Fraud Investigation Policy

3.1 Inclusions

This policy and associated procedure applies to police officers and police staff across Cambridgeshire, in particular

• Demand Hub operators
• Front office enquiry staff
• Front line response officers
• Investigations Management Unit (IMU)
• Supervisors
• Intelligence and Specialist Crime Department.

3.2 Exclusions

There are no exclusions.

Responsibilities

4.1 Initial Responder

4.1.1 In line with national Action Fraud guidance, the victim should be directed to contact Action Fraud (AF) via the website www.actionfraud.police.uk3 or by telephoning 0300 123 2040. Victims can report online 24/7 and specialist advisors are available on web chat and by phone Monday – Friday 9am to 6pm.

4.1.2 There are, however, some exceptions;

4.1.3 If they are a business, charity or other organisation which is currently suffering a live cyber-attack (in progress), recommend that they call 0300 123 2040 immediately. This service is available 24 hours a day, 7 days a week. Advisors are also available 24/7 on a web chat.

4.1.4 If the fraud amounts to one of the following then the Force must record the crime on their own crime recording systems and investigate it as per local investigation policies;

• Making or supplying articles for use in fraud
• Possess/control article(s) for use in fraud
• Possession of false documents
• Making off without payment (including all forms of bilking)
• Theft of fuel
• Forgery or use of drug prescription
• Forgery etc, associated with vehicle or driver records
• Other forgery
• All POCA crimes
• Cash seizures/confiscations

4.1.5 The person reporting the fraud requires a ‘call for service’. This ‘call for service’ would be required in the following circumstances;

• an offender has been arrested for a fraud offence, or
• the offender is committing, or has recently committed, a fraud offence, at the time of the ‘call to service’ to police
• the suspect is known and police can/could locate the suspect with the details provided, or, have sufficient details to apprehend an offender
• there is likely to be a loss of evidence
• the victim is ‘vulnerable’

It is likely that Police will receive reports relating to a variety of fraud related subjects and the following guidance should be applied in those circumstances;

4.2 Action Fraud

4.2.1 For those reports suitable for reference to Action Fraud, once assessed by them, they will disseminate to National Fraud Intelligence Bureau (NFIB) who will assess them for investigative opportunities. They will then either send them to a specific force for immediate investigation or add the victim and crime details to a spreadsheet which is sent to individual forces on a monthly basis.

4.3 National Fraud Intelligence Bureau (NFIB)

4.3.1 For those reports disseminated by the NFIB for immediate investigation; the Investigations Management Unit will triage the report and allocate to the appropriate investigation team, as per the attached flowchart4 . (appendix E)

4.3.2 For those reports disseminated by the NFIB on a monthly basis, the Intelligence and Specialist Crime Team Detective Sergeant will triage the report and allocate to the appropriate investigation team.

4.4 Fraud Escalation Process

4.4.1 New processes have been implemented to enable an escalation of serious and complex fraud investigations between local, regional and national capabilities (appendix d) Through its new intelligence capabilities, the National Fraud Intelligence Bureau will provide improved support to forces to link crime series and information post dissemination (appendix G).

4.4.2 The National Fraud Intelligence Bureau will monitor the take up of serious and complex crime dissemination by forces. The high priority grid developed by the National Economic Crime Centre will be rolled out to wider policing to track high priority fraud investigations. Regional fraud development officers will play a key role in this process.

4.5 Force Specialist Crime Team (SCT)

4.5.1 SCT consist of designated fraud and cyber staff with responsibility for managing serious and complex fraud investigations. Due to the complex nature of these investigations, the Fraud Investigations Model (FIM) (appendix F)  is utilised as opposed to a standard Investigation Action Plan (IAP). The FIM focuses on early disruption and involvement of partner, preventing exploitation of further victims and reducing financial loss.

5.1 Strategy/ Plan

• National Fraud Policing Strategy 2019 – 2022 (Draft) – Appendix A

Latest Draft available from City of London Police

5.2 Policies

• none

5.3 Procedures (Various appendices apply)

• NPCC Fraud Operating Model – Appendix B
• Action Fraud Guide for Control Rooms – Appendix C
• Fraud Escalation Process – Appendix D
• Flow Chart for Investigation Management – Appendix E
• Fraud Investigation Model – Appendix F

5.4 Forms (National/ Local)

• Referral Form Fraud Escalation (ROCTA) – Appendix G

6.1 Director of Intelligence, Intelligence and Specialist Crime Department

6.1.1 Detective Chief Inspector / Detective Inspector /Detective Sergeant, Specialist Crime Team

 

7.Equality Impact Assessment

• Name of Sponsor - Director of Intelligence, Intelligence and Specialist Crime Department
• Name of Author - Director Superintendent Becky Tipping
• Description of proposal being analysed - Fraud Investigation Policy
• Date EIA started - 06/08/2019
• Date EIA finished - 06/08/2019

The Equality Impact Assessment is being undertaken as a result of:

Delete as appropriate

• A new or updated policy or procedure

 

STEP 1 – Relevance

The general duty is set out in section 149 of the Equality Act 2010. In summary, those subject to the Equality Duty must have DUE REGARD to the need to:

• eliminate unlawful discrimination, harassment and victimisation;
• advance equality of opportunity between different groups; and
• foster good relations between different groups.

 

Authors have a statutory requirement to have DUE REGARD to the relevant protected characteristics shown below, whilst taking a common sense approach.

• age
• disability
• gender reassignment
• marriage & civil partnership* 
• pregnancy and maternity
• race
• religion or belief
• sex
• sexual orientation

*marriage and civil partnership – the analysis applies only to the elimination of unlawful discrimination, harassment and victimisation.

Section 23 of the Equality Act 2006 allows the Equality and Human Rights Commission (EHRC) to enter into a formal agreement with an organisation if it believes the organisation has committed an unlawful act.

Under section 31 of the Equality Act 2006, the EHRC can carry out a formal assessment to establish to what extent, or the manner, in which a public authority has compiled with the duty.

Additional guidance can be found by accessing the EHRC website

Step 1 Questions

Question	Answer options	Answer
Does this proposal have a direct impact on people who	a) are any part of the Police workforce (including volunteers?)	Yes
Does this proposal have a direct impact on people who	b) reside in any part of England and Wales	Yes

If No, to both questions explain why and give rationale:

• No further action and return to sponsor for authorisation

If Yes to either question continue through to Step 2.

STEP 2 – Consultation / Engagement

You should engage with those people who have an interest in how you carry out your work generally, or in a particular proposal. This may include former, current and potential service users, staff, staff equality groups, trade unions, equality organisations and the wider community. In deciding who to engage, you should consider the nature of the proposal and the groups who are most likely to be affected by it.

The proposal owner (Sponsor/Author) must be satisfied that consultation / engagement will take place with the relevant business lead and stakeholders.

This MUST include engagement with the following relevant groups:

• Equality and Diversity Specialist
• Staff Associations
• Staff Support Groups
• Relevant community groups and members of the public

In addition, consider who else should you consult with internally and externally?

Who might be affected?

Does what you are considering further the aims of the general duty, to

• eliminate unlawful discrimination, harassment and victimisation;
• advance equality of opportunity between different groups; and
• foster good relations between different groups.

Identify the risks and benefits where applicable, according to the different characteristics.

Characteristic	Positive Impact or Benefits	Negative Impact or Risks
Age (Consider elderly or young people)	There are no obvious considerations	There are no obvious considerations
Disability Groups (Consider physical, sensory, cognitive, mental health issues or learning difficulties)	There are no obvious considerations	There are no obvious considerations
Gender Reassignment (Consider transgender, Transsexual, Intersex)	There are no obvious considerations	There are no obvious considerations
Marriage & Civil Partnership	There are no obvious considerations	There are no obvious considerations
Pregnancy and Maternity	There are no obvious considerations	There are no obvious considerations
Race and Ethnic origin – includes gypsies and travellers.(Consider language and cultural factors)	There are no obvious considerations	There are no obvious considerations
Religious / Faith groups or Philosophical belief (Consider practices of worship, religious or cultural observance including non belief)	There are no obvious considerations	There are no obvious considerations
Sex (Male, Female)	There are no obvious considerations	There are no obvious considerations
Sexual orientation (Consider known or perceived orientation, lesbian, gay or bisexual)	There are no obvious considerations	There are no obvious considerations

 

Question	Positive Impact or Benefits	Negative Impact or Risks
Have you considered how this decision might affect work life balance? (Consider caring issues re: childcare & disability, safeguarding issues, environmental issues, socio economic disadvantage, and low income families)	Yes and there are no obvious considerations	Yes and there are no obvious considerations

 

 

 

STEP 3 – Assessment

Complete the EIA by analysing the effect of your proposal and detail the outcomes.

What were the main findings from any consultation carried out?

What feedback has been received?

Using the information you have gathered and consultation that you have undertaken answer the following questions. This will help you to understand the effect on equality your proposal might have.

Question	Answer
Has the feedback indicated any problems that need to be addressed?	No
Describe and evidence any part of the proposal which could discriminate	N/A
Can the adverse impact identified be justified as being appropriate and necessary? If so, state what the business case is:	N/A
Where impact and feedback identified, what, if anything can be done?	N/A
What outcome will be achieved that demonstrates a positive impact on people?	The aim of this policy is to provide clear guidance to staff when responding to and investigating allegations of fraud in relation to both calls for service and National Fraud Intelligence Bureau disseminations for enforment to avoid ambiguity.

 

 

STEP 4 - Monitoring and Review

Equality analysis is an ongoing process that does not end once a document has been produced.

What monitoring mechanisms do you have in place to assess the actual impact of your proposal?

• This policy and procedure will be monitored for compliance when the first review takes place, or if national draft guidance changes.

First review must be no later than one year. Review Date:

This will be reviewed and updated by Director of Intelligence no later than 06/08/2020.

 

 

STEP 5 - Sign Off

Once the Equality Impact Assessment is complete it should be signed off by the Proposal Sponsor.

This sign off is confirmation that the analysis is accurate, proportionate and relevant and actions will be delivered as required.

Approved by Senior Officer / Proposal lead: Consultation with local and regional leads has been completed, including the ERSOU regional fraud co-ordinator. Date: 06 August 2019 Name: Detective Superintendent Becky Tipping.