Recommendation 1
IOPC recommendationThe IOPC recommends that, where information or intelligence is obtained by the MPS about a potential declarable association, or an actual or perceived inappropriate relationship which does not amount to potential conduct, that an intervention with the officer or staff member in the form of a reminder of the declarable association policy and invitation to consider their current relationships in conjunction with the policy, be considered in order to mitigate any future risk to themselves and/or others. This follows an investigation where, the MPS DPS on two occasions were informed of the relationship between Male A and the subject by another police force. Despite there being a mechanism in place for the DPS to alert officers when they are in a potentially declarable relationship, this route was not taken. Furthermore, in both cases, the investigation was initially closed with no further action. The rationale centred largely around the fact that Male A was above the age of consent, and the sex was described by Male A as consensual. It was only when information came to light about Male A’s additional vulnerabilities, that the case was re-opened and referred to the IOPC.
Accepted
The recommendation has been accepted by the DPS (Directorate of Professional Standards) Intelligence Bureau and is predominantly managed by the DPS Integrity Assurance Unit.
Below is a general response with further detail extracted from the MPS Declarable Associations Policy added at the end of this response.
The current and published MPS policy on Declarable Associations provides for circumstances whereby an association has been identified that may present risk but the officer or member of staff has not disclosed the association and/or maybe be unaware of the need to disclose. The published process allows for the association to be risk assessed and managed by the Directorate of Professional Standards whilst ensuring compliance with GDPR and Data Protection Legislation.
The policy is readily available on the MPS Intranet. New recruits are given training input regarding Declarable Associations and local awareness and reinforcement is provided by BCU/OCU-specific Professional Standards Units. We are consistently finding information regarding potential Declarable Associations through the ongoing integrity screening measures we have adopted. This includes regular checks as to maintain high standards and as part of the aftercare of our officers and staff, and information we find through legacy operations such as our PNC and PND data washes. We are using these as opportunities to remind our officers and staff of the Declarable Opportunities policy and to consider their current relationships relative to this.
The case in question was, on both occasions, dealt with as potential misconduct and referred for assessment and recording and was not initially treated as a Declarable Association.”
Extracted from the MPS Declarable Associations Policy on the MPS intranet:
‘MPS officer or staff member becomes aware of a relationship held by another MPS officer or staff member that it considers might be declarable. All MPS police officers and staff are required to report and challenge conduct that has fallen, or appears to have fallen, below the required standards. Where an officer or staff member becomes aware of an individual who has an association that should be declared in line with this policy, they have a responsibility to report them to their line manager, or Appropriate Authority. Further options are available via the Raising concerns Policy.’