IPCO Annual Report 2018
Inspections
11.5
Our intention is to inspect all UK LEAs annually,29 and 39 authorities were inspected in
2018. There are two visits to each authority, the first looking at the acquisition of CD and
the second looking at property interference under the Police Act, along with Covert Human
Intelligence Sources (CHIS) and surveillance activities under RIPA. Where possible, we carry
out both inspections at the same time.
11.6
In addition, we conducted 46 inspections of renewal of authorisations in respect of 76
relevant sources (undercover operatives) under the enhanced oversight and authorisation
regime in Statutory Instrument 2013/2788.
Findings
11.7
With regard to CHIS and surveillance under RIPA, we noted, in general, that the existence
of experienced and specialist teams is important to establishing and maintaining a good
level of compliance. Although standards vary across law enforcement, we are content
that appropriate processes are in place and that cases are handled in compliance with the
new (CoP).
11.8
We have continued to note a good level of compliance across law enforcement in relation
to property interference. We made no substantial recommendations in this area in 2018.
11.9
We made several recommendations to the intercepting agencies to support the transition
to the IPA so that, while maintaining the current high standards, they would be compliant
with the new CoP. The majority of our recommendations related to administrative
processes and all have now been implemented. There were no themes that caused us
particular concern.
11.10
We were generally satisfied with the methodology applied across LEAs in relation to CD.
We note that the workflow systems currently available should decrease the likelihood of
manual errors occurring and have encouraged forces to use these to improve the clarity of
their records. In particular, where possible, we encourage Single Points of Contact (SPoCs)
to use workflow system functionality to make explicit which data lines will be renewed. It is
also reassuring that workflow systems are being used to record urgent oral authorisations;
we believe that this approach to maintaining comprehensive records represents
best practice.
11.11
We have seen some forces introduce a validation check via a second SPoC for applications
to resolve Internet Protocol Addresses; given the higher number of recordable errors in this
area, we would encourage this practice.
11.12
As well as a summary of our findings, the below includes examples of some more specific
recommendations to highlight some of the key outcomes from our inspections.
29 Certain inspections were postponed in 2018 owing to: the involvement of Inspectors in the evolution of IPCO; a large number of
vacant positions; and the need to train Inspectors in the new Investigatory Powers Act 2016. We deferred inspections which we
judged to be lower risk. Those inspections were completed in 2019.
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