10th July 2024

Seeing the big picture

The gathering, recording, sharing and analysis of data can be a thorny issue for Trading Standards — but it is vital to addressing some of the problems the profession faces


By Richard Young
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We’ll continue to push an intelligence-led approach and assist Trading Standards in developing a fuller intelligence picture

The complexity of Trading Standards work, combined with pressures on overstretched local authorities and other public services, can mean that the details of consumer protection incidents often go unrecorded, or are not recorded properly. And for a variety of reasons — including changing consumer habits, a lack of awareness of where to report problems, and the shame that can sometimes accompany being a victim of crime — many incidents go unreported by the public.

So how can Trading Standards teams improve the ways in which intelligence is gathered and acted upon?

Since it was set up in 2012, National Trading Standards (NTS) has promoted the Intelligence Operating Model (IOM), which provides a national intelligence framework to support the day-to-day work of Trading Standards teams locally, regionally and nationally.

NTS Programme Manager, Donna Sidwell, explains: “NTS has provided funding for the NTS Intelligence Team, Regional Intelligence Teams, and encourages local authorities to have a local intelligence liaison officer. NTS pays for a number of databases and information sources. It gives funding to help Trading Standards (in England and Wales) pay for their access to IDB, the national intelligence database.”

NTS also pays for access to the Police National Computer (PNC) and, where appropriate, can help users access the Police National Database (PND) — although only when certain criteria are met, in compliance with data protection rules. Specially trained financial analysts on the NTS Intel Team also have access to banks’ Suspicious Activity Reports (SARs), which contain data on financial fraud.

“From an NTS perspective, we very much believe in the use of intel, but it’s down to encouraging local authority Trading Standards Officers to record intelligence,” Sidwell adds. “It needs to be a standard process — to analyse and share data you need to have it in the first place.”

Head of the NTS Intelligence Team, Aaron Hesketh, believes good record keeping is vitally important. “In an ideal world, there would be more resource available to help Trading Standards services record more intelligence. Because resources are stretched, we often hear that Trading Standards services can’t always record as much intelligence as they would like. Instead, some record what they feel is absolutely necessary, as they don’t always have the time to record all of the intelligence they gather.

“It’s always going to come back to resourcing — local authorities are struggling and Trading Standards services are getting smaller across the country,” Hesketh adds. “But in any case, we’ll continue to push an intelligence-led approach and assist Trading Standards in developing a fuller intelligence picture.”

Real-world problems
As well as being CTSI Lead Officer for Energy and Net Zero, Steve Playle is Trading Standards Manager at the City of London, where he and his team tackle financial fraud through Operation Broadway. He has his own set of frustrations when it comes to the gathering and implementation of intelligence.

“I think it’s fair to say that, because Trading Standards Officers are so busy, not everything gets caught on the IDB,” he says. “I’m not saying I can defend that — because you should do it. But when you’ve got another 15 jobs piled up, what do you do? It’s all about that resource issue.”

Playle believes another key problem is a lack of clarity for consumers as to where they can go with complaints and concerns. “I’ve just done the the annual satisfaction survey for Citizens Advice, and I say the same thing every year: that Citizens Advice don’t advertise their service. So there’s a lack of reporting, and people don’t know where to report incidents to,” he says.

Playle believes that Trading Standards teams can benefit from data sources outside the official channels. “As well as things like IDB, Citizens Advice and Action Fraud, some of the open source review sites have lots of really good data. Of course, there are fake reviews on there — but I’ve been working very closely with Trustpilot over the last 12 months or so for Operation Broadway, and it seems to me that they’ve got a pretty robust system.

“Whenever I get a complaint now, I always go on to Trustpilot; it gives a good indication of whether the complaint might just be a one-off or whether there’s more to it. So I think that needs to be brought into the mix. And with green heating businesses, there are so many different trader approval schemes and trade associations out there, and they have data on complaints. That information isn’t in the public domain and isn’t available to Trading Standards, but perhaps it should be.”

Playle echoes Sidwell and Hesketh in their pleas for better intelligence recording — but he has concerns over what comes next. And again, it comes back to resources: “With Net Zero, intel-gathering and analysis is a big issue. At the end of the day though, even if we had all the intel and we knew who all these bad traders were, what are we going to
do about it?

“But it’s better to know who the bad players are, and then we can start thinking about ways of disrupting them. It’s important to get that intel in place in the first place, and then decide how to use it.”

Social media could provide a wealth of data about recurring consumer problems, as people go online to vent their frustrations rather than using traditional avenues of complaint. “It is something that we do monitor, because we are finding a lot of people are not reporting issues to Citizens Advice,” says Hesketh. However, he points out, “It’s very hard to monitor something that big; we’re a very small team and we don’t have the resources to monitor social media on a constant basis. There are tools out there that can scrape social media and come back with anything that may be relevant, but they’re very, very expensive.

“There are always new ways of complaining, and the consumer landscape changes all the time. But we try and keep up with it,” he adds.

Missing pieces
Someone else who appreciates the value of accurate, reliable intel is Dr Tim Day, CTSI Lead Officer for Doorstep Crime. In the course of his work, he has examined the dangers of letting intelligence go unreported and unrecorded, and he believes that incomplete or inaccurate recording can distort Trading Standards’ approach to certain issues.

“With a lot of doorstep crime, police control rooms aren’t identifying fraud sufficiently,” he believes. “What we have is a situation where we’re almost by default decriminalising a lot of rogue trading, which is not being picked up or identified as a crime, when it really is.” (Day recently published a paper on the police response to doorstep crime and rogue trading.)

Playle shares those concerns: “When I have worked on doorstep crime cases in the past, some police officers thought it was OK that someone had paid £3,000 for a single roof tile. That’s not OK. That victim was pressured, coerced and manipulated. And that isn’t a civil dispute — that’s a crime, it’s fraud.

“I think the police have come a long way since then,” he adds. “Some are really, really good. But sometimes they’re under pressure themselves, they’re under financial constraints in the same way as Trading Standards. And they just need to park reports that come in and ‘No Further Action’ (NFA) them, because they haven’t got the resources.”

According to Day, “In academic terms, there’s the ‘dark figure of unrecorded crime’. I’m all for evidence-based enforcement and an intelligence-led approach, but we have to recognise that, with current levels of under-reporting and under-recording, the picture that we’re basing our decisions on now is probably less than 5% of incidents.”

Part of the solution to that, he believes, lies in changing the tone of the conversation around scams — and he highlights NTS’s ‘No Blame No Shame’ campaign as vitally important in bringing about that change. “I think the societal response to scams needs to improve. We often hear that the response from victims’ families is ‘I can’t believe they’ve done this, how could they be so stupid?’ It’s an emotional response, but it’s incredibly unhelpful. People are far more likely to internalise their experience and not report when that is the backdrop.”

Sidwell says that, when it comes to the recording of doorstep crime incidents at least, things are improving. “We’re in the process of producing the NTS strategic assessment, and the figures on the intel being recorded have gone up this year. And doorstep crime is a key priority area.

“Not everything will be recorded, I appreciate that. But actually, I would say Trading Standards are doing a really good job at recording intel. And once we’re able to analyse the data, it helps inform the work to be done, and sharing intel with the police and other agencies is the positive way forward.”

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