Challenging the “nationally agreed” vetting level in the Framework Service Level Agreement

On 13 April 2026, a revised Framework Service Level Agreement was published on gov.uk under the name of the Biometrics and Surveillance Camera Commissioner. Section 4 of the Framework Service Level Agreement now states that local authority CCTV staff “should be vetted to the nationally agreed minimum standard of NPPV Level 2 (Abbreviated)”. Every previous edition of Section 4, including the edition first published in 2021 and the working draft that preceded it, used the words “nationally agreed minimum standard” without naming any level.

We have written to the Commissioner's office to challenge this. The CCTV User Group was consulted on every one of those earlier drafts, from 2019 through to 2023. No draft naming a level was ever put to us, and the April 2026 revision cites no source for the figure it now contains.

To be clear, the CCTV User Group's position is not that CCTV operators should go unvetted. Vetting staff who access police information is essential, and we support it. Our concern is with how a level gets decided: not a single blanket figure that any force can point to, but a proper assessment specific to each role.

This matters because naming NPPV Level 2 (Abbreviated) as a nationally agreed minimum standard conflicts with how police vetting actually works. The College of Policing's own Vetting Authorised Professional Practice requires the vetting level for non-police roles, including CCTV operators, to be assessed case by case, against the risk of each role. It does not list local authority CCTV staff among the roles that carry a fixed, prescribed level. A single sentence describing one level as “nationally agreed” risks being read by councils and police forces alike as settling a question that is supposed to be decided locally.

We have already seen this happen. In August 2026, Kent Police wrote to the councils in its area requiring NPPV Level 2 Full, a higher level than the one named in Section 4, for every CCTV operator with access to Airwave radio. Kent Police's letter relied on national vetting guidance, not on the Framework Service Level Agreement, which illustrates the problem: the guidance that actually governs these decisions makes no mention of a nationally fixed level, while the Framework Service Level Agreement now asserts one with no stated basis.

We are concerned this is not confined to one force. HM Inspectorate of Constabulary and Fire and Rescue Services has already found, in a 2023 inspection of a different force, that it lacked a clear understanding of the vetting level required for non-police personnel. A sentence in a national document naming a figure removes the pressure on forces to work that out properly themselves, and could see more members facing demands similar to Kent's, with all the cost, delay and risk to long-serving staff that involves.

What this means in practice for councils and their teams

Even at the level named in Framework Service Level Agreement, Section 4, a change in vetting status is not just paperwork. NPPV Level 2 (Abbreviated) already reaches into an operator's private life: checks on a partner, on anyone they live with and on notifiable associations, alongside the standard police record and intelligence checks. Councils pay the police force's fee for every application and renewal, a cost that rises with the number of staff who need vetting or re-vetting.

The risk goes further where forces escalate beyond the level in Section 4, as Kent Police has already done. NPPV Level 2 Full adds a credit reference check and extends the household checks to former partners and wider family. For a long-serving operator, failing checks of that depth could mean losing a role they have done well for years, with councils left to manage the loss of experienced staff and the cost of recruiting and re-vetting a replacement.

A change on this scale is not only a vetting unit's problem. Where an existing operator's role could be affected, councils carry their own obligations to consult trade unions and staff before acting, and to consider the equality and data protection implications of any change. None of that falls to the police force; it falls entirely on the council. If this becomes a pattern followed by more forces rather than one force's decision, as the Kent example and HM Inspectorate's own findings suggest it could, the scale of consultation and HR work needed across many councils at once is unlikely to match the resource most control room teams currently have for it.

We have asked the Commissioner's office to identify the agreement behind the sentence, or to amend Section 4 so that it correctly reflects the case-by-case assessment the national guidance requires. We have suggested replacement wording, and offered to agree joint wording with the Public CCTV Managers Association and the National Police Chiefs' Council.

Read our full position, with the national sources: https://vetting.cctvusergroup.com/vetting/vetting-levels

We will update members once we have a response.