Response to an inspection report on Border Force operations at Stansted Airport (accessible version)
Published 28 March 2018
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The Home Office thanks the Independent Chief Inspector of Borders and Immigration for this report.
Border Force at Stansted has seen a significant increase in passenger volumes over recent years and throughout this period has continued to deliver both border security outcomes and the processing of arriving passengers within agreed service levels. Stansted is one of Border Force’s strongest performing ports for staff engagement, as measured by the 2017 Civil Service wide people survey and has delivered significant improvements across a range of areas since the previous ICIBI inspection in 2013.
This strong performance has been enabled in part by ongoing collaboration with the airport operator, a collaboration which has delivered improvements to the arrivals hall (including the installation of 30 e-Passport Gates). More efficient planning and deployment of staff has allowed a stronger operational response to a range of risks, including the introduction of dedicated customs teams and an increased presence in the customs channels.
There are observations within the report with which Border Force does not agree. One such observation is in relation to e-Passport gates. The successful mix of e-Passport gates and professionally trained staff at the frontline is a fundamental part of the Border Force operating model and one that delivers well for the public. Staff engagement is another area where the report findings do not align with other indicators. The 2017 people survey was completed by two-thirds of Stansted staff and showed one of the highest engagement scores in Border Force. Whilst Border Force recognises that there is more to do to improve its operations and performance at Stansted, the improved survey results, a step change since the 2013 inspection (and the 2012 survey results when Stansted’s engagement score was 14% below the average), is testimony to the hard work of managers at the port and their achievements to date in improving staff morale.
It should also be noted that although the report refers to officers not having drugs testing equipment “to hand”, Border Force Stansted has a wide range of portable equipment available for staff to use at the terminal or at freight sheds as and when required. The equipment and testing kits used provide indicative results to inform the decision on whether to seize goods that have been tested. Border Force does not have an investigative function. Should a case be taken forward for criminal prosecution, forensic testing to an evidential standard will be carried out as appropriate by the relevant investigating law enforcement agency.
Border Force has accepted, or partially accepted, all of the recommendations made in this report, some of which were already being addressed.
The Home Office response to the recommendations
In relation to resourcing and training:
Recommendation 1
Review the Stansted “staffing formula” and ensure overall numbers, including the “Seasonal Workforce (SWF)”, are sufficient to enable permanent staff to be released for skills training, and allow for newly-trained staff to be mentored in order to become fully competent in those skills.
Accepted.
Border Force Stansted deployment planning has already improved significantly over recent years to provide a more resilient and flexible approach to operational risk and the wider deployment of staff. This has ensured that key performance indicators are maintained whilst staff receive an average of eight days training per annum. Border Force Stansted will review the current staffing formula in advance of the new business year in April 2018, to assess whether any further changes may be required.
Recommendation 2
Support and encourage permanent staff to become “multi-functional officers”, ensuring that those who wish to do so are able to access places on all 3 “Core Skills” training courses within a reasonable timescale of joining Border Force Stansted.
Accepted.
Border Force Stansted is committed to ensuring that all current staff who are required to be Core Skills 2 or Core Skills 3 trained to meet business needs will receive this training by the end of March 2019.
Recommendation 3
Provide appropriate training and support for newly-promoted Border Force Higher Officers (BFHO) to enable them to become fully-effective managers in the minimum time.
Accepted.
Border Force managers at Stansted have access to a package of training and development programmes to support their development. In addition to this a specific course to enhance decision making skills will be rolled out from summer 2018. We will also ensure that every manager has a tailored development plan in place from April 2018.
In relation to staff engagement:
Recommendation 4
Produce an improvement plan for internal communications at Stansted that reduces the reliance on email, ensures ‘top down’ messages reach and are understood by all affected staff, and that staff have a means of communicating upwards that is seen to be effective.
Partially accepted.
Border Force Stansted already has a comprehensive engagement approach which is designed to meet the challenge of delivering effective communications across a 24/7 organisation. This has contributed significantly to the increased engagement scores as shown in the recent Stansted people survey. However, to deal with some of the findings from this inspection, Border Force Stansted will produce an updated communications plan for the business year commencing in April 2018.
In relation to e-Passport gates:
Recommendation 5
Ensure that sufficient “Roving Officers” are deployed at Stansted to discharge fully Border Force’s responsibilities for safeguarding passengers, both adults and children, in particular when 15 or more of the e-Passport gates are in use.
Accepted.
Border Force Stansted deploys roving officers in line with Border Force guidelines. The national policy states that for terminals with six or more e-Passport gates there is a mandatory requirement for a roving officer to be deployed at all times. Where there are more than 10, it is recommended that two or more roving officers are deployed to the e-Passport gates. A national review of the existing roving officer guidance will be carried out in time for summer 2018 and the findings of this inspection will be factored into that review.
Recommendation 6
Review the guidance to “Monitoring Officers” regarding their safeguarding responsibilities and produce workable advice on how they are to satisfy themselves that a child or young person, or vulnerable adult, does not require them to take safeguarding action. (This recommendation is not restricted to Stansted).
Partially accepted.
Border Force fully accepts that monitoring officers have a role to play in the safeguarding of children and vulnerable people. However as drafted this recommendation fails to take into account the multi-layered approach to safeguarding at the PCP which includes targeted use of intelligence, behavioural detection training, and roving officers at larger ports.
Whilst reviewing roving officer guidance, we will also look at the capabilities of the monitoring officer role. This work will be completed by the summer 2018.
In relation to decision making and record keeping:
Recommendation 7
Ensure that all Border Force staff at Stansted, including the “Seasonal Workforce (SWF)”, understand the need for, and are allocated sufficient time to produce, an accurate and detailed record of their decisions and actions when exercising immigration and customs functions, including their reason(s) and justification(s) for their decisions and actions.
Partially accepted.
In a frontline environment it is important to ensure that officers record accurately that which is legally and operationally required, whilst not being overwhelmed with administrative processes that could delay or even impede frontline delivery. It would not represent the best use of frontline officer time to record every stage of every interaction. For that reason, we have partially accepted this recommendation. As part of the assurance trial described at (9) below, a particular focus will be put on improving the standard of record keeping and data capture. Operational Assurance Directorate will review the outcomes by December 2018.
Recommendation 8
Review operational guidance in relation to entry clearance and Temporary Admission and provide a steer (with examples) to Border Force officers at the immigration controls on how to interpret “compelling compassionate circumstances”, also putting in place assurance checks to ensure that there is an appropriate degree of consistency in how this judgement is being applied across all ports and airports.
Partially accepted.
The provisions in Schedule 10 of the Immigration Act 2016 commenced on 15 January 2018, replacing the powers of temporary admission, temporary release, release on restrictions and all forms of Chief Immigration Officer and Immigration judge bail with a single power of immigration bail. Temporary admission guidance has therefore been withdrawn.
It is not operationally possible to be too prescriptive in defining circumstances that would be considered compelling and compassionate, as each case should be considered on its individual merits based on the professional judgement of the specially trained officers. However, Border Force will engage with operational and policy colleagues across the Home Office to consider whether it would be appropriate to provide operational staff with further guidance (and follow up assurance) in this area. This initial consultation work will be completed by the end of May 2018.
In relation to assurance:
Recommendation 9
Review the assurance regime at Stansted and relaunch it so that it is no longer regarded as a “tick-box exercise” with little value, ensuring that those responsible for completing assurance checks are allocated sufficient time to carry them out effectively, and that the lessons learned are fed back to staff, including on an individual basis where appropriate.
Accepted.
Plans were already in place, and shared with the ICIBI team over the course of this inspection, to review and refine first line assurance processes and outcomes. A trial commenced in January 2018 at Stansted for that purpose.
As part of the 6 month trial, the Border Force Assurance Standards Scheme of Control has been replaced with a high-level Expectations Document for the period which has been designed to empower local managers to determine their highest risks and to focus their assurance activity in those areas. It is anticipated that this approach will result in improved engagement with assurance allowing a better feed into risk management and lessons learned/improvement processes. The trial will conclude in June and following evaluation may be extended or trialled at other ports before a decision is made to fully revise the national approach to first line assurance.