1. Police & Crime Commissioner comments:
- I welcome the findings of this report, and the following sections outline how the Force is addressing the Areas for Improvement (AFIs) identified. While some aspects of the recent inspection were understandably disappointing, significant progress has been made, reflecting Surrey Police’s ongoing commitment to tackling the issues raised. I have discussed the report and our response in detail with the Chief Constable and am confident that we are now on the right track. I will continue to monitor progress through my Office’s established oversight mechanisms.
1.2 I have requested the Chief Constable’s view on the report, and he has stated:
In May 2025, HMICFRS published their report into the effectiveness of Surrey’s integrity arrangements, following a weeklong inspection of our Professional Standards Department in October 2024. The Force was graded as ‘requiring improvement’ for vetting and upholding standards of behaviour, and ‘good’ for tackling potential corruption.
HMICFRS issued seven Areas for Improvement, all of which have been formally recorded on our Strategic Governance system, Keto, to ensure clear oversight. We have accepted all the AFIs, and progress is being closely tracked through both the Local Policing Accountability Board and the Organisational Reassurance Board.
We are committed to addressing and completing all AFIs by the end of 2025, with considerable work already underway.
2. Responses
2.1 The Joint Force Vetting Unit (JFVU) received 3 AFIs, The Professional Standards Department (PSD) 3 AFIs with a further force level AFI in respect of organisational learning. No AFIs were identified for the Anti-Corruption Unit (ACU).
2.2 Vetting AFIs (3)
2.3 Within Surrey Police all vetting requirements are completed by a shared Joint Force Vetting Unit (JFVU) based at Lewes. This team supports both Surrey and Sussex Police. The vetting function received 3 AFIs to improve vetting arrangements, how the unit records adverse information in vetting decisions and to improve the understanding of any disproportionality. The HMICFRS expressed concerns about the resourcing of the unit, demand management and timeliness.
2.4 AFI 1
2.5 The force should improve its vetting arrangements. The force should make sure that its vetting unit has sufficient resources to meet the demand it faces:
2.6 The establishment of the unit has increased with an additional Supervisor, 6 Caseworkers and an Administrator recruited, trained and operational. A Business Support Assistant, capable of collecting and analysing vetting data, has been identified as a key growth post. The unit is progressing a business case and growth bid, subject to approval, to secure this additional capability which will improve the understanding of any disproportionality within vetting decisions.
2.7 A review of recent demand management demonstrates significantly improved processing times for clearance:
2.8
2.9 The JFVU achieved the current 30-day Service Level Agreement (SLA) by the end of June compared to being 13 weeks over in January 2025. At the time of the inspection 30 people had expired vetting and this now sits at 2 (maternity and career break absences). During the inspection 469 personnel didn’t have the right level of vetting, this has been reduced to 94. When inspected, 10 Contractors had expired vetting versus 1 today (with a renewal in hand).[1]
2.10 The SLA is being revised to better reflect risk and the unit undergoing planned restructure into functional teams with dedicated areas of responsibility to allow for greater specialisation of operators. This new risk-based approach has been discussed with the HMICFRS who raised no objections, displaying interest in its implementation and potential positive impact on workflow and demand management.
2.11 The Force should have a clear understanding of the level of vetting required for all posts and that all members of the workforce have been vetted to a high enough level for the posts they hold:
2.12 To improve the understanding of vetting levels and to ensure that when personnel move they have the requisite clearance, closer links with HR have been established. HR now maintain a live database of proposed moves, with moves now only taking place once vetting has been approved. Vetting renewal processes have been revised with renewal packs sent with sufficient time for completion with supervisory oversight.
2.13 The Force should have a robust process to research and assess all notifications of changes of circumstances in a timely manner.
2.14 As a result of the success of the new Annual Integrity Review (AIR) process the unit receives considerable volumes of change of circumstance forms (227 pending at time of inspection). Further amendments are being made to the AIR process to link directly into the Personal Circumstances Online Form.
2.15 Decision making is recorded on a proforma with a move from an omnicompetent model to functional teams who specialise in different aspects of vetting. There are distinct vetting teams for Business Interests, Notifiable Associations and Internal Moves – currently processing applications within 23 days, 5 days ahead of the agreed SLA. All JFVU Staff have received NDM training.
2.16 The first Performance & Accountability Meeting was held in July to ensure timely processing of applications. This is a regular, monthly meeting to ensure oversight and is chaired by the Head of the JFVU.
2.17 To improve the workforce understanding of vetting, all personnel are receiving an input on vetting obligations, with this to be completed by November. These obligations are also set out in the PSD Handbook which will be published later this year and made available to staff on Mobile Data Terminals. A new PSD Guidance Hub, setting out vetting obligations and expectations regarding standards, was launched on the Force’s intranet in October 2024 and has had over 8,000 visits from 1028 unique visitors since then.
2.18 Business Interests and Notifiable Associate reviews and decisions have moved from the JFVU to the PSD ACU. This team is better skilled for such assessments and allows for more detailed intelligence checks. JFVU staff now also have access to the full Strategic Threat Assessment for the Force, produced annually by PSD. Training on the current risks was delivered in June. There is an aspiration to train a small number of Vetting Case Workers in the use of the ACU IBase system. This would allow direct access to corruption intelligence to inform vetting decisions. This is currently being worked on by the ACU DCI and Head of Vetting.
2.19 AFI 2
2.20 The force should improve how it explores and records adverse information in vetting decisions. The force should make sure that in relevant cases, it interviews applicants to explore adverse information to help assess risk:
2.21 The JFVU has increased the number of vetting interviews from 33 (Jan-June 24) to 92 for the same period in 2025 with greater emphasis on this line of enquiry. This is now an established vetting tactic within the unit and routine practice.
2.22 When it identifies adverse information during the vetting process, it supports all vetting decisions (refusals, clearances, and appeals) with a sufficiently details written rationale.
2.23 The Vetting Decision Making Template was revised in May 2025 and quality assurance checks on decision making completed fortnightly by the unit manager to ensure compliance.
2.24 A new monthly performance meeting has been established for oversight.
2.25 AFI 3
2.26 The force should improve how it analyses vetting data to identify, understand and respond to any disproportionality.
2.27 A Business Support Assistant, capable of collecting and analysing vetting data, has been identified as a key growth post for the JFVU. The unit is progressing a business case and growth bid which, subject to approval, will improve the understanding of any disproportionality within vetting decisions.
2.28 The JFVU has an established PowerBI dashboard, but work is required to improve data quality to information analysis of potential disproportionality.
2.29 The JFVU is in the process of sharing available data with the Force Equality, Diversity and Inclusion Team to promote transparency and accountability. They will also seek to become regular attendees at the Force RAPID board which explores disproportionality within the Force.
2.30 The JFVU are also engaging and requesting support from the Race Equality Network, Polfed and Unison to ensure these bodies are represented on Vetting Appeal Panels. This will ensure that decisions are informed by subject matter experts with lived experience and promote open justice.
2.31 The OPCC currently conduct thematic reviews of Vetting decisions to explore potential vetting disproportionality.
2.31 Force Level AFIs (1)
2.32 AFI 4
2.33 The force needs to improve its processes for collecting, sharing and evaluating organisational learning.
2.34 The Force had already recognised shortfalls in the processes for collecting, sharing and evaluating organisational learning prior to the HMICFRS inspection. However, this AFI strengthens the Force ambition to improve the situation. A scoping meeting has been held with the Head of Corporate Development and DCC, and planned changes are in place for the Organisational Reassurance Board (ORB). Previously, organisational learning was held jointly with Sussex Police. Surrey Police will be withdrawing from this process to move organisational learning into a new more frequent Force Assurance Board (replacing ORB) with additional Chief Officer oversight and governance. The new structure aims to strengthen senior leadership oversight of corporate performance, including risk management, issue resolution, and organisational learning.
2.35 PSD AFIs (3)
2.36 The Surrey Professional Standards Team consists of an overt capability who manage public complaints and conduct investigations. The ACU provide a covert capability as well as processing intelligence. They also have responsibility for delivery of the Force’s Prevention Plan. Overt PSD received 3 AFIs setting out required improvements in managing demand, investigation quality and its understanding of potential disproportionality required. There is currently a Joint Force Learning Board chaired by Sussex, but the report highlights the need for closer ownership and governance in force.
2.37 AFI 5
2.38 The force needs to improve the professional standards department’s ability to manage investigation demand.
2.39 In response PSD establishment has increased with an additional DCI post, DS post in the ACU and 2 additional investigators for overt PSD. To compliment the DS growth post the ACU are currently recruiting a PSD Admin Assistant, using unused establishment hours, to allow warranted officers and IOs to focus on tasks better suited to their skill set.
2.40 PSD currently have an omni-competent investigation model but to improve timeliness and throughput a functional model is being explored. Whilst still being scoped this is likely to create a dedicated team of Complaint Handlers with a separate Conduct Team. A draft business case has been prepared by the Complaint Manager which recommends a growth in establishment of 5 complaint handlers. This requires Finance BP oversight and costing before being reviewed by the relevant HR BP. Once finalised it will be passed to the DCC for his consideration as to whether to support the business case progressing through internal processes.
2.41 The introduction of a PowerBI dashboard in PSD will provide significant business intelligence including who is carrying the greatest workload, productivity data and timeliness. This will give supervisors the ability to better manage demand, recognise those who make a disproportionate positive impact and support those who may be struggling. This performance tool will significantly improve departmental understanding of demand.
2.42 AFI 6
2.43 The force needs to improve the way it responds to complaints and conduct allegations. This is in relation to (1) the force’s timeliness in handling complaint and conduct allegations:
2.44 Post inspection ambitious complaint management KPIs have been introduced; 15 days for service recovery; 100 days for Other than by Investigation (OTBI) and 180 days for investigations. These reflect most similar forces (MSFs), and national targets and adherence will be tested by the Complaint Manager at 90 days.
2.45 Currently OTBIs (26% of all complaints) take 119 days in Force compared to 119 days MSF and 124 days nationally. This has improved since the inspection when OTBIs took on average 128 days.
2.46 72% of all complaints are service recovered with the latest IOPC data recording Surrey takes on average 15 days to finalise versus 24 days MSF and 20 days nationally. Force performance in these 2 areas is therefore positive.
2.47 The current area of concern relates to local investigation, equating to 2% of demand, which take an average of 303 days in force compared to 210 days MSF and 220 Nationally to finalise (Source Q4 24/25 IOPC Bulletin).
2.48 Compliance against KPIs will be tracked via the PSD PowerBi dashboard due for completion August 25.
2.49 (2) documentation of complaints and allegations
2.50 To improve investigation standards and documentation an Investigation Strategy Template has been introduced and mandated. It reflects HMICFRS direction and requires workflow to a supervisor for endorsement. 28-day supervisor checks are now taking place with a checklist covering minimum lines of enquiry and compliance with regulations. Compliance will be reported by a PSD PowerBi dashboard which is in the final stages of development. A meeting with the Falcon Lead and Strategic Governance has been held to share best practice from Op Falcon (the force investigation improvement project) and to use subject matter experts to develop an Investigation Framework for PSD. This is an ongoing piece of work being led by the Conduct DCI.
2.51 All compliant investigations are now scrutinised at the newly introduced monthly Complaint Job Review Meeting. This reflects the approach of the Conduct Review Meeting and ensures IOs prioritise those cases with the greatest risk and monitors timeliness.
2.52 A new initial complaint handling process has been introduced during which PSD support in defining points of complaint. This simple change will significantly reduce delays associated with complainants not engaging and ambiguity, which in turn delays confirmation, impacting on overall timeliness.
2.53 All these measures will improve both investigative standards and timeliness. The new KPIs, Supervisory Reviews, Meeting Structure and templates were introduced to the PSD team during mandated CPD in April 2025.
2.54 (3) PSD staff generally log complaint and conduct matters on Centurion, the PSD complaint and conduct IT system, in a timely way.
2.55 PSD use Centurion, a national standalone crime management software for conduct, to manage all investigations. It’s a complex system with Surrey currently not making full use of its capabilities. To optimise the benefit of this system PSD are writing a comprehensive user guide for all investigators, sections of which have already been published on the departmental SharePoint.
2.56 PSD are also exploring “Auto Functionality” with the makers of Centurion, if successful this capability could complete administrative tasks for IOs allowing them to focus on investigative actions. This machine automation will be tested before activation but could have significant efficiency benefits.
2.57 AFI 7
2.58 The force needs to improve its understanding of potential disproportionality in handling, investigation and resolution of complaints and conduct matters.
2.59 The Force has improved its understanding of potential disproportionality in conduct and complaint investigations. Post inspection the complaint data set reported to the PSD Performance Meeting has been expanded to cover all 9 protected characteristics. PSD already report on the relevant conduct data at the Integrity Board and RAPID Board. Both the Complaint Manager and the Conduct DI have been commissioned to complete a retrospective review examining potential disproportionately for FY24/25. This will be repeated annually with the first iteration published in July 2025. The successful Race Scrutiny Group used by PSD to advise on matters engaging racial discrimination has been replicated for matters that engage homophobia in any form.
2.60 PSD are now routine attendees at the DCCs Advice, Challenge and Support Quarterly event for ethnically diverse officers and staff. PSD have delivered presentations on data to address the force perception of unfairness within this forum.
2.61 Once a PSD PowerBi Dashboard is finalised consideration will be given to allowing access to high level data to all personnel in the force to mitigate perceptions of unfairness.
3. Closing Comments
3.1 The findings of this inspection are welcomed, and it is anticipated that all current AFIs will be delivered by the end of 2025.
3.2 The greatest challenge for PSD remains increasing demand (see table below showing case volumes over time). However the measure set out in this report will meet these challenges and deliver the areas of identified improvement.
3.3
3.4 PSD performance is now included at the monthly Force Performance Board, chaired by the CC, which will assist in driving the required improvement.
Lisa Townsend
Police and Crime Commissioner for Surrey
[1] Data correct as of June 2025.