effective Force as required bythe Police Act 1996. It also assists in the compliance with Principle 7 of the DataProtection Act 1998, Section 8 of the Official Secrets Act 1989, Section 115 Crimeand Disorder Act 1998 and Section 82 of the Police Reform Act 2002 and theCabinet Office Security Policy Framework.4.2 Motivators/Driving ForcesTo provide the Force, its officers and staff, together with procedures to follow and toensure compliance with the ACPO National Vetting Policy for the Police Community.This is turn is designed to ensure the public has confidence in Lincolnshire Police.4.3 General Principles of the PolicyTo ensure that the Force has a robust and consistent system for vetting all thosewishing to work with or for Lincolnshire Police and that the individuals concerned arevetted to a level appropriate to the level of access to sensitive and ProtectivelyMarked information and assets they enjoy. Additionally, the policy will provide a highlevel of assurance that the vetting levels held retain their currency by theimplementation of a meaningful system of vetting Aftercare.To achieve the above the Vetting Unit will carry out checks on all working with orwishing to work with or for Lincolnshire Police. This will necessarily involve officers,Special Constables, support staff, contractors, agency staff and volunteers. Thesechecks include searching databases held both within the Force and nationallytogether with financial checks, Security Service checks and enquiries with otherForces and organisations where necessary. Additionally, the Unit will be responsiblefor conducting the Aftercare process on all those holding Designated 1 Posts.All personnel who have access to any part of the Lincolnshire Police site, its assets,systems or information will be subject to a vetting procedure commensurate with therisk involved in providing such access.The decision on whether an applicant’s vetting is approved, rejected or withdrawnrests entirely with Force Vetting Officer (FVO). This decision however is open toreview and / or appeal. (The procedures are detailed at SOP 9)The Force Vetting Officer is to ensure that all information provided by applicants orgathered during the vetting process remains secure and is treated confidentially.1 Those personnel having access to our more sensitive & Protectively Marked information.- 4 -

NOT PROTECTIVELY MARKED4.4 Legal BasisData Protection Act 1998Official Secrets Act 1989Crime and Disorder Act 1998Police Reform Act 2002Cabinet Office Manual of Protective SecurityHealth and Safety at Work etc 1974Police Act 19964.5 Human Rights Considerations/Articles EngagedApplication of this policy has the potential to engage various articles of the EuropeanConvention of Human Rights/Human Rights Act 1998.Article 1 – Protocol 1 states:‘Every Natural or legal person is entitled to the peaceful enjoyment of hispossessions. No one shall be deprived of his possessions except in the publicinterest and subject to the conditions provided for by law and by the generalprinciples of international law’. This could relate to existing members of staff losingbenefits (e.g. overtime) if not permitted to serve or remain in a particular post.Article 8 –Right to respect for private and family life.‘There shall be no interference by a public authority with the exercise of this rightexcept such as in accordance with the law and is necessary in a democratic societyin the interests of national security, public safety or the economic well-being of thecountry, for the prevention of disorder or crime, for the protection of health or morals,or for the protection of the rights and freedoms of others’Article 14 –Prohibition of discrimination.‘The enjoyment of the rights and freedoms set forth in this Convention shall besecured without discrimination on any ground such as sex, race, colour, language,religion, political or other opinion, national or social origin, association with a nationalminority, property, birth or other status.’Action taken in pursuit of this policy must be proportionate to its aims. In this casethe policy seeks to ensure that the Force complies with the ACPO National VettingPolicy for the Police Community.- 5 -

NOT PROTECTIVELY MARKED5. Standard Operating ProceduresSOP 1 – Vetting Levels and their relevance to the Government ProtectiveMarking SchemeSOP 2 – AuthenticationSOP 3 – Recruitment VettingSOP 4 – Management Vetting and Enhanced Management VettingSOP 5 – Non-Police Personnel VettingSOP 6 – National Security VettingSOP 7 – Vetting InterviewsSOP 8 – Convictions and Cautions CriteriaSOP 9 – Appeals/Review ProcedureSOP 10 – Aftercare/Renewal of ClearanceSOP 11 – Transferees and RejoinersSOP 12 – Career BreaksSOP 13 – Other Force Vetting Checks (the use of PND)SOP 14 – Reciprocal VettingSOP 15 – Business Interests/Secondary Working in respect to VettingSOP 16 – Risk Assessments – Third PartySOP 17 – Adverse Information and Judicial Findings (TAINT)SOP 18 – Financial ChecksSOP 19 – Glossary of Terms6. IMPLICATIONS OF THE POLICYIt is recognised that the guidance contained under this heading may not bedirectly applicable to all policies. Where it is relevant however, the followingareas should be considered:6.1 Financial Implications/Best ValueBy ensuring that all those working with and for Lincolnshire Police are vetted to theappropriate level the Force reduces the potential for security and financial risk.6.2 Human Resources/TrainingAppropriate training will be required on Force computer systems. All training will bein-house, including PARASOL. Additionally, HRSC and the Vetting Unit will continueto work closely to ensure their respective roles compliment and support each other.6.3 Strategic/Business PlanN/A6.4 Risk ManagementN/A6.5 Health and SafetyN/A- 6 -

NOT PROTECTIVELY MARKED6.6 DiversityAn initial equality impact assessment has been carried out on this policy and isconsidered as having a low impact.6.7 Every Child MattersChildren act 2004Section 10 Co-operation to improve well-beingSection 11 Arrangements to safeguard and promote welfare6.8 Crime and Disorder ActSection 115 applies – Disclosure of Information.6.9 Internal Policy/Strategy LinksGovernment protective marking system PD119MOPI policy PD118MOPI codes of guidance 2006HR recruitment & selection guidance6.10 ConsultationOriginal consultation for this policy was taken with COG, Divisional Commanders,Heads of Departments and Staff Associations.As this is a review, not a new policy, further consultation was not required.6.11 PublicationThe policy document can be disclosed to the public.Details of the policy will be published via a link on the Force Routine Orders.7. PROMOTION/DISTRIBUTIONThe policy document will be placed on the Internet.The policy document will be placed on the Force Intranet.- 7 -

8. MONITORING/REVIEWNOT PROTECTIVELY MARKEDThe Force Vetting Officer will continually monitor the effectiveness of the policy andreview it annually.The Force Vetting Officer will submit the review to the DPA and FOIA Manager on anannual basis.- 8 -