Combined Financial Regulations .pdf

Reserves Policy 2025-26.docx

Estimated Reserve Position (Jan 2025).xlsx

STANDARD OPERATING PROCEDURES: OFFICE OF THE BEDFORDSHIRE POLICE AND CRIME COMMISSIONER

 

Title	Police and Crime Commissioner/Deputy Police and Crime Commissioner Code of Conduct
Version No.	3
Senior Lead	Head of Governance and Compliance
Author	Compliance

 

Revision History

Date	Revision	Change	Next Review Date
19/08/2022	2.0	Complete review	19/08/2023
09/10/2023	2.0	No changes	09/10/2024
20/08/2024	2.0	Update of Combined Financial Regulations URL link	20/08/2025
13/08/2025	3.0	Changed Logo, links updated, and grammar amended	20/08/2026

 Introduction

The Code of Conduct applies to the Police and Crime Commissioner for Bedfordshire (PCC), and any Deputy Police and Crime Commissioner for Bedfordshire (DPCC) when acting or representing within that role.

The Code does not apply when the PCC or DPCC is acting in a purely private capacity, although high standards of behaviour are always expected from the PCC/DPCC including in their private affairs.

This Code of Conduct applies to the individual when they are acting in their capacity as PCC/DPCC which may include when:

• They misuse their position as a PCC
• Their actions would give the impression to a reasonable member of the public with knowledge of all the facts that they are acting as a PCC.

The Code applies to all forms of communication and interaction, including but not exclusive to:

• at face-to-face meetings
• at online or telephone meetings
• in written communication
• in verbal communication
• in non-verbal communication
• in electronic and social media communication, posts, statements, and comments.
• in videos/blogs/podcasts

Any individual to which this procedure may apply is also expected to uphold the highest standards of conduct and always demonstrate leadership when acting as PCC/DPCC.

1.   General Obligations

The Policing Protocol Order 2011 (issued under the Police Reform and Social Responsibility Act 2011) requires that all parties to whom the Protocol applies will abide by the seven

principles set out in Standards in Public Life: First Report of the Committee on Standards in Public Life, known as the Nolan Principles.

The PCC/DPCC is expected to abide by the Nolan Principles in the following manner:

• SELFLESSNESS - Holders of public office should act solely in terms of public interest. They should not do so to gain financial or other material benefits for themselves, their family, or their friends.
• INTEGRITY - Holders of public office should not place themselves under any financial or other obligation to outside individuals or organisations that might seek to influence them in the performance of their official duties.
• OBJECTIVITY - In carrying out public business, including making public appointments, awarding contracts, or recommending individuals for rewards and benefits, holders of public office should make choices on merit.
• ACCOUNTABILITY - Holders of public office are accountable for their decisions and actions to the public and must submit themselves to whatever scrutiny is appropriate to their office.
• OPENNESS - Holders of public office should be as open as possible about all the decisions and actions that they They should give reasons for their decisions and restrict information only when the wider public interest clearly demands.
• HONESTY - Holders of public office have a duty to declare any private interests relating to their public duties and to take steps to resolve any conflicts arising in a way that protects the public interest.
• LEADERSHIP - Holders of public office should promote and support these principles by leadership and example. In addition, all colleagues, partners and members of the public have the right to be treated equally and should not be discriminated against on the grounds of age, disability, gender reassignment, pregnancy, maternity, race, religion or belief, sex, sexual orientation or marital/civil partnership status. The PCC/DPCC has a responsibility to ensure that the office’s Equality Policy is adhered to in all work activities.

The PCC/DPCC must treat the public, partners, and colleagues fairly, efficiently, politely and in line with the Office of the Police and Crime Commissioner (OPCC) policies. In addition, the PCC/DPCC will do the following:

• Commit to publishing and abide by this ethical Code of Conduct and will ask his/her Deputy to do the same if in post.
• Ensure an open and transparent process when appointing the Chief Constable and all key staff and include an independent external member on the appointing
• Publish up-to-date accessible data on his/her pay, rewards, gifts and hospitality, business interests and notifiable memberships on the OPCC

2.       The Police and Crime Commissioner Oath

 All PCCs take an oath when accepting their role, which includes a commitment to act with impartiality, integrity, and transparency. The PCC pledges to lead policing for the people and therefore the PCC is not only responsible for their own ethical standards but for the standards of those in their office and those of the Chief Constable.

3.   College of Policing Code of Ethics

 The College of Policing Code of Ethics sets out policing principles and the standards of behaviour expected of police forces in England and Wales. The Commissioner will abide by the Code of Ethics, promote the Code amongst the OPCC staff and ensure that it is embedded in both the OPCC and the wider Force.

Code of Ethics | College of Policing

4.   Use of resources

The PCC is responsible for ensuring effective and efficient use of public resources.

The PCC will use resources responsibly and will always look to provide value for money. There are legal requirements, policies and procedures in place concerning the use of resources.

Policies and procedures Financial regulations including contract standing orders can be found on the policy section of the OPCC website.

The PCC will not use the resources of the Office of the Police and Crime Commissioner/Bedfordshire Police for personal benefit or for the benefit of any other person in relation to any personal business interest.

These resources will not be used improperly for political purposes, including political purposes. The PCC/DPCC will only claim expenses and allowances in accordance with the expenses policy that is aligned to the Home Office published scheme.

The Expenses Policy can be found on the policy section of the OPCC website. The GOV.UK website also provides guidance on expenses for PCC’s.

5.   Confidentiality and the General Data Protection Regulation

The PCC/DPCC will respect the confidentiality of the information to which they have access to because of their role. This includes respecting the interests of OPCC colleagues, officers and staff from Bedfordshire Police, partner organisations and from the public. Any information to which access is available must not be used for personal gain or passed on to others who might use it in this way.

The PCC/DPCC must not discuss confidential matters including the contents of confidential documents unless permitted to do so. The PCC/DPCC will not disclose information given to him/her in confidence or information acquired which is of a confidential nature, unless they have the consent of a person authorised to give it; they are required by law to do so (for example for safeguarding) or for the lawful purposes of the OPCC.

Any disclosure of information made must be reasonable, proportionate, and legal.

The PCC/DPCC will not prevent another person from gaining access to information to which they are entitled by law. Data Protection Act 2018 laws are always observed.

6.   Register of Disclosable Interests

The PCC/DPCC will declare any disclosable interests, including those arising in relation to gifts and hospitality and those of a pecuniary nature. He/she will act solely in the public interest and in exercising the functions of the office, will not act to gain financial or other benefits for his/herself, family, friends, or any person in relation to any business or use or attempt to use the office to confer or secure for any person, including his/herself, an advantage or a disadvantage.

Within 28 days of taking office, the PCC will enter any disclosable interest into the register held in the OPCC. This must be reviewed on an annual basis.

PCC Register of interest published on the website

Deputy PCC Register of interest published on the website

This register will be updated within 28 days of any change in circumstances.

7. Conflicts of Interests

In any case where the interests of exercising the functions of the Commissioner may conflict with any disclosable or other interest which has become known to them, they will as soon as possible declare such conflict to the Head of Governance and Compliance. In consultation with the Chief Executive/Monitoring Officer and the Head of Governance and Compliance, it will be determined whether the conflict of interest is so substantial that the function should not be exercised personally but should be delegated or dealt with in some other manner to ensure the conflict of interest does not arise.

If the PCC/DPCC acting in the capacity of the PCC/DPCC, is involved in any civil or criminal legal proceedings or any legal proceedings these should be reported to the Chief Executive/Monitoring Officer and/or Deputy Monitoring Officer as most expedient.

8.   Transparency

The Register of Interests and Register of Gifts and Hospitality will be published on the OPCC website.

Meet the team

9. Making a complaint about the Commissioner or DPCC

If a member of the public, employee or partner organisation wishes to raise a concern/complaint about the conduct of the PCC, this should be reported to the Chief Executive/Monitoring Officer and sent to the Police and Crime Panel for consideration.

Bedfordshire Police and Crime Panel | Bedford Borough Council

If a member of the public, employee or partner organisation wishes to raise a concern/complaint about the conduct of the DPCC, this should be reported to the Chief Executive/Monitoring Officer for consideration.

Click the link to download Policy

STANDARD OPERATING PROCEDURES: OFFICE OF THE BEDFORDSHIRE POLICE AND CRIME COMMISSIONER

Title	Expenses Policy
Area of Compliance	Compliance
Version No.	1.1
Senior Lead	Chief Executive
Author	Compliance

 

Revision History

Date	Revision	Change	Review Date
01.07.2017	1.0	New Document	01.07.2018
28.09.2018	1.0	No Change	28.09.2019
18.06.2019	1.0	No Change	18.06.2020
19.06.2020	1.0	No Change	19.06.2021
17.09.2021	1.0	No Change	17.09.2022
17.10.2022	1.0	No Change	17.09.2023
29.09.2023	1.0	No Change	17.09.2024
20.08.2024	1.0	No Change	20.08.2025
13.08.2025	1.1	Logo, links and grammar updates	20.08.2026

 

Expenses of the Police and Crime Commissioner

Secretary of State for Home Department - determination on Police and Crime Commissioner expenses

Introduction

Paragraph 3 of Schedule 1 to the Police Reform and Social Responsibility Act 2011 ('the 2011 Act') provides that a Police and Crime Commissioner (PCC) is to be paid authorised allowances. 'Authorised allowances' means allowances in respect of expenses incurred by the Commissioner in the exercise of the Commissioner's functions, which are of the kinds and amounts determined by the Secretary of State. The determination under paragraph 3 may make different provisions for different cases.

Authorised allowances

The purpose of authorised allowances is to reimburse expenses incurred by PCCs in carrying out their duties, not to provide a general gratuity for undertaking the role.

Commissioners are paid a salary determined by the Secretary of State on the advice of the senior salaries review board.

The kinds of allowances determined by the Secretary of State for the purposes of paragraph 3 of Schedule 1 to the 2011 Act are allowances in respect of:

• travel expenses
• subsistence expenses
• exceptional expenses
• reasonably incurred by a PCC in the exercise of the commissioner’s

The amounts of such allowances determined by the Secretary of State are set out in the table below:

Table of PCC authorised allowance amounts

Type of expense	Key Restriction	Rates
Train	In course of business	Reimbursed up to standard class rates
Mileage allowances	Only if necessary	As per HMRC rates
Taxis	Only where public transport not available	Cost of taxi fare
Foreign Travel	Prior authority from Chief Executive and for Business Purposes	Economy class for flights
Hotel Accommodation	Business purposes and agreed in advance. Value for money and best use of public funds – lower priced suitable accommodation	No explicit limitation on star standard of hotel accommodation
Subsistence (UK and Foreign)	Only paid for evening meals and, where applicable, breakfast (not lunch)	Breakfast £10, Dinner £30
Exceptional expenses not falling within any of the other types	Reasonable incurred in carrying out business of the authority	As approved by the Chief Executive

45p per mile for the first 10,000 miles, then 25p per mile

Chief Executive Approval

The Commissioner’s Chief Executive should subject all of the Commissioner’s claims for expenses to rigorous verification and auditing.

Any claims for exceptional expenses incurred by the Commissioner in the exercise of the Commissioner’s functions will require the approval of the Commissioner’s Chief Executive. In considering whether to grant this approval the Chief Executive shall consider the following factors:

• whether there are exceptional circumstances warranting additional support
• whether the Commissioner could reasonably have been expected to take any action to avoid the circumstances which gave rise to the expenditure or liability
• whether the Commissioner’s performance of their Commissioner functions will be significantly impaired by a refusal of the claim

In absence of the Commissioner’s Chief Executive, the Chief Finance Officer / S151 Officer is required to review and approve the Commissioner’s claims and expenses.

Publishing Allowances

Under paragraph 1(d) of the Schedule to the Elected Local Policing Bodies (Specified Information) Order 2011, PCCs are required to publish the allowances paid to them and to their deputies in respect of expenses incurred by the commissioner or deputy in the exercise of the commissioner’s functions.

PCCs and their deputies should publish a breakdown of their expenses including:

• their name, force area, financial year, month, date, claim reference numbers, expense type (e.g. travel, accommodation), short description, details, amount claimed, amount reimbursed, amount reimbursed, amount not reimbursed, and the reason why a claim was not reimbursed
• for travel and subsistence claims: date, place of origin, place of destination, category of journey, class of travel, mileage, length of hotel stay, category of hotel stays

Information Source: Information surrounding this policy can be found on the gov.uk website under publications.

For further information on Bedfordshire PCC, DPCC and CEO Expenses

Download the policy with this link.

STANDARD OPERATING PROCEDURES: OFFICE OF THE BEDFORDSHIRE POLICE AND CRIME COMMISSIONER

 

Title	Decision Making Policy
Area of Compliance	Compliance
Version No.	3.0
Senior Lead	Head of Governance and Compliance
Author	Compliance

Revision History

Date	Revision	Change	Review Date
01.05.2016	1.0	New Document	01.05.2017
01.05.2017	1.0	No Change	01.05.2018
28.09.2018	1.0	No Change	01.09.2019
01.09.2019	1.0	No Change	01.09.2020
19.06.2020	1.0	No Change	19.06.2021
17.09.2021	1.0	No Change	17.09.2022
17.10.2022	2.0	New OPCC logo added	17.09.2023
29.09.2023	2.0	No Change	17.09.2024
20.08.2024	2.0	No Change	20.08.2025
13.08.2025	3.0	Logo change and link updates	20.08.2026

 

A Policy Statement on decision making by the Police and Crime Commissioners for Bedfordshire, Cambridgeshire, and Hertfordshire

Introduction

The statutory framework for decision making by Police and Crime Commissioners (PCCs) consists of:

• Police Reform and Social Responsibility Act 2011 – this creates the PCC as a corporation sole, assigning functions, giving ancillary powers to facilitate the principal functions, and requiring that their decisions and actions be reviewed and scrutinised by a Police and Crime Panel. It also enables the Local Government Ombudsman to investigate any allegations of apparent maladministration by the PCC,
• The Policing Protocol Order 2011 highlights that the PCC will be responsible for the totality of policing and that their conduct must abide by the seven Nolan principles of good governance in public life,
• The Elected Local Policing Bodies (Specified Information) Order 2011 and The Elected Local Policing Bodies (Specified Information) (Amendment) Order 2012 set out the information which must be published relating to decision making,
• The Financial Management Code of Practice for the police service provides clarity around financial governance arrangements,
• Various general social and organisational legislation e.g., Human Rights Act 1998, employment law, local Government Acts.

The quality of a decision is usually judged on its outcome after the event. However, a robust decision-making process is likely to produce more consistent, reliable, and objectively sustainable decisions rather than a weak one. This policy and associated guidance seek to set the right framework to facilitate good decisions, which will inevitably range from routine administrative, technical, or professional decisions to those of significant public interest.

Decision making culture

Policing in this country is carried out with the consent of the public. If the public are to trust the PCC to use their powers wisely and fairly, and to continue to grant their consent, it is critical that clear ethical standards and the highest levels of integrity underpin the PCC’s decision-making process.

The principles set out below will help to ensure that the decisions of the PCC will comply with those aspirations and expectations.

Principles

The overarching principles for decision making to be adopted by the PCCs for Bedfordshire, Cambridgeshire and Hertfordshire (BCH) are that all decisions will be in accordance with the:

• powers and duties established within the statutory framework,
• good governance principles¹,
• Nolan principles²,
• good administrative practice³.

Good governance principles

Governance comprises the arrangements put in place to ensure that the intended outcomes for stakeholders are defined and achieved.

The fundamental function of good governance in the public sector is to ensure that entities achieve their intended outcomes while always acting in public interest.

Nolan principles

Selflessness Holders of public office should act solely in terms of the public interest.

Integrity

Holders of public office must avoid placing themselves under any obligation to people or organisations that might try inappropriately to influence them in their work. They should not act or take decisions to gain financial or other material benefits for themselves, their family, or their friends. They must declare and resolve any interests and relationships.

Objectivity

Holders of public office must act and take decisions impartially, fairly and on merit, using the best evidence and without discrimination or bias.

Accountability

Holders of public office are accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this.

Openness

Holders of the public office should act and take decisions in an open and transparent manner. Information should not be withheld from the public unless there are clear and lawful reasons for so doing.

Honesty

Holders of public office should be truthful.

Leadership

Holders of public office should exhibit these principles in their own behavior. They should actively promote and robustly support the principles and be willing to challenge poor behavior wherever it occurs.

Decision making process

Through adopting the above principles, the PCC will ensure that the right climate is set for decision making. These principles are all of critical importance but require the consistent application of good process. Although some of the decisions to be taken by the PCC will be of significant public interest, complex and costly, the basic process to be followed prior to each decision will be:

• all relevant material, information and facts will be assembled,
• consultation with all interested and affected parties,
• consideration of all available courses of action,
• specialist / significant advice sought,
• information presented which focuses on the core issues, and is consistent with the police and crime commissioner’s aims and objectives
• consider risk
• consider financial implications
• consider performance measures
• consider value for money
• consider equalities

The scale of each of the above elements will depend upon several factors such as the level of public interest, the risk, impact, complexity, and cost.

A plan for forthcoming business to be considered by the PCC will be maintained.

The PCC will make significant decisions at the PCC’s board meetings. The name of this board is different in the 3 offices, but all can be seen on the respective websites of the PCC and will include agendas, reports, and minutes subject to exemptions as detailed below.

Urgent decisions that cannot wait until the next scheduled board meeting because the public interest requires them to be made before such a meeting will be reported to the next board so that the decision can be seen as soon as practicable afterwards.

The ability of PCCs to make decisions quickly and in an agile way is a benefit of the system so board meetings need not consider routine decisions and those that follow a policy approved previously. They must, however, be recorded and follow the process above in a way that is proportionate to the importance of the decision.

All relevant decisions are presented to the Police and Crime Panel at each meeting.

Recording, transparency, and publication

The above policy principles require good record keeping, not only of the decisions taken by the PCC, but also the accompanying information and challenge, which supports each decision.

Therefore, the respective OPCC Chief Executive will ensure that a record of each decision is made, and all associated information is retained in accordance with the record management policy.

In addition, the Chief Executive will ensure that once decisions are taken by the Police and Crime Commissioner, they are effectively communicated both internally and externally and to ensure that any implementation and accountability arrangements are initiated.

The statutory requirements for transparency⁴ set out the minimum standards for access, publication, and availability of information. However, the Offices of the PCCs will ensure that all information used in coming to a decision will be made accessible to local people through a variety of means. The means will be determined by where the decision lies on the sliding scale of public interest including:

• Office of PCC website – decision records and associated papers,
• Media releases,
• Leaflets,
• Social media g., twitter, blogs,
• Web casts,
• Annual reports

Statutory Officers

The Chief Executive (Monitoring Officer) and Chief Finance Officer are part of the legal framework to report contraventions of the law, financial requirements, or maladministration. They have statutory responsibility for identifying contraventions and any deviation from the core principles of good governance and to report anything which gives rise to concern over a proposal, decision, or omission.

These post holders will therefore ensure that this policy and its principles are implemented.

Local Controls and Mechanisms

To ensure good governance in relation to decision making the PCC will have arrangements in place which will cover the way the OPCC will work. These will include the Scheme of Governance, Financial Regulations, Contract Standing Orders, a Joint Audit Committee, a risk register as well as a register of interests, gifts, and hospitality.

The Scheme of Governance sets out the delegations by the Commissioner to the Deputy Police and Crime Commissioner, the Chief Executive and the police via the Chief Constable and the Chief Constable’s Chief Finance Officer. It forms part of the overall Corporate Governance Framework of the two corporations’ sole.

The Financial Regulations and Contract Standing Orders form a part of the Scheme of Governance and prescribe the procedural arrangements and financial limits for decisions taken by the PCC’s and Chief Constable’s officers and staff.

The Joint Audit Committee provides an independent oversight of the governance and financial management of the Corporations Sole. It has a relationship with the internal and external auditors and looks also at Internal Controls, financial reporting, and corporate governance.

The approach to risk set out in the Scheme of Governance states the risk registers maintained by the Corporations Sole will provide assurance that the decisions made take account of the organisational risks.

Public Interest and Transparency

In assessing the public interest in decisions made, the OPCC will consider all the circumstances, including local ones. The OPCC will use guidance from the Information Commissioner’s Office (ICO) in assessing public interest. Public interest means the public good, not what might interest the public. There is a public interest in transparency and accountability. There is therefore a presumption that all decisions should be accessible to the public. However, in some cases there is also a public interest in not disclosing information behind decision making.

The OPCC will consider the exemptions in the Freedom of Information Act 2000 in deciding whether information may be exempt from disclosure and then go on to consider if it is also in the public interest not to disclose it or not to disclose it in its entirety. In addition, it may become appropriate to disclose information after a period of time. For example, a financial negotiation may mean that information that can be disclosed after the transaction has been completed when it would not have been in the public interest to disclose it before that happens.

Exemptions in the Freedom of Information Act 2000 are set out in the Act and the general ones are:

• It would cost too much or take too much staff time to deal with the
• The request is
• The request repeats a previous request from the same

In addition, there are specific exemptions:

• Information is accessible by other
• Information supplied by or relating to bodies dealing with security
• Court records and information relating to court proceedings
• Prejudice to the conduct of public affairs
• Personal
• Information provided in
• Information where disclosure is prohibited by an enactment or would constitute contempt of court.
• If the public interest in confidentiality outweighs the public interest of
• Information intended for future
• Investigations and proceedings conducted by public
• Law
• Health and
• Environmental
• Personal information relating to a third
• Legal professional
• Commercial

Publication Scheme

The Offices of the PCCs have a Publication Scheme which is approved by the

Information Commissioner’s Office. This sets out the information routinely published by the offices which is available to the public. The scheme also sets out the information publication requirements of the Elected Local Policing Bodies (Specified Information) Order 2011.

Summary

The Police and Crime Commissioners for Bedfordshire, Cambridgeshire and Hertfordshire have robust and transparent decision-making processes that comply with the law and allow the public to see easily what the respective Commissioners are doing to fulfil their role.

 

STANDARD OPERATING PROCEDURES: OFFICE OF THE BEDFORDSHIRE POLICE AND CRIME COMMISSIONER

 

Title	Gifts and Hospitality
Area of Compliance	Compliance
Version No.	5.0
Senior Lead	Head of Governance and Compliance
Author	Compliance

 

Revision History

 

Date	Revision	Change	Review Date
01.12.2015	1.0	New Document	01.12.2015
01.12.2016	1.0	No change	01.12.2016
01.12.2017	1.0	No change	01.12.2017
01.09.2018	1.0	No change	01.09.2019
19.06.2020	1.0	No change	19.06.2021
17.09.2021	1.0	No change	17.09.2022
17.10.2022	2.0	Updated OPCC Logo	17.09.2023
29.09/2023	3.0	All gifts and hospitality of any value to be declared	17.09.2024
17.09.2024	4.0	Policy amended to reflect local Government allowances of recording any gifts and hospitality over the value of £25	17.09.2025
13.08.2025	5.0	Logo update, links and grammar changes	13.08.2026

Purpose

The purpose of this policy is to provide guidance to the Police and Crime Commissioner (PCC) and all staff of the Office of the Police and Crime Commissioner (OPCC) in Bedfordshire, as to the acceptance of gifts, gratuities, and hospitality.

The entire office must comply with this policy, though some sections are applicable only to the following due to the increased risk associated with their role:

• Police and Crime Commissioner
• Deputy Police and Crime Commissioner
• Chief Executive and Monitoring Officer This guidance is necessary to ensure that:

The actions of members of Bedfordshire OPCC will not give rise to, or foster suspicion that outside individuals or organisations have gained favour or advantage, by any member of Bedfordshire OPCC accepting gifts or hospitality from any such person or organisation.

No member of Bedfordshire OPCC will accept any gift or hospitality which could cause their judgement or integrity to be compromised, either in fact or by reasonable implication, and thereby damage the reputation of Bedfordshire OPCC.

Any gift or hospitality over the value of £25, whether accepted or declined, will be recorded in the Gift and Hospitality Registry and will be subject to audits.

This policy will apply to all staff working in the OPCC whether employed full-time or part-time, fixed term, permanent, contracted, seconded or on a temporary basis.

The Gifts and Hospitality policy will be monitored by the Chief Executive to always ensure full adherence to the policy.

The following guidance is to be noted on instances where an exemption from any requirement to record is in order, and discretion may to an extent be exercised:

• Where there is an impromptu and unforeseen provision of light refreshments in line with staff duties.
• Where working lunches of a modest standard are offered during OPCC-related meetings, without alcoholic drinks.
• Where a discount is offered on a service or product that is available to the entire office.
• Internal Events refreshments
• Anything that is gifted

All gifts, gratuities, or hospitality accepted or declined, which do not fall within the categories as stated above, will be recorded by the PCC, Deputy PCC and Chief Executive in the manner outlined below, and by all other OPCC staff as outlined below.

The following guidance applies to the PCC, Deputy PCC, and Chief Executive. An individual register for each of these positions is required to be updated and maintained by the claimant, with the latest edition to be published on the OPCC website quarterly. It is a statutory requirement that this information be available on an on-going basis.

An individual register for each member of staff working within the OPCC is required to be completed on a quarterly basis. Where possible, acceptance of gifts, gratuities or hospitality must be approved by the Chief Executive.

Should there be any doubt as to whether a gift, gratuity or hospitality should be recorded, advice should be sought from the Chief Executive.

Policy Implications

The provisions of this policy are consistent with the Bribery Act 2010. As with all legislation, OPCC regulations must be read and given effect as far as possible in a way which is compatible with the European Convention on Human Rights. Article 8 of the Convention states that there shall be no interference with a person’s private life unless: -

1. It is in accordance with the law, and
2. Is necessary in a democratic society: -

• In the interests of national
• In the interests of public
• In the interests of economic well-being of the
• For the prevention of disorder and
• For the protection of health and
• For the protection of the rights and freedoms of

Subject to proportionality it can be said on one or more grounds referred to above, that restrictions on the receipt of gifts, gratuities and hospitality are necessary to ensure that the OPCC remains effective, protects its reputation, maintains high standards of conduct and probity from its staff, and avoids any conflict of interest within their duty as a holder of office or member of staff.

The risks emanating from the acceptance of gifts, gratuities and hospitality are to both the individual’s integrity and the organisation’s reputation. Both risks will be mitigated by the adoption of this policy and adherence to its guidance.

Responsibilities

The Chief Executive is responsible for ensuring the effective implementation and operation of the arrangements. Managers will ensure that themselves and their staff operate within this policy and arrangements, and that all reasonable and practical steps are taken to avoid discrimination. Each manager will ensure that:

• All their staff are aware of the policy and the arrangements, and the reasons for the policy.
• To ensure that an individual register for each member of staff working within the OPCC is completed on a quarterly basis.

Download the policy with this link

STANDARD OPERATING PROCEDURES: OFFICE OF THE BEDFORDSHIRE POLICE AND CRIME COMMISSIONER

 

Title	Complaints
Area of Compliance	Compliance
Version No.	11
Senior Lead	Head of Governance and Compliance
Author	Compliance

 

 Revision History

Date	RH	Change	Review Date
01.07.2017	V4	No Change	01.07.2018
27.09.2018	V5		27.09.2019
16.09.2019	V5	No Change	01.02. 2020
01.02.2020	V6	Chief Constable Complaints updated due to complaints reform	01.02.2021
19.06.2020	V7	Signpost Management added	19.02.2021
17.09.2021	V7	No Change	17.09. 2022
17.10. 2022	V8	OPCC logo updated, Signpost’ changed to Bedfordshire Victim Care Services, Bedfordshire Police complaints website page link updated	17.09.2023
01.02.2023	V9	Investigator of Chief Executive complaints	01.02.2024
27.09.2023	V10	IOPC Link update, Chief Finance Officer address	27.09.2024
20.08.2024	V11	Removal of Bedfordshire Victim Care Services, update of IOPC Statutory Guidance URL, update of Police and Crime Panel complaints policy URL	20.08.2025
15.08.2025	V12	Amend Logo	January 2026 – due to move to model 2
04.03.2026	V13	Amended advice and updated due to Model 2 implementation.	27.09.26

Office of the Police and Crime Commissioner (OPCC) for Bedfordshire Complaints Policy

Introduction

We want people across Bedfordshire to be safe and feel safe and for the police to provide you with the best service possible. Everyone has a right to fair, honest and respectful treatment by the police.

Sometimes, something goes wrong in the force’s day-to-day dealings with the public. When this happens, we want to ensure that the appropriate person or body responsible[1] for putting it right hears about it and takes appropriate action.

This policy has been produced to make it easier for you to make a formal complaint. A summary of the policy is attached at Annex A.

This policy provides guidance in respect to making a complaint about:

• Bedfordshire Police
• Chief Constable of Bedfordshire Police
• Office of the Police and Crime Commissioner (OPCC) and its staff
• Police and Crime Commissioner (PCC)

We would also like to hear if you believe any of our staff or officers have exceeded your expectations and gone further to help resolve your query, question, or crime.

Complaints against Bedfordshire Police Force, including its officers and staff

A complaint is any expression of dissatisfaction with a police force made by, or on behalf of, a member of the public. To qualify as a complaint, it must be submitted by someone who meets the definition of a complainant as set out in the Independent Office for Police Conduct (IOPC) Statutory Guidance. The complainant must also demonstrate an intention to bring their concerns to the attention of the police force or the local policing body.

A complaint does not need to be submitted in writing, nor does it have to be explicitly labelled as a “complaint” for it to be treated as such.

Under current legislation, all complaints relating to the conduct of a Bedfordshire Police officer or member of police staff (excluding the Chief Constable) fall under the responsibility of the Police and Crime Commissioner (PCC). These complaints are initially triaged and managed by the Complaint Resolution Team (CRT).

Where appropriate, and where the legislation allows, the CRT will seek to resolve the matter outside of Schedule 3 through service recovery. However, depending on the nature or seriousness of the issues raised, it may be necessary to formally record the complaint under Schedule 3 of the Police Reform Act 2002. If formal recording is required, the complaint will be referred to the Professional Standards Department (PSD) within Bedfordshire Police, who will take responsibility for all further handling.

Complaints about any member of Bedfordshire Police (excluding the Chief Constable) may also be submitted directly via the Force website at:

Complaints | Bedfordshire Police and follow the process outlined for complaints.

Alternatively, you may wish to e-mail your complaint to:

[email protected]  Complaints about Bedfordshire Police Force

received by the OPCC will be acknowledge within 2 working days.

Complaints against the Chief Constable

The appropriate authority for a complaint or recordable conduct matter that relates to the conduct of a Chief Constable or acting chief officer is the local policing body with responsibility for that police force area, this is the Police and Crime Commissioner.

The Police and Crime Commissioner delegates responsibility to review and investigate Chief Constable complaints to their Chief Executive/OPCC.

Chief Constables engage with the public in a different way to most police officers. They are not usually involved in frontline policing, but they can still be the subject of a complaint. They may also be included in complaints made about their police force. When people raise concerns about Chief Constables, the OPCC should establish whether the matter is an expression of dissatisfaction and make sure the complainant is eligible to complain, as they do for all complaints.

The OPCC is the appropriate authority only when a complaint is about the conduct of the Chief Constable. Therefore, it is vital that the OPCC clarifies whether a complaint that references the Chief Constable does involve his or her conduct. If it is about the decisions of the force in general, or about a delegated power rather than the Chief Constable, these matters should be directed to the correct appropriate authority – this being Bedfordshire Police.

Chief Constable’s or Police and Crime Commissioners may receive complaints about the Chief Constable that do not relate to their direct actions but instead reference actions that have been delegated or given to another member of the police force to carry out. From a complainant’s point of view, the Chief Constable represents the Force. These complaints are often made in good faith, but without a clear understanding that in practice, the matter does not involve the Chief Constable. The OPCC would provide a response that explains that the matters raised will be addressed by the appropriate authority and will include the next steps.

Recording Complaints

A complaint must be recorded under Schedule 3 of the Police Reform Act 2002 and handled in accordance with the provisions of that Schedule, if at any point the person making the complaint wants it to be recorded.

This applies even if previous attempts have been made to handle the complaint outside of the requirements of Schedule 3. Where a complainant’s wishes are unclear, reasonable steps should be taken to clarify what they are.

A complaint must also be recorded and handled under Schedule 3 if Bedfordshire Police or the OPCC (where it is the appropriate authority or it has taken on responsibility for the initial handling of complaints) decides that it is appropriate or if the complaint:

• is an allegation that the conduct or other matter complained of resulted in death or serious injury?
• is an allegation that, if proved, might constitute a criminal offence by a person serving with the police or justify the bringing of disciplinary proceedings?
• is conduct or any other matter which, if proved, might have involved the infringement of a person’s rights under Articles 2 or 3 of the European Convention on Human Rights?

Or

• meets any of the mandatory referral

These criteria must be assessed based on the allegations made, not on apparent merit. Therefore, no scoping is required before making this decision, except to ensure that the complainant’s allegations are fully understood.

The only time a complaint that meets these criteria does not need to be recorded is where it has been withdrawn.

Referrals to the IOPC involving the Chief Constable

For complaints, the mandatory referral criteria include any complaint relating to a Chief Constable where the appropriate authority is unable to satisfy itself from the complaint alone that the conduct complained of, if proved, would not justify the bringing of criminal or disciplinary proceedings. The test must be

applied to the substance of the complaint alone, and not to the merit of the allegation.

For all complaints involving the Chief Constable, the first consideration after logging is whether the complaint should be recorded and referred. For conduct matters, in deciding whether the matter relates to conduct, the OPCC will already have applied the indication test by reviewing the available evidence to decide if there is an indication that the Chief Constable may have committed a criminal offence or behaved in a way that would justify the bringing of disciplinary proceedings.

Therefore, all conduct matters, as they already meet that definition, must be referred to the IOPC.

Reasonable and proportionate handling

Many complaints against the Chief Constable will be suitable for handling outside of Schedule 3 because an explanation is often all that is needed to resolve a matter to the satisfaction of the complainant. As with all complaints, the OPCC should try to understand the reasons behind the complaint and identify exactly what the complainant wants to be addressed.

An eligible complainant can request that their complaint is formally recorded under Schedule 3 at any time during the handling of their complaint. In addition, if they are dissatisfied with the outcome of any initial handling, and want the complaint to be recorded, then it must be recorded under Schedule 3.

Some complaints that have been recorded and referred to the IOPC will not meet the threshold for the indication test. In this situation, there is no requirement for the IOPC to investigate the complaint, and it will be passed back to the OPCC to address.

The OPCC should follow the principles of reasonable and proportionate handling to resolve the matters raised. Good customer service is at the heart of the response the OPCC provides.

Making a Complaint

If you wish to make a complaint about the Chief Constable, then please set out clearly what the complaint is about by writing to the address below:

Office of the Police and Crime Commissioner Bedfordshire Police Headquarters

Woburn Road Kempston Bedford MK43 9AX

Or via email at: [email protected]

Dealing with a Complaint

We will acknowledge receipt of your complaint within five working days and the OPCC will decide whether to record the complaint and notify you accordingly in accordance with the Statutory Guidance provided by the IOPC.

In cases where a complaint is recorded, the OPCC will decide whether the complaint can be resolved locally by the OPCC or if there could be potential grounds for criminal or misconduct proceedings, which will require formal investigation and involvement and referral of the IOPC.

Right of Review

You have a right to review the decision of the PCC, in writing to the IOPC, who can be contacted at:

Independent Office of Police Conduct PO Box 473

Sale

M33 0BW

[email protected]

Complaints against a member of staff of the OPCC

The staff of the OPCC strive to uphold the highest standards in their dealings with the public. However, should you have a complaint against any member of the PCC’s staff, please write to us at the address below.

If the complaint refers to:

Commissioner’s Statutory Officer the Chief Executive

The complaint should be addressed to:

The Police and Crime Commissioner

Office of the Police and Crime Commissioner Bedfordshire Police Headquarters

Woburn Road Kempston Bedford MK43 9AX

Or via email at: [email protected]

The PCC will then determine whether the complaint should be dealt with by the Chief Finance Officer (CFO) or seek an independent investigator to review the complaint.

Commissioner’s Statutory Officer, the Chief Finance Officer

The complaint should be addressed to:

The Chief Executive

Office of the Police and Crime Commissioner Bedfordshire Police Headquarters

Woburn Road Kempston Bedford MK43 9AX

Or via email at: [email protected]

The PCC will then determine whether the complaint should be dealt with by the Chief Executive Officer (CEO) or seek an independent investigator to review the complaint.

For all other staff

The complaint should be addressed to:

The Chief Executive

Office of the Police and Crime Commissioner Bedfordshire Police Headquarters

Woburn Road Kempston Bedford MK43 9AX

Or via email at: [email protected]

The Chief Executive will review the complaint and assign a case handler. When making your complaint, please try to be specific about what went wrong and what you would like the OPCC to do to put things right. The OPCC will acknowledge receipt of your complaint within 10 working days, providing the name and telephone number of the person investigating it and indicating the date by which you should receive a reply. This will not normally exceed 28 working days and if it is a relatively straight forward matter, you should receive a reply more quickly. If we cannot meet this target, we will write to explain the reasons and keep you informed of progress.

Right of Appeal

 We would expect all complaints to be satisfactorily resolved through our complaint’s procedure, but if having exhausted this process you are still not satisfied that the OPCC has dealt with your complaint appropriately, you have the right to make a complaint to the Local Government Ombudsman at the following address:

Make a complaint - Local Government and Social Care Ombudsman

PO Box 4771

Coventry CV4 0EH

Tel: 0300 061 0614

Complaints about the PCC

The Police and Crime Panel (PCP) for Bedfordshire is responsible for handling complaints against the PCC.

A complaint form is available on the PCP’s webpage at:

Bedfordshire Police and Crime Panel | Bedford Borough Council

This may be submitted electronically or alternatively downloaded for completion. A hard copy of the form may be obtained by telephoning (01234) 228256. If you are unable to use the online form, please email the PCP directly at: [email protected]

Forms submitted through the PCP’s webpages will automatically be forwarded to the Council’s Monitoring Officer. Hard copies of the complaint form should be sent to:

Monitoring Officer Bedford Borough Council Borough Hall

Cauldwell Street Bedford

MK42 9AP

The PCP complaints policy is available with this link.

Annex A - Summary of Bedfordshire OPCC Complaints Policy

 

Complaint received by Bedfordshire OPCC
Complaint is against Bedfordshire Police Force, or any of its officers and staff	Complaint is against the Chief Constable of Bedfordshire Police Force	Complaint is against a member of staff of the OPCC	Complaint is against the PCC
Complaint acknowledged by OPCC	Complaint acknowledged by OPCC	Complaint acknowledged by OPCC	Complaint forwarded to the Police and Crime Panel for consideration
Complaint sent to force (Customer Support Department) for initial handling	Decision made on whether to record the complaint or if can be handled reasonably and proportionately outside of Schedule 3 and complainant notified	If a complaint is against the Chief Executive, the complaint will be passed to the Chief Finance Officer, and the PCC will be notified. The investigation may be delegated for an appropriate person to complete and a reply to complainant within 28 working days
	If decision is to deal with outside of Schedule 3 – Complainant to be notified full and informed of next steps	If a complaint is against any other member of staff, the Chief Executive will investigate and reply to the complainant within 28 working days. The Chief Executive can delegate this authority to an OPCC member of staff if appropriate.
	If the decision is taken to record, action considered in accordance with IOPC guidelines
PCC oversight of all complaints through regular meetings with OPCC and Bedfordshire Police Force

[1] Police Reform and Social Responsibility Act 2011, The Elected Local Policing Bodies (Complaints and Misconduct) Regulations 2012 and The Police (Complaints and Misconduct) Regulations 2020

Download the policy with this link

STANDARD OPERATING PROCEDURES: OFFICE OF THE BEDFORDSHIRE POLICE AND CRIME COMMISSIONER

 

Title	Guidance on managing unacceptable and unreasonable complainant behaviour
Area of Compliance	Compliance
Version No.	3
Senior Lead	Chief Executive
Author	Head of Governance and Compliance

Revision History

 

Date	Revision	Change	Review Date
28/09/22	2.0	No Change	28/09/23
28/09/23	2.0	No Change	28/09/24
20/08/24	2.0	No Change	20/08/25
15/08/25	3.0	Change Logo, updated links, related legislation	15/08/26

Policy Statement

Bedfordshire Office of the Police and Crime Commissioner (OPCC) is committed to providing a high-quality service for everyone it deals with. We value all kinds of complainant feedback, and all expressions of dissatisfaction are treated seriously and recognised as a tool to identify and implement service improvements.

We are committed to dealing with all complainants fairly and impartially. As part of this service, we do not normally limit the contact that our complainants have with us. However, in a minority of cases, complainants can pursue their dissatisfactions/complaints or queries in a way which can either impede the progress of their issue or can create serious resource issues. These actions can occur either while their complaint/concern is being dealt with, or once findings have been concluded.

This policy aims to guide OPCC staff in the management of unreasonable or unreasonably persistent complainant complaints.

An unreasonable or unreasonably persistent complainant can take up a disproportionate amount of time that can hinder the other work of staff. We must therefore ensure that we use our resources both wisely and proportionately and limit the amount of time spent on queries that are considered to be unreasonable or unreasonably persistent.

Complainants demonstrating unreasonable behaviour and unreasonably persistent complainants may have justified complaints or grievances but are pursuing them in inappropriate ways; or they may be intent on pursuing complaints that appear to have no content, or which have already been dealt with and responded to.

The decision to restrict contact with the OPCC will be taken by the senior management team where appropriate and will normally follow a prior warning from the complainant. Any restrictions imposed will be appropriate and proportionate. Amongst the options that may be considered are:

• Requesting contact in a particular form (for example, written correspondence only)
• Requiring contact to take place with a named case manager
• Restricting telephone calls to specified days and times; and/or
• Asking the complainant to enter into an agreement about their future contact with

In all cases where we decide to treat a complainant as an unreasonable or unreasonably persistent complainant, we will write to tell the complainant why we believe their behaviour falls into that category, what actions we are taking and the duration of that action. We will also tell them how they are able to challenge that decision.

Where a complainant whose case is closed persists in communication with us about the same issue, we may decide to terminate contact with that complainant about the matter. In such instances, we will read all the correspondence from that complainant, but unless there is fresh evidence or new information which affects our decision on the complaint, we will either acknowledge it without further comment or place it on the file with no acknowledgement.

New complaints dealing with unrelated issues from people who have come under the unreasonably persistent complaints policy will be treated on their merits.

What is unacceptable behaviour?

Complainants have often experienced traumatic or distressing circumstances that lead them to make a complaint. Anger or frustration about the complaint is a common response, but it can become unacceptable if it escalates and/or becomes abusive, and/or is personally directed at complaint handlers.

In this context, unacceptable behaviour is defined as any behaviour that has the potential to cause harm, injury or negatively impact on the health and safety of complaint handlers. Unacceptable behaviour may be isolated to a single incident or form a pattern of behaviour over time. Even if a complaint has merit, a complainant’s behaviour can still be unacceptable.

People communicate and express themselves differently depending on their background and a range of other factors. It is important to be aware that formality, pacing and emotion can vary significantly across cultures. Certain mental health conditions or disabilities may make it difficult for people to express themselves and/or to communicate clearly. Forces should always aim to make the complaints system accessible to all and, where appropriate, make reasonable adjustments if they are advised of access requirements. However, they may still need to put in place contact strategies in some circumstances.

Types of unacceptable behaviour

Violent, threatening, or abusive behaviour

Complainants may be distressed or upset because of the circumstances leading to their complaint. The complainant’s behaviour is considered unacceptable when these emotions lead to behaviour which is violent, threatening, or abusive.

Staff should not endure or tolerate violent, threatening, or abusive behaviour. The safety and wellbeing of staff should always be protected, even if the service provided to the complainant has fallen short of expected standards.

Violent, threatening, or abusive behaviour may involve any or all of the following:

• verbal abuse, derogatory, discriminatory, or defamatory remarks (verbal or written)
• escalating agitation, intimidating body language or invasion of personal space harassment, intimidation, or threats
• threats or harm to people or property
• stalking (in person or online)
• psychological manipulation
• oppressive or coercive behaviour

Action to take if a caller is abusive:

• the complaint/case handler should tell the complainant their behaviour is unacceptable, explaining why the behaviour is unacceptable
• warn them that if the behaviour continues, they will end the call
• report it to a line manager and seek advice on the appropriate steps to take
• a reference note should be made on the case file, setting out why a call was ended and what other actions were taken.

Any member of the OPCC team should be confident and supported to end telephone calls where they experience threatening, or abusive behaviour. Threatening and abusive correspondence is also unacceptable; in this instance an appropriate contact strategy should be created and recorded in the case file.

What is unreasonable behaviour?

Unreasonable persistence

A complainant’s behaviour may be unreasonable if they continue to write, email or telephone about their complaint(s) excessively (and without providing new information) despite being assured that their complaint is being dealt with or being told their complaint has concluded.

While this behaviour may not appear to be as severe as violent, threatening, or abusive behaviour, it is considered unreasonable because of the impact it can have on the time and resources of staff, which in turn can impact on the capacity to manage other complainants.

Unreasonable persistence may consist of:

• persistently calling, writing, or emailing to demand updates, despite being assured that matters are in hand, and being given reasonable timescales for when an update can be expected
• refusing to accept reasonable explanations following the conclusion of a complaint, and/or failing to follow appropriate review channels
• contacting different people in the same organisation to try to secure a different outcome
• the volume or duration of contact impacting on the ability of complaint handlers to carry out their functions (this can include calling several times repeatedly on the same day)
• re-framing or re-wording a complaint that has already been finalised
• persisting with the complaint despite failing to provide any evidence to support it after numerous requests to do so

Unreasonable demands or obstructive behaviour

 This type of behaviour is considered unreasonable because of its impact on the time and resources of the organisation, its services, and staff, and on the ability to thoroughly investigate the complaint. It can include:

• repeatedly demanding responses within an unreasonable timescale, or insisting on speaking to a particular member of staff despite being told that it is not possible or appropriate
• not following appropriate channels for engagement, despite receiving information more than once about the appropriate channel/s to use
• issuing demands about how their complaint should be handled, despite being told about the process and receiving regular updates
• demands to speak to senior leaders/managers at the outset, before the call handler has fully considered the complaint
• repeatedly copying staff into emails sent to other public bodies where there is no demonstrable reason to do so
• refusing to provide information needed to progress an investigation

Unreasonable persistence and demands can impact on staff wellbeing, supervisors and managers should make sure appropriate support is in place to support.

Underlying causes

 There are many reasons why a person’s behaviour may become unacceptable or unreasonable. Case handlers should not make assumptions about what is driving the behaviour. Understanding the reasons behind it is vital in deciding how best to manage it.

Frustration caused by poor communication and/or lack of timeliness when handling a complaint can cause a complainant’s behaviour to escalate. When a complainant displays unacceptable or unreasonable behaviour, the case handler should consider the following questions:

• Have we explained the complaints process to the complainant and checked they understand it?

i.e. That the point of contact for police complaints is Bedfordshire Police not the OPCC or is it a Chief Constable complaint.

OPCC Oversight – Questions can be reviewed against police action and rationale.

• Has the complaint been handled in a reasonable and proportionate manner?
• If the complaint is ongoing, has the communication been regular and effective with the complainant?
• Have we asked the complainant if they would benefit from additional support? If so, has the complainant received this?
• If a decision has been made on the complaint, has the complainant been given a clear rationale for the decision, in a way that they can understand how that decision has been reached?

If the case handler answers ‘yes’ to these questions and the behaviour of the complainant is still unacceptable or unreasonable, a decision needs to be made on how best to manage it. If these obligations have not been met, steps should be taken to address any shortcomings where appropriate. This may be enough to stop the behaviour.

Needs of individual complainants

Throughout the complaints process, the case handler should be alive to the possibility a complainant may have additional needs, and if so, consider whether providing that complainant with additional tailored support would make it easier for them to make their complaint. Throughout the complaints process, all reasonable efforts should be made to make sure additional needs are identified and catered for as far as possible and practicable.

Where it is identified that a complainant requires additional support, appropriate steps should be taken to address their needs in a way that satisfies the requirements of the Equality Act. If unsure of these obligations, a call/case handler should seek advice from a colleague in their organisation who has responsibility or expertise for equality and diversity issues or alternatively seek advice from an external organisation.

Case handlers must also be aware of other issues which may hinder a complainant’s ability to effectively access the complaints system. For instance, complainants who lack proficiency in English may become frustrated if they are unable to understand the complaints process or updates regarding their complaint. Reasonable efforts should be made to make sure complainants have a clear understanding of the information communicated to them and, where their understanding is unclear, reasonable measures should be taken to help them.

Verbal abuse, threats or violent behaviour of any kind should not be tolerated by staff under any circumstances. However, the knowledge and understanding that a complainant has specific needs should influence the decision about the most appropriate course of action to take.

Approaches to managing unacceptable or unreasonable behaviour

Before taking steps that reduce or restrict communication, any issues with behaviour should be addressed with the complainant. The case handler should have a clear idea about how they would like their behaviour to change.

The complainant should be informed about the issues with their behaviour and why it is considered unacceptable or unreasonable. They should be advised how they can adjust their behaviour. Some examples of ways to address the behaviour include:

• reminding the complainant that violent, threatening or abusive behaviour will not be tolerated
• summarising the complaint(s) and asking the complainant to confirm that all the issues they have raised have been understood correctly
• providing guidance to the complainant on the structure their correspondence should follow
• informing the complainant about where to send correspondence
• signposting the complainant to other sources of support if they raise matters that fall outside the Office of the Police and Crime Commissioner.

When communicating with complainants who are behaving in an unacceptable or unreasonable way, call handlers should be clear about the consequences if the behaviour continues.

Wherever possible, a complainant should be given the opportunity to change their behaviour before a decision is taken to restrict contact.

A contact strategy may be implemented if unacceptable or unreasonable behaviour continues. A contact strategy will set out how and when further contact with the complainant will take place, any restrictions on communication, and the reason for introducing the strategy.

Before introducing a strategy, consider the following: ‘what are we trying to achieve by implementing this strategy?’ and ‘is restricting contact in this way fair, reasonable and proportionate?’

The complainant should be notified in writing about the strategy (considering any specific needs and reasonable adjustments).

The explanation should emphasise the strategy has been implemented to make sure complaints are dealt with promptly and accurately, and that failure to comply with it could frustrate the handling of their complaint(s).

It must be made clear the strategy relates only to complaints, and that police assistance can still be requested through emergency or non-emergency routes if required.

Contact strategies can include:

• limiting duration of phone calls to specific times
• restricting contact to email or post only (considering any reasonable adjustments)
• using a dedicated email address and auto-diverting emails
• blocking email addresses or other communication channels if appropriate
• requiring the complainant to use an advocate for any contact with the complaint handling department
• requiring the complainant to communicate only with a single point of contact (SPOC)

Adhering to and reviewing/revising the contact strategy

It is important the case handler adheres to the contact strategy once it is in place. Any breach of the strategy by the complainant must be dealt with swiftly. A clear reminder should be communicated to the complainant about the consequences of breaching the strategy. They should also be reminded about the reasons for the strategy being introduced.

Systems should be in place locally to review any contact strategies on a regular basis - for instance, every six months. These reviews should make sure the contact strategy is still appropriate and fit for purpose.

The complainant should be told about any changes to the contact strategy. Call handlers should seek advice from colleagues with expertise in equality and diversity issues when making amendments to agreed reasonable adjustments.

In certain situations, it may be necessary to share details of the contact strategy with partner agencies. However, this should only be done when there are legitimate reasons for doing so and checks should be made to ensure compliance to General Data Protection Regulations (GDPR).

            

Further action

It may be necessary to take further action to protect staff welfare if a contact strategy proves to be unsuccessful and the unacceptable behaviour continues despite numerous attempts to adjust the strategy.

In practice, this should rarely be necessary and should be reserved only for the most severe cases. In these circumstances, it is best to seek legal advice to see what avenues are available under the law to deal with the complainant’s behaviour.

Staff welfare and protecting privacy

Dealing with unacceptable behaviour from complainants can have a significant impact on staff welfare. The office needs to ensure the following:

• opportunities for complaint handlers to routinely report unacceptable or unreasonable behaviour to their supervisors and seek support
• encouraging complaint handlers subject to unacceptable or unreasonable behaviour to discuss their experience and signpost them to employee assistance programmes or other support networks

Although rare, there are cases where complainants have tried to find out about a complaint handler’s private life and used that information to target the complaint handler (for example, the complaint handler’s home address or other personal information).

There are several steps complaint handlers can take to preserve their privacy online. For example:

• conducting regular internet searches about themselves to check whether their name or any other personal information is available in the public domain (for example, their workplace, employer name, social media platforms, home address)
• check social media privacy settings regularly, bearing in mind platforms frequently update these settings
• consider family and friend connections online, and whether people could either use these connections as a means of identification or draw adverse inferences about these connections
• use directory enquiry websites to check whether home contact details are easily accessible (this information can be removed from directory enquiries services on request)
• check listings with Companies House or the Charity Commission (when a person holds a relevant position their full name and current address may be listed)
• take reasonable precautions online, such as:
• not listing employment details or personal contact information on social media
• consider using a different name on social media to that used at work, particularly if the name is distinctive
• consider using a profile picture that does not show the face
• consider removing colleagues from friends/connections on social media, particularly if they are using their real names
• avoid following policing social media accounts or interacting with posts
• consider the cumulative effect of information posted online and how it can be put together to locate officers and staff

Related Policies and Legislation

Police Reform and Social Responsibility Act 2011

Equality Act 2010

Data Protection Act 2018

PCC Policies and procedures

 

Download the policy with this link

STANDARD OPERATING PROCEDURES: OFFICE OF THE BEDFORDSHIRE POLICE AND CRIME COMMISSIONER

 

Title	Whistleblowing - Handling of Qualifying Disclosures Policy
Area	Compliance
Version No.	5.0
Senior Lead	Head of Governance and Compliance
Author	Compliance

 

 

Revision History

Date	Revision	Change	Review Date
28.09.2018	1.0	New Document	28.09.2019
28.09.2019	1.0	No Change	28.09.2020
19.06.2020	1.0	No Change	19.06.2021
17.09.2021	2.0	Protect Details (pg. 7)	17.09.2022
17.10.2022	3.0	Added Bedfordshire Victim Care Services (BVCS) to policy	17.09.2023
28.09.2023	4.0	No Change	28.09.2024
20.08.2024	4.0	No Change	20.08.2025
15.08.2025	5.0	Logo and links updated	15.08.2026

The Office of the Police and Crime Commissioner (OPCC) has developed a policy to handle qualifying disclosures that encompasses the protection afforded to staff under Part IVA Employment Rights Act 1996 (as inserted by the Public Interest Disclosure Act 1998), relating to ‘Protected Disclosures’.

This policy enables any member of staff to be able to make a ‘protected disclosure’ about any corruption or wrongdoing of any kind within the organisation. It enhances professionalism in the workplace preventing and discouraging malpractice and corruption.

This policy encourages staff to report wrongdoing or suspected wrongdoing or unethical behaviour with confidence that any such report will be taken seriously and dealt with correctly. The policy encourages staff to use internal mechanisms and any member of staff making a protected disclosure under this policy will be supported.

Qualifying Disclosures

Certain kinds of disclosures qualify for protection (qualifying disclosures). Qualifying disclosures are disclosures of information which the staff member making the disclosure reasonably believes tends to show one or more of the following is either taking place, has taken place, or is likely to occur in the future:

1. a criminal offence
2. a breach of a legal obligation
3. a miscarriage of justice
4. a danger to the health or safety of any individual
5. damage to the environment, or
6. deliberately concealing information relating to any of the

Any staff member who makes a disclosure must have a reasonable belief that the information disclosed tends to show one or more of the offences or breaches listed above.

The belief need not be correct, it might be discovered subsequently that the member of staff was wrong, but the staff member must show that they held a reasonable belief in the circumstances, at the time of disclosure.

The PCC is determined that the culture and tone of the organisations is one of honesty and opposition to fraud and corruption. There is an expectation and requirement that all individuals and organisations associated in whatever way with the OPCC will act with integrity, and that the PCC and staff at all levels will lead by example in these matters.

The PCC, the Chief Constable and their staff are important in the stance on fraud and corruption and are positively encouraged to raise any concerns that they may have on these issues where they are associated with the activities of the Force and the OPCC. Concerns may be about something that:

• is unlawful
• is against the PCC’s Standing Orders, Financial Regulations, or policies
• falls below established standards or practices
• results in waste or loss to the PCC
• amounts to improper conduct

Members of staff are often the first to realise that there may be something seriously wrong within the Office of the Police and Crime Commissioner (the OPCC) in Bedfordshire.

However, they may not express their concerns because they feel that speaking up would be disloyal to their colleagues or to the Police and Crime Commissioner. They may also fear harassment or victimisation. In these circumstances it may be easier to ignore the concern rather than report what may just be a suspicion of malpractice.

The Police and Crime Commissioner is committed to the highest possible standards of openness, probity, and accountability. In line with that commitment, the Police and Crime Commissioner expects officers and others that we deal with, who may have serious concerns about any aspect of the OPCC’s work to come forward and voice those concerns. It is recognised that most cases will have to proceed on a confidential basis. The Commissioner will not tolerate the victimisation of anyone raising a genuine concern and anyone responsible for such conduct will be subject to disciplinary action.

This policy makes it clear that you can do so without fear of victimisation, subsequent discrimination, or disadvantage. This Confidential Reporting Policy is intended to encourage and enable members of staff to raise serious concerns within the OPCC rather than overlooking a problem or “blowing the whistle” externally.

This policy applies to all OPCC staff (temporary, permanent, part-time and full-time), Bobby Scheme and any agency staff or consultants undertaking work on behalf of the OPCC. It also applies to contractors working for the OPCC, such as agency staff.

Any disclosure must be made in the ‘public interest’. Therefore, matters relating to your own employment should be raised under the appropriate existing procedures

e.g., Bedfordshire Police Fairness at Work Policy.

This policy aims to:

• encourage you to feel confident in raising serious concerns and to question and act upon concerns about practice
• provide avenues for you to raise those concerns and receive feedback on any action taken
• ensure that you receive a response to your concerns and that you are aware of how to pursue them if you are not satisfied and reassure you that you will be protected from possible reprisals or victimisation if you have a reasonable belief that your concerns are justified.

The Confidential Reporting Policy is intended to cover major concerns that fall outside the scope of other procedures. Your concern may be about something that:

• is unlawful (e.g., theft, false claims )
• is related to miscarriages of justice
• relates to possible fraud and corruption
• is a health and safety risk (including risks to the public as well as colleagues)
• damages the environment
• relates to the unauthorised use of public funds
• relates to sexual or physical abuse
• amounts to improper or other unethical conduct
• makes you feel uncomfortable in terms of known standards, your experience, or the standards you believe the OPCC subscribes to
• is against the OPCC’s procedures, rules, and policies or
• falls below established standards of practice
• relates to the conduct of the Police and Crime Commissioner

The OPCC is committed to good practice and high standards and wants to be supportive of staff.

The OPCC recognises that the decision to report a concern can be a difficult one to make (not least because of the fear of reprisal from those responsible for, or suspected of, the malpractice). If what you are saying is true, you should have nothing to fear because you will be doing your duty to your employer.

The OPCC will not tolerate any harassment or victimisation in accordance with the

Anti-Discrimination in the Workplace guidance and will take appropriate action to protect you when you raise a concern. However, should you feel that you have suffered harassment, either directly or indirectly, from your employer and or co-workers as a result of raising a concern then you should refer the matter to the Chief Executive.

Any investigation into allegations of potential malpractice will not influence, or be influenced by, any disciplinary or redundancy procedures that may already affect you.

Confidentiality

All concerns will be treated in confidence and every effort will be made not to reveal your identity if you wish. However, you should appreciate that the investigation process may reveal the source of the information and a statement by you may be required as part of the evidence. At the appropriate time you may need to come forward as a witness.

Anonymous disclosures

This policy encourages you to put your name to any expression of concern about possible wrongdoing whenever possible

Concerns expressed anonymously are generally likely to be less credible and much more difficult to investigate. Factors to be considered would include:

• the seriousness of the issues raised
• the credibility of the concern; and
• the likelihood of confirming the allegation from attributable
• Unsubstantiated concerns

If you make a disclosure in the public interest and it is not confirmed by the investigation, no action will be taken against you. If, however, you make an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against you.

How to raise a concern

You may wish to consider discussing your concern with a colleague or professional association representative first and you may find it easier to raise the matter if there are two (or more) of you who have had the same experience or concerns.

You may invite your professional association representative or colleague to raise a matter on your behalf. As a first step, you should normally raise any concerns about a member of staff with your immediate manager. This depends, however, on the seriousness and sensitivity of the issues involved and who is suspected of malpractice. If in any doubt, speak to the Chief Executive or Head of Governance and Compliance.

Concerns may be raised verbally or in writing. If you do not feel able to put your concerns in writing, you should phone or meet the appropriate officer who will agree your statement with you. If you wish to make a written report, you are invited to use the following format:

• the background and history of the concern (giving relevant dates names and places)
• the reason why you are particularly concerned about the situation

The earlier you express your concern the easier it is to act. Although you are not expected to provide proof, you will need to demonstrate to the person that you contact that there are reasonable grounds for your concern.

How the OPCC will respond

The OPCC will respond to your concerns. Please note that testing out your concerns is not the same as either accepting or rejecting them. Where appropriate, the matters raised may:

• be investigated by management, internal auditors, or through the disciplinary process
• be referred to the Police
• be referred to the external auditor
• form the subject of an independent inquiry

To protect individuals (and those accused of misdeeds or possible malpractice) initial enquiries will be made to decide whether an investigation is appropriate and, if so, what form it should take. The overriding principle which the OPCC will have in mind is the public interest.

Concerns or allegations which fall within the scope of specific procedures (for example, grievance issues) will normally be referred for consideration under those procedures. Some concerns may be resolved by agreed action without the need for investigation. If urgent action is required, this will be taken before any investigation is conducted. Within ten working days of a concern being raised, the person to whom it is addressed will write to you:

• acknowledging that the concern has been received
• indicating how the OPCC proposes to deal with the matter
• giving an estimate of how long it will take to provide a final response
• telling you whether any initial enquiries have been made, and
• telling you whether further investigations will take place and if not, why

The amount of contact between you and the officer(s) considering the issue(s) will depend on the nature of the matter(s) raised, the potential difficulties involved, and the clarity of the information provided. If necessary, the OPCC will seek further information from you.

Where any meeting is arranged (off-site if you wish) you can be accompanied by a professional association representative or a colleague (who is not involved in the area of work in which the concern relates).

The OPCC will take steps to minimise any difficulties that you may experience as a result of raising a concern. For instance, if you are required to give evidence in criminal or disciplinary proceedings the OPCC will arrange for you to receive advice about the procedure.

The OPCC accepts that you need to be assured that the matter has been properly addressed. Subject to any legal constraints, we will inform you of the outcome of any investigation.

The Responsible Officer

The Chief Executive has overall responsibility for the maintenance and operation of this policy. The Chief Executive will maintain a record of concerns raised and the outcomes (but in a form which does not endanger your confidentiality).

How the matter can be taken further

This policy is intended to provide you with an avenue within the OPCC to raise concerns. The OPCC hopes you will be satisfied with any action taken. If you are not, and if you feel it is right to take the matter outside the OPCC, the following are possible contact points:

• the external auditor
• your trade union
• your local Citizens Advice Bureau or a relevant voluntary organisation
• relevant professional bodies or regulatory organisations
• the Police
• your solicitor
• the Ombudsman
• Police and Crime Panel

If you do take the matter externally, you should ensure that you do not disclose confidential or privileged information. Please check with the Chief Executive or your line manager first.

Statutory Protection

This policy does not in any way affect your statutory rights as an employee under Part IV A of the Employment Rights Act 1996[1], which was brought into force by the Public Interest Disclosure Act 1998 [2] commonly referred to as “The Whistleblowing Act”.

These provisions give employees statutory protection against unfair dismissal and other forms of disciplinary action if they make certain types of disclosure in the public interest.

A “qualifying disclosure” means any disclosure of information which in the reasonable belief of the worker making the disclosure tends to show one or more of the following:

• That a criminal offence has been committed, is being committed or is likely to be committed
• That a person has failed, is failing or is likely to fail to comply with any legal obligation to which he is subject
• That a miscarriage of justice has occurred, is occurring or is likely to occur
• That the health or safety of any individual has been, is being or is likely to be endangered
• That the environment has been, is being or is likely to be damaged, or
• That information tending to show any matter falling within any one of the preceding paragraphs has been, is being or is likely to be deliberately concealed.

Protect (formerly Public Concern at Work)

If you are unsure about whether to follow the OPCC’s “Whistleblowing” Policy or want further independent advice, you may contact Protect.

This is a charity completely independent of the OPCC, which specialises in providing free and confidential legal advice on how to raise concern about serious malpractice at work.

Protect will also help to advise you on whether a circumstance can be properly reported to an additional outside body.

Telephone: 020 3117 2520

Web form: Contact our Advice Line - Protect - Speak up stop harm

[1] Employment Rights Act 1996

[2]Public Interest Disclosure Act 1998

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STANDARD OPERATING PROCEDURES: OFFICE OF THE BEDFORDSHIRE POLICE AND CRIME COMMISSIONER

 

Title	Subject Access Request Policy
Area of Compliance	Compliance
Version No.	5.0
Senior Lead	Head of Governance and Compliance
Author	Compliance

 Revision History

 

Date	Revision	Change	Review Date
21/05/2018	1.0	New Document	21/05/2019
21/05/2019			21/05/2020
20/09/2019		Review due to ICO Audit	20/09/2020
20/09/2020		No change	20/09/2021
24/09/2021		No change	24/09/2022
17/10/2022	2.0	Updated OPCC Logo	24/09/2023
27/09/2023	3.0	Accessibility check – changed the headings	24/09/2024
20/08/2024	4.0	Update of information following review of ICO website	20/08/2025
14/08/2025	5.0	Updated PCC Logo Updated links	14/08/2026

Introduction

Under the Data Protection Act 2018 you have the right to a copy of the information that is held about you. This is known as a subject access request (SAR). Please note that the Office of the Police and Crime Commissioner (OPCC) is a separate organisation to Bedfordshire Police and as such we do not hold information regarding criminal records.

Your rights

You have a right to be told whether information is held about you and a right to a copy of that information within one month of receipt unless certain exemptions apply. Your request can only be processed once you have provided satisfactory proof of your identity. Information may not be provided if someone else can be identified in or from the information.

The Police and Crime Commissioner's Rights

The provisions of the Data Protection Act (DPA) means that in certain circumstances some personal data will not be provided. For example, you will not be provided with personal data if releasing it to you would be likely to affect the rights and freedoms of others.

The subject rights are as follows:

1.   The right to be informed

Individuals have the right to be informed about the collection and use of their personal data; we are obligated to provide individuals with information including: the purposes for processing their personal data, retention periods for that personal data, and who it will be shared with. This is referred to as ‘privacy information’; which must be concise, transparent, intelligible, easily accessible, and it must use clear and plain language.

Information Asset Owners, working with the assistance of the Data Protection Officer, are responsible for ensuring this right is satisfied through the provision of privacy notices.

2.  The right to access

Individuals have the right to be aware of and verify the lawfulness of the processing the forces are carrying out. Individuals can make SARs verbally or in writing, including via social media. A third party can also make a SAR on behalf of another person. We are required to provide a copy of the information free of charge, and at the latest within one month of receipt (subject to exemptions). We can extend the time limit by a further two months if the request is complex or if we receive a number of requests from an individual.

3.  The right to rectification

Individuals have a right to have inaccurate personal data rectified or completed if it is incomplete. An individual can make a request for rectification verbally or in writing. The Office of the Police and Crime Commissioner for Bedfordshire are obligated to provide a response within one calendar month. In certain circumstances the OPCC Bedfordshire can refuse a request for rectification.

4.   The right to erasure

Individuals have the right to request the deletion or removal of their personal data. The right is not absolute and only applies in certain circumstances. Individuals can make a request for erasure verbally or in writing and we have one month to respond to the request.

5.   The right to restrict processing

Individuals have the right to request restrictions or suppression of their personal data. This is not an absolute right and only applies in certain circumstances. When processing is restricted, it is permitted to store the personal data but not use it. An individual can make a request for restrictions verbally or in writing, and the Office of the Police and Crime Commissioner for Bedfordshire have one calendar month to respond to a request.

6.   The right to data portability (only applies to General Processing)

The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services. It allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.

7.   The right to object (only applies to General Processing)

Individuals have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling). Individuals have an absolute right to stop their data being used for direct marketing. An individual can make an objection verbally or in writing and we have one calendar month to respond to the request.

8.   Rights in relation to automated decision-making including profiling

Individuals have the right to object to decisions made about them solely based on automated processing, where those decisions have legal or other significant effects.

9.   Right to lodge a complaint with the Information Commissioner’s Office (ICO)

Individuals have a right to make a complaint to the ICO regarding any concerns they have about the information rights practices of an organisation.

10.  Rights in relation to compensation and remedies in court

Individuals have a right to seek judicial remedy or make a claim for compensation for a contravention of data protection legislation.

Handling Subject Rights Requests

The Subject Access Request form can be found on the OPCC website. Whilst the use of the form is not mandatory, it does make it easier to process the request. Requests should be submitted to the PCC inbox email: [email protected]

The Compliance Officer within OPCC manages all subject rights requests.

It is in the data subject’s and the OPCC’s best interests, to handle these requests promptly.

Any member of staff or other individual working within the OPCC must consider the following when they identify that an individual is attempting to exercise one of their subject rights:

Take immediate steps to verify the identity of the person making the request, such as viewing a document such as a driving license, passport etc., recording the details of the request, and the method of identity verification. A copy of the proof of identification should be taken and filed.

Where a request is initially made verbally, staff must write the request down and ask the requestor to verify the accuracy of their recording of it and amend it where necessary.

Additional guidance on how to submit a subject access request is available via the Information Commissioners Office website.

You are entitled to obtain records of any personal data held by the OPCC.

The OPCC will consider each request in accordance with all applicable Data Protection laws and regulations. No administration fee will be charged for considering and/or complying with such a request unless it is deemed to be manifestly unfounded or excessive.

Download the policy with this link

OFFICE OF THE BEDFORDSHIRE POLICE AND CRIME COMMISSIONER

 

Title	General Data Protection Regulation (GDPR) Privacy Notice
Area of Compliance	Compliance
Version No.	4.0
Senior Lead	Head of Governance and Compliance
Author	Compliance

Revision History 

Date	Revision	Change	Review Date
21/05/2018	1.0		21/05/2019
20/09/2019	1.0		20/09/2020
20/09/2020	1.0	No Change	20/09/2021
24/09/2021	1.0	No Change	24/09/2022
17/10/2022	2.0	Change of OPCC Logo	24/09/2023
29/09/2023	3.0	Accessibility check (Headings)	29/09/2024
20/08/2024	3.0	No Change	20/08/2025
14/08/2025	4.0	Updated PCC Logo Updated Links	14/08/2026

The Police and Crime Commissioner for Bedfordshire is a separate corporate sole to Bedfordshire Police and is a data controller under the Data Protection Act 2018 (DPA) and the UK General Data Protection Regulation (GDPR).

This Privacy Notice explains how we use any personal information we collect about you and your organisation when you work with the Office of the Police and Crime Commissioner (OPCC), when you enter a contract with the OPCC or provide us with your personal information for the purposes of an event, issue, or activity.

Topics:

• What information do we collect about you?
• How will we use the information about you?
• How long will we keep your information for?
• Marketing
• Access to your information and correction
• Cookies
• Other websites
• Changes to our privacy policy
• How to contact us

What information do we collect about you?

We collect information about you when you enter into the Commissioners grant bidding process or enter into a contract for the provision of services. We also collect information when you register with us to participate in events and activities, voluntarily complete surveys, provide feedback on consultations, or contact us in relation to an application, complaint or enquiry against Bedfordshire Police or the Chief Constable of Bedfordshire Police. Website usage information is collected using cookies.

Where necessary, the OPCC may request and hold sensitive personal data to carry out our legal functions ‘in the exercise of official authority. This covers public functions and powers that are set out in law; or to perform a specific task in the public interest that is set out in law.

How will we use the information about you?

We may collect information about you to process your enquiry, manage your bid and contract and, if you agree, email you about other events and activities that we think may be of interest to you.

We use information about you in order to carry out our official functions or public tasks that are set out in law, mainly the Police Reform and Social Responsibility Act 2011. For example, when a complaint is made against the Chief Constable, the Commissioner’s Office will retain and process the personal information shared with us to carry out the lawful public task of investigating this complaint. The OPCC will also respond quickly to share any personal information with Bedfordshire Police when it relates to a risk to life or the need to protect and safeguard the public.

In order to process any complaint or issue of dissatisfaction raised against Bedfordshire Police, its officers and staff, the Commissioner is required to share relevant personal information with Bedfordshire Police Force to ensure that the complaint is looked into and to meet our public task - (e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.

We may pass on your personal information to Bedfordshire Police Force (including where necessary the parts of Bedfordshire Police Force that are collaborated with Hertfordshire and Cambridgeshire Constabularies) so that they may offer you a response to any enquiry of an operational nature, or a response to a complaint or issue of dissatisfaction.

Information on how Complaints are processed by the OPCC is available on our website here: Complaints policy

In processing any bid for a contract to provide services, we may share your details with the Bedfordshire Police Force and send your information to credit reference agencies and fraud prevention agencies.

How long will we keep your information for?

In general, we will keep personal information only for as long as we need it. This means that we will delete or destroy it when it is no longer needed. The Commissioner has a legal obligation to retain some data in connection with the statutory obligations of the Police and Crime Commissioner as a public authority. Further information on how and when we will retain or delete data is available via our website here: Record Management, Retention and Disposal Policy

Marketing

We would like to send you information about events and services of ours and other providers that support the work of the PCC and Police Force which may be of interest to you.

If you have consented to receive marketing, you may opt out later. You have a right at any time to stop us from contacting you for this purpose. If you no longer wish to be contacted for marketing purposes, please email [email protected].

Access to your information and correction

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the following address:

Office of the Police and Crime Commissioner for Bedfordshire:

Bridgebury House, Bedfordshire Police Headquarters, Woburn Road, Kempston, Bedford MK43 9AX

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.

More information about your right to access, update, erase and control the processing of your personal data are available on the Information Commissioner’s Office website: here.

If you are unhappy about the way that the OPCC has managed or used your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact the Information Commissioners Office at: 0303 123 1113 Or via email, web form and live chat: Contact us

Or at the following address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity.

For further information visit www.aboutcookies.org or www.allaboutcookies.org

You can set your browser not to accept cookies, and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

Other websites

Our website contains links to other websites. This Privacy Notice only applies to the OPCC website, so when you link to other websites you should read their own Privacy Notices.

Changes to our Privacy Policy

We keep our privacy policy under regular review, and we will place any updates on this web page. This Privacy Notice was last reviewed on 14^th August 2025.

How to contact us

Please contact us if you have any questions about our Privacy Notice or information that we hold about you:

Email: [email protected]

Telephone: 01234 842064

In Writing: Bedfordshire Police Headquarters, Bridgebury House, Woburn Road, Kempston, Bedfordshire, MK43 9AX

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STANDARD OPERATING PROCEDURES: OFFICE OF THE BEDFORDSHIRE POLICE AND CRIME COMMISSIONER

 

Title	Freedom of Information Policy
Area of Compliance	Compliance
Version No.	4.0
Senior Lead	Head of Governance and Compliance
Author	Compliance

 Revision History

Date	Revision	Change	Section	Review Date
November 2015	1.0	New Document		November 2016
November 2016				November 2017
November 2017				November 2018
21/05/2018				21/05/2019
21/05/2019				21/05/2020
20/09/2019				20/09/2020
20/09/2020				20/09/2021
24/09/2021				24/09/2022
17/10/2022	2.0	Change of OPCC logo, added Bedfordshire Victim Care Services (BVCS) to policy		24/09/2023
27/09/2023	2.0	No change		27/09/2024
20/08/2024	3.0	Removal of BVCS from policy		20/08/2025
14/08/2025	4.0	Updated PCC Logo		14/08/2026

 POLICY STATEMENT

The Office of the Police and Crime Commissioner (OPCC) is fully committed to complying with the Freedom of Information Act 2000 (FOIA) and its principles of openness and accountability of public authorities. The intention of this policy is to provide a framework for ensuring compliance with the provisions of the FOIA, that:

• A growing proportion of information about the Office of the Police and Crime Commissioner is promoted to the public through the Publication Scheme.
• Information not available through the Publication Scheme is readily available on request unless an exemption applies. Where reasonably practicable, information will be provided in a medium preferable to the applicant. When it is not reasonably practical, we will notify the applicant of the reasons why.
• All requests for information are dealt with in a timely
• Exemptions under the Act, and associated harm public interest tests, are applied
• A fair and efficient internal appeal system is

Purpose

FOIA gives a general right of access to all types of recorded information held by the Office of the Police and Crime Commissioner for Bedfordshire, sets out exemptions from that right and places a number of obligations on the OPCC. Any person who makes a request to the OPCC for information will be informed whether the information is held, and, subject to exemptions, will be supplied with that information within 20 working days.

Background

The aim of this policy is to ensure that the OPCC meets the appropriate governance standards for public services.

Affected Persons

 This procedure will apply to all staff working within the OPCC, whether employed full- time or part-time, fixed term, permanent, seconded or on a temporary basis.

Policy

 The application of the FOIA is the responsibility of the Compliance Officer’s within the OPCC. They have a responsibility to ensure the following:

• that FOIA requests are addressed in a timely and accurate
• that records are maintained in such a manner to ensure easy, appropriate, and timely retrieval of information.

The right of individuals to request information will be balanced against the need of the OPCC to support the police to protect the public and effectively and safely carry out operations and the core functions of law enforcement. Therefore, information that could compromise the police’s effectiveness will not be released.

The identity of the requester will be protected unless there is an operational need, or it is unavoidable due to the nature of the request.

Information requested and disclosed relating to the Police and Crime Commissioner, and members of the OPCC will be in accordance with transparency legislation, limited to their role in the organisation and within the constraints of the exemption to be applied under Section 40 of the FOIA.

The supply of information through normal business processes will be unaffected by the requirements of the Act.

No member of staff will make a request for information under the FOIA in the name of the Office of the Police and Crime Commissioner to another public authority without the written permission of the Chief Executive.

The Freedom of Information Act 2000 allows for specific fees to be charged where the cost of compliance and communication within the Act exceeds the appropriate limit. The Office of the Police and Crime Commissioner reserves the right to levy such fees.

Effective record management will support the provision of information under the Act. The OPCC will manage its records in line with its Records and Retention and Disposal Policy.

In the application of this policy the OPCC will not discriminate against any persons regardless of sex, race, colour, language, religion, political, or other opinion, national or social origin, association with national minority, property, birth, or other status as defined under Article 14, European Convention Human Rights (ECHR) and the Equality Act 2010.

Procedures and Guidance

In processing FOI requests, in addition to local procedures, the OPCC will have regard to the Association of Chief Police Officers FOI Manual of Guidance and where appropriate, will seek advice from the ACRO Central Referral Unit.

The OPCC’s Publication Scheme is available on the website or on request. The Publication Scheme specifies:

• What information the OPCC will make routinely available to the public as a matter of course
• How it does so
• Whether or not this information will be made available free of charge or require the payment of a fee

The Compliance Officer is responsible for the maintenance and updating of the Publication Scheme.

Requests for information

Information not already available through the Publication Scheme will be accessible through an FOI request, subject to the provisions of the Act.

The FOIA establishes three related rights:

1. The right to be told whether the information exists
2. The right to receive the information (subject to the provisions of the Act)
3. The right of internal and external appeal on any aspect of the way the request has been dealt with.

A request for information may be received anywhere in the organisation. It must be made in writing (for example letter, email, online form). It does not have to mention the Act by name.

The request should be forwarded to the Compliance Officer’s as soon as it is received so that the 20-day limit for responding to requests can be met.

Third Party information - In accordance with the section 45 Code of Practice and the ACPO FOI manual of guidance, the Office of the Police and Crime Commissioner will consult with third parties wherever possible when their information or interests may be involved in disclosure of information.

Decision-making and the public interest test (PIT)

The decision on whether information is or is not disclosed will be made in accordance with the Freedom of Information Act and with reference to the ACPO manual of guidance. Where necessary, specialist advice will be sought. A harm test and a public interest test must be applied if a qualified exemption is considered.

Any person who is not satisfied with the way a request has been dealt with may appeal. The OPCC’s appeals process is independent of any person who has been involved in the FOI process to that point, involving the monitoring officer of the OPCC.

If you are dissatisfied with the decision, you may make an application to the Information Commissioner for a decision on whether the request for information has been dealt with in accordance with the requirements of the Act.

Responsibilities

 The Office of the Police and Crime Commissioner’s performance against the requirements of the FOIA will be monitored by the Head of Governance and Compliance.

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STANDARD OPERATING PROCEDURES: OFFICE OF THE BEDFORDSHIRE POLICE AND CRIME COMMISSIONER

Title	Data Protection/Information Management Policy
Area of Compliance	Compliance
Version No.	5.0
Senior Lead	Head of Governance and Compliance
Author	Compliance

 Revision History

Date	Revision	Change	Review Date
21.05.2018	1.0		21.05.2019
21.05.2019	1.0	No Change	21.05.2020
20/09/2019	2.0	Info regarding BCH Force policy added	20/09/2019
20/09/2019	2.0	No Change	20/09/2020
20/09/2020	2.0	No Change	20/09/2021
24/09/2021	2.0	No Change	24/09/2022
17/10/2022	3.0	Updated OPCC logo	24/09/2023
27/09/2023	4.0	Accessibility check (Headings) Grammar	27/09/2024
20/08/2024	4.0	No Change	20/08/2025
19/08/2025	5.0	Updated PCC Logo	19/08/2026

Introduction

The Police and Crime Commissioner (PCC) is the Data Controller for all Office of Police and Crime Commissioner (OPCC) business, however the OPCC does not need to be registered with the Information Commissioner’s Office (ICO). From 1 April 2019, the Data Protection (Charges and Information) (Amendment) Regulations 2019 exempted the processing of personal data by members of the House of Lords, elected representatives, and prospective representatives. ‘Elected representatives’ is defined by the Data Protection Act 2018 and includes, but is not limited to, MPs, MSPs, MSs in Wales, MEPs, elected councillors in county councils, district councils, London boroughs, parish councils, elected mayors and police and crime commissioners. ‘Prospective representative’ refers to anyone seeking to become an elected representative as defined above.

The PCC is committed to conducting its business in accordance with the data protection laws. During our activities, we will collect, store and process personal data about our service users, employees, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.

All OPCC employees are obliged to comply with this policy when processing personal data.

The types of personal data that the PCC may be required to handle include information about service users, employees, and others that we communicate with. The personal data, which may be held on paper or on a computer or other media, is subject to certain legal safeguards specified in the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (together referred to as the Data Protection Legislation).

Bedfordshire OPCC links BCH (Bedfordshire, Cambridgeshire, Hertfordshire) Information Management Unit when dealing with Information Management - BCH14/001 Joint - Information Management Policy (IMP) which is available on the police intranet.

Definition of Data Protection terms

Data subjects for the purpose of this policy include all living individuals about whom we hold personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal information.

Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (for example, a name, a unique reference number, address, or date of birth) or it can be an opinion about that person, their actions and behaviour.

Data Controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed. They are responsible for establishing practices and policies in line with GDPR. The PCC is the data controller of all personal data all elements of the OPCC collects or uses in its day-to-day business and in providing services.

Data Processors include any person or organisation that is not a data user that processes personal data on our behalf and on our instructions. Employees of data controllers are excluded from this definition, but it includes suppliers, providers and contractors which

handle personal data on PCC’s behalf.

Processing is any activity that involves the use of data. It includes obtaining, recording, or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, viewing, disclosing, erasing or destroying it.

Processing also includes transferring personal data to third parties.

Special Category Data (also known as “sensitive personal data”) includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The definition also includes the processing of genetic data, biometric data for the purpose of uniquely identifying an individual, data concerning health or data concerning an individual’s sex life or sexual orientation. Special Category Data can only be processed under strict conditions. Personal data relating to criminal convictions and offences is subject to additional requirements and should be handled in a similar way to Special Category Data.

Third Party is any individual/organisation other than the data subject, the data controller (the PCC’s) or its agents.

Data Protection Impact Assessment is a process to help identify and minimise the data protection risks of a project. A DPIA should be carried out for processing that is likely to result in a high risk to individuals. The DPIA must: describe the nature, scope, context, and purposes of the processing; assess necessity, proportionality, and compliance measures; identify and assess risks to individuals; and identify any additional measures to mitigate those risks.

Responsibilities under the General Data Protection Regulation (GDPR)

The PCC is a Data Controller under GDPR; they (or functions within their office under their direction) are also a Processor of information for other organisations.

The Chief Executive has delegated authority to carry out all the functions and responsibilities of the Data Controller, although liability remains with the PCC as a corporation sole.

The Data Protection Officer is responsible for ensuring compliance with GDPR and with this policy and may assign officers to support this process.

Compliance with Data Protection legislation is the responsibility of everybody who processes personal information.

The PCC, through its staff (the OPCC), is responsible for ensuring that any personal data supplied is accurate and up to date.

Data Protection Principles

Anyone processing personal data must comply with the six principles relating to processing personal data in the GDPR. These provide that personal data must be:

• Processed lawfully, fairly and in a transparent manner in relation to the data subject (lawfulness, fairness and transparency). For personal data to be processed lawfully, it must be processed based on one of the legal grounds set out in GDPR. These include, among other things, processing is necessary:
  • for the performance of a task carried out in the public interest or in the exercise of official authority vested in the PCC.
  • for the performance of a contract to which the data subject is
• for compliance with a legal
• the data subject has given consent for the data to be processed for a specific purpose(s).

When special category data (sensitive personal data) is being processed, additional conditions must be met. When processing personal data as data controllers in the course of our business, we will ensure that those requirements are met.

• Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. We will only process personal data for specific We will notify those purposes to the data subject when we first collect the personal data or as soon as possible thereafter.
• Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed (data minimisation). Personal data, which is not strictly necessary for the purpose for which it is obtained, should not be If personal data is given or obtained which is excessive for the purpose, they should be immediately deleted or destroyed.
• Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (accuracy). Personal Data, which is kept for a long time, must be reviewed, and updated as necessary. No personal data should be kept unless it is reasonable to assume that it is accurate. It is the responsibility of individuals to ensure that personal data held by the PCC is accurate and up to date. Individuals should notify the PCC of any changes in circumstance to enable personal records to be updated accordingly. It is the responsibility of the PCC to ensure that any notification regarding change of circumstances is noted and acted upon.
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. We will not keep personal data longer than is necessary for the purpose or purposes for which they were collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required. On occasion, personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) of the GDPR.
• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures (integrity and confidentiality).

Notifying Data Subjects

If we collect personal data directly from data subjects, we will inform them through our Privacy Notices about:

a. The purpose or purposes for which we intend to process that personal

b. The legal basis for

c. The types of third parties, if any, with which we will share or to which we will disclose that personal data.

d. The length of time that we will retain the

e.The means, if any, with which data subjects can limit our use and disclosure of their personal data.

 

If we receive personal data about a data subject from other sources, we will provide the data subject with this information within the required timescales.

We will also inform data subjects whose personal data we process that we are the data controller regarding that data, and the contact details of our Data Protection Officer.

Data Security

We will take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.

We will put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction.

Personal data will only be transferred to a data processor who has provided sufficient guarantees to implement appropriate technical and organisational measures that will comply with the Data Protection

legislation and ensure that data subjects rights are protected and that these requirements are governed by a contract or other legally binding agreement.

 

We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:

a. Confidentiality means that only people who are authorised to use the personal data should access it.

b. Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.

c. Availability means that authorised users should be able to access the personal data if they need it for authorised purposes.

Security procedures include:

a. Entry controls:  Any stranger seen in entry-controlled areas will be reported.

b. Secure lockable desks and  cupboards: Desks and cupboards will be kept locked if they hold confidential information of any kind. (Personal information is always considered confidential.).

c. Methods of disposal: Paper documents will be shredded. Digital storage devices will be physically destroyed when they are no longer required.

d. Equipment: OPCC employees will ensure that individual monitors do not show confidential information to passers-by and that they lock their PC when it is left unattended.

e. IT Security: IT provision is provided for the PCC / OPCC by the Bedfordshire Police Force ICT Department. A condition of use is compliance with the security policies of Bedfordshire Police.

Training for staff includes:

a. Mandatory training (E-Learning) for all staff on Data Protection, with annual refresher

b. Training for specialist Data Protection staff, including those who handle Subject Access

c. Training for new starters as part of the corporate induction (E-Learning)

Governance and assurance procedures include:

a. Internal and external audits of the PCC’s Information Management processes and

b. For new data collection processes the PCC will ensure that a Data Protection Impact Assessment is conducted in conjunction with the Data Protection Officer for all new and/or revised systems or processes.

Disclosure and sharing Personal Information

We will only disclose or share a data subject's personal data where we are legally permitted to do so, to comply with any legal obligation, or to enforce or apply any contract with the data subject or other agreements; or to protect our rights, property, or safety of our employees, service users or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

An example of this is when the OPCC receives a complaint, and they are not the appropriate authority. The OPCC must forward this complaint to the appropriate authority and the lawful basis in doing so is e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.

Individual’s rights under GDPR

Individuals have a number of rights under GDPR including the right to:

• ask the PCC via the OPCC if it holds personal information about
• ask what it is used
• be given a copy of the information (subject to certain exemptions);
• be given details about the purposes for which the PCC uses the information and of other organisations or people to whom it is disclosed.
• ask for incorrect data to be
• be given a copy of the information with any unintelligible terms
• be given an explanation as to how any automated decisions taken about them have been made.
• ask that information about them is erased (“right to be forgotten”).
• ask the PCC not to use personal
• for direct marketing, which is likely to cause unwarranted substantial damage or
• to make decisions which significantly affect the individual, based solely on the automatic processing of the data.

These rights are not absolute, if the PCC (usually via the OPCC) is unable to respond to a request, it will outline the legal reasons for its decision clearly.

Dealing with Subject Access Requests

The PCC has provided application forms on its website (OPCC) to assist data subjects to make a request to access information we hold about them. Data subjects do not have to use our forms or use any wording. A subject access request is valid if it is submitted by any means, i.e. in a letter, an email or verbally. Employees who receive a request should pass it without delay to the Compliance Officer.

Any individual who wishes to exercise this right should provide satisfactory proof of identity and sufficient information to enable the data to be located.

The OPCC often receives Subject Access Requests from the public requesting their data and personal information held by the Bedfordshire Police Force. This information must be requested from the Bedfordshire Police Force directly.

Subject to satisfactory completion of the above, the PCC (usually via the OPCC) should respond within one month.

There are some limited circumstances in which personal data relating to the applicant may be withheld. Examples of this include repeat access requests, confidential references, and third-party information.

Further information can be found in the GDPR Privacy Policy.

Dealing with a Data Security Breach

A personal data breach means a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data. This includes breaches that are the result of both accidental and deliberate causes. It also means that a breach is more than just about losing personal data.

A data security breach must be reported to the Data Protection Officer without delay to be recorded and reported as appropriate.

Further information can be found in the PCC’s Data Breach Policy.

Retention and disposal of data

The PCC discourages the retention of personal data for longer than is required.

Personal data must be disposed of in a way that protects the rights and privacy of data subjects (e.g., shredding, disposal as confidential waste, secure electronic deletion).

The PCC maintains a Retention Policy and a Retention Schedule that is specific and relevant to specific types of information and the services they relate to. These outline the appropriate periods for retention.

Where the PCC deviates from its Retention Schedule it will record the reasons why and will indicate how long the information will be retained.

Further information can be found in the PCC’s Retention and Disposal Policy.

 

Download the policy with this link

STANDARD OPERATING PROCEDURES: OFFICE OF THE BEDFORDSHIRE POLICE AND CRIME COMMISSIONER

Title	Data Breach Management Policy
Area of Compliance	Compliance
Version No.	4.0
Senior Lead	Head of Governance and Compliance
Author	Compliance

Revision History

Date	Revision	Change	Review Date
21.05.2018	1.0		21.05.2019
21.05.2019	1.0	No Change	21.05.2020
20.09.2019	1.0	No Change	20.09.2020
20.09.2020	1.0	No Change	20.09.2021
20.09.2021	1.0	No Change	20.09.2022
17.10.2022	2.0	ICO email updated, details for Data Protection Lead Officer and Data Protection Officer	20.09.2023
29.09.2023	3.0	Removal of ICO email address due to form now being available on ICO website	20.09.2024
20.08.2024	3.0	Update of DPO contact details	20.08.2025
20.08.2025	4.0	Updated PCC Logo, grammar amended	20.08.2026

Introduction

The Office of the Police and Crime Commissioner (OPCC) of Bedfordshire are committed to ensuring appropriate measures are taken against any information security threat/incident and data breach aimed to compromise the confidentiality, integrity and availability of police information including government classified and personal data as defined by the General Data Protection Regulation (GDPR) & Data Protection Act 2018 (DPA18). Bedfordshire, Cambridgeshire and Hertfordshire (BCH) will also react appropriately and proportionately to bring the situation within appropriate control.

Identifying and assessing a personal data breach is important in reducing risk. Reporting breaches to the Information Commissioners Office (ICO) becomes mandatory within 72 hours under GDPR and can be reported by the Police and Crime Commissioner, the Data Protection Lead Officer (DPLO), the Data Protection Officer (DPO) or a member of the OPCC staff team who have reasonable cause to believe that there has been a breach in personal data.

The ICO describes a personal data breach as:

A breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data. This includes breaches that are the result of both accidental and deliberate causes. It also means that a breach is more than just about losing personal data.

 This can include:

 Access by an unauthorised third party

• Deliberate or accidental action (or inaction) by a controller or processor
• Sending personal data to an incorrect recipient
• Computing devices containing personal data being lost or stolen
• Alteration of personal data without permission
• Loss of availability of personal data

 All breaches in relation to personal data will be reported to the ICO within 72 hours and recorded on the Reporting Breaches log.

Examples of a breach

The main examples of a breach of information that may occur in the OPCC are:

• Forwarding an e-mail outside the OPCC which includes personal e-mail addresses from someone who has not given their consent to have their e-mail shared
• Providing personal information outside the OPCC
• Loss of sensitive documents g., leaving a document marked ‘official sensitive’ or higher level of security in a public place
• Having a Force laptop or phone which contains, or has access to, sensitive or personal information stolen

This is not an exhaustive list.

Reporting process

The Head of Governance and Transparency should be notified immediately if a personal data breach is suspected. They should be given evidence in relation to the breach and may seek clarification of the law from professionals. They will consider the material significance of the breach, considering its cause, effect, the reaction to it, and its wider implications, including (where appropriate) dialogue with the Police and Crime Commissioner.

If the Head of Governance and Transparency is not available, the Data Protection Officer or any other OPCC staff member may report and record the breach.

When reporting a breach, you need to consider the following:

• Potential detriment to individuals
• Volume of data affected
• Sensitivity of data

The method of reporting is currently commenced with the completion of a Security Incident Form found on the intranet homepage. It is then emailed to the Information Assurance Unit (IAU) whereby a member of the IAU team will act upon the incident and record it and make an initial assessment. A running log will be kept of all action taken, and regular updates to this log will be made by the IAU team members.

The first 72 hours after you become aware of a data breach are critical. This is the deadline given to organisations under the Data Protection Act 2018 to report information security incidents to the Information Commissioners' Office (ICO).

However, not all breaches need to be reported to the ICO. Data breaches only need to be reported if they "pose a risk to the rights and freedoms of natural living persons". This generally refers to the possibility of affected individuals facing economic or social damage, such as discrimination, reputational damage, or financial losses. Most breaches fit into this category, but not all. For example, if the information can't be linked to a specific individual, there's likely to be very little risk to the 'rights and freedoms of an individual'.

The Information Commissioners Office reporting process

Breaches must be reported to the ICO using their ‘Reporting Breaches’ process, providing as much information as possible. For help or advice, ring the ICO helpline on 0303 123 1113.

When reporting the breach, you need to include the following information:

• Data controller’s name:

Police and Crime Commissioner for Bedfordshire

• Data Protection Lead Officer for OPCC:

Head of Governance and Compliance, Katie Beaumont

• Data Protection Officer:

BCH Information Rights Supervisor, Philippa Silver

• Data controller’s address:

OPCC, Bridgebury House, Bedfordshire Police Headquarters, Woburn Road, Kempston, Bedford MK43 9AX

• Who the ICO should contact if they require further details concerning the incident
• Details of the breach, including a description of the nature of the breach, the categories and number of individuals concerned, and the categories and approx. number of personal data records concerned.
• Description of the likely consequences and of the measures taken, or proposed to be taken, to deal with the breach, including where appropriate, the measures taken to mitigate any possible adverse effects.

If the breach is likely to adversely affect the personal data or privacy of an individual, you must notify the individual of the breach without unnecessary delay and give them the following information:

• Your name and contact details
• The estimated date of the breach
• A summary of the incident
• The nature and content of the personal data
• The likely effect on the individual
• Any measures you have taken to address the breach; and
• How they can mitigate a possible adverse impact

You do not have to tell individuals of a breach if you can demonstrate the data was encrypted but the ICO can require you to do so if they consider the breach is likely to adversely affect the individual.

If the personal information was originally received via a 3rd party, the 3rd party should also be notified of the data breach.

Record the date and nature of the breach and action taken on the Reporting Breaches Log, which can be found in the OPCC GDPR Folder.

Bedfordshire OPCC link with BCH Information Management Unit when dealing with Information management – BCH16/006 Information Security Incident and Data Breach Management Procedure are available on the intranet.

Download the policy with this link

STANDARD OPERATING PROCEDURES: OFFICE OF THE BEDFORDSHIRE POLICE AND CRIME COMMISSIONER

Title	Publication Scheme
Area of Compliance	Compliance
Version No.	5.0
Senior Lead	Head of Governance and Compliance
Author	Compliance

Revision History

Date	Revision	Change	Review Date
November 2012	1.0	New Document
December 2015	2.0	No change to document	December 2016
December 2016	2.0	No change to document	December 2017
December 2017	2.0	No change to document	December 2018
25th May 2018	2.0	No change to document	25th May 2019
20/09/2019	2.0	No change to document	20/09/2020
20/09/2020	2.0	No change to document	20/09/2021
17/09/2021	3.0	Updated FOI/DP OPCC website link	17/09/2022
17/10/2022	3.0	No change to document	17/09/2023
27/09/2023	4.0	Accessibility Changes	27/09/2024
20/08/2024	4.0	No change to document	20/08/2025
22/08/2025	5.0	Updated PCC Logo  Grammar amended Updated website links	22/08/2026

Purpose

This document was developed to be compliant with the statutory requirements and guidance of the Freedom of Information Act 2000, the Police Reform and Social Responsibility Act 2011 and the Code of Recommended Practice for Local Authorities on Data Transparency 2011.

Police and Crime Commissioners were introduced in the Police Reform and Social Responsibility Act 2011 as directly elected Local Policing Bodies to hold their Police to account in the delivery of an effective and efficient policing service.

As the local policing body, the Police and Crime Commissioner and their Office are regarded as a public office.

Background

Legal Requirements

Police and Crime Commissioner Role and Responsibilities

The current Police and Crime Commissioner for Bedfordshire was elected on 2^nd May 2024 and took office on 9^th May 2024. It is part of the Commissioner’s role to ensure that there is an efficient and effective police force for Bedfordshire and to make sure that the Chief Constable and Force are accountable to the public in carrying out their responsibilities and serving our communities.

The Commissioner engages with the public and communities in Bedfordshire and holds the Chief Constable to account for the delivery of policing, sets and updates a Police and Crime Plan, sets the Force budget and council tax precept, and appoints and, where necessary, dismisses the Chief Constable.

The Police and Crime Commissioner cannot influence any operational policing decisions. Therefore, any information required regarding police operations are the responsibility of the Chief Constable and the Force. If you would like to request for information from the Force you can contact [email protected], or alternatively [email protected] if you would like to request for information held about yourself.

The Freedom of Information Act 2000

The Freedom of Information Act 2000 (FOIA) provides rights of public access to information held by public authorities. The FOIA requires all public authorities to have a publication scheme.

The Elected Local Policing Bodies (Specified Information) Order 2011 of the Police Reform and Social Responsibility Act 2011 sets out statutory requirements for the publication of specific information by the Office of the Police and Crime Commissioner.

The Code of Recommended Practice for Local Authorities on Data Transparency 2011 sets out key principles for authorities to create greater transparency and enhance accountability through the publication of public data.

This Publication Scheme has been developed to be compliant with the statutory requirements and guidance of the Freedom of Information Act 2000, the Police Reform and Social Responsibility Act 2011 and the Code of Recommended Practice for Local Authorities on Data Transparency 2011.

Model Publication Scheme

The Office of the Police and Crime Commissioner (OPCC) for Bedfordshire has adopted the Model Publication Scheme of the Information Commissioner’s Office (ICO) as set out below and incorporated all specific information requirements of the Police Reform and Social Responsibility Act 2011 and the Code of Recommended.

Practice for Local Authorities on Data Transparency 2011, thus providing compliance to all statutory requirements regarding the publication of information at the time of implementation.

Information Commissioner – Model Publication Scheme

This model publication scheme has been prepared and approved by the Information Commissioner. It may be adopted without modification by any public office without further approval and will be valid until further notice.

This publication scheme commits an office to make information available to the public as part of its normal business activities. The information covered is included in the classes of information mentioned below, where this information is held by the office. Additional assistance is provided to the definition of these classes in sector specific guidance manuals issued by the Information Commissioner.

The scheme commits an office:

• To proactively publish or otherwise make available as a matter of routine, information, including environmental information, which is held by the authority and falls within the classifications below.
• To specify the information which is held by the authority and falls within the classifications below.
• To proactively publish or otherwise make available as a matter of routine, information in line with the statements contained within this scheme.
• To produce and publish the methods by which specific information is made routinely available so that it can be easily identified and accessed by members of the public.
• To review and update on a regular basis the information the authority makes available under this scheme.
• To produce a schedule of any fees charged for access to information which is made proactively available.
• To make this publication scheme available to the
• To publish any dataset held by the authority that has been requested, and any updated versions it holds, unless the authority is satisfied that it is not appropriate to do so; to publish the dataset, where reasonably practicable, in an electronic form that is capable of re-use; and, if any information in the dataset is a relevant copyright work and the public authority is the only owner, to make the information available for re-use under the terms of the Re-use of Public Sector Information Regulations 2015, if they apply, and otherwise under the terms of the Freedom of Information Act section 19. The term ‘dataset’ is defined in section 11(5) of the Freedom of Information Act. The term  copyright work’ is defined in section 19(8) of that Act.

Classes of Information

•  Who we are and what we do

Organisational information, locations and contacts, constitutional and legal governance.

• What we spend and how we spend it

Financial information relating to projected and actual income and expenditure, tendering, procurement, and contracts.

• What our priorities are and how we are doing

Strategy and performance information, plans, assessments, inspections, and reviews.

• How we make decisions

Policy proposals and decisions. Decision making processes, internal criteria and procedures, consultations.

• Our policies and procedures

Current written protocols for delivering our functions and responsibilities.

• Lists and Registers

Information held in registers required by law and other lists and registers relating to the functions of the office.

• The services we offer

Advice and guidance, booklets and leaflets, transactions, and media releases. A description of the services offered.

The classes of information will not generally include:

• Information the disclosure of which is prevented by law, or exempt under the Freedom of Information Act, or is otherwise properly considered to be protected from disclosure.
• Information in draft
• Information that is no longer readily available as it is contained in files that have been placed in archive storage or is difficult to access for similar

The method by which information published under this scheme will be made available

The office will indicate clearly to the public what information is covered by this scheme and how it can be obtained.

Where it is within the capability of a public office, information will be provided on a website. Where it is impracticable to make information available on a website or when an individual does not wish to access the information by the website, a public office will indicate how information can be obtained by other means and provide it by those means.

In exceptional circumstances some information may be available only by viewing in person. Where this manner is specified, contact details will be provided. An appointment to view the information will be arranged within a reasonable timescale.

Information will be provided in the language in which it is held or in any other language that is legally required. Where an office is legally required to translate any information, it will do so.

Obligations under disability and discrimination legislation and any other legislation to provide information in other forms and formats will be adhered to when providing information in accordance with this scheme.

Charges which may be made for information published under this scheme

The purpose of this scheme is to make the maximum amount of information readily available at a minimum inconvenience and cost to the public. Charges made by the office for routinely published material will be justified and transparent and kept to a minimum.

Material which is published and accessed on a website will be provided free of charge.

Charges may be made for information subject to a charging regime specified by Parliament.

Charges may be made for actual disbursements incurred such as:

• photocopying
• postage and packaging
• the costs directly incurred because of viewing information

Charges may also be made for information provided under this scheme where they are legally authorised, they are in all circumstances, including the general principles of the right of access to information held by public authorities, justified and are in accordance with a published schedule or schedules of fees which is readily available to the public.

Charges may also be made for making datasets (or parts of datasets) that are relevant copyright works available for re-use. These charges will be in accordance with the terms of the Re-use of Public Sector Information Regulations 2015, where they apply, or with regulations made under section 11B of the Freedom of Information Act, or with other statutory powers of the public authority.

If a charge is to be made, confirmation of the payment due will be given before the information is provided. Payment may be requested prior to provision of the information.

Written Requests

Information held by a public office that is not published under this scheme can be requested in writing, when its provision will be considered in accordance with the provisions of the Freedom of Information Act.

This policy applies to all permanent, temporary, and contracted staff working at the Office of the Bedfordshire Police & Crime Commissioner (OPCC).

The Publication Scheme will be monitored by the Chief Executive/Compliance Officer to always ensure full adherence to the policy, and to incorporate changes via the Information Commissioner (www.ico.org.uk).

Policy

The OPCC for Bedfordshire will publish all required information on its website at www.bedfordshire.pcc.police.uk.

A Monitoring Plan, listing all statutory required information for publication with time frames and location is attached to this document.

Our website contains a copy of the Publication Scheme at: www.bedfordshire.pcc.police.uk. If there is no access to the website, the office will provide a single copy free of charge.

Charging for Publications

All listed information will be available on the website.

Free of charge on the website: There is no charge made by us, although the user will, of course, must meet any charges made by their Internet service provider and/or telephone service as well as any personal costs for printing, photocopying etc. For those without access to the internet, we will provide a single printout of an individual publication, as shown on the website, free of charge from the above contact address.

Chargeable on website: Requests for multiple copies of publications or multiple printouts from our website or for copies of archived material no longer available on the website will attract a charge. The cost will be 10p per printed sheet plus postage. We will let you know the cost when we receive your request. The charge will be payable in advance. Where the information is available via the website, but a value-added service is requested using that information, a charge will be made.

Free of charge hard copy: Indicates a leaflet, booklet or periodical which is published by the Office of the Police and Crime Commissioner for Bedfordshire, still current and available, without charge.

Chargeable hard copy: Indicates a bound paper copy or other product as shown in our publication list. Where a charge applies, the cost and the reasons for levying such a charge will be made known to you. Any charge will be payable in advance.

Complaints about the Publication Scheme

If you think we have not supplied information in accordance with our Scheme, then you should write, in the first instance, to:

Chief Executive

Office of the Police and Crime Commissioner for Bedfordshire Police HQ, Woburn Road Kempston MK43 9AX

Telephone: 01234 842064

 E-mail:[email protected]

We aim to deal with your complaint within 20 working days. If you are dissatisfied with the response, you can ask for the matter to be internally reviewed. We aim to complete an internal review and respond to you within 20 working days.

 

If, after the internal review, you remain dissatisfied then you can complain to the Information Commissioner:

Information Commissioner Wycliffe House

Water Lane Wilmslow, Cheshire

SK9 5AF

Review of the Bedfordshire Publication Scheme

We will review and update our Publication Scheme annually or in accordance with any new national guidance or legislation.

Copyright

Different bodies might own the copyright of material.

Copyright Material of the Office of the Police and Crime Commissioner

For material where we own the copyright, it can be reproduced free of charge in any format or medium for research, private study or for internal circulation within an organisation. This is subject to the material being reproduced accurately and not being used in a misleading context. Where material is being republished or copied to others, the source of the material must be identified, and our copyright acknowledged. The Office of the Police and Crime Commissioner for Bedfordshire logo is also copyrighted and may not be reproduced other than as it appears on copied material.

Other Copyrighted Material

Some material we include in our Scheme may be the copyright of a third party. Our rights to hold and use such material do not extend to others. You must obtain

authorisation from the copyright holder(s) concerned if you wish to copy or reproduce such material. This requires the consent of the Police and Crime Commissioner.

Requests for Personal Information (Online Form linked)

Under the Data Protection Act 2018, you already have a statutory right to have access to personal data we hold about you on computer or in a structured manual file (i.e. on paper). You also have the right to expect us, as the data controller, to ensure that data is:

• processed fairly and lawfully
• obtained for specific and lawful purposes
• adequate, relevant, and not excessive
• accurate and where necessary kept up to date
• not kept for longer than is necessary
• processed in accordance with the rights of the data subject
• kept secure
• not transferred abroad unless to countries with adequate data protection

Information where the Office of the Police and Crime Commissioner for Bedfordshire is the Data Controller

Where we are the data controller, you are entitled to be told whether we hold data about you, and if we do:

• to be given a description of the data in question
• to be told for what purposes the data is processed
• to be told the recipients, or classes of recipients, to whom the data is or may be disclosed

You are also entitled to a copy of the information with any unintelligible terms, acronyms or codes explained. You will also be given any information available to us on the source of the data. The data will be in its latest form. Unless there are any exemptions which need to be applied.

If you consider that a request by you for access to your personal data has not been dealt with properly, you may: Contact the Information Commissioner, who is appointed to consider such complaints at:

Office of the Information Commissioner Wycliffe House

Water Lane Wilmslow, Cheshire

SK9 5AF

https://ico.org.uk/

The Information Commissioner is empowered to assess whether there has been a failure to comply with the 2018 Act. The Commissioner can issue enforcement proceedings if satisfied that there has been a contravention of the Data Protection Act.

Information where the Office of the Police and Crime Commissioner for Bedfordshire is not the “Data Controller”

In many cases, it is the Police and not the Office of the Police and Crime Commissioner that hold personal information. The Police National Computer (PNC) includes information on prosecutions, convictions, and cautions. Chief Officers of Police are the “data controllers” for this information and not Bedfordshire OPCC.

Police Forces provide a form to simplify the exercise of your subject access rights to PNC information. In the case of Bedfordshire Police, you should contact: -

Data Protection Officer Information Governance Unit Bedfordshire Police HQ Woburn Road

Kempston Bedfordshire MK43 9AX

Email: [email protected]

Requests under the Environmental Information Regulations 2004

If you wish to make a request for information under the Environmental Information Regulations 2004 (EIR), you should write to:

Compliance Officer

Office of the Police and Crime Commissioner for Bedfordshire Woburn Road Kempston MK43 9AX

Tel: 01234 842064

Email: [email protected]

 

The Chief Executive has overall responsibility for this Publication Scheme.

 

No	FOI Act 2000 Requirement	Description	ELPB (Specified Information) Order 2011i	COP 2011 Data Transparency	Location of information
1	Who we are and what we do Organisational information, structures, locations and contacts. Information to be published as soon as practicable and available for current year
1.1	Structure of the Local Policing Body	Names of PCC and Deputy PCC (if any) and any council or other body represented. Any sub-committee structure.	Name of each relevant officer 1(a) and salary of each relevant officer 1(c)		PCC Website
1.2	Staff structure of the Local Policing Body	Basic staff structure or other details indicating administrative support of OPCC.	Number of staff 2(a); details of gender, ethnicity and disability 2(b) ; organisational chart 2(c) and job title, responsibilities and salary of senior employees1 2(d)	Organisational chart, senior staff salaries, pay multiple’	PCC Website
1.3	Contact information	Contact details, preferably by reference to name.	Address for each relevant officer 1(b)		PCC Website
1.4	Geographical area of operation	N/A	N/A		PCC Website
1.5	General outline of responsibilities	N/A	N/A		PCC Website
1.6	Appointment of independent custody visitors	N/A	Information on operation of the arrangements (ICV Scheme) made under section 51 of the Police Reform Act 2002 Section 8	​	PCC Website
2	What we spend and how we spend it Financial information relating to projected and actual income and expenditure, procurement, contracts and financial audit. Information to be published as soon as practicable and available for the current and previous two financial years
2.1	Summary of revenue budget estimates of the Local Policing Body itself	N/A	Total budget 3(a); Proposed expenditure 3(d)	​	PCC Website
2.2	Annual statement of the Local Policing Body’s accounts	N/A	Annual Investment Strategy 3(e)	​	PCC Website
2.3	Budget set for the Police Force	N/A	N/A	N/A	PCC Website
2.4	Expenses and allowances paid to or incurred by the Local Policing Body and Chief Executive.	Details of the allowances and expenses that can be claimed or incurred. Total of the allowances and expenses incurred by categories (travel, subsistence and accommodation)	1(d) Required quarterly	​	PCC Website
2.5	Annual audit letter	N/A	N/A	​	PCC Website
2.6	Financial audit reports	N/A	N/A	​	PCC Website

¹ Salary exceeds £58,200

 

2.7	Internal financial regulations and delegated office	N/A	N/A	​	PCC Website
2.8	N/A	N/A	Precept issued 3(b) before financial year to which it relates	​	PCC Website
2.9	N/A	N/A	Anticipated source of revenue 3(c) before financial year to which it relates	​	PCC Website
2.10	N/A	N/A	Each grant made including conditions, recipient, purpose and reasons why given 3(f) (monthly)	​	PCC Website
2.11	N/A	N/A	Each spend over £500 including recipient, purpose, why good VFM (i) of the Commissioner and (ii) of the Chief Officer of Police 3(g) (monthly)	​	PCC Website
2.12	N/A	N/A	Identify premises or land owned or occupied 4(a)	​	PCC Website
2.13	N/A	N/A	Copy of each contract over £10,000 (i) that the elected body, or (ii) the chief officer of the force maintained by the body is or is to be party 4(b)	​	PCC Website
2.14	N/A	N/A	Copy of each invitation to the tender expected to have a value exceeding £10,000 issued by (i) the elected policing body or (ii) the chief officer 4(c)	​	PCC Website
2.15	N/A	N/A	List of every contract with a value not exceeding £10,000 to which (i) the elected policing body or (ii) the chief officer is or is to be party, including value of contract, identity of every other party and purpose of contract.4(d)	​	PCC Website
3	What our priorities are and how we are doing Strategies and plans, performance indicators, audits, inspections and reviews. Information to be published as soon as practicable and available for the current and previous two years
3.1	Strategic plan or local policing objectives set for the Police Force	N/A	N/A	​	PCC Website
3.2	Reports presented to the Local Policing Body indicating service provision, performance assessments, operational assessments	N/A	N/A	​	PCC Website
3.3	Reports by external inspectors	N/A	N/A	​	PCC Website
3.4	Statistical information provided to the Local Policing Body	N/A	N/A	​	PCC Website

 

3.5	N/A	Each year after the end of the financial year to which it relates	The number of complaints or conduct matters that have been brought to the attention of a relevant office holder by the police and crime panel either referred to the Independent Police Complaints Commission, or because they are being subjected to informal resolution by the panel 1(f)	​	PCC Website
4	How we make decisions Decision making processes and records of decisions. Information to be published as soon as practicable and available for the current and previous two years
4.1	Schedule of meetings open to the public	N/A	5(a)	​	PCC Website
4.2	Agendas and approved minutes of the Local Policing Body and sub- committees	N/A	5(b) Also, meetings, not public, but where a matter of significant public interest is discussed 5(c)	​	PCC Website
4.3	Background papers for meetings open to the public	N/A	N/A	​	PCC Website
4.4	Facts and analyses of facts used for decision making	N/A	N/A	​	PCC Website
4.5	Public consultations	N/A	N/A	​	PCC Website
4.6	N/A	N/A	Record of each decision of significant public interest 5(d)	​	PCC Website
4.7	N/A	N/A	Copy of any report from the responsible office for a local government area under sec 7(1) C&D Act 1998 Section 7	​	PCC Website
5	Our policies and procedures Current written protocols, policies, and procedures for delivering our services and responsibilities. Information to be published as soon as practicable and be available for current year
5.1	Policies and procedures for the conduct of the office’s business	Standing Orders, delegated powers, corporate governance, code of conduct, memorandum of understanding and similar information.	Decision making process 6(b) Qualifying disclosures (whistle- blowing) 6(d)	constitution	PCC Website
5.2	Policies and procedures for the provision of services	This will include any policies and procedures for handling requests for information.	N/A	​	PCC Website
5.3	Policies and procedures for the employment of staff	Where the office employs its own staff, details of the policies in place, or where staff are employed through another body, reference to the policies of that body vacancies.	N/A	​	PCC Website
5.4	Customer service	Standards for providing services to the office’s customers, including the complaint procedure. Complaints procedures will include those covering	6(a)	​	PCC Website

 

 

		requests for information and operating the publication scheme.
5.5	Records management and personal data policies	This will include information security policies, records retention, destruction and archive policies, and data protection (including data sharing) policies.	6(c)	​	PCC Website
6	Lists and registers Information to be published as soon as practicable and kept up to date
6.1	Register of interests	N/A	1(e)	​	PCC Website
6.2	Register of gifts and hospitality	N/A	2(e)	​	PCC Website
6.3	FoIA disclosure log	N/A		​	PCC Website
7	The services we offer Information about the services we offer, including leaflets, guidance, and newsletters. Information to be published as soon as practicable and kept up to date
7.1	Leaflets and explanatory booklets	N/A	N/A	​	PCC Website
7.2	Media releases	N/A	N/A	​	PCC Website
7.3	Services for which the Local Policing Body is entitled to recover a fee, together with those fees	N/A	N/A	​	PCC Website

ⁱ Elected Local Policing Bodies (Specified Information) Order 2011 and Elected Local Policing Bodies (Specified Information) (Amendment) Order 2012

Download the policy with this link

STANDARD OPERATING PROCEDURES: OFFICE OF THE BEDFORDSHIRE POLICE AND CRIME COMMISSIONER

Title	Record Management, Retention and Disposal Policy
Area of Compliance	Compliance
Version No.	6.0
Senior Lead	Head of Governance and Compliance
Author	Compliance

Revision History

Date	Revision	Change	Review Date
December 2015	1.0		December 2016
29/09/2017	2.0	Full review completed	29/09/2017
15/05/2018	3.0	Full GDPR review	15/05/2019
15/05/2019	3.0	No Change	15/05/2020
20/09/2020	3.0	No Change	20/09/2021
17/09/2021	3.0	Complaints Policy website link updated	17/09/2022
17/10/2022	4.0	OPCC Logo Updated, update of Protective Marking Scheme	17/09/2023
27/09/2023	5.0	Accessibility amendments, Updated Article 5 wording, updated links	27/09/2024
20/08/2024	5.0	No Change	20/08/2025
22/08/2025	6.0	Updated PCC Logo Updated website links	22/08/2026

Introduction

The Office of Police and Crime Commissioner (OPCC) for Bedfordshire is committed to the highest possible standards of openness, probity, and accountability. All organisations generate records which must be collated, maintained, and revised over time.

As a public body, the OPCC for Bedfordshire has a responsibility to be accountable to the public for their actions. Therefore, the records must be accurate and capture accurate details. The policy for management of these must protect the rights of privacy, confidentiality, and security. This applies to the management of records of all formats or media, whether created or received.

Effective records management is essential to support compliance with the UK General Data Protection Regulations (GDPR) and the Freedom of Information Act 2000 (FOIA).

This policy statement sets out how the OPCC for Bedfordshire manages information and complies with its statutory obligations and will be kept under annual review. It applies to all the information held by the office, regardless of its format or origin. It includes policy and procedures around:

• Records management, security and sharing information; and
• Retention and deletion of

Under the GDPR the OPCC has a number of responsibilities as both a ‘data controller’ and ‘data processor’. The OPCC will use personal information and may, on occasion, use some categories of sensitive personal information to carry out our official functions or public tasks that are set out in law, mainly the Police Reform and Social Responsibility Act 2011. For example, when a complaint is made against the Chief Constable, the Commissioner’s Office (OPCC) will retain and process the personal information shared with us to carry out the lawful public task of investigating this complaint.

Article 5 of the GDPR requires that personal data shall be:

Personal data shall be:

• processed lawfully, fairly and in a transparent manner in relation to the data subject (lawfulness, fairness and transparency).
• collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be incompatible with the initial purposes (purpose limitation).
• adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (data minimisation).
• accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (accuracy).
• kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);
• processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (integrity and confidentiality).

Article 5(2) requires that:

The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (accountability).

There are special arrangements under the Act for processing sensitive personal information. This includes racial or ethnic origin, political opinions, religious or other beliefs, trade union membership, physical or mental health condition, sexuality, criminal proceedings or convictions.

The lawful bases for processing are set out in Article 6 of the GDPR. At least one of these must apply whenever any organisation processes personal data:

• Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
• Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering a
• Legal obligation: processing is necessary for you to comply with the law (not including contractual obligations).
• Vital interests: processing is necessary to protect someone’s
• Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in
• Legitimate interests: processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)

We may collect personal information to process an enquiry, manage a bid for services or a contract and subject to consent to partners and members of the public about other events and activities that we think may be of interest to them.

When a complaint is made against the Chief Constable, the OPCC will retain and process the personal information shared with us to carry out the lawful public task of investigating this complaint. The OPCC will also respond quickly to share any personal information with Bedfordshire Police when it relates to a risk to life or the need to protect and safeguard the public.

In order to process any complaint or issue of dissatisfaction raised against Bedfordshire Police, its officers and staff, the Commissioner is required to share relevant personal information with Bedfordshire Police Force to ensure that the complaint is looked into and to meet our public task - (e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.

The OPCC will pass relevant personal information to the Bedfordshire Police Force (including where necessary the parts of Bedfordshire Police Force that are collaborated with Hertfordshire and Cambridgeshire Constabularies) so that they may offer the individual a response to a complaint or issue of dissatisfaction that reflects the operational role of the police force.

More information on how the OPCC process complaints is available within the Complaints policy.

Bedfordshire OPCC will not share personal information with other organisations or companies without a lawful purpose (as set out under Article 6 GDPR 2018) or without the explicit consent of the data subject.

In processing any bid for a contract to provide services, the OPCC may share data with Bedfordshire Police Force, credit reference agencies and fraud prevention agencies, consent to share information will be sought from bidding organisations via the grant application form.

The Freedom of Information Act and Subject Access Requests

Under the Freedom of Information Act and the Environmental Information Regulations the public have a right to request any recorded information held by a public authority.

Any individual has the right to ask for any information that think a public authority may hold. The right only covers recorded information which includes information held on computers, in emails and in printed or handwritten documents as well as images, video and audio recordings.

They can do this in writing. The public authority must tell the applicant whether it holds the information. A public authority can only refuse to confirm or deny whether it holds the information if this would reveal information that falls under an exemption. The public authority must supply it within 20 working days, in the format requested. The Act applies to all information, not just information held since the Act came into force.

Guidance on how to submit a Freedom of Information request is available via the Information Commissioners Office website.

Guidance on how to submit a subject access request is available via the Information Commissioners Office website.

In some circumstances information may not be provided in response to a data access request because it is exempt, for example because it would unfairly reveal personal details about somebody else. The OPCC does not have to provide information if an exemption applies, or in certain cases if the cost of providing the information is too high.

Records Management and Information Security

All organisations generate records which must be collated, maintained and revised over time. Public authorities are accountable for their actions to the public so need to ensure their records are accurate and reliable. A record is any report, letter, email, minute, decision note, meeting note or other document whether hard copy or electronic, whether created or received or includes any personal data.

The OPCC approach to record management aims to ensure that:

• The value of information is understood
• Records are present
• Records can be accessed and updated easily
• Records can be easily interpreted
• Records are a reliable representation of that which it is supposed to document; and
• Qualities of the document can be maintained, despite alterations or adaptations over time.

The OPCC is committed to the creation, storage, management, and eventual disposal of records in a manner accurately documenting the functions of the OPCC and compliant with this policy. All staff who create, receive, and use records have record management responsibilities at some level.

The OPCC will ensure that it develops and utilises systems for the documenting of its activities and registering its records. To maintain records efficiently and where applicable, there should be a tracking system in place so the location of records can be established and retrieved.

Our policy is to:

• Manage information effectively as a strategic corporate body by providing timely, appropriate, accurate and up-to-date information when it is needed
• Make information available to those with a business need to see it
• Take appropriate measures to protect information, including personal information, which cannot be shared for reasons of security or privacy
• Assess and manage risks to confidentiality, integrity and availability of information
• Ensure that information created, collected and stored is proportionate to the business need, and is retained only for as long as it is needed
• Ensure information is of the appropriate quality, and in the appropriate media, to support business needs
• Create an information literate culture, where all staff recognise that information is everyone’s responsibility and have the skills, confidence & commitment to effectively manage information according to the requirements of their role; and 
• Comply with all relevant statutory and regulatory requirements

Electronic records

Electronic records will be held in structured folders and will logically group information together with security arrangements to ensure that the integrity of the records can be maintained and protected from loss or destruction. It should be remembered that it may be necessary for electronic records to be transmitted from one system to another and their format should be consistent with this.

Information Security

All employees should report any breach, possible breach, or threat of any sort to the security of OPCC information systems, to the designated Data Protection Officer (DPO) for the OPCC, who will follow an agreed Data Breach Management Plan. Any data breach will be recorded, investigated, and reported to the Information Commissioner’s Office via the Information Management Unit as appropriate.

Mobile Working and Transportation of Data

All devices containing OPCC data must be safe and secure when unattended both in and outside of the office. Information contained on a mobile device and taken off-site should be kept to a minimum.

Our policy is to:

• discourage unnecessary requests to transport sensitive data away from the main office and to seek clarity on the destination and proposed use of the information
• ensure all documents are clearly marked ‘confidential’ where appropriate, and conceal paper documents from sight at all stages of the journey
• provide secure external media devices (pen-drives, hard drives) to facilitate the need to transport sensitive data
• ensure all staff are aware of their responsibilities when transporting data from one location to another, and
• ensure staff immediately report any loss of information to their line manager, in the first instance, a report will be submitted in all cases to the Data Protection Officer.

E-mail

Information that is passed over an insecure network should be considered as being open to the public. Therefore, information which is not suitable for the public domain should not be processed or stored on personal computing equipment. Material marked as ‘Official sensitive’, ‘Restricted’ or ‘Confidential’ should not be sent electronically to personal, unsecure email addresses.

The OPCC electronic system is delivered by the Tri-Force and procedures will reflect the requirements outlined in the Tri-Force Joint Information Management Strategy (IMS).

Passwords

All staff have a responsibility for managing their own passwords and should not share passwords with others. Passwords should be changed regularly but not sequentially.

Protective Marking Scheme

Those handling police information have a responsibility to value and safeguard all information they send or receive. Where necessary, appropriate classification and measures should be clearly identified to enable sharing and to protect from loss, damage or unauthorised and inappropriate access to the information.

Classification ensures that police information is handled appropriately to protect individual rights in accordance with the law (part 3, chapter 2, section 40 Data Protection Act 2018) and with respect for the wider public interest.

Although there is no direct correlation between the new Government Security Classification (GSC) and outgoing Government Protective Marking Scheme (GPMS), the below demonstrates how GSC compares with GPMS. It also identifies the three new categories and the use of OFFICIAL-SENSITIVE within OFFICIAL:

Government Protective Marking Scheme (GPMS): Top Secret, Secret, Confidential, Restricted, Protect, NPM

Government Security Classification (GSC): Top Secret, Secret, Official [Official- Sensitive]

In deciding the correct marking for the information, the initiator should consider how damaging the consequences would be if the material was lost, stolen, disclosed, or destroyed.

Securing your PC

Where staff must leave their desks in the office unattended, they should press Ctrl-Alt-Delete together to lock their PC or log out of all systems. For a meeting or similar period of absence PC monitors should be also switched off.

Review

The OPCC regularly reviews their Record Management Retention and Disposal Policy, but no less frequently than every twelve months. Records management procedures are in place to ensure compliance with this policy statement and to incorporate changes where necessary.

Retention and Destruction Procedure and Schedule

The OPCC is committed to operating in an open and transparent manner. The record disposal procedure is designed to support the Commissioner’s corporate governance framework. The purpose of this procedure is to:

• prevent the premature destruction of records
• provide consistency of preservation/destruction
• improve record management

Records will be retained for the periods shown in the below Record Retention and Disposal Schedules. All retention periods are given in whole years and are from the end of the financial year to which the records relate. Records should be disposed of by shredding / arranging for collection as confidential waste for destruction by the appropriate body and this should also include all back-up copies on alternative media.

Litigation

Whenever there is a possibility of litigation or a request under either the Freedom of Information Act or Data Protection Act, the records that are likely to be affected should not be amended or disposed of until the threat of litigation has ended or the appeal processes under the Freedom of Information Act have been exhausted.

Record of Disposal

A record of disposal of the information detailed in the attached schedule should be maintained which identifies each record destroyed.

Standard Operating Procedure

This applies to records which do not need to be kept at all. Information, which is duplicated, unimportant or of short-term use can be destroyed under the Standard Operating Procedure, including:

• compliment
• catalogue and trade
• telephone message
• trivial e-messages or notes not related to OPCC
• working papers which lead to a final report (including notes of meetings).
• duplicated and superseded material such as stationery, manuals, drafts, address books and reference copies of annual reports.
• e-copies of documents where a hard copy has been printed and filed or vice

Except where these may be used as evidence to prove that something has happened.

Record Retention and Disposal Schedules

Contents

• Office of the Police and Crime Commissioner
• Police and Crime Commissioner/Deputy Police and Crime Commissioner
• Management and Administration
• Legal and Contracts
• Human Resources
• Financial Management
• Property and Land Management
• General

Download the policy with this link

1 OFFICE OF THE POLICE AND CRIME COMMISSIONER

	Function	Records	Retention	Statutory Provisions/Authority	Method of disposal
1.1	Appointment of Chief Constable	Advertisements, Application Forms, Interview Reports.   Personnel Files	2 years   6 years from the date of the last pension payment	Common Practice     Common Practice	E-copy – delete Hardcopy – Confidential shred
1.2	Audit Committee meetings	Minutes, agendas, reports, indexes Draft and audio minutes   Background papers     Terms of reference Membership	Permanent   Destroy once minutes are formally approved 4 years from date of production at meeting   Until superseded	Common Practice Common Practice   Common Practice     Common Practice	Archive   E-copy – delete Hardcopy – Confidential shred
1.3	Complaints against the Chief Constable	Correspondence	6 Years after finalisation	Common Practice	E-copy – delete Hardcopy – Confidential shred
1.4	Complaints and enquiries directed at the OPCC	Correspondence, summary reports, details of investigations	6 Years after finalisation	Common Practice	E-copy – delete Hardcopy – Confidential shred
1.5	Corporate planning and reporting	Police and Crime Plans Strategic Plans Annual Reports	Permanent	Common Practice	Archive
1.6	Dismissal of the Chief Constable	Resignation, redundancy, dismissal, death, retirement	6 years after termination or, if pension paid, 6 years after last pension payment	Common Practice	E-copy – delete Hardcopy – Confidential shred

 

1.7		Employment Tribunals		Cases		6 years after last action		Common Practice		E-copy – delete Hardcopy – Confidential shred
1.8	External Meetings (where the OPCC does not own the record)		Minutes, agendas and reports		3 years		Common Practice		E-copy – delete Hardcopy – Confidential shred
1.9	Independent Custody Visiting Scheme		Panel minutes, agendas, reports   Visiting reports, rotas, Panel contact details Personnel files     Scheme/handbook Complaints against Visitors Newsletters Expense Claims		2 years   6 years   Until age 100. Consider age 85 years of age for non-pay/pension records Until superseded   On termination of membership 2 years 6 years from termination of membership		Common Practice Common Practice Common Practice Common Practice Common Practice Common Practice Common Practice		E-copy – delete Hardcopy – Confidential shred
1.10	Independent Members serving Police Misconduct Panels and Audit Committees		Personnel files Expense Claims   Scheme/handbook Complaints about Independent members		Until age 100. Consider age 85 years of age for non-pay/pension records 6 years from termination of membership Until superseded Permanent		Common Practice Common Practice   Common Practice Common Practice		Archive   E-copy – delete Hardcopy – Confidential shred Archive
1.11	Partnership, agency and other meetings (where the OPCC owns the record)		Minutes, agendas and reports		Permanent		Common Practice		Archive
1.12	Police Appeal Tribunals		Cases		Permanent		Common Practice		Archive
1.13	Statutory Inspections, reviews and external audit reports		Reports		Permanent		Common Practice		Archive
1.14	Statutory returns		Reports to Central Government		7 years		Common Practice		E-copy – delete Hardcopy – Confidential shred
1.15	Working Groups / Project Boards		Minutes, agendas and reports		5 years		Common Practice		E-copy – delete Hardcopy – Confidential shred

2 POLICE AND CRIME COMMISSIONERS /DEPUTY POLICE AND CRIME COMMISSIONERS

	Function	Records	Retention	Statutory Provisions/Authority	Method of disposal
2.1	Appointment	Personnel Files   Advertisements, application forms, interview notes   Legislation/national guidance	Until age 100. Consider age 85 years of age for non-pay/pension records 2 years after date of appointment   until superseded	Common Practice Common Practice   Common Practice	Archive   E-copy – delete Hardcopy – Confidential shred
2.2	Conduct	Complaint Cases	Permanent	Common Practice	Archive Scan into E- copy
2.3	Payments	Salary and allowances	6 years from termination of membership	Common Practice	E-copy – delete Hardcopy – Confidential shred
2.4	Registers of Interests, Gifts and Hospitality	Register of Interests Register of Gifts and Hospitality	Permanent	Common Practice	Archive – E- copy must be kept

 

3 MANAGEMENT AND ADMINISTRATION

	Function	Records	Retention	Statutory Provisions/Authority	Method of disposal
3.1	Association of Police and Crime Commissioners (APCC) Circulars	Circulars	Permanent	Common Practice	Archive – E- Copy
3.2	Diaries and calendars	Electronic and manual diaries and calendars	3 years	Common Practice	E-copy – delete Hardcopy – Confidential shred
3.3	Enquiries – Other OPCCs and general	Routine responses to enquires	1 year	Common Practice	E-copy – delete Hardcopy – Confidential shred
3.4	General correspondence	Correspondence – minor and routine	1 year	Common Practice	E-copy – delete Hardcopy – Confidential shred
3.5	Home Office Circulars	Circulars	1 year	Common Practice	Archive – E- Copy

3.6

Information Management

Filing indices   Records of transfers to archives   Summary of responses to enquiries Disposal records Reports/correspondence on OPCC action Routine responses to enquiries General Correspondence/emails and faxes

Permanent 12 years 6 years       2 years Archive for 1 year – destroy if no further use. No file should remain open for more than 5 years and may be closed at any time within

Common Practice Common Practice     Common Practice   5-year rule specified in Code of Practice on Records

Archive   E-copy – delete Hardcopy – Confidential shred     E-copy – delete Hardcopy – Confidential shred

 

			the period based on monitoring of usage and additions. If closed and new activity begins, a new volume of the file should be created, and the retention period of the old volume be brought in line with the new volume.	Management under s46 Freedom of Information Act 2000.
3.7	Marketing	Developing and promoting OPCC events   Information about the OPCC	2 years   When superseded	Common Practice   Common Practice	E-copy – delete Hardcopy – Confidential shred
3.8	Media Relations	Media reports Media releases	3 years	Common Practice	E-copy – delete Hardcopy – Confidential shred
3.9	Newsletter	OPCC Newsletter	1 year	Common Practice	E-copy – delete Hardcopy – Confidential shred

 

 

3.10	Office Management	Contracts with suppliers	12 years if sealed 7 years from end of contract	Common Practice	E-copy – delete Hardcopy – Confidential shred
3.11	Policy Development	Policies Instructions/Rules/Procedures Organisational Charts Financial and Contract Regulations Routine responses on policy or procedures (printed material, letters)	25 years then review and archive 1 year after revision	Common Practice         Common Practice	Archive         E-copy – delete Hardcopy – Confidential shred
3.12	Policy/strategy review	Reports and supporting documentation	5 years from closure		E-copy – delete Hardcopy – Confidential shred
3.13	Publications	The process of designing and setting information for publication   The published work of the OPCC	3 years from the last action     Destroy after administrative use is concluded. Note one copy from the initial print run should go directly to the archive.	Common Practice Common Practice	E-copy – delete Hardcopy – Confidential shred
3.14	Public Consultation	Consultation on development of significant policies   Consultation on development of minor policies   Consultation meeting notes, records, correspondence, minutes, supporting papers and correspondence	5 years     1 year     2 years	Common Practice Common Practice Common Practice	E-copy – delete Hardcopy – Confidential shred

 

3.15	Quality and Performance	OPCC Inspection/ Best Value Review reports	5 years	Common Practice	E-copy – delete Hardcopy – Confidential shred
3.16	Unstructured records	Records that do not support a business process i.e. there is not an existing place for them in a filing structure and none will be created. This applies to filing structures for paper and electronic formats including e- mails. Working papers which lead to a final report (unless report is submitted to Committee – in which case papers should be available for 6 years in line with availability of the minutes for public inspection)	Destroy as soon as use has ceased	Local Government Act 1972 – Access to information for working papers as background to reports to Committee	E-copy – delete Hardcopy – Confidential shred

 

4 LEGAL AND CONTRACTS

 

	Function	Records	Retention	Statutory Provisions/Authority	Method of disposal
4.1	Agreements	Service level agreements with the OPCC	6 years after agreement expires	Common Practice. It depends on the value of agreement. Mainly to do with agreements between public bodies. Not in regard to contracts.	E-copy – delete Hardcopy – Confidential shred
4.2	Asset acquisition/disposal	Legal documents relating to purchase/sale Leases   Tender documents	3 years	Common Practice   Common Practice	E-copy – delete Hardcopy – CONFIDENTIAL SHRED
4.3	Contract development (ordinary)	Tender specification	6 years after the terms have expired	Statutory	E-copy – delete Hardcopy – Confidential shred
4.4	Contract development (under seal)	Tender specification	12 years after the terms have expired	Statutory	E-copy – delete Hardcopy – Confidential shred
4.5	Conveyance	Conveyance files	12 years after closure.	Statutory	E-copy – delete Hardcopy – Confidential shred
4.6	Evaluation of tenders (ordinary)	Evaluation criteria Successful tender document	6 years after the terms have expired	Statutory	E-copy – delete Hardcopy – Confidential shred

 

 

4.7	Legal Advice	Correspondence Fees	3 years	Common Practice	E-copy – delete Hardcopy – Confidential shred
4.8	Litigation	Correspondence Criminal and civil case files	7 years after last action	Common Practice	E-copy – delete Hardcopy – Confidential shred
4.9	Post tender negotiation	Minutes Correspondence	1 year after the terms of the contract have expired	Common Practice	E-copy – delete Hardcopy – Confidential shred
4.10	Tenders	Tender envelope	1 year after the start of contract	Statutory	E-copy – delete Hardcopy – Confidential shred
4.11	Unsuccessful tender documents	Tender documents quotations	1 year after the start of contract.	Common Practice	E-copy – delete Hardcopy – Confidential shred

 

5 HUMAN RESOURCES

	Function	Records	Retention	Statutory Provisions/Authority	Method of disposal
5.1	Appointment of Statutory Officers	Vacancies and applications records Interview notes prospective staff Records Registers of Unsuccessful applicants application records	2 years after date of appointment	Common Practice	E-copy – delete Hardcopy – Confidential shred
5.2	Disciplinary and Grievance investigations (proved)	Disciplinary records Grievance records	Oral warning – 6 months Written warning – 1-year Final warning – 18 months Dismissal – after determination of all internal and external appeals – 2years	Common Practice	E-copy – delete Hardcopy – Confidential shred
5.3	Disciplinary and Grievance investigations (unproved)	Disciplinary records Grievance records	3 years	Common Practice	E-copy – delete Hardcopy – Confidential shred
5.4	Employee relations	Agreements Correspondence re Formal negotiations Correspondence re minor and routine matters	Permanent 2 years	Common Practice	Archive E-copy – delete Hardcopy – Confidential shred
5.5	Equal Employment Opportunities	The process of investigation and reporting on specific cases to ensure that entitlements and obligations are in accordance with agreed Equal Employment Opportunities guidelines policies.	5 years after action completed	Common Practice	E-copy – delete Hardcopy – Confidential shred
5.6	Medical Records	Medical examinations Adjustment to work examinations	72 years after DOB	Common Practice	E-copy – delete Hardcopy – Confidential shred
5.7	PDR	Probation reports Performance reports and plans	5 years after action completed	Common Practice	E-copy – delete Hardcopy – Confidential shred

 

 

5.8	Personnel administration	Establishment lists Personnel files	Permanent Destroy 6 years from date of last pension payment/leaving date	Common Practice	Archive E-copy – delete Hardcopy – Confidential shred
5.9	Recruitment – the selection and appointment of an individual for an established position	Advertising, application forms, references, interview reports   Vetting checks and associated documentation	1 year after the appointment was made.   Positive outcomes – 2 years after date of check. Negative outcomes – 1 year after date of check.	Common Practice     Common Practice	E-copy – delete Hardcopy – Confidential shred
5.10	Staff leave/Sickness monitoring	Sickness records Leave records Flexi cards	Until age 72	Common Practice	E-copy – delete Hardcopy – Confidential shred
5.11	Staff retention	Financial reward	Destroy 7 years after action completed	All records relating to actual payments are dealt with under Finance	E-copy – delete Hardcopy – Confidential shred
5.12	Staff termination	Resignation, redundancy, dismissal, death or retirement	6 years after termination or, if pension paid, 6 years after last pension payment	Common Practice	E-copy – delete Hardcopy – Confidential shred

 

6 FINANCIAL MANAGEMENT

	Function	Records	Retention	Statutory Provisions/Authority	Method of disposal
6.1	Annual reports	Annual Statement of Accounts	Permanent	Common Practice	Archive
6.2	Approvals/process for purchase	Purchase/sales order	7 years after end of financial year	Statutory	E-copy – delete Hardcopy – Confidential shred
6.3	Asset Acquisition and Disposal	Management of the acquisition (by financial lease of purchase) and disposal (by sale or write off) process for assets	6 years, if under £50,000 or 12 years if over £50,000, after all obligations / entitlements are concluded	Statutory	E-copy – delete Hardcopy – Confidential shred
6.4	Asset monitoring and maintenance	Asset registers     Inventories Stocktaking Acquisition & disposal reports Service/maintenance records	7 years after the end of the financial year   2 years after admin use     7 years after sale or disposal	Statutory Common Practice Statutory	E-copy – delete Hardcopy – Confidential shred
6.5	Budget setting	Final annual budget   Draft budgets and estimates Quarterly budget reviews	Permanent     2 years after budget set Destroy after following years budget adopted	Only the final version of the annual budget needs to be kept Common Practice Common Practice	Archive     E-copy – delete Hardcopy – Confidential shred

 

 

6.6	Expenditure	Invoices/receipts Bank statements Vouchers/ledger Write offs of public monies Processes to balance and reconcile financial accounts	6 years after end of financial year       2 years after admin use is concluded	Statutory       Common Practice	E-copy – delete Hardcopy – Confidential shred E-copy – delete Hardcopy – Confidential shred
6.7	Finance reports	Quarterly budget reports Working papers	Destroy when admin use complete	Common Practice	E-copy – delete Hardcopy – Confidential shred
6.8	Internal Audit	Internal Audit reports – main financial and subsidiary systems Value for money studies Working papers   Follow up audits	Destroy on completion of next full audit       Destroy on full implementation of recommendations or completion of follow-up audit Destroy on completion of next full audit	Common Practice         Common Practice	E-copy – delete Hardcopy – Confidential shred
6.9	Loans	Loan files (borrowing money to enable authority to perform its functions and exercise its powers) Loans register/summary management of loans	Destroy after the loan has been repaid     Permanent	Statutory       Common Practice	E-copy – delete Hardcopy – Confidential shred Archive
6.10	Payroll	Claim forms Pay/tax records Summary pay reports Non-applicable processes relating to payment of employees	7 years after the end of the financial year   Destroy after admin use	Statutory     Common Practice	E-copy –delete Hardcopy – Confidential shred

 

7 PROPERTY AND LAND MANAGEMENT

	Function	Records	Retention	Statutory Provisions/Authority	Method of disposal
7.1	Insurance	Insurance policies Correspondence	7 years after terms expire	Common Practice	E-copy – delete Hardcopy – Confidential shred
7.2	Management of buildings of special interest	Project specification Plans Certificates of approval	Permanent	Common Practice	Archive
7.3	Property acquisition	Plans	Life of property plus 12 years	Common Practice	E-copy – delete Hardcopy – Confidential shred
7.4	Property disposal	Legal documents Survey reports Tender documents Conditions of contracts	15 years after all obligations end	Common Practice	E-copy – delete Hardcopy – Confidential shred
7.5	Property inventories	Inventories	Permanent	Common Practice	Archive

 

8 GENERAL

	Function	Records	Retention	Statutory Provisions/Authority	Method of disposal
8.1	Freedom of Information requests where exemptions apply, complaints or appeals are made	Requests for information dealt with under the provisions of the Freedom of Information Act 2000 where: The records are subject to exemptions (partially or wholly), A Public Interest Test has been formally applied, A complaint has been made to OPCC about the application of exemptions or handling of the request, A complaint has been made to the Information Commissioner about the application of exemptions or the handling of the request	The request itself, associated records, and any records to which the request applies should not be destroyed until LPA is satisfied that requestor does not wish to pursue an appeal or the appeal process has been exhausted.   The documentation should remain current for 1 year from the last action, then closed for 1 further year, then destroyed if no further activity occurred.   Should an activity occur within that period, the documentation should become current again.	Freedom of Information request (not routine); Correspondence with requestor/Information Commissioner; Correspondence in locating records; Records of public interest tests and exemptions decisions; Details of records relating to the request (references, titles, locations, owners).	E-copy – delete Hardcopy – Confidential shred
8.2	Health and Safety	Risk assessments Accident books/RIDDOR correspondence and fire certificates	Risk Assessments current plus 10 years, Accident books 3 years from last entry and Fire certificates until superseded	Common Practice	E-copy – delete Hardcopy – Confidential shred

 

Memorandum of Understanding for between Bedfordshire Police and Crime Commissioner and Chief Constable Bedfordshire Police for Live Facial Recognition

This Memorandum of Understanding (MOU) sets out the terms and understanding between the Police & Crime Commissioner for Bedfordshire and Bedfordshire Police surrounding the principles and governance for the ethical, legal, and proportionate use of Live Facial Recognition (LFR) technology by Bedfordshire Police, under the oversight of the Police and Crime Commissioner (PCC).

Live Facial Recognition

LFR is a real-time deployment of facial recognition technology, which compares a live camera feed (or multiple feeds) of faces against a predetermined watchlist, in order to locate persons of interest by generating an alert when a possible match is found.

LFR is being used by forces for a number of policing purposes, including:

• supporting the location and arrest of people wanted for criminal offences
• preventing people who may cause harm from entering an area (for example, fixated threat individuals, persons subject to football banning orders)
• supporting the location of people about whom there is intelligence to suggest that they may pose a risk of harm to themselves or others (for example, stalkers, terrorists, missing persons deemed at increased risk)

Bedfordshire Police must ensure compliance with:

• Home Office Surveillance Camera Code of Practice
• College of Policing Authorised Professional Practice (APP)
• Data Protection Act 2018 and UK GDPR
• Human Rights Act 1998
• NPCC National Guidance

Strategic Intent

The use of LFR will be intelligence-led, targeted, and proportionate, supporting operational policing (as defined in Bedfordshire Police policy and the APP to:

• supporting the location and arrest of people wanted for criminal offences
• preventing people who may cause harm from entering an area (for example, fixated threat individuals, persons subject to football banning orders)
• supporting the location of people about whom there is intelligence to suggest that they may pose a risk of harm to themselves or others (for example, stalkers, terrorists, missing persons deemed at increased risk)
• Supporting the use of targeted preventative policing tactics in areas where intelligence suggests violent crime may be committed.

Governance and Oversight

• The Chief Constable is accountable for operational deployment.

Bedfordshire Police will hold the Strategic Police powers board, this in turn will feed into the local performance board. Every deployment is subject of an authority process which will be overseen by a Superintendent which considers the legality of the deployment given full consideration to ECHR, the Data Protection Act, Equality Act amongst others.

• The PCC will hold the Chief Constable to account for this operational deployment.
• The PCC provides strategic oversight and ensures public confidence but has no operational responsibility.

• An Ethics Panel supported by the PCC’s Office, will scrutinise deployments, compliance, and community impact.
• An Equality Impact Assessment (EIA), Data Protection Impact Assessment (DPIA) and legal mandate must be completed annually.

Deployment Principles

Prior to any new operational use of LFR, the PCC must agree at the request of the Chief Constable to its strategic application, but the Chief Constable is responsible and accountable for deployment.

Deployments must:

• Be targeted using a pre-defined watchlist of individuals
• Be proportionate to the legitimate and lawful policing objective
• Be transparent, with clear signage and public engagement
• Be recorded and auditable

Community Engagement and Transparency

The PCC will ensure that Bedfordshire Police inform the public of LFR use through:

• Signage at deployment sites
• Online publication of deployment rationale and outcomes unless advance notice would impact operational outcomes sought.
• Community engagement events
• Feedback mechanisms will be in place to address concerns

Monitoring and Reporting

Formal Outcome Monitoring reports (national returns) will be completed by Bedfordshire Police on a quarterly basis to be brought to Performance and Governance Board for review and discussion, to include ethics panel comments in order scrutinise.

Evaluation and Continuous Improvement

The use of LFR will be evaluated for:

• Accuracy and effectiveness
• Impact on communities
• Compliance with policy and law
• Reviewed by ethics and scrutiny panels
• Reports will be published by the Chief Constable on LFR use
• An annual report will be published by the PCC Ethics Panel

Signatures

By signing below, both parties agree to the terms outlined in this agreement.

Police and Crime Commissioner Signature:

 

Name: John Tizard

Title: Police and Crime Commissioner

Date: 04.08.2025

Chief Constable Signature:

Name: Trevor Rodenhurst

Title: Chief Constable

Date: 29.08.25

The MOU covers a period commencing 30^th July 2025 and ends 1st May 2028, however will be reviewed annually.