Legal and Professional Standards Department - Non-police personnel vetting procedure (P04d)

1. Summary of changes

1.1. This standard operating procedure (SOP) was reviewed in October 2023 - paragraph 3.34 amended. 

2. What this procedure is about

2.1. 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, having physical or remote access to police premises, information, intelligence, financial or operational assets have been assessed as to their reliability and integrity and thus suitability for clearance.

Compliance with this SOP and any governing policy is mandatory.

3. Detail the procedure

3.1. There are four levels of NPPV. The authentication procedure (SOP P04a) must be completed prior to NPPV being initiated. Authentication on its own does not allow access to police protectively marked assets, or unescorted access to any police premises. 

3.2 NPPV level 1 is required by non-police personnel with access to police premises but who have no access to police information, intelligence, financial or operational assets. Individuals with NPPV level 1 may 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.

3.3 NPPV level 2 (abbreviated) is required by non-police personnel with access to police material up to OFFICIAL-SENSITIVE, either on police premises or by remote access, but with no systems access. Individuals with this level of clearance may have regular access to CONFIDENTIAL national security assets and occasional access to SECRET.

3.4 NPPV level 2 (full) is required by non-police personnel with unsupervised access to police systems and premises and allows access to classified police material/information up to OFFICIAL-SENSITIVE with occasional access to SECRET. Individuals with this level of clearance may have regular access to CONFIDENTIAL national security assets and occasional access to SECRET.  

3.5. 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 a security check (SC), allows long-term, frequent and uncontrolled access up to SECRET government assets.

3.6 Administration of the NPPV process is the responsibility of the Vetting Team leaders, Central Vetting Unit.

3.7 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 level 2 (full) and NPPV level 3 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.

NPPV level 1: limited access – no classified police material

3.8  Level 1 applies to non-police personnel having unsupervised access to police premises on an ad hoc 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.

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

3.10 This level does not afford any access to classified police material or assets.

3.11 Minimum standard requirement: On applicant only - Police National Computer (PNC); local intelligence checks; Police National Database (PND)/other force checks; Special Branch. Where an applicant meets the residency qualification but identifies a period of residency outside the UK, consideration should be given to undertaking checks through the ACRO criminal records office for any potential foreign convictions.

3.12 Length of clearance: up to three years.

NPPV level 2 (abbreviated): unsupervised access – protectively marked assets police material up to OFFICIAL-SENSITIVE either on police premises or by remote access but no systems access

3.13  Level 2 (abbreviated) applies to non-police personnel having unsupervised access to police premises and allows access to police material up to OFFICIAL-SENSITIVE, either on police premises or by remote access.

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

3.15 This level does not afford systems access.

3.16 Minimum standard requirement: on applicant, partner and co-residents (aged ten years and over) - Police National Computer (PNC); local intelligence checks; Police National Database (PND)/other force checks; Special Branch. On applicant only – military checks/Professional Standards checks (as required). Where an applicant meets the residency qualification but identifies a period of residency outside the UK, consideration should be given to undertaking checks through the ACRO criminal records office for any potential foreign convictions.

3.17 Length of clearance: three years.

NPPV level 2: (full) unsupervised access – police material/information up to OFFICIAL-SENSITIVE with occasional access to SECRET

3.18  Level 2 (full) applies to non-police personnel having frequent unsupervised access to police premises and systems and allows access to classified police material/information up to OFFICIAL-SENSITIVE with occasional access to SECRET, either on police premises or by remote access.

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

3.20 Minimum standard requirement: on applicant, partner, all family members and co-residents (aged ten years and over) - Police National Computer (PNC)/local intelligence checks; Police National Database (PND)/other force checks; Special Branch. On applicant only - military checks/Professional Standards checks (as required); credit reference check. A Counter Terrorist Check (CTC) may be applied where appropriate. Where an applicant meets the residency qualification but identifies a period of residency outside the UK, consideration should be given to undertaking checks through the ACRO criminal records office for any potential foreign convictions.

3.21 Length of clearance: three years.

NPPV level 3: unsupervised access – police material/information up to SECRET and occasional access to TOP SECRET

3.22  Level 3 applies to non-police personnel having unsupervised, unrestricted access to police premises and systems, and could include those working in areas where the police roles have been identified as designated posts, and allows access to classified police material/information up to SECRET and occasional access to TOP SECRET.

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

3.24 Minimum standard requirement: on applicant, partner, all family members and co-residents (aged ten years and over) - checks as required for level 2 (full). On applicant only - military checks/Professional Standards Checks (as required); full financial checks. Where an applicant meets the residency qualification but identifies a period of residency outside the UK, consideration should be given to undertaking checks through the ACRO criminal records office for any potential foreign convictions. Also requires annual vetting review.

3.25 Length of clearance: five years, with annual vetting review.

Application

3.26 The following are amongst those who will be vetted in accordance with this SOP. 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 and Crime Commissioner’s Office
• HM Revenue and Customs
• UK Border Force
• Department for Work and Pensions
• chaplains
• police choir and band

3.27 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.

3.28  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 has 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.

Initial vetting

3.29 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. 

3.30 Force policy U01g (Warrant and identity/access cards) for the issue of identity cards to persons subject of this SOP, must be adhered to.

3.31  In order to avoid any disputes on vetting, contracts and agreements must contain clauses mandating this vetting procedure (together with details of charges for contractor vetting where appropriate) and the force's right to exclude any person from having access to force premises, force databases or sensitive information, in some instances without explanation.

National Contractor Vetting Scheme

3.32 Warwickshire Police on behalf of all UK police forces, run the National Contractor Vetting Scheme and vet contractors who work across a number of forces to a level appropriate to the requirements of the Vetting Code of Practice and APP Vetting, and act as an authority in this regard. A database containing a full list of companies participating in the scheme and details of members of their staff who have received NPPV clearance, is available within the Central Vetting Unit. 

3.33 The National Contractor Vetting Scheme eradicates the need for forces to duplicate the vetting of contractors who require access to more than one police force. The contractors pay for the vetting enquiries.

7- Force Strategic Collaboration Programme - charging for contractor vetting

3.34 On 26 July 2016, the 7-Force Eastern Region Alliance Summit comprising the chief constables and Police and Crime Commissioners for Bedfordshire, Cambridgeshire, Essex, Hertfordshire, Kent, Norfolk and Suffolk agreed that a charge will be levied for vetting of contractors. Charging applies to NPPV Levels 1, 2 (abbreviated), 2 (full) and 3 and applies to new contracts on or after 1 April 2017. Charges will not apply to existing contracts that were live as at 1 April 2017. NPPV2 (Abbreviated), NPPV2 (Full) and NPPV3 chargeable vetting is administered by the National Contractor Vetting Scheme.

Re-vetting criteria

3.35  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.  

Responsibility for carrying out the process

3.36 The Vetting Team Leaders are responsible for the administration of the process in liaison with the following:

• Business Centre for recruitment where the individual will be working for the force
• county-wide volunteer co-ordinators for volunteers
• liaison sponsors for partnership contractors
• estates and facilities departments for regular contracted staff
• PCC’s office for staff/volunteers within the remit of the PCC’s office, i.e. lay custody visitors and staff recruited directly by the PCC

Finances

3.37 Financial checks are required for NPPV Levels 2 (full) and 3.

3.38 An Experian credit reference check will be carried out to establish the financial status of the applicant. The information obtained will be cross-referenced against the information provided by the applicant. Serious financial difficulties are likely to lead to rejection.

Decision making

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

3.40 Once a decision has been made, the sponsor/company/organisation is advised and if vetting clearance is granted a copy of the vetting certificate is sent electronically. If vetting clearance is refused a refusal certificate is sent to the sponsor/company/organisation electronically. For vetting refusals, all submitted paperwork and generated intelligence will be retained securely on the CVU database, Corevet, for one year from the date of notifying the applicant of the result.

Contract negotiations

3.41 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 and charges apply to contractor vetting. In whatever category, binding terms must include the fact that contractors’ staff must notify the CVU of any relevant changes to their personal circumstances.

Residency criteria

3.42 The residency criteria for all applicants are outlined in SOP P04k residency criteria.

Interpreters

3.43 Vetting for interpreters is carried out under the National Contractor Vetting Scheme, administered by Warwickshire Police and West Mercia Police, who are in a strategic alliance, in accordance with the requirements of the Vetting Code of Practice and APP Vetting.

Counter Terrorism and Security Act

3.44. The Counter Terrorism and Security Act 2015 places a duty upon specified authorities (which includes the police) to ensure that their functions are discharged having due regard to the need to prevent people being drawn into terrorism. Our staff are not immune from radicalisation, therefore if such concerns regarding an individual or institution are identified, these should be referred to the Kent Police Prevent Team via the FIMU at Kent SB JIU.

Vetting refusals and withdrawals

3.45. Non-police personnel are able to submit an appeal against decisions made to refuse or withdraw force vetting clearance. Where vetting is refused, the applicant may send a written request seeking a review to the force vetting manager within 14 days of receipt of notification of vetting refusal. The review will be conducted by the Force Vetting Manager who will aim to review the case as soon as possible, and provide the applicant with a written statement outlining the result of the review. The decision reached will be final.

3.46. Where vetting clearance is withdrawn, the applicant may send a written request seeking a review to the head of professional standards within 14 days of receipt of notification of the vetting withdrawal. The review will be conducted by the Head of Professional Standards who will aim to review the case as soon as possible, and provide the applicant with a written statement outlining the result of the review. The decision reached will be final. In respect of reviews for both vetting refusal and withdrawal, third party review requests will not be considered and there is no right of personal representation.

3.47 Where the force takes a decision to refuse or withdraw non-police personnel national security vetting clearance (which is separate from Force Vetting), the applicant may send a written request seeking a review to the Head of Professional Standards within 14 days of receipt of notification of the vetting withdrawal. The review will be conducted by the Head of Professional Standards who will aim to review the case as soon as possible, and provide the applicant with a written statement outlining the result of the review. If the applicant remains dissatisfied, there is right of appeal to the Security Vetting Appeals Panel (SVAP).

4. Equality Impact Assessment (EIA)

4.1. An EIA has been carried out and shows the proposals in this policy would have no potential or actual differential impact on grounds of race, ethnicity, nationality, gender, transgender, disability, age, religion or belief or sexual orientation.

5. Risk assessment

5.1 This SOP has been assessed as medium risk.

6. Consultation

• Head of Emergency Planning
• Central Vetting Unit
• Human Resources
• IT Security
• Legal
• Freedom of Information
• Health and Safety
• Finance

7. Monitoring and review

7.1 This SOP will be monitored, and reviewed after two years, by the Force Vetting Manager. The monitoring will take into consideration any changes in relevant legislation or procedures impacting on non-police personnel vetting.

8. Other source documents

None listed.

9. Security

9.1 Kent Police have measures in place to protect the security of your data in accordance with our Information Management policy (Policy W1000 – Information Management).

10. Retention and disposal of records

10.1 Kent Police will hold data in accordance with our Records Review, Retention and Disposal policy (Policy W1012 – Records Review, Retention and Disposal).