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I11e Non-police personnel vetting

1. Security protective marking

1.1. Not protectively marked.

2. Summary of changes

2.1. The following changes have been made to this policy on 13 September 2011:

    • previous policies I11I Appeals and reviews, I11K vetting refusal, withdrawal and lapses and I11O Finances have been merged in to this policy.

2.2. This policy is due for review in September 2013.  

3. Application

3.1. The purpose of ‘Non-Police Personnel Vetting’ (NPPV) is to provide a means of ensuring that persons other than police officers, police staff, including PCSOs and members of the Special Constabulary, (non-police personnel) having physical or remote access to police information, intelligence, corporate databases, data networks or hard copy material, have been assessed as to their reliability and integrity.
 

4.  Purpose

4.1. The purpose of NPPV is to provide a means of ensuring that persons other than police officers, police staff, including PCSOs, and members of the Special Constabulary, having physical or remote access to police information, intelligence, financial or operational assets have been assessed as to their reliability and integrity. The procedure serves to reduce the risks associated with the loss of, or the unauthorised disclosure of, police assets.

 

4.2. There are three levels of NPPV.  NPPV Level 1 for persons with access to police premises but who have no access to police information, intelligence, financial or operational assets.  Individuals with ‘NPPV Level 1 can be granted regular access to CONFIDENTIAL national security assets and occasional access to SECRET.  NPPV Level 1 does not allow access to protectively marked police assets.

 

4.3. NPPV Level 2 is required by individuals with access to police premises and access to police information, intelligence, and financial or operational assets.  Individuals with this level of clearance, may have regular access to CONFIDENTIAL national security assets and occasional access to SECRET.  NPPV Level 2 also allows occasional access to police assets up to SECRET. 

 

4.4. NPPV Level 3 is required by individuals who require long-term frequent and uncontrolled access to SECRET - police and occasional access to TOP SECRET - police assets.  Level 3 supported by an SC, allows long-term, frequent and uncontrolled access up to SECRET government assets.

 

4.5. The NPPV process is the responsibility of the Vetting Team Leaders, Central Vetting Unit.

 

4.6. Completion of the Authentication process (see I11b – Authentication Procedure) is a preliminary requirement for NPPV.

 

4.7. NPPV relies on the provision of personal information and written authorisation for appropriate checks and associated enquiries to be carried out. For those subject of the NPPV 2 vetting procedure a financial review is included, the purpose of financial checks is to assess whether applicants are in serious financial difficulty, or show signs, from their financial history or current financial circumstances, of financial irresponsibility to the extent they could become vulnerable to financial inducement.

 

5. Level 1. Limited Access – No Protectively Marked Assets

5.1. Level 1 applies to those persons having unsupervised access to police premises on an ad hoc and irregular basis but no access to any electronic systems and/or hard copy material. In the main this applies to utility workers such as plumbers, electricians etc and may, on occasions, apply to
individuals on work experience etc if they have NO access to protectively marked information or electronic systems.

 

5.2. This level does not afford any access to protectively marked police material or assets.

 

5.3. Minimum Standard Requirement: PNC/CHS/CIS and PND (Police National Database)/local intelligence and other non-conviction databases, including Special Branch on applicant only.

 

5.4. Length of clearance: 12 months.

 

6. Level 2. Unsupervised Access – Protectively Marked Assets up to CONFIDENTIAL

6.1. Level 2 applies to those persons having frequent and regular unsupervised access to police premises and/or access to police information and/or hard copy material or protectively marked material, either on police premises or by remote access.

 

6.2. Level 2, supported by authentication, allows regular access to police protectively marked assets up to CONFIDENTIAL and occasional access up to SECRET.

 

6.3. It is the responsibility of the employer to ensure that the authentication process is completed and that references are sought.

 

6.4. Minimum Standard Requirement: PNC/CHS/CIS and INI/local intelligence checks, other non-conviction databases and Special Branch for applicant, spouse/partner and co-residents. Military and Professional Standards checks on the applicant if required. Credit Reference check on applicant. CTC may be applied where appropriate.

 

6.5. Length of Clearance: 3 years.

 

7.   Level 3. Unsupervised Access – Protectively marked Assets up to SECRET

7.1. Level 3 applies to all Non Police Personnel who require long term, frequent and uncontrolled access to SECRET – POLICE, and occasional access to TOP SECRET – POLICE assets.

 

7.2. Level 3, supported by an SC, allows long-term frequent and uncontrolled access up to SECRET government assets.

 

7.3. Minimum Standard Requirement: Checks as required for Level 2 clearance to be conducted on applicant and all family members and co-residents, with full financial checks on the applicant which may be supplemented by CTC or an SC. Also requires annual security review.


7.4. Length of Clearance: 5 years, with annual security review.

 

8. Application

8.1. The following are amongst those who will be vetted in accordance with this policy.  This list is not exhaustive.

    • Partners’ or Contractors’ staff, including their agents and sub-contractors, and those working under a contract for services e.g. consultants and forensic medical examiners;
    • employees of partnership agencies;
    • auditors, consultants and researchers;
    • volunteers assisting police;
    • lay visitors;
    • members of the Police Authority;
    • HM Revenue and Customs;
    • HM Immigration Service;
    • Department for Work and Pensions;
    • chaplains.

8.2. Persons admitted to police premises for the purposes of meetings/conferences etc who are kept under direct and constant supervision need not be vetted. They will be treated as visitors and required to complete visitor registration procedures.  It is therefore important that visitors are not allowed access to material or to overhear conversations from which sensitive information could be obtained.  This exemption is not to be used in place of vetting for contractors carrying out one off tasks on police premises.
 
8.3. Persons whose work requires them to have access to force databases, data network systems or hard copy material to carry out their functions will be the subject of NPPV 2 vetting. This will  require a personal information questionnaire, form 3520b and a financial questionnaire, form 2521b to be completed.

 

8.4. Persons who will not require access to force databases, systems or hard copy material, but who require unsupervised access to force premises, will be the subject of NPPV 1 vetting.  This will require the completion of form 3520b only. 

 

8.5.  In order to appropriately share information with our Kent Resilience Forum partners, in the event of an emergency and/or counter terrorist incident, and to enable representation at the Strategic Co-ordinating Group, Kent Police have agreed to facilitate vetting to Security Check (SC) level for personnel at director/executive level of the category 1 responder group (as indicated in the Civil Contingencies Act 2004).  Where necessary, this may also include their key advisers.  This facility will only be made available when the relevant agencies do not have the ability to carry out the appropriate vetting procedures for themselves.  The process will be co-ordinated through the Head of Emergency Planning, Kent Police.

  

8.6. Initial vetting

8.6.1. Vetting will be completed before any persons referred to above will be admitted to any police premises or provided with access to force databases and/or sensitive material. 

8.6.2. Force Policy L83, for the issue of identity cards to persons subject of this policy, must be adhered to.

8.6.3. In order to overcome any disputes on vetting, contracts and agreements must contain clauses mandating this vetting policy and the force's right to exclude any person from having access to force premises, force databases or sensitive information, without explanation.

8.7. National Police System contractors

8.7.1. Warwickshire Police, on behalf of all UK police forces, vet all National Police System contractors to NPPV level.  A database containing a full list of companies participating in the scheme and details of members of their staff who have received NPPV clearance by Warwickshire, is available within the Central Vetting Unit. 

8.7.2. The Warwickshire scheme eradicates the need for forces to duplicate the vetting of National Police System contractors who require access to more than one police force.  The contractors pay for the vetting enquiries.

8.8. Re-vetting criteria

8.8.1. Persons holding NPPV clearance are required to notify changes to their personal circumstances, at the time the changes occur. These may include: changes of spouse or partner, co-residents, criminal convictions, cautions or other judicial adjudications, disciplinary findings, association with persons involved in crime, matters which could make them susceptible to pressure or improper influence to disclose information, and financial difficulties, depending upon the level of clearance.   

8.9. Responsibility for carrying out the process 

8.9.1. Vetting enquiries and relevant checks will be undertaken by the Vetting Team Leader in liaison with the following:

      • the Business Co-ordinator on the Division or for the Department where the individual will be working, or a member of staff nominated by the Business Co-ordinator;
      • the Kent Police officer or employee responsible for issuing a contract or arranging for non-police personnel to work in partnership with the force.

 8.10. Finances

8.10.1. Financial checks are required for NPPV Levels 2 and 3.

8.10.2. The principles outlined in I11C recruitment vetting paragraphs  

 8.11. Decision making

8.11.1. Having completed all vetting checks and enquiries, the Vetting Team Leader will evaluate the information collated and make a decision as to vetting clearance.

8.11.2. Once a decision has been made, the applicant, company or organisation will be notified in writing by the relevant Division or Department utilising form 3529a, accompanied by a short letter of introduction.  All papers utilised in arriving at the decision will be returned under sealed cover endorsed with the vetting decision, for retention on file for 6 years from the date of notifying the applicant of the result.

8.12. Contract negotiations

8.12.1. During contract negotiations it must be made clear to prospective contractors that the requirement for all contractors’ staff to obtain NPPV clearance is non-negotiable.  Agreeing a contract on a provider or supplier's terms and conditions is not likely to adequately protect the force.  In whatever category, binding terms must include the fact that contractors’ staff must notify the NPPV Team Leader of any relevant changes to their personal circumstances.

 

9. Residency criteria

9.1. The residency criteria for all applicants are outlined in policy I11Q Residency criteria 

10. Interpreters

10.1. In terms of the security risks presented by non-police personnel working with the force, interpreters are in a unique position of having access to sensitive information and vulnerable individuals, without effective verification of the accuracy of the interpretation of interviews or other services provided.  It is therefore important that all interpreter applicants are vetted to the NPPV 2. For the same reasons all interpreters will also be the subject of Counter-Terrorist Check (CTC) clearance.  Interpreters who are likely to have regular access to SECRET or occasional access to TOP SECRET national security assets (e.g. those working with Special Branch) will require Security Check vetting.

11. Associated documents and policies

 

Policy reference: I11e Non-police personnel vetting
Policy owner: Professional Standards
Contact point: Policy Unit 01622 654662
Date last reviewed: 13 September 2011
Document last saved: 25 April 2013