Vetting - An Overview

Vetting is undertaken in line with the Police Scotland Vetting Manual of Guidance, which is largely mirrored on
the College of Policing’s Authorised Professional Practice (APP) and Code of Conduct for vetting in England and
Wales.

Risk based approach
The vetting process is fair and proportionate in that thorough and
careful consideration is given to whether any risks can be managed or not in respect of granting clearance.
The degree of proximity with family members and associates will be a consideration however there may be occasions
where the risk of reputational damage and negative impact on public confidence through association cannot be
managed.

Vetting is by its very nature, an intrusive process. In order to ensure vetting officers are equipped to carefully
consider a varied and diverse range of issues they may encounter, we have invested in training to ensure that they
are culturally aware and treat each applicant’s circumstances individually and sensitively.

Enhancements to vetting
Over the last 12 months, Police Scotland has refined its approach and added additional safeguards to the vetting
process. Recognising the fundamental role vetting plays in keeping the public safe, we have also enhanced capacity
within in our vetting department, ensuring we keep abreast of growing demand whilst continuing to develop and grow
processes, benchmarking and learning from outcomes from other police forces.

In 2021, Police Scotland introduced an additional process specifically for police officers. Prior to taking their
oath of office to become probationary constables, a re-affirmation process is now in place to ensure any changes
in personal circumstances since the individual was initially vetted are declared and risk assessed, providing an
assurance as to continued suitability to hold vetting clearance. If an individual is not deemed suitable to become
a police officer, steps are taken immediately to remove the individual’s vetting and their offer of appointment.
Since its introduction, 84 individuals have declared a change in circumstance with 3 individuals having failed
vetting as a result and their vetting and offers of appointment subsequently withdrawn.

Police Scotland has reviewed its tolerance levels in respect of areas of risk such as finances and associations
and have taken on board improvements and recommendations arising from the HMICFRS Inspection into Vetting, Conduct
and Misogyny in police forces in England and Wales.

Challenges
Risks will change depending on a number of societal factors however current main themes in vetting refusals are:

Honesty/integrity issues – Rightly, the public expects the highest levels of honesty and integrity from all
applicants who wish to work within policing. We therefore take a very serious view of those who do not fully
disclose relevant information during the vetting process.

Criminality – Personal conduct of applicants is also a fundamental consideration. There are criminal convictions
which will not be accepted by Police Scotland, regardless of their age. We are currently developing a criminal
conviction framework which will set out and make clear to applicants which convictions will never be accepted in
order to manage expectations.

Finances – Individuals who have had or are currently experiencing financial difficulties are more susceptible to
financial inducement/coercion. As a result, we have reviewed our processes in respect of financial circumstances
prior to awarding a vetting clearance. Applicants who have an undischarged Trust Deed shall be refused vetting on
the basis that they have not yet demonstrated financial stability. This will also be the case for applicants who
have discharged a Trust Deed but less than 12 months have passed since the date of discharge.

Third party associations – Individuals with ties to organised crime groups or individuals who are involved in
criminality can bring operational and reputational risks to the organisation. There is a risk of infiltration or
the potential employees may be susceptible to blackmail or coercion by their criminal associates, putting
information, individuals and assets at risk.

Case Studies
The following are case studies from the previous 12 months where vetting has been refused;

B applied to join Police Scotland as a police officer. B had no previous convictions or any pending matters,
nor were there any third party associations of concern. On review of social media accounts, posts were found
suggesting that B disagreed with diversity and inclusion; in fact, some of B’s posts could have been construed
as racist.

S applied to join Police Scotland as a police officer. S had no adverse findings, however was closely associated
with an individual, C, who, intelligence suggested, was well known for supplying Class A drugs to vulnerable
children within the community. The intelligence was recent and credible. S did not disclose an association to C,
leading the vetting department to question the integrity of S as it was assessed it was more likely than not S
would be aware of C’s involvement in the supply of controlled drugs.

M was applying to join Police Scotland as a police staff member. M was in a trust deed which had commenced in 2019. M appeared to be on track and meeting obligations under the trust deed, however upon conducting a deeper financial check, it showed that M had 3 further defaults since 2019 suggesting M was still financially vulnerable. M’s vetting was refused on the basis that M had not demonstrated financial stability and that the risk of financial inducement was high.

NEXT STEPS

Having recently undergone an inspection of vetting by His Majesty’s
Inspectorate of Constabulary in Scotland, Police Scotland await the outcome and any recommendations for improvements.

In the meantime, Police Scotland are progressing a number of initiatives to improve vetting and public confidence within policing;

Review/update of designated posts list
A review of all posts contained on the organisations designated posts list is due to commence. Designated posts
are those posts with access to sensitive information, intelligence, financial or operational assets.
Assets might include certain IT systems and entry to sensitive police premises may be a consideration.
This will be a significant undertaking but will ensure that all posts are updated in accordance with Force policy
and staff are accessing information appropriate to their role and level of vetting.

Recruitment vetting renewals
Police Scotland is introducing a process for renewals of Recruitment Vetting (RV) across the workforce.

Continuous Integrity Screening
In January 2023, Deputy Chief Constable Professionalism, Strategy and Engagement announced that Police Scotland
would check all officers and staff against national systems, in line with work being taken forward in England and
Wales at the request of the Home Secretary. This work is currently ongoing.