Investigatory Powers Commissioner’s Annual Report 2019
15.9
In 2018, we also highlighted concerns about the adequacy of training for Authorising
Officers (AOs). We have not seen substantial progress in this area but understand that
HMPPS intend that a regional restructuring, centralising the AO role, will improve this area
by creating a smaller group of trained officials to review and authorise applications. This
restructuring is described in further detail below.
Directed
Surveillance
Figure 21: 2019 CHIS and directed surveillance activity at HMPPS, SPS and NIPS.
2019
2018
Her Majesty's Prison and Probation
Service (HMPPS)
Northern Ireland Prison Service (NIPS)
Scottish Prison Service (SPS)
CHIS
2019
2018
0
10
20
30
40
50
60
15.10
The most recent inspection of HMPPS led to continued concerns regarding compliance
levels. Policies and Prison Service Instructions remain outdated and newly proposed
replacements still need approval and implementation. We found some improvement in
the procedures adopted for the management of applications and authorisations. However,
ongoing inconsistencies and consequential compliance issues demonstrate that there is
still significant work to be done. The delay in implementing commercial software which
has been purchased by HMPPS remains a frustration. The expected improvement in the
operational competence of AOs has not materialised. HMPPS are aware of these concerns
and their obligation to implement remedial measures.
15.11
HMPPS have proposed structural changes which would introduce a regional model. The
concept of regionalisation of the application process for RIPA powers has been discussed
over the last two years. This would create professional RIPA applicants and a small cadre
of trained regional AOs, which would almost certainly have a positive impact on the
compliance levels that currently exist. It is encouraging that the model has secured strategic
support, funding from HM Treasury and that posts are being filled.
15.12
Despite the challenges HMPPS face, we have noted some impressive and inventive work
during our inspections. A separate inspection of the HMPPS Digital Investigation Unit
highlighted some innovative work and HMPPS are well placed nationally with regard to the
use of the internet for investigative purposes. We hope that the policies and procedures
that they have in place will enable this work positively to develop in the coming years.
CHIS in Scottish Prisons
15.13
We have found that the SPS has an excellent working relationship with Police Scotland
regarding the management of CHIS in prisons. Members of the SPS are co-located with
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