Investigation into recruitment irregularities and the actions of a civilian staff member – British Transport Police, June 2018

British Transport Police · Ref: 2018/104270, 2018/111500

Recommendation date: 15 December 2022

Response due: 9 February 2023

Published: 28 June 2023

In November 2015 and May 2018, two different job roles were advertised as new vacancies within the British Transport Police (BTP) Legal Services directorate. A candidate, who had worked previously with the panel chair at another company, was offered the first role before the process closed. The panel chair continued to be involved with the recruitment process despite the conflict of interest. Staff accounts contained discrepancies over whether the candidate attended relevant assessments and interview.In the second recruitment process, an applicant passed the assessment and interview, but the outcome was delayed. Representations were made to senior managers that the role required a higher salary and change in responsibilities to attract a preferred candidate. The applicant who had passed the assessment at the lower pay grade was told she was unsuccessful. The role was re-advertised at the higher rate and the preferred candidate applied. Before attending an interview, the professional standards …

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Recommendations (7)

Recommendation 1 Accepted

Recommendation

The IOPC recommends that British Transport Police reviews how it manages interactions with people who report wrongdoing through the internal CARS reporting system. This should include both how they are kept informed and their involvement in providing information to the … Read more

Force Response

Accepted action: The CARS system was an anonymous reporting system for information to be passed directly to Professional Standards. BTP have changed the system and relaunched a new anonymous reporting system named ‘Speak Up’. The new system had a high-profile … Read more

Recommendation 2 Accepted

Recommendation

The IOPC recommends that British Transport Police considers working practices in the Professional Standards Department to consider and take action to address any issues with: During our investigation we found that there were various issues with the processes followed in … Read moreThe IOPC recommends that British Transport Police considers working practices in the Professional Standards Department to consider and take action to address any issues with: During our investigation we found that there were various issues with the processes followed in PSD. PSD Investigators’ Reports reviewed during the investigation did not identify the specific evidence that was being relied upon to express views and reach conclusions. This meant that appropriate authority delegates were not always provided with the fullest information to make their decisions. IOPC statutory guidance states in chapter 14 that both special procedures and non-special procedures investigations should include an accurate summary of the evidence and should attach or refer to any relevant documents. Evidence obtained during the investigation showed that a supervisor amended a draft report provided to him with an opposing view. There was no record of the original author accepting those changes or a review of the evidence that supported that view meaning that the process that led to the final report was not transparent. The investigation identified that PSD investigators were using different methods of recording policy decisions. One DI stated that all decisions are recorded on Centurion to negate the need for paper records while another had a formal policy book in which decisions were recorded. This can cause problems for overseeing the progress of the investigation and having a clear audit trail. We were told during the investigation that it was common practice that where no formal witness statement is being taken, it is common practice to summarise the conversation within the Investigator’s Report and that at least one investigator believed there was no requirement to add it to the Centurion system. This could mean that the investigation does not have access to the full evidence provided by the witness or that evidence could be misrepresented within a report with no means of verifying it. During the course of the PSD investigation, the PSDIU Appropriate Authority asked a DI to perform a limited review of facts that had been presented. On conclusion of this task, a short report was provided which indicated the original responses by the subject were incorrect and open to challenge. It has become apparent that this report was not shared with the DCI of the PSD reactive team, whose responsibility it was to arrange for the matter to be re-investigated and the issues in the report addressed. Do you accept the recommendation? Yes Show less

Force Response

Accepted action: Below details action taken against each bullet point issue. It should be noted that this recommendation comes several years after the investigation, and systems and practices in BTP PSD are significantly different. The regulations have changed, and the … Read more

Recommendation 3 Accepted

Recommendation

The IOPC recommends that British Transport Police reviews the current practice of passing investigations between different teams within the Professional Standards Department and different appropriate authority delegates and sets out clear roles and responsibilities for all those involved in carrying … Read more

Force Response

Accepted action: We have updated the operating practices within BTP PSD and embedded these over the past 18 months. An investigation would now only be passed to another investigating officer in exceptional circumstances. The Appropriate Authority positions are now well … Read more

Recommendation 4 Accepted

Recommendation

The IOPC recommends that British Transport Police reviews its recruitment policy in light of the issues raised in this investigation and makes amendments to address any areas for improvement. This should include: As part of an IOPC investigation we reviewed … Read moreThe IOPC recommends that British Transport Police reviews its recruitment policy in light of the issues raised in this investigation and makes amendments to address any areas for improvement. This should include: As part of an IOPC investigation we reviewed British Transport Police’s recruitment policy. We found that some of the areas that came up as issues in the investigation could benefit from more clarity which may help avoid similar situations arising in future. While the recruitment policy does set out who should perform certain tasks, this does not appear to have been adhered to, for example things which should be done by HR being done by the hiring manager or others on their team, and this was not challenged. Other obligations were not carried out at all. British Transport Police may want to consider whether a simple recruitment checklist, completed for each recruitment exercise, may assist in ensuring that all steps are taken by the appropriate person and there is clear accountability for this. Any review of roles and responsibilities needs to be realistic about what can be achieved with the resource available. For example, there seemed to be an impression that although the policy says “Where possible HR or Recruitment representatives must be included in interview panels” there were never the resources available for this. In this investigation, an external person who had previously supported an interview panel and provided questions to them for the recruitment exercise was a candidate in the same recruitment exercise with no formally documented actions to mitigate any conflict of interest. There was also evidence of previous contact with candidates not being acknowledged or consideration given to whether there was a potential conflict of interest. This leaves recruitment open to suggestions of bias and unfairness. An external panel member was engaged to support a recruitment process with technical however they were not vetted and were provided with personal information about candidates which could create data protection issues. Do you accept the recommendation? Yes Show less

Force Response

Accepted action: Our current Police Recruitment & Selection policy was reviewed in 2019. This provides a standard operating procedure for the Police Staff Recruitment Process and the Shortlisting and Interview sub-process. This Policy described the roles and responsibilities for both … Read more

Recommendation 5 Accepted

Recommendation

The IOPC recommends that British Transport Police puts in place measures to ensure that the recruitment policy is adhered to. This follows an IOPC investigation which considered two separate recruitment exercises. Although there was a recruitment policy in place, this … Read more

Force Response

Accepted action: Since this case happened additional investment in Recruitment has seen extra resources in place to oversee campaigns and handling. A new Team Leader role for Police Staff recruitment is in place which provides greater supervision and oversight. The … Read more

Recommendation 6 Accepted

Recommendation

The IOPC recommends that British Transport Police put in place a robust process for visitors to BTP premises to sign in and, where appropriate, be accompanied by a BTP employee. The IOPC investigation examined visitor logs for BTP’s Leeds office … Read more

Force Response

Accepted action: BTP have had Physical Security Policies in place before and after the relevant period of Op Myall, all of which provided proportionate but robust guidance on visitor management. Had the 2015 version of our policy been followed, Recommendation … Read more

Recommendation 7 Accepted

Recommendation

The IOPC recommends that British Transport Police puts in place mechanisms to monitor deletion of documents or files from shared and personal computer drives and to recover them where appropriate. In this investigation, allegations were made about the deletion of … Read more

Force Response

Accepted action: BTP Technology has already greatly improved since the events examined by Op Myall. Supported by considerable investment, particularly since March 2020, our adoption of Cloud based storage and Microsoft Office 365 have significantly improved our ability to monitor … Read more