- 22 Dec 2020
Attendees and apologies
- Neil Ritchie (Chair), Scottish Government (SG), Head of Consumer, Competition and Energy Company Services Unit
- Saskia Kearns, Scottish Government, Consumer Policy and Interventions
- Pauline Scott, Scottish Government, Consumer Policy and Interventions
- Tanya Friel, Scottish Government, Consumer Policy and Interventions
- Connor McKay, Scottish Government, Cyber Resilience
- Francesca Gualco, Scottish Government, Justice Analytical Services
- Pam Stewart, Advice Direct Scotland
- Ruth Mendel, Citizens Advice Scotland
- Karen Carrick, Improvement Service
- Amy Hemmings, Ofcom
- Jonathan Ruff, Ofcom
- Chris McColl, Police Scotland
- Greig McOustra, Police Scotland
- Kim Riddoch, Royal Mail
- Julie McCarron, Trading Standards Scotland/COSLA
- Katie Lips, Which?
Items and actions
Welcome and introductions
The Chair welcomed everyone to the meeting and gave a quick introduction, emphasising the need to move forward as well as the challenge of joining up all three sub working groups. The importance of updating other sub groups on progress was also mentioned.
Data working group – remit and aims
The Chair gave a quick overview of the groups’ aim and outputs which are threefold:
- establish a baseline understanding of the current scams data landscape in Scotland, including any gaps and opportunities
- agree a commonly shared set of key indicators for the measuring and monitoring of scams in Scotland across partner organisations moving forwards and
- facilitate the sharing and collation of relevant scams data (based on key indicators) across advice and enforcement bodies
The importance of ensuring the correct terminology is used by all members was highlighted. It is important to make a distinction between what can be monitored and what can be evaluated, the latter requiring research and analysis.
Current data landscape
The Chair then opened up discussion to the group around the need for a baseline for scams. Questions included: what is the purpose or intent of establishing a baseline; what difference will it make on the ground for people (what does it mean in the “real world” at an operational level); and what would it look like, for example national, official crime statistics or could it be intelligence based case studies which highlight trends? Partners’ responses below:
SG – Justice Analytical Services (JAS)
JAS agree that there is a need to establish a baseline and have a clear set of indicators to monitor success of the strategy. Although this may be difficult as correlation does not equal causation, as part of the evaluation process it is both important and likely feasible to determine a level of contribution made by key interventions introduced under the strategy to a change in the level of scams recorded. To achieve this, the right indicators are needed at the beginning.
Advice Direct Scotland (ADS)
ADS use a set of coding which is used and understood by Trading Standards across the UK. It is difficult to establish consistency in coding across a large range of different stakeholders, but using the same terminology will help at an operational level. This can be refined further by all partners working together to understand the broad picture. The coding ADS use can be amended to react to the changes in scams, which are quick to evolve.
Trading Standards Scotland (TSS)
TSS feel it would be helpful if ADS were able to categorise their data based on crime type as opposed to or in addition to categorisation by product or service. Intelligence logs are also shared between TSS and Police Scotland (PS) proactively regarding doorstep crime, but TSS would welcome access to other types of scams data in addition to this. TSS indicated the added importance of this data sharing between enforcement organisations, following the removal of Police Scotland’s participation in Action Fraud. Further to this, Consumer Scotland could play a role in establishing a baseline but it is important to make the distinction between data that solves crimes (operational), and data that has a more strategic purpose to inform policy development.
Police Scotland (PS)
Due to technical difficulties PS were unable to contribute to the discussion; however, they were content to answer any questions by email and signalled that they would be happy to have a conversation with TSS and ADS to drill down into more detail around the issues raised.
- SG to arrange a follow up meeting between PS, TSS and ADS to facilitate a more detailed operational discussion regarding reporting for enforcement action, and data sharing necessary to enable a more coordinated approach
Making distinctions in relation to data sharing is important – there is a difference in terms of operational needs and process arrangements between data for enforcement, and data for intelligence and policy purposes. There is also a need to be clear on what individuals need to know by way of education and awareness raising, informed by the data – this will be considered by Working Group (2) Accessing Support and Enabling People. It is also necessary to ensure systems put in place to coordinate data avoid the risk of double counting, particularly if the organisations involved are public facing.
Reference to Research Data Scotland was raised for partners’ awareness, as it was suggested that it may be able to play a role in supporting the coordination of data for intelligence purposes as well as ensuring robust data sharing agreements are established. Work on development of the new organisation is on-going with Scottish Government.
Ofcom referred to understanding more what the purpose would be of having an overall number or baseline of scams in Scotland. Would this show numbers of scams increasing, decreasing? The risk of duplication of reporting of scams was also highlighted. For example, if a number of organisations take reports on scams this could prove to be an obstacle in ensuring a robust number going forward.
Ofcom also publish statistics on nuisance calls and complaints data. As their remit is mainly nuisance calls, focusing on silent and abandoned calls and collecting complaints data, the data picture they have will not reflect the full extent of scams in this context as it will not include unreported cases. However, Ofcom are happy to work with the group and act as mediator between the work of the Advisory Group and telecoms companies, to help inform the strategy. Ofcom conduct research and are willing to share insights in relation to telecoms scams prevention work.
Citizens Advice Scotland (CAS)
CAS acknowledged that all partners are trying to effectively gather relevant scams data, but they suggested that it would be important to not only identify gaps in this data landscape but also how better synergy across existing databases could be created. CAS welcomed further discussion regarding gaps in the bureaux network data they collect to help further inform the work stream. In relation to the customer journey, it can be difficult to separate different types of scams; however, having a single point of contact may help, and the bureaux network can signpost customers.
Which? emphasised the need to be clear on the purpose of collecting scams intelligence. For their purposes, Which? collect scams data to build up their advice content, as well as informing on-going development of their helplines, and to inform policy. Which? stated that they do not yet have a robust mechanism in place for collecting scams data effectively, but are beginning considerations this year in order to align with wider partners. For example, they don’t yet collect data on location of scams perpetrated, modus operandi, scam type, and would also like to gather more evidence on the emotional harm experienced by victims.
Which? are keen to share intelligence with other organisations and made an offer to support and gather data in a more structured format, working alongside partners. This could feed into how data is presented and could lead into a discussion within Working Group 3: Sharing Good Practice.
Royal Mail (RM)
Royal Mail deal with scam mail but have seen a dramatic drop in recent times as scammers move online. RM are restricted in what they can share, as they are not allowed to intercept scam deliveries and mail.
The Chair made clear the ask around defining what data we want to collect at an operational level and stressed the importance of feeding back to the advisory group for wider input after the follow up meeting between TSS, ADS and PS in order to check that no gaps are being overlooked. It was suggested that once clarity between these operational partners was established regarding scams data categorisation, it may then be possible to aggregate wider partners’ data under these in order to aggregate and present a more complete data picture by scams types.
The Chair asked for views on the appropriate frequency of sharing scams data between partners for purposes of awareness raising and building a broader intelligence picture.
In response, TSS indicated they share some information with PS related to trends on a monthly basis for operational purposes, but commented that sharing this information quarterly may work better from a policy perspective. SG Cyber Team have been issuing regular bulletins in response to Covid and the emerging threat. As the pandemic has progresses the frequency of the bulletins has changed and has gone from every week to now once a month and will become a permanent link online. The bulletin will be available on the Cyber Scotland Week webpage. This page will also include a recap of some of the types of scams see over the course of the pandemic.
Delivering the vison: improving the data landscape
Partners were asked their views on the value and role of a single point of contact model for the reporting of scams, in the context of effective data sharing between frontline organisations and enforcement bodies. The notion of a single point of contact approach to the coordination of scams data had been raised by various partners in initial bilateral discussions with the Scottish Government during a stocktaking exercise following the onset of the pandemic.
TSS commented that a single point of contact model could help clarify and distinguish data relating to those scams that represent a criminal fraudulent activity – to be referred on to PS – and those that concern consumer protection rights – to be referred on to trading standards bodies. TSS suggested the value of reflecting on the pros and cons, as well as lessons learnt, following the Action Fraud experience in Scotland. However, to some extent the evidence base regarding the scale and impact of scams in Scotland needs to be in place first to justify the relevance and value of introducing a single point of contact. On the other hand, this data picture may only be fully developed once such a model has been established.
ADS agreed that a single point of contact model made sense in terms of simplifying the consumer journey for reporting of scams – this would help to project those in vulnerable circumstances, and can prevent emotional harm. ADS qualified this by adding that feedback to the individual would be important, to establish closure, even if only generic to give assurance that their experience had been captured and would inform wider scams prevention work in Scotland. It is important therefore that data is shared both ways.
- PS will send comments on the above discussion
Summary and conclusion
The Chair brought the meeting to an end, highlighting that there seemed to be a general consensus around exploring further the opportunities that a single point of contact model could bring to the landscape but that the details would need to be teased out further through the follow up meeting to discuss coding arrangements between ADS, TSS and PS.
- SG - SG to arrange a follow up meeting between PS, TSS and ADS to facilitate a more detailed operational discussion regarding reporting for enforcement action, and data sharing necessary to enable a more coordinated approach
- Police Scotland - PS to liaise with SG in follow up to the meeting to ensure their views and comments on discussions are also fed into considerations moving forwards, as appropriate