- 8 Mar 2021
Attendees and apologies
- Pam Stewar, Advice Direct Scotland
- Glen Nixon, Advice Direct Scotland
- Ruth Mendel, Citizens Advice Scotland
- Katherine Hart, Chartered Trading Standards Institute
- Rebecca Evans, Financial Conduct Authority
- Karen Carrick, Improvement Service
- Cat Livesey, NatWest
- Jonathan Ruff, Ofcom
- Tayyba Mahmood, Ofcom
- Matthew Paden, Police Scotland
- Valerie Arbuckle, Police Scotland
- Jim Robertson, Police Scotland
- Alan McCartney, Royal Mail
- Ian Stephen, Scottish Business Resilience Centre
- Graeme Paton, Society of Chief Officers of Trading Standards in Scotland (SCOTSS)
- Ken Daly, Society of Chief Officers of Trading Standards in Scotland (SCOTSS)
- Julie McCarron, Trading Standards Scotland/COSLA
- Thomas Docherty, Which?
- 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
- Conor McKay, Scottish Government – Cyber Resilience
- Alan Nicholson, Scottish Government – Organised Crime: Detect and Disrupt
- Willie Clark, Neighbourhood Watch Scotland
- Madhu Bedhan, Ofcom
- Hollie Gibson, Scottish Government – Building Safer Communities
Items and actions
Welcome and introductions/purpose of meeting
The Chair welcomed partners to the second meeting of the Advisory Group and gave a quick overview of the purpose of the meeting – to discuss paper 1 focused on key outcomes and considerations made by the working groups that will be used by the Scottish Government to inform drafting of the Scams Awareness, Prevention and Enforcement Strategy. The group was invited to note that the strategy would be published before commencement of the pre-election period.
Advisory Group outcomes: open floor discussion (paper 1)
Partners were asked to note that the discussion paper, as circulated, set out the strategic direction of travel that would be reflected in the strategy based on the outputs and/or conclusions of working group discussions to date.
A key emerging theme throughout discussions has been the importance of developing a holistic package of support for individuals, both in terms of support for those impacted by scams but also to help people avoid scams in the first place. This requires a multi-pronged approach.
The three key considerations from the discussion paper were as follows:
- to explore the value of a ‘single point of contact’ or ‘one stop shop’ model for the reporting of scams and effective accessing of advice and support in Scotland, including through working with enforcement bodies to identify key gaps and determine the real-world practicalities and operational feasibility of this type of approach
- to establish a longer-term Scams Prevention Delivery Partnership, or Forum to build on and continue facilitating communication, collaboration and learning between public, private and third sector organisations involved in scams awareness raising, prevention and enforcement activities
- to explore the opportunities for a more strategic approach to provision of education and skills development on scams prevention in Scotland, working with a range of learning and education providers to map existing activities and any gaps for further intervention. This should include recognising the good work already being undertaken in related areas that can be added to rather than duplicated, and learning from previous approaches, including those delivered by local Trading Standards
Paper (1): open floor discussion
Streamlining the scams prevention landscape – reporting and advice
Single point of contact/one stop shop model
Trading Standards Scotland (TSS) in principle are very supportive of this approach. At present, TSS and Police Scotland (PS) could be missing out on vital intelligence as people are asked to self-triage and may report scams to the wrong organisation due to lack of awareness. This approach can be more person-centred with opportunities for enforcement bodies to get better intelligence by working together and although this isn’t new there is room for improvement. This also provides an opportunity to fill a gap. Action Fraud is a household name and it would be beneficial to have something which has the same profile in Scotland.
PS, having directly fed back on the discussion paper on the single point of contact previously circulated, are supportive of the aspirations but state that the picture is complex and agree with TSS that there is a lot of work to do. There was acknowledgement that the proposal is at present, high level. There will be challenges to this approach however having the vision is a good starting point. PS stated that as things progress and move forward the right people will need to feed in so that appropriate expertise are drawn on to inform next steps, in particular on the delivery and operational side.
PS referred to work already being undertaken resulting from the Covid-19 pandemic and made reference to Project Etherin. This project includes members from UK Government and National Economic Crime Centre and various trusted partners throughout the UK. The group meets monthly to look at the threat of all scams relating to Covid-19 however, it was added that it considers all types of scams. The notion of a single point of contact may be a big ask, but what SG is trying to achieve may already exists within Project Etherin, so there is a need to avoid duplication. There may be scope for SG to be a part of this project, with the help of PS. This could offer good insight as it deals with the same types of issues within a UK basis.
PS are working alongside SG (Serious Organised Crime) on The Economic Crime Action Plan and added a note of caution on the overlap from the action plan with the scams strategy.
- PS to introduce SG to Project Etherin partners
The single point of contact has opportunities, however there are concerns around the information fed in and how this gets out to the correct local authority, where the role is to intervene and protect consumers. The data flow for any single point of contact also needs to comply with Data Protection Regulations.
The Financial Conduct Authority (FCA) agree that a single point of contact would allow for greater coordination of scams data and is good for the consumer but seek clarity on how such a model would differentiate between types of scams and decide which reports would go to which relevant authority for further investigation. Any single point of contact also need to be properly resourced, but aspiration is supported in principle.
Which? commented that they were worried that any aspiration to establish a single point of contact model for scams was overly ambitious. To make the process of reporting scams less complex, there is a need to understand what is meant by reporting. It is less about a single point but more about providing clear messages for reporting and having clearer pathways for people which would support a streamlined journey for consumers. Different types of reporting will lead to different outcomes.
To follow on from this point, CTSI commented that potential victims of scams may be crying out for help and may need lots of support from different agencies. There is a worry if it goes to an advice centre, we may forget that there is attempted criminality. These may be repeat victims and this needs to be considered.
Citizens Advice Scotland (CAS) are generally supportive of the single point of contact approach, and stress that considering the journey for consumers is important and there is further exploration work to be done. CAS are keen to stay involved in further groups and events looking at scams prevention.
Advice Direct Scotland (ADS) agreed with the comments made by Which? that any potential ‘single point of contact’ model will not be able to be all things to all people, but that any change from the current system would be desirable in terms of delivering better outcomes. The single point of contact model could help to coordinate the language used across partners organisations, and it could enable better coordination of intelligence for bigger picture around enforcement actions in Scotland. At present, information in the landscape is not coordinated, and only by improving this can partners begin to take more proactive steps to prevent scams most effectively.
Key for ADS – as a frontline advice organisation – is that someone is responsible at the end of the chain for feeding back to the individual who reports a scam so that they know what has happened as a result. Focus needs to be on the consumer / citizen journey through the system – the process needs to be easy.
Police Scotland further commented that a starting point will be to better understand the scale of the problem, as this will help inform whether or not a single point of contact model is fully achievable according to ambitions currently being discussed. There is a need to understand the volume of calls on reporting scams across all relevant organisations in the landscape, meaning that initial mapping/scoping must be done. Police Scotland support the principle of streamlining the reporting pathways for people across the landscape, but highlighted in the meeting that risk management associated with key things, such as data protection and resourcing (both financial and in terms of the high skillset that frontline staff will need to have to manage, in a live situation, those individuals at risk of detriment) must be addressed.
NatWest are also supportive of the single point of contact model, but stated that the banking sector asks people to contact their bank as the best place to recover funds in the event of a scam, as a first step, and don’t want this to be lost if another route is agreed.
In any consideration of change to the current processes in place for Scotland, partners discussed the need for careful consideration to be given to ensure that change does not create further complication. It is important to avoid mixed messaging being given to the public, in particular to vulnerable people. We don’t want to give scammers other avenues to travel down. There are so many different ways to report scams and this will be a challenge. Which? agreed and stated that presently the consistency in messaging isn’t there and this is something partners should be working together on, and thinking of ways to get that consistency for the public.
The Scottish Government reminded partners that work was already underway via consultants to map the existing prevention landscape – this will provide a fuller understanding of what is out there right now in terms of contact channels. Additionally, the work will lead to the creation of a guidance document, or toolkit to be used by partners as a reference point for better understanding who does what and why in the scams landscape, organisation’s key roles and responsibilities. All partners will be contacted to contribute to the evidence gathering that will inform this work.
Partnership Delivery Group, or Forum
There was broad support from partners to establish a group to continue to build on the positive engagement and partnership working to date promoted through development of the strategy.
Strategic communication plan, supported by a calendar of events
Partners were generally supportive, with recognition also being given the value of considering a local as well as national approach to communication around scams. Partners also briefly mentioned the potential value of a protocols based approach to frontline messaging across organisations.
It was mentioned that under Project Etherin (see above) there is a sub group focused on communications at a UK level, in order to ensure consistent messaging is filtered through to the public. The sub- group referred to may be the same as the Multi-Agency Campaign Group (MACG) that SG had recently engaged with, as organised by the City of London Police. Partners recognised the importance of ensuring join up across existing groups of this nature moving forwards.
- SG will confirm if the MACG sub-group is attached to Project Etherin
Education and skills
Partners were invited to note the intention to develop an Education Action Plan moving forwards, in order to build a more strategic approach to resilience and capacity building across different groups of people at risk of scams. Reference was made to the Scottish Government’s on-going work around the same theme being led by Cyber Resilience, and recognition was given that there may be opportunities under this existing work programme for scams prevention partners to add value, building on what is already in place but expanding scope of particular interventions.
Police Scotland commented that they offer two specific training courses for officers and partners, focused on economic crime and financial investigations.
- all partners to provide more specific feedback on Paper 1 by 12 February
Summary and next steps
The chair thanked partners for attending and gave a quick summary of discussions, before drawing the meeting to a close. SG would take stock of all feedback in drafting of the final strategy.
- PS - PS to introduce SG to Project Etherin partners.
- SG - SG will confirm if the MACG sub-group is attached to Project Etherin
- all - all partners to provide more specific feedback on paper 1 by 12 February