The short answer: what you actually have to declare
In shortThere is no list of declarable names, groups or relationship thresholds; the published position is a set of principles, so the test is whether it could affect, or be seen to affect, your job or security.
The honest published answer is: there is no list of names, no list of banned memberships and no threshold such as 'second cousin or closer'.
What exists is a set of principles. HMPPS staff must declare private interests that interfere, or could interfere, with the performance of their duties. Staff must report changes in their personal circumstances during vetting aftercare.
And the Civil Service rules say that where a conflict of interest arises you declare it so that management can decide how to proceed.
That shifts the question from 'is this on the list?' to 'could this affect, or be seen to affect, how I do my job or my security?'. If the answer might be yes, declare. The cost of declaring a relationship that does not matter is a short conversation.
| Route | Source | What it covers | Who you tell |
|---|---|---|---|
| Conflict of interest declaration | Counter Corruption and Reporting Wrongdoing framework, paras 4.26 to 4.31 | Business interests including secondary employment; serious financial difficulty; criminal convictions, cautions and investigations; relationships or associations with offenders; other domestic or personal circumstances | Line manager and Local Counter Corruption Manager (LCCM), on the standard form |
| Vetting aftercare | Security Vetting PSI 07/2014 para 9.1 and Annex F (revised 20 February 2025) | Address, marriage, civil partnership or co-habiting, new housemates, relationships or relatives abroad, finances, criminal activity, charges and convictions, involvement with groups of security concern, disciplinary procedures | Line manager and the vetting team |
| Civil Service conflict of interest principle | Civil Service Management Code (2016) ch. 4 principles | Interests that could be furthered by your position, including dealings with individuals who share your private interests, such as freemasonry, societies, clubs, organisations and family | Senior management |
The HMPPS conflict of interest declaration in detail
In shortThe framework wants pre-existing offender relationships declared so they can be managed rather than discovered, and the form is not an admission of corruption.
The Counter Corruption framework says staff must declare private interests that interfere or could interfere with the performance of their duties, and that line managers and LCCMs keep a register. LCCMs are Deputy Governor grade in most establishments and are security-cleared to SC level.
- Business interests (including secondary employment).
- Serious financial difficulty.
- Criminal convictions, cautions or investigations.
- Relationships or associations with offenders.
- Other domestic or personal circumstances.
Relationships with offenders
This causes most uncertainty. The framework says pre-existing relationships with offenders, known through friends, family or previous employment, are a conflict of interest to declare on the standard form.
This is deliberate: HMPPS wants staff to declare a former classmate on the wing, a neighbour's son who has been remanded or a cousin's friend who is now serving a sentence, precisely so that it can be managed rather than discovered.
Early disclosure
The framework encourages early disclosure by staff who have fallen short and says they will be treated sensitively and fairly, with support that can include moving the prisoner, changing duties or a public interest transfer. We do not promise that outcome in any individual case.
We do say the published policy treats voluntary early disclosure as the preferred route.
Vetting aftercare and Annex F: the 'change of circumstances' list
In shortVetting does not end when you are cleared: you report change events as they happen, and no threshold is published for 'criminal associates'.
The Security Vetting policy (PSI 07/2014, AI 05/2014, PI 03/2014, revised 20 February 2025) says individuals must report changes in personal circumstances, 'including partners and criminal associates', and that line managers should watch for changes in behaviour. Holders of Security Check and Developed Vetting complete an annual security review form.
If you are an applicant rather than a serving officer, our guides to vetting, vetting and family in prison and the free vetting checker cover what is asked before you start.
- Address.
- Marriage, civil partnership or co-habiting.
- New housemates or relatives sharing the home.
- Relationships or relatives abroad.
- Finances (large receipts or hardship).
- Involvement in criminal activity.
- Criminal charges, warnings and convictions.
- Involvement with any individual, group, society or organisation that may be of security concern.
- Disciplinary procedures.
- Security incidents, including employer sanctions for code of conduct misconduct.
Friends, family and partners with a criminal record or a prison link
In shortNo published rule bars you from the job because a relative or partner has a record, but a change should be reported rather than left to be discovered.
No published rule says that having a relative or partner with a criminal record bars you from being a prison officer or requires you to resign. The published vetting framework asks about criminal associates and relationship changes after appointment, and the unpublished HMPPS Vetting Action Team deals with individual cases.
In the Counter Corruption framework, the concern is the risk of abuse of position, influence or pressure, not the label.
If a partner, parent, sibling or close friend is arrested, charged or imprisoned, or a new partner has a record
- Treat it as a reportable change of circumstances and a possible conflict of interest.
- Speak to your line manager or LCCM.
- For a relative in the establishment where you work, expect a conversation about duties and perhaps a move.
- The risk is greater if you stay silent and a colleague, the police or an intelligence report brings it to light.
If someone close to you asks for something
If someone you are close to asks you for anything related to your work, such as information about a prisoner, a favour or a message, say no and report the approach. HMPPS describes 'corruptor' alerts on prisoner records and encourages staff to disclose pressure early.
Do not discuss your suspicions with others beyond the people handling the report, because the framework says that can itself be treated as bullying and harassment.
Groups, societies and organisations of concern
In shortThe published texts do not name the organisations of concern, so three practical questions decide whether to ask.
At recruitment, Enhanced Check Level 2 includes a signed declaration of not belonging to racist groups, and Annex F asks staff to report involvement with any individual, group, society or organisation that may be of security concern. The published texts do not name the organisations.
The Civil Service Management Code lists freemasonry, membership of societies, clubs and other organisations and family as examples of private interests which can give rise to conflicts where they share an interest with someone the civil servant deals with officially.
If the answer to any is yes or maybe, ask your line manager or the vetting team
- Could membership put you in a position of loyalty or obligation to someone you supervise or deal with officially?
- Could it be seen as incompatible with the impartiality the Civil Service Code requires?
- Is it an organisation that could be associated with extremist, criminal or hostile interests?
What happens after you declare
In shortThe published aim is to remove the risk rather than punish the disclosure, but declaring is not risk-free and HMPPS-specific guidance is not public.
The published Counter Corruption framework describes a sensible sequence: your declaration is recorded on a register held by your line manager and LCCM; the LCCM considers whether the interest can be managed. Management options include moving duties, changing who supervises you, restricting access to certain prisoners or information, and in some cases a transfer.
You may be asked for further information, reminded of your obligations, or asked to keep the LCCM updated. If asked to sign anything, you can take a copy and ask your POA rep to read it.
If a declaration leads to an investigation, you have the same rights as in any investigation, including to be accompanied. Our guides to investigations and relationships with prisoners explain those stages.
Declaring is not risk-free, and anyone who says otherwise is overselling. But the published policy tilts clearly towards early disclosure. A conflict that is discovered rather than declared can be treated as concealment, and in a corruption context the risk of dismissal and criminal investigation is the highest in the system.
- Write down the facts: who, how you know them, when it started, any contact since you joined, and anything you have been asked to do.
- Do not contact the person to 'sort it out' or to ask them to stop; if there has been pressure, keep messages and tell your LCCM.
- Ask your line manager or LCCM for the current conflict of interest form, or use the one on your intranet, and complete it factually.
- Take a copy of what you submit with the date, and note who you gave it to.
- If you are worried about the consequences, speak to your POA rep first, but do not let that delay a report where there is any pressure on you.
- Update the declaration if circumstances change, and report vetting changes through the vetting route as well.
Lived experience, past records and risk management plans
In shortIf you work under a risk management plan, the plan itself can include contact and association requirements, and breaching it would be a conduct matter.
Since 1 April 2026 the HMPPS policy framework on risk assessed access for personnel with lived experience of the criminal justice system (issued 5 March 2026) governs people who cannot obtain standard clearance because of their own criminal history.
It offers role-specific risk management plans through Going Forward into Employment for directly employed posts and LEAP for non-directly employed posts.
We have summarised it because declaration and risk management overlap.
If you are working under a plan
- Read the plan and keep a copy.
- Ask your line manager what counts as a reportable change.
- If you have not been given a plan in writing, ask for it.
- If unsure whether a new association is covered, tell your contact in the vetting team before it develops rather than afterwards.
Common mistakes and a decision checklist
In shortIf any answer to the decision checklist is yes, declare.
The framework's example of relationships known 'through friends, family or previous employment' covers distant, informal and pre-joining relationships, which is exactly where people go wrong.
The common mistakes
- Assuming a thing does not count because it is distant, informal or from before you joined.
- Assuming that because nobody has asked, nobody minds.
- Discussing the problem with colleagues in the hope of reassurance, which can spread the issue without protecting you.
- Treating a report as a confession, which the published wording explicitly rejects for the conflict of interest form.
Decision checklist
If yes to any of these, declare.
- Is the person a prisoner, ex-prisoner, supervised individual or associated with one?
- Do you have regular contact?
- Has anything been offered, requested or implied?
- Could the relationship be seen as a conflict by someone who did not know you?
- Does it involve a group or organisation of security concern?
Frequently asked questions
Do I have to declare a friend who has been convicted?
If the friend is an offender, the Counter Corruption framework says pre-existing relationships with offenders, known through friends, family or previous employment, are a conflict of interest to declare on the standard form. Declaring is not an admission of corruption.
If the friend is simply convicted but not in prison, vetting aftercare may still apply as a change in circumstances.
Does my partner's criminal record have to be declared?
Vetting aftercare says to report changes in circumstances including partners and criminal associates. No threshold is published, so tell your line manager or the vetting team about a new partner with a record and ask how it applies. Do not wait to be asked.
Can I be a prison officer if a family member is in prison?
No published rule bars it. The published vetting policy asks about criminal associates and relationship changes, and the unpublished decision is made case by case. Declare it early and ask the vetting team. Our guide on vetting and family in prison covers this for applicants.
Is freemasonry declarable?
The Civil Service Management Code names freemasonry among examples of private interests that can give rise to conflicts of interest where they share an interest with those a civil servant deals with officially.
Whether HMPPS requires a declaration for membership itself is not published for England and Wales, so ask your LCCM. If you are asked, answer truthfully.
What if I declare something and it is not needed?
Nothing in the published framework penalises an unnecessary declaration. It says completing the form is not an admission of corruption. The risk lies in failing to declare something that mattered. If you are unsure, declare and ask.
How long do I have to report a change of circumstances?
There is no published England and Wales time limit in the sources we could open. Scottish Prison Service policy normally says within 72 hours, but that is a different employer. Report as soon as practicable and, if unsure, ask the vetting team what they expect.
Who sees my declaration?
The Counter Corruption framework says line managers and LCCMs keep a register of declared interests. For reports about wrongdoing, a reporter's identity is restricted to counter corruption staff unless needed for proceedings. The retention rules and wider access to a conflict of interest form are not published, so ask when you submit it.
Sources
- assets.publishing.service.gov.ukHMPPS Counter Corruption and Reporting Wrongdoing Policy Framework (re-issued 10 May 2022; PDF)
- gov.ukGOV.UK: Counter corruption and reporting wrongdoing (publication page)
- assets.publishing.service.gov.ukHMPPS Security Vetting Policy Framework (PSI 07/2014, revised 20 February 2025; PDF, incl. Annex F change of circumstances)
- gov.ukGOV.UK: The Civil Service Code (updated 16 March 2015)
- gov.ukGOV.UK: Civil Service Management Code (document read: November 2016 version, chapter 4 on conduct)
- assets.publishing.service.gov.ukExclusion from Working for HMPPS Policy Framework (issued 14 October 2024, in force 1 January 2025; PDF)
- assets.publishing.service.gov.ukHMPPS risk assessed access for personnel with lived experience of the criminal justice system policy framework (issued 5 March 2026, effective 1 April 2026)
- assets.publishing.service.gov.ukGOV.UK: Prison Service Instructions index (PDF generated 10 July 2026; PSI 06/2010 listed as extant but not published)
- crimeandjustice.org.ukPrison Service Journal 283: Prison staff wrongdoing, a synthesis of the literature (2026)
- sps.gov.ukScottish Prison Service: Code of Conduct, HR010/001 (published 23 February 2018)
- questions-statements.parliament.ukUK Parliament: written question 16009, answered 9 July 2026 (HMPPS conduct and grievance policies)