This page is from APP, the official source of professional practice for policing.
The resourcing of firearms licensing activity must meet both:
- the underpinning aims and objectives
- legislative requirements, including the statutory guidance
The strategic demand assessment also influences resourcing. This assessment highlights local factors and considerations.
It is important to configure resources against the responsibilities outlined in this section. This configuration can include police officers and/or police staff (this could include volunteers) and will also need to consider delegated authority.
The key factors are that:
- staff are confident and competent to assess suitability and make decisions aligned with the legislation, this guidance and the Home Office statutory guidance
- there is sufficient capacity to respond to demand in an efficient, rigorous and proportionate way
Competence can be achieved through experience and training. (Note: national firearms licensing training is being developed by the College).
Senior management team
Accountability
The chief constable is responsible and accountable for firearms licensing in their force. They need to be satisfied that clear decision-making processes are in place.
See more information about decision making.
To fulfil this responsibility, the chief constable needs to do the following.
- Consider if and how they will delegate their authority. They need to identify staff to hold delegated authority. They need to document any associated parameters around different levels of authority. (See 3.47 of the Home Office statutory guidance for further information.)
- Appoint an individual to oversee and manage the firearms licensing department.
- Consider appointing a member of the chief officer team to act as senior responsible officer (SRO) and strategic lead in force. The strategic lead can help ensure the infrastructure is in place to support the firearms licensing department and firearms licensing processes in force.
Governance meetings
The chief constable, or appointed strategic lead, should chair regular governance meetings. These meetings should be used to discuss and assess the overall performance of their force’s licensing department. These meetings should cover the following areas.
Performance assessment, including:
- performance monitoring regarding the granting of certificates, renewals, refusals, revocations and returns
- timeliness of the department’s processes, for example in relation to applications for granting certificates and renewals
- dip sampling of all licensing-related decisions, including return of firearms and certificates.
Reviews of processes, including:
- the outcome of appeals and any relevant promising practice or learning
- finance and resourcing, especially any impacts resulting from the strategic demand assessment (SDA)
- cases of note that may need further investigation or review
- the processes used to identify and flag intelligence or criminal use of firearms
- implications of new developments, promising practice or learning associated with firearms licensing
- monitoring and management of any identified risks, for example demand exceeding capacity, workforce planning
Engagement, including:
- public engagement strategies and stakeholder meetings
- engagement with shooting clubs and organisations (note: this engagement should involve the strategic lead)
- partnership working – for example, identifying or discussing any strategic challenges or opportunities that impact the firearms licensing process, including the requirement for and development of memorandums of understanding (MoU) and/or information sharing agreements (ISAs)
- complaints, including their investigation, resolution and any learning from experience
Governance meetings should also consider the possibility of wider scrutiny of performance, processes and engagement that could involve bodies that are independent of the firearms licensing process. For example, police and crime commissioners (PCC) or independent advisory groups.
Firearms licensing manager
The firearms licensing manager oversees the running of the firearms licensing department. They have an important role in decision making.
As well as decision making, firearms licensing managers should do the following.
- Plan and develop the work of the department to ensure it can meet anticipated demand based on the SDA. This should be done in accordance with the underpinning aims and objectives.
- Monitor and manage the performance of the department. Firearms licensing-related issues should be escalated to the strategic lead and chief constable when necessary.
- Take responsibility for staff development, including recruitment, training and continuing professional development (CPD).
- Manage the welfare and wellbeing of firearms licensing staff. For example, by ensuring workloads are manageable and that staff are aware of, and can access, local or national wellbeing resources.
- Establish and oversee processes for ensuring staff integrity. For example, by ensuring that staff are vetted in line with force policy, establishing processes and safeguards that promote ethical decision making, and capturing and managing potential conflicts of interest that may impact on assessing suitability and/or decision making related to firearms licensing.
- Provide leadership and specialist or technical support. For example, in complex, sensitive or contentious cases to the department or wider force.
- Engage in problem solving and innovation to help meet the aims and objectives of firearms licensing. For example, by developing dip sampling or quality assurance (QA) mechanisms for decisions, and making the most efficient and effective use of IT systems and platforms.
- Engage with internal and external stakeholders through an engagement plan, to build and maintain effective working relationships and partnerships. This can help licensing and decision-making processes. This plan should be agreed with the strategic lead.
- Engage with national and regional forums to contribute to disseminating good practice across forces. For example, sharing experiences and outcomes of engagement planning.
Staff may need to support the firearms licensing manager with these responsibilities. For example, by providing supervision and management on different aspects of firearms licensing.
Firearms enquiry officers
Role in assessing suitability
Firearms enquiry officers (FEOs) have a critical role in ensuring, as far as is possible, that people who may pose a risk of harm through access to firearms are prevented from so doing.
To be effective in this role, FEOs – while not necessarily recognised as formal investigators – need to use investigative skills, such as curiosity. This allows them to look beyond the obvious communication to elicit as much information as possible and identify clues that might point towards lines of enquiry.
After an application has been received and initial checks and enquiries undertaken, the FEOs will conduct further investigative activity to develop recommendations on whether an individual is suitable to acquire, possess and lawfully use firearms. To achieve this, the FEO should:
- visit the applicant or licence holder when establishing suitability (in line with statutory guidance on when to conduct visits)
- discuss with the applicant or licence holder any aspects of their physical and mental health and prior experience of vulnerability that may impact their suitability
- interview other individuals who may help inform the suitability assessment – for example, partners, family members, referees and if necessary, former partners
- generate recommendations about suitability and identified risk
- prepare reports and manage case files to ensure an audit trail of fair and transparent decisions
- ensure that all obtained information is processed in accordance with the provisions of data protection legislation and the Freedom of Information Act 2000
They should also:
- develop and maintain specialist knowledge on firearms licensing – including legal requirements, security standards and safe shooting
- share their knowledge with colleagues in policing and the public – for example, engaging with local policing teams on firearms licensing issues (such as short notice voluntary surrender or seizure of firearms), and sharing process and practice with licence holders, shooting organisations and clubs
- assist in the seizing, surrendering or recovery of guns when required – ensuring safe handling and accurate record keeping
Other responsibilities
FEOs are also involved in other licensing-related activity. This includes but is not limited to:
- engagement with stakeholders, such as clubs, clay pigeon shoots and rough shoots
- engagement with registered firearms dealers – for example, carrying out stock checks or audits
- providing specialist knowledge and advice on firearms licensing matters – for example, land surveys and antiques
- the licensing of explosives – some FEOs may also be explosive licensing officers (ELOs). This is a specialist area that is governed by the Explosives Regulations 2014. It requires appropriate training from other agencies (including the Health and Safety Executive)
Firearms licensing administration and casework
Staff involved in firearms licensing administration and casework, and their supervisors, have an important role in firearms licensing. For example, they are often the first point of contact for enquiries and applications. They can also contribute to investigative activity that can help the assessment process.
Although titles and responsibilities may vary across forces, staff involved in firearms licensing administration and casework should:
- recognise and raise any risk issues that arise when logging and managing enquiries, applications and renewals
- collate information and intelligence around an application – for example, taking general practitioners’ (GPs) proformas, contacting applicants’ GPs for clarifications, checking whether referees are of good character, and interrogating systems. (For example, checking for convictions and information or intelligence relating to the applicant through force intelligence systems and open-source checks)
- make decisions at the level that is authorised by their force
Partnership working
Firearms licensing staff should access and assess information from other parts of the force, other forces and external partners to help inform assessments and decisions on suitability of applicants and certificate holders.
In some circumstances, the information will come directly to staff. For example, medical information from a GP or other medical professional registered with the General Medical Council (GMC) is an important component of the application form. (Note: an application cannot be considered without this information.)
In other circumstances, firearms licensing staff may need to be proactive. They may need to clarify or pursue information or a line of enquiry with an internal or external partner. For example, following up on vulnerability concerns with a safeguarding team.
Professional judgement helps to identify relevant partners and guide any interaction with them. This includes clues, curiosity and communication.
Firearms licensing staff should develop and maintain good working relationships with internal and external stakeholders. This can maximise the benefits of partnership working. Good working relationships can be achieved by, for example:
- being open about the role and remit of firearms licensing
- providing a rationale for any requests for information
There may be occasions when internal or external partners provide information to the firearms licensing department. If regular interaction with a partner is expected, it may be appropriate to develop an MOU.
An information sharing agreement (ISA) with relevant partners can be useful and allows both the police and partner organisation(s) to communicate issues and concerns relating to suitability and public safety. Information sharing must comply with GDPR, the Data Protection Act (2018) and Human Rights Act (1998).
Information management APP provides further advice and information on developing MOUs and ISAs, the policing purposes that underpin information sharing, and training for staff on data protection.
Ongoing effective partnership working can help:
- gain a broader perspective on assessing suitability and subsequent decision making
- encourage external partners to make proactive contact when they have information that could affect the suitability of a current certificate holder or applicant (this could form part of an MOU)
Firearms licensing staff should also liaise and meet with relevant stakeholders. For example, through an engagement plan that includes gun clubs and shooting organisations. This helps build good relationships and promote the underpinning aims and objectives around police involvement in firearms licensing activity.
Assessing suitability and applying professional judgement
All staff involved in firearms licensing contribute to the assessment and decision-making processes regarding suitability and the management of risk. This can range from a case worker making an initial assessment of an application to a senior member of staff making a decision on an initial grant, refusal, revocation of a certificate, or whether to return a firearm and certificate following their seizure.
This section provides a framework to help all staff contribute to the suitability assessment process. The statutory guidance covers the key processes and criteria for assessing suitability and should be read in conjunction with this APP. The national decision model (NDM) provides a framework that can be used to examine and challenge decision making.
Staff should consider all available information to inform and contribute to the assessment. For example:
- the application form
- referees
- the applicant, via the home or premises visit and interview
- partners and family members
- intelligence systems and open-source checks
- partner agencies
- practitioners including shooting clubs and organisations – for example, through club secretaries or club liaison officers
- law and policy – for example, firearms legislation and Home Office guidance
These sources of information provide a starting point for assessing an applicant’s suitability. Professional judgement, informed by the best available information, is required to build on this initial assessment.
Evidence-based guidelines on vulnerability-related risks present three overlapping factors that inform professional judgement around risk. These are:
- communication
- curiosity
- clues
These three factors are not hierarchical, and they are potentially self-reinforcing. For example, good communication can reveal more clues, which may identify more avenues for investigation (curiosity). This can lead to more focused communication.
Potentially relevant factors from a firearms licensing perspective include but are not limited to the following.
Communication
Staff should develop and use communication skills to assess suitability. For example:
- building rapport with the applicant
- addressing and probing sensitive issues that are relevant to the application – for example, an individual’s past, health and vulnerability
- active listening during the premises visit and interview
- adopting a procedurally just approach – for example, being open, transparent and respectful
- minimising bias and preconceptions
Curiosity
Staff should exercise professional curiosity to actively identify and investigate suitability. For example:
- exploring and understanding the application and recommendations – for example, asking questions and keeping an open mind
- seeking clarifications on any ambiguities during the licensing process
- not accepting things at face value – enquiring deeply and challenging one’s own (and others’) assumptions
Clues
Staff should be alert to and understand the clues that may impact on suitability. For example:
- previous criminal or alleged criminal behaviour
- associations
- medical conditions
- clues related to drug or alcohol misuse, such as drunken or drug-related incidents
- indicators of domestic abuse
- clues that arise from open-source social media checks
- clues that arise from credit or financial checks, such as debt collection and high-risk financial activity
- signs of vulnerability and/or exploitation
- information from other agencies (for example, multi-agency safeguarding hubs, family courts)