Recommendations - Greater Manchester Police, December 2020

The IOPC recommends that GMP update their policies on the use of personal social media to reinforce to officers and staff that using personal social media to contact members of the public they have met through their work or duties is not acceptable. This message should be made explicit and unambiguous to all officers and staff, and may require dedicated inputs or line manager discussions to ensure understanding.

This follows an IOPC investigation into a complaint made about a GMP staff member’s social media contact with a child who he met through his policing duties. GMP's social media policies and guidance lacked explicit instructions to officers and staff that personal social media should not be used to contact members of the public they have met through their work.

Do you accept the recommendation?

Yes

Accepted action:

​The Media and Social Media Communications Policy and Procedure has been re-written in October 2020 and is with the Assistant Chief Constable for approval and sign off.

PSB were one of the stakeholders who initiated the re writing of the document and have been a key contributor to the policy throughout having consulted with the staff within the PSB for their thoughts and feedback. It is acknowledged that the previous policy lacked detail particularly around the personal use of social media and what was permitted.
The new policy is now much more detailed with dedicated sections including;
Official Corporate, official group, official other, individual professional or individual personal accounts.

To emphasise the issue and dangers around contacting members of the public they have met through their work, section 5.17.3 of the report, under "key principles" includes a section which states;

•Individuals should never contact a victim or witness through their own social media accounts. This includes personal-professional and personal-individual accounts. Doing so crosses the boundary between work and personal life and could give false or misleading messages to that person. Officers accused of serious corruption within the police in cases of abuse of position for sexual purpose often started their campaigns to target vulnerable persons by contacting them in this way.

As has been recommended in the IOPC report, the dissemination of this policy is a key priority to ensure that the workforce with the organisation are completely clear around their use of social media. Education has already started on this with inputs being given by the branch's Organisational Learning team to the new student officers on day three of them joining GMP where amongst other important messages, their use of social media is one that we put a very strong emphasis on.

We are also providing inputs to the newly promoted Sergeants courses where we are emphasising the perils of misuse of social media and requesting that they take this message away from the input and cascade it to their staff via briefings and one to one discussions.

How GMP communicates key messages to staff is an ongoing action at the forces Strategic Organisational Learning Board that is chaired by the Deputy Chief Constable. This issue was raised at a recent board where the DCC gave head of Corporate Communications an action to produce a full Communications plan around learning within the organisation. Some of the suggestions being muted are a monthly learning bulletin similar to what is produced by the IOPC and a top 10 themes for learning which will feature prominently on the force's intranet page as well as being disseminated at briefings and Continuous Personal Development events.

The IOPC recommends that GMP ensure that officers and staff working with children in any capacity are aware of the appropriate communications channels and that contact with a child via social media is never appropriate.

This follows an IOPC investigation into a complaint made about a GMP staff member’s social media contact with a child who he had met through his policing duties. The investigation found that work to improve in this area has been implemented as a result of another investigation which related to the Volunteer Police Cadet (VPC) scheme, but GMP should confirm that this message is also being received outside of the official VPC scheme.

Do you accept the recommendation?

Yes

Accepted action:

​GMP has a responsibility to protect and promote the safety and wellbeing of everyone involved in the VPC, both online and offline. Therefore, it is important to ensure all staff and volunteers involved in the VPC are aware of their responsibilities relating to the use of technology and social networking sites.

A Statement of Purpose, outlining GMPs expectations relating to online content can be found on the National VPC Safeguarding Guidance A-Z webpage, https://vpc.police.uk/media/1708/82-social-media-statement-of-purpose.pdf

The following guidelines apply to all VPC social media accounts and must be adhered to:

• only official GMP VPC social media accounts and the Marshall platform should be used for any business relating to the VPC
• all VPC social media accounts must be approved by the central VPC team and only approved individuals can use these accounts, details of all those who have access will be stored centrally
• staff/ volunteers should not make friend requests to young people, they can only accept them. Staff are responsible for ensuring that member social media accounts are genuine before accepting requests
• staff/volunteers should not ‘friend’, ‘connect’, ‘follow’ their own personal account or that of theirs friends/family/personal associates
• communication with cadets should take place in open forums such as the main Facebook/Instagram page, groups or group messages. Another member of staff must always be made aware of and check when the group message function is used
• communication with cadets through social media must always be for a specific purpose such as planning an event or sharing information and we should avoid excessively social chat and conversation and mindful of the time at which they are communicating
• the private or direct messaging function in a one to one setting must not be used. If a cadet tries to make contact using the private or direct messaging function it should be responded to in an open forum or by another means of communication

Staff and volunteers involved in the VPC should not have any contact with cadets through personal social media accounts or any other form of personal, electronic communication such as email. If a young person attempts to make contact with staff or volunteer online this should be reported to a supervisor and the Central VPC team to be logged on the VPC risk register. The same procedure applies if any adult involved in the VPC has a legitimate reason to have online contact with a cadet.

GMP's Safeguarding Adults and Young People Lead has devised a new safeguarding policy as part of his role which will be disseminated in similar ways to the Social Media Policy. This will ensure that the message is also received outside of the official VPC scheme. This information will also be included in the Volunteer Police Cadet (VPC) newsletter. He is also establishing networks and contacts with school based officers and will ensure the information is cascaded as part of is wider work on safeguarding. He is also working on a safeguarding policy for apprentices which will include similar guidance and dissemination strategies.

The IOPC recommends that the Police Staff Council strengthen the Standards of Professional Behaviour (September 2008) in respect of ‘Authority, Respect and Courtesy’ to make it explicit to police staff that they should not establish or pursue an improper sexual or emotional relationship with a person with whom they come into contact in the course of their work who may be vulnerable to an abuse of trust or power.

This follows an IOPC investigation into a complaint made about a police staff member’s social media contact with a child who he had met through his policing duties. The investigation found that the Standards of Professional Behaviour for police staff did not provide clear expectations in relation to abuse of position for sexual purposes

Do you accept the recommendation?

No

1. The IOPC has not provided any evidence to us that the case against the individual referred to in your email was hampered in any way by the lack of any explicit injunction to refrain from abuse of position for sexual gain in our Standards;
2. We believe that the case against the individual referred to in your email would have been adequately covered by any one, or all three, of the following existing PSC Standards:
   1. Honesty and Integrity
   2. Authority, Respect and Courtesy
   3. Discreditable Conduct
3. In particular, the following injunction under the ‘Authority, Respect and Courtesy’ standard would have applied in full to the case to which you refer:
   1. Police staff do not abuse their powers or authority and respect the rights of all individuals.
4. In the introduction to the PSC Standards it is made clear that ‘They are not intended to describe every situation but rather to set a framework which everyone can easily understand.’ Were we to add additional injunctions to the Standards to cover specific
   circumstances we believe these would in time become unwieldy and unmanageable.
5. The College of Policing’s Code of Ethics sets out very clearly under Standard Two ‘Authority, Respect and Courtesy’ that staff and officers shall:
   ‘…not establish or pursue an improper sexual or emotional relationship with a person with whom you come into contact in the course of your work who may be vulnerable to an abuse of trust or power.’
6. The NPCC National Strategy to address the issue of police officers and staff who abuse their position for a sexual purpose or to pursue an improper emotional relationship provides additional guidance.
7. The PSC Standards deliberately mirror the police officer standards, with some differences to acknowledge the separate employment status of the two groups, and as far as we are aware, there has been no similar request to the Home Office to amend the officer standards in the way that the IOPC recommends we change our Standards.