Page 42 - Aanbevelingen om de integriteit

Pages includes some guidance in respect of handling of information as well as the use of social
media.

214. The report on “Organised Crime and the Integrity within Law Enforcement Organisations”
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(2017) by the Research and Documentation Centre (WODC) of the Ministry of Justice and Security ,
which reflects research into serious integrity violations by law enforcement services (including the
NPN and KMar), inter alia, notes that several integrity violations appear to be linked to organised
crime groups and that misuse of confidential information is by far the most common integrity
violation in the police.

215. The WODC study, public media reports and several interlocutors met by the GET on-site,
pointed to a considerable lack of control over misuse of information and confidential information
that police officers have been leaking to criminal groups, family and friends through the use of
various technical devices, including smartphones. The GET noted that the management in both
services is well aware of these problems and was informed that both the NPN and the KMar take a
number of organisational measures to better protect information, through the granting of
authorisations to access systems and information, but also through awareness raising and training.
Unfortunately, it would appear that these problems are far from being resolved.

216. The GET wishes to stress that the problems encountered in respect of third party contacts
and the handling of confidential information go hand in hand and should be considered top priority
for both NPN and KMar to resolve. Detailed rules and guidance on third party contacts are called for
and the same goes for the handling of confidential information. Existing guidance should preferably
be further developed in a future code of conduct as recommended in paragraph 154. Further
awareness raising and training in this respect are also necessary measures. Above all, comprehensive
control mechanisms need to be introduced to prevent incidents in this area in the future.
Consequently, GRECO recommends enhancing control measures in respect of access to and use of
confidential information, in order to prevent unauthorised access to law enforcement registers and
leaking of information.

Post-employment restrictions

217. There are no restrictions in respect of post-employment in the NPN and the KMar. The GET
takes the view that in a country such as the Netherlands, which has a vibrant commercial private
sector and which has a liberal policy in respect of secondary activities of police officials, the complete
lack of regulations for situations of conflicts of interests in post-employment situations appears
rather striking. Despite the fact that the GET did not come across any incidents and abuse in relation
to such situations, it is of the opinion that the current situation merits further reflection as being an
important area for preventing potential conflicts of interest and thus corruption. The problems of
“revolving doors” can be dealt with in various ways, but it is an area where transparency and
oversight are important tools. Considering the insufficient information about the needs in this area,
GRECO recommends that a study be conducted concerning risks of conflicts of interest in relation
to post-employment and other activities of police officers (including the top level), after they leave
the police service, with a view to considering appropriate regulations in this area.

Declaration of assets, income, liabilities and interests

218. All employees of the NPN must declare secondary activities, but only in case such activities
affect the interests of the NPN. They need permission to carry out such activities. The GET
understood that the declarations of ordinary officers are not made public, while the declarations of

50 Organized Crime and Integrity Violations within Law Enforcement Organizations, the Research and Documentation Centre
(WODC), Ministry of Justice and Security, 2017, see https://www.wodc.nl/onderzoeksdatabase/2748-georganiseerde-
criminaliteit-versus-integriteit-handhavers.aspx

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