The Home Office response to the Independent Chief Inspector of Borders and Immigration’s report: An inspection of Border Force insider threat
Published 7 September 2023
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January-March 2023
The Home Office thanks the Independent Chief Inspector for this report.
The Border Force Insider Threat and Integrity Programme was formed as a result of the Home Office recognising that additional safeguards were required in a high-risk area of activity above normal vetting and other procedures that already exist for Home Office civil servants. The structures the programme has established mean that Border Force is in a strong position to ensure the integrity of its operations and its people. That approach can flex according to the nature of the threat. We are therefore pleased that the report found that Border Force had demonstrated a willingness to build organisational trust and develop a supportive culture by creating the Protecting People and Risk Team and by introducing a dedicated ‘Protecting People Policy’ alongside its network of integrity leads.
We do recognise there is more to do, and access to data has been a key issue in relation to developing and informing the overall approach. Our plan of work over the next six to twelve months will be informed and updated as we get access to that data and are able to review the overall risk as recommended within the inspection report.
Recommendation 1
Conduct a review of insider threat in Border Force within six months, utilising NPSA advice and guidance, and considering ongoing contemporary changes in UK law enforcement, to facilitate the development of an insider threat strategic vision and a plan that is reviewed annually.
Partially accepted
The Border Force Insider Threat and Integrity Committee (BITIC), which has representation at a senior level from key partners, reviews the risk level and associated mitigations on a regular basis and signed off the plan of work that the Insider Threat Programme is part way through delivering.
It is important that the focus of the work remains on delivering key programme milestones, including the next stages of mandatory declarations now underway, the further roll out of additional security checks and drugs and alcohol testing from the end of 2023.
We will work through the BITIC over the course of 2023 to take the outcomes of the inspection and wider organisational issues into consideration to ensure that the plan remains fully valid, and the initiatives have had the expected impact over the coming months, following which we will update or adapt as necessary.
Home Office expected implementation date: December 2023.
Recommendation 2
Ensure that there is a clear escalation route to a single, senior Home Office leader for the Border and Enforcement Insider Threat and Integrity Committee to resolve issues that cut across both Border Force and the wider Home Office.
Accepted and fully implemented
The Director General (DG) of Border Force is the senior responsible officer for the Border Force Insider Threat and Integrity Committee. The Director of the Insider Threat Programme reports to the DG to ensure a direct line of communication for any issues.
Recommendation 3
Make insider threat awareness training part of formal induction training for new recruits and mandatory training for existing staff.
Accepted
The awareness sessions continue to take place across Border Force with 56 sessions held between January 2022 and June 2023, with over 2750 attendees. A proposal to make the session mandatory for all BF staff (biennially) and included in induction training has been made to the Border Force Learning and Development Board and we expect to ratify this arrangement this year. This is in addition to the Home Office Integrity e-learning sessions that are already mandatory for all Home Office staff.
Home Office expected implementation date: End 2023.
Recommendation 4
Publish an updated social media policy, tailored to Border Force operational staff and ensure that this is widely disseminated and communicated.
Accepted
An updated policy for the whole Home Office, which has been informed through consultation including with Border Force, was published on the 21 July. The Border Force Operational Assurance Directorate will ensure that supporting communications are developed and disseminated that link clearly to our operational landscape and the Border Force Code of Ethics.
Home Office expected implementation date: End 2023.
Recommendation 5
Redacted
Recommendation 6
Conduct role-based risk assessments in key areas and specialist roles.
Partially accepted
The fact that Border Force has a separate programme of work from the wider Home Office is an acknowledgement of the additional risk the work at the border presents. We also have additional checks and clearances in place for certain roles and functions and so to that extent, we have applied a risk-based approach.
The Home Office approach at this stage is to roll out the programme of initiatives to all Border Force staff to ensure we maintain maximum flexibility of deployment and maximum cultural impact. To focus on certain areas or teams only would create human resources and policy issues that would overcomplicate the approach. Once the programme is further rolled out within Border Force, we will review with key partners through the BITIC by the end of 2024.
Home Office expected implementation date: end 2024.
Recommendation 7
Ensure relevant data from vetting, Home Office Security, and Human Resources is available to Border Force, in order to allow Border Force to create a comprehensive insider threat picture to drive early intervention.
Accepted
The programme has long recognised the need to lawfully obtain additional data sets from across the Home Office to inform its work. We are now in a position to take that forward and develop processes to provide appropriate access to relevant data which will be provided over the course of 2023 where there is a lawful basis for this to happen.
Home Office expected implementation date: end 2023.
Recommendation 8
Conduct a review of the effectiveness of the Joint Anti-Corruption Intelligence Team and map its outcomes, using data to support decisions and recommendations, to ensure the team is adding value for all partners.
Accepted
We regularly review operational outcomes to feedback into intelligence partners and to the development of the programme. Access to the HR data as set out in recommendation 7 above will be the right baseline to allow us to review the overall effectiveness of the team and adjust or refocus as necessary. We will carry out a review by the end of March 2024 to assess effectiveness and agree a future strategy for the team.
Home Office expected implementation date: March 2024.