Law Enforcement
Austerity Audacity
Deputy Chief Constable for Nottingham and ACPO national lead on business crime, Sue Fish talks about collaborative working with retailers and how to be “legally audacious” in fighting fraud.
EDITOR: What does true collaboration mean to you and how do you achieve it?
FISH: I think if we consider the big picture, we are all in it together, and I have to say that since I took up this portfolio, I have received nothing but positive indications from the business community that they also see it this way.
Businesses need to make a profit to survive, the Police need to reduce crime, and collectively, we need to understand each other’s perspectives. This is fundamental to our joint success. With that in mind, true collaboration is the Police and the business community working together to address crime, sharing information, and intelligence and jointly acting upon it.
EDITOR: How do we overcome the reluctance to share business crime data and intelligence to more effectively prevent and detect business crime?
FISH: The Police have been no better at data sharing than the business community. I think we have all viewed it as a thorny issue. Traditionally we suffered from a tyranny of experts, and we have hidden behind the Data Protection Act as the reason to not share data. Why? We are all looking to prevent and detect crime. We all know that if we do it lawfully, ethically, and proportionately, it will benefit us all. Austerity has in many ways encouraged us all to review our processes and procedures, and I think my challenge to both law enforcement and the business community is “let’s be lawfully audacious!”
A few years ago we wouldn’t have dreamed of having collaborative public-private partnership intelligence sharing that is funded by business with law enforcement analysts working alongside private-sector analysts. If we look at the results that this has already achieved, we are now questioning why we didn’t do it earlier. If it is lawful, ethical, and works to address the issues we all face in tackling crime, then that is a positive result.
EDITOR: Historically, business crime has not featured as a Policing priority. Has this changed, and, if so, how?
FISH: There have been a number of fundamental changes to Policing in recent times, such as the advent of Police and Crime Commissioners (PCCs), Government policy, and austerity, together with the continuing determination of the Police to drive down crime locally. I recognise that businesses are victims of crime like everyone else. Business crime now forms part of the National Threat Assessment for organised crime and is also included on the U.K. risk register. I am in the process of getting a definition of business crime agreed and it being tagged on all Police force crime recording systems. All these are positive steps that help to raise the profile and awareness of this very important crime area.
EDITOR: Business crime is changing and increasingly features online crime. What changes do the Police need to make to respond to this?
FISH: Online crime is an issue yes, but let’s be honest; we all know that crooks are opportunists and that they look for the next opportunity. We tell people to lock their doors and windows, well, we can also apply the same analogy to the computer and to business premises which contain data.
The internet and technology has provided the thief with an environment where now they don’t have to leave their armchair to commit a crime. Internet-enabled crime is an increasing threat and, like the offenders, law enforcement is changing its approach to meet the challenge. There are also a few basics that the potential victims can do to reduce their vulnerability. Due to its global reach, cyber is a crime type where prevention is much easier than cure. Basic, well-managed cyber- and information-security policies and practices will help dramatically—good housekeeping and employee awareness are key. Law enforcement and government have made massive changes to their combined response to cyber-crime with the introduction of Action Fraud, the National Crime Agency (NCA), and the National Fraud Intelligence Bureau (NFIB), and collectively these will have an impact, but businesses reducing their vulnerability with rigorously applied policies is equally essential.
EDITOR: How are you working with business to reduce business crime and raise awareness of the issues affecting them?
FISH: My Staff Officer and I are engaged with just about every business body that you can think of. I am also working closely with my colleague, Commander Simon Letchford in the Metropolitan Police, on a local business crime strategy for London. I am also working in tandem with all Police forces and the National Association of Police and Crime Commissioners to ensure both contribution and buy-in to the way I am shaping the national Policing vision for business crime.
The various business bodies that we engage with have been absolutely brilliant at telling us “as it is” and have been really honest about what they think. It has been a true partnership where we don’t blame each other, but are critical friends. You asked the question about collaboration earlier and I think that listening, piloting, adapting, and adjusting on both parts has enabled us jointly to get to the point we are currently at. We have a jointly agreed definition, a timeline for Police forces to begin tagging to that definition, and a developing momentum with agreed partnership standards that will act as the foundation for the future work we will do together. These are big foundations to lay, but as I look at what we have achieved together over the last twelve months since I have been in post, it is pretty significant. EDITOR: How many of the 43 Police Chief Constables have bought into your business crime initiatives?
FISH: I would say without doubt that they are all on board with our aims. The common objectives that businesses have are national and whilst there will always be those that see things differently, the message we are receiving from business at a local level is exactly the same as at national level. The business community seeks a business simplification model that introduces a cost-effective and simplified approach to addressing business crime, not dissimilar to the objectives of my Chief Officer colleagues nationally. The business community is a powerful voice, and the message they bring to Policing is consistent, likewise our response is consistent—“We want to work with you to achieve the best collaborative outcomes.”
EDITOR: How do you ensure that the work you have done to date in effecting changes in business crime initiatives become a legacy and are sustainable?
FISH: We are turning a super tanker here. Changing Police and business cultures whilst simultaneously introducing a business crime definition, tagging to the definition, and then adding partnership standards is no small task. The standards that the business community and Policing are developing, and their implications from a financial, policy, and delivery perspective affect us all, so we need to get them right first time. To that end we have engaged with businesses from all sectors, large and small, local to global, and involved them in the process. We have piloted aspects of the model locally, considered pockets of best practice, and then reviewed the whole model to ensure complete engagement. This collaborative approach will ensure sustainability and continuity.
EDITOR: How do you plan to increase the public-private collaboration with Police in driving down crime and creating consistency?
FISH: I have established a national network of key individuals from each force across England and Wales, known as SPOCs (Specific Point of Contacts). Their role in developing local strategy and operational delivery in line with the national model is really beginning to expose the Police nationally to a better and more comprehensive understanding of business risk in order to provide an improved service. I also intend to introduce an intelligence capability that sees forces, via their force intelligence bureaus appointing business crime intelligence SPOCS who engage with the National Business Crime Solution (NBCS) to provide a local process for public-private intelligence exchange.
EDITOR: How do you get the strategy to be not seen as Nottingham-centric?
FISH: I am the national Policing lead for business crime that happens to work in Nottinghamshire. I am proud to be the Deputy Chief Constable of Nottinghamshire Police, and I am delighted to be able to pilot a variety of new ways of working within my force area. In addition I want to spread good practice and encourage that in other parts of England and Wales. I also have a national network of SPOCs, and importantly, we have had national endorsement from my Chief Officer colleagues to the approach we are taking. In addition, as I have already said, we are working with other forces, such as the Metropolitan Police to ensure that the Mayor’s Office for Police and Crime (equivalent of PCC in London) approach forms part of the collaborative and consistent response to business crime nationally. EDITOR: What is the plan with SPOCs?
FISH: The plan with the SPOCs is to maintain contact locally, to keep them attending business crime networking events where I can expose them to other aspects of business crime and good practice, ensuring that a consistent and professional service is provided across the country to business.
EDITOR: What do you see as the role of the National Business Crime Forum?
FISH: The National Business Crime Forum (NBCF) has been invaluable in supporting me and retailers through this change. The fact that it represents the wider business community adds the dimension that is sometimes forgotten in retail circles. For me, the NBCF is a true example of collaboration where national business membership bodies of varying natures have actually done what I am trying to do. They have respected each other’s individual identities, but collaborated to address business crime. Let’s not forget that the Federation of Small Businesses (FSB) and Chambers of Commerce, for example, represent the service, construction, manufacturing, and other sectors, all of which at some point feature in the retailer’s supply chains. If we are serious about business crime and reducing risk, it is the broader “whole” perspective we need to engage with. This cross-sector insight on business crime can only serve our mutual benefit. EDITOR: What do you see as the role of the National Business Crime Solution? FISH: When I assumed the portfolio for business crime, the NBCS was very much in its infancy and was still being shaped. However, at the recent British Retail Consortium (BRC) conference it was very reassuring to see that national business organisations and Police forces were speaking highly of the pockets of intelligence that had been enhanced by sharing information.
It’s really easy to be sceptical about whether or not this would work, and I would like to credit the people who have pushed the model forward, as now it is starting to produce results. We were adamant from both a Policing and a business perspective that the NBCS was needed, but had to be independent of Policing, all inclusive, and with a governance structure that provided all businesses with the opportunity to contribute. The NBCF provided this platform and with the business-driven governance structure it provides, I think we can all be confident of its all-inclusive approach to intelligence management.
EDITOR: What is your vision?
FISH: The business world is a really exciting dynamic. It recognises the need for change, it consistently strives for efficiency, and is very focused. My vision is to work with the business community in landing the objectives I have discussed and then using those strong foundations to build upon.
EDITOR: What are the plans for the next six, twelve, twenty-four months?
FISH: Six months should see the further development of the standards, a more comprehensive roll-out of the civil remedy model and the Business Crime Assessment Unit (BCAU), which is really exciting and pioneering in approach. In twenty-four months, I’d like to be looking at the first national assessment of the business crime statistics achieved by the introduction of the new definition. At that point the work really starts. EDITOR: Are the Met on the same page?
FISH: Yes, as discussed earlier with my working relationship with Commander Simon Letchford at the Met and the Mayor’s Office. EDITOR: What do you believe is the best integrated collective working partnership to reporting crime?
FISH: I’m not going to answer that directly as businesses know the ones that provide them the consistency and efficiency they need to make this work. My task is to capture the best bits from a few to drive up the standards. Let’s not forget that even the worst performing partnership approach to business crime is better than no partnership response. A national standard will give all partnerships a consistent benchmark to work to.
Businesses need to make a profit to survive, the Police need to reduce crime, and collectively, we need to understand each other’s perspectives. This is fundamental to our joint success. With that in mind, true collaboration is the Police and the business community working together to address crime, sharing information, and intelligence and jointly acting upon it.
A few years ago we wouldn’t have dreamed of having collaborative public-private partnership intelligence sharing that is funded by business with law enforcement analysts working alongside private-sector analysts. If we look at the results that this has already achieved, we are now questioning why we didn’t do it earlier. If it is lawful, ethical, and works to address the issues we all face in tackling crime, then that is a positive result.
The various business bodies that we engage with have been absolutely brilliant at telling us “as it is” and have been really honest about what they think. It has been a true partnership where we don’t blame each other, but are critical friends. I think listening, piloting, adapting, and adjusting on both parts has enabled us jointly to get to the point we are currently at.
I have established a national network of key individuals from each force across England and Wales, known as SPOCs (Specific Point of Contacts). Their role in developing local strategy and operational delivery in line with the national model is really beginning to expose the Police nationally to a better and more comprehensive understanding of business risk in order to provide an improved service.
