Ms E Shanklin v The Chief Constable of North Wales Police — 2026

Ms E Shanklin sought to bring a claim of direct philosophical belief discrimination over the decision to reject her application to become a Role Play Actor with North Wales Police at the vetting stage. The preliminary issue was whether the position amounted to employment under a contract personally to do work within section 83 of the Equality Act 2010. The Tribunal corrected the Respondent's identity to the Chief Constable of North Wales Police, found that Ms Shanklin was not an applicant for employment within section 83, and dismissed the claim for lack of jurisdiction without deciding its merits.

Role Play Actors underwent an application process that included references, medical assessment, Welsh language assessment and vetting. Once appointed, they could accept or decline duties offered on an ad hoc basis. There was no obligation to accept any duty or complete a minimum number of hours, no sanction for declining work, and no obligation on the Respondent to offer work. The Tribunal also found that an actor could leave after starting a duty without giving rise to a contractual remedy for the Respondent.

An actor who attended a duty was expected to perform the assigned scenario, follow directions and record the duty through the Dutysheet system. The Tribunal considered the vetting rules, conduct standards, training, social media expectations and other requirements arising from the police setting. It accepted that some expectations applied, but found that optional welfare screening and training did not create enforceable work obligations. The application documents and their occasional employment-related wording did not establish a contract personally to perform work.

Role Play Actors received no wage or retainer. Mileage and receipted subsistence payments were reimbursement of out-of-pocket costs, not remuneration. The subsistence caps of £7.23, £14.66 and £24.15, and the £175 value attributed by the Claimant to an optional mindfulness course, were evidence considered in the worker-status dispute rather than awards. Clothing provided when needed, access to a third-party Blue Light Card and optional courses were not valuable consideration forming part of a wage-work bargain.

The Tribunal found that personal performance and direction were present when an actor carried out a duty, but the required wage-work bargain was absent. Viewed objectively, the parties did not intend to create an employment relationship under which work was performed in return for remuneration. Any enforceable contract was limited to repayment of properly incurred expenses and did not fall within the employment field. The discrimination claim was therefore dismissed for lack of jurisdiction, and no remedy was awarded.