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NTS IOM Operating Procedures – v4 March 2018 OFFICIAL of 33

TRADING STANDARDS INTELLIGENCE OPERATING MODEL

OPERATING PROCEDURES Version 4 March 2018

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Page

Executive Summary 4

Introduction and background 5

The IOM Stages 6 - 8

Stage 1 – Planning and direction 9

Stage 2 – Information gathering 10 - 12

Stage 3 – Assessment and analysis 13 - 17

Stage 4 – Tasking and coordination 18 - 25

Stage 5 – Review 26 - 27

Case studies (examples of the IOM in practice) 28 - 30

Glossary of terms / definitions 31 - 33

Appendices

STAGE 2 - INFORMATION GATHERING

Appendix 1 – Intelligence report (template)

Appendix 2 – Guidance on completing intelligence reports

Appendix 3 – Intelligence report guidance leaflet (provided by the Trading Standards South West (TSSW))

Appendices 4a, 4b, 4c, 4d – Examples of completed intelligence reports and common mistakes

STAGE 3 – ASSESSMENT AND ANALYSIS

Appendix 5 – NTS Intelligence Team host arrangements

Appendix 6 – Intelligence product specification (analyst tasking proforma)

Appendix 7 – Trading standards collection plan

Appendix 8 – Intelligence results collection plan

Appendix 9 – Intelligence requirement request

Appendix 10 – Example of a composite intelligence report

Appendix 11 – Strategic assessment outline

Appendix 12 – Control strategy (template)

Appendix 13 – Tactical assessment (template)

Appendix 14 – Problem profile (template)

CONTENTS

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Appendix 15 – Subject profile (template)

Appendix 16 - Analysis (based on the problem solving approaches including SARA and PAT)

STAGE 4 – TASKING AND CO-ORDINATION

Appendix 17 – Intelligence scoring matrix

Appendix 18 – Referral review form

Appendix 19 – Investigation/project action plan (template)

Appendix 20 – Tasking Matrix

Appendix 21 – Composite referral review including tasking decisions

Please note the NTG Protocol provides copies of the referral/request forms to be used and guidance on the use of

these forms.

STAGE 5 – REVIEW

Appendix 22 – Ongoing review (template)

Appendix 23 – Post activity review (template)

DOCUMENT HANDLING INSTRUCTIONS

This document has been produced by the NTS Programme Office

It is classified as OFFICIAL when completed as defined by the Government Security Classifications (April 2014)

and may only be disseminated to the approved distribution list as detailed below. If dissemination is required

outside this list please contact the NTS Programme Office ([email protected]) who produced this

document.

Approved distribution list:

All local authorities in England and Wales

National Trading Standards Intelligence Team, Regional Intelligence Analysts and Regional Coordinators

Consumer Protection Partnership members

Government Departments and other public authorities with enforcement responsibilities

Version 4 March 2018

Review date: As required

Change summary: December 2016 - Considerable changes throughout the document in all sections; including revised

stages, new and revised appendices, NTG protocol changes, a new second-hand car case study etc.

April 2017 – IOM Stages pages 7-8 – changed the order of the intelligence cycle information.

IOM Stage 2 and appendices 1-4 pages 10 - 11 – changed to incorporate the new intelligence report.

March 2018 – Region to region tasking included page 21-22, NTS Scambuster Teams and NTS Estate

Agents Team changed to NTS Regional Investigation Teams and NTS Estate Agency Team, and

removed reference to the NTS Illegal Money Lending Teams.

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The Trading Standards Intelligence Operating Model (IOM) has been developed by National Trading Standards

(NTS) for the benefit of the local authority trading standards services, regional trading standards groups, and the

NTS Teams. It introduces a national intelligence framework to support NTS and the NTS Teams in dealing with

national and regional enforcement needs and local authorities in their day to day work. The role of local

authorities is essential to its success. This document sets out the benefits of the model and how it all fits together.

For many years the trading standards profession has evolved and embraced the use of intelligence as a tool in the

detection and prosecution of offenders. Although there are examples of excellent practices, this was fragmented

and lacked a consistent structure. Following consultation with trading standards services the NTS Board

developed the IOM, which is a framework that consists of several components:

a Strategic Overview document provides the background to the model together with an understanding

of its benefits, roles and responsibilities, an explanation of tasking and how it all fits together at local,

regional and national level,

this Operational Procedures document details the IOM stages, associated processes, and provides

templates and examples of good practice that may be used locally, regionally and nationally,

a Management of Intelligence Material and Data document provides a framework to facilitate the

management and handling of intelligence related material,

a short Guide to the Intelligence Operating Model,

a training and development programme to ensure that managers and officers understand the model

and have the confidence to use the system, and intelligence analysts and officers have skills and a

common understanding of how they fit into the structure,

a physical network of intelligence functions consists of officers, intelligence databases, software, etc.

working together locally, regionally and nationally, and

a monitoring and review programme determines any responses tasked and/or undertaken are effective

and appropriate, to ensure that the model can evolve in the future.

Examples of templates, guidance and good practice which are given throughout the document. NTS hope

that these will be used by local trading standards services, regional groups and NTS Teams to adopt a

consistent approach.

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In 2012 the NTS Board conducted a review of the use of intelligence by local authority trading standards services.

They found a genuine willingness and enthusiasm among trading standards services to embrace intelligence led

processes. This was encapsulated by the comment of one interviewee who stated all they wanted to achieve was

“to develop a culture of intelligence as part of the day job”. The review found that knowledge and application of

consistent intelligence-led practices throughout local services was limited. Reasons for this included a

misunderstanding of what ‘intelligence led’ means and the difference between information and intelligence. The

difference between information and intelligence is analysis, which identifies patterns and meaning and allows the

development of new insights into the nature of crime and criminals. Simply it can be expressed as:

INFORMATION + ANALYSIS = INTELLIGENCE

At the heart of the IOM is the effective use of intelligence. Good quality intelligence enables valuable resources to

be targeted effectively against challenges and emerging trends, ensuring the best opportunities for positive

intervention and maximum value for money. It aims to achieve a common understanding of the business

processes that will help to better coordinate enforcement efforts nationally, regionally and locally in England and

Wales, focusing on agreed priorities and the issues causing significant consumer and business detriment.

The IOM is not about the use of an intelligence database; it is a whole system that enables an intelligence led or

problem solving approach to enforcement to be used. It is designed to be a comprehensive tool to assist frontline

delivery of trading standards, at all levels, regardless of size and resources.

Local authority trading standards, regional trading standards groups and NTS Teams can all use the IOM to help

identify and assess local, regional and national problems, manage prioritised threats and identified risks through

enforcement and other activities, as well as reviewing the effectiveness of measures taken.

The IOM is designed to provide a structured approach to decision making. There is a lot of good practice and this

document provides standard policies and procedures to facilitate an intelligence-led approach. It provides

processes for the NTS National Tasking Group (NTG) and Regional Tasking Groups to follow, which can also be

used locally by trading standards services to effectively allocate resources to target the greatest threats.

Historically, services have had a complaint led and risk model approach to activities. NTS recognises there are

times when it is still vital to react to individual complaints but supports using available strategic and tactical

intelligence to make a much bigger impact on the problem and the people causing the detriment. To make the

IOM truly work it is important that everyone understands the meaning and practicalities of being intelligence led

and a glossary of terms provides some standard definitions that officers may find helpful. NTS provided regional

training for officers and managers to meet intelligence training needs. The use of intelligence is embedded in the

trading standards’ professional qualification. NTS e-learning material will be provided on the IOM.

If an intelligence-led approach to consumer detriment is adopted the IOM will become invaluable in helping to

manage resources, business planning and enforcement activities.

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The IOM consists of the following continually evolving five stages as detailed below:

These stages will provide a framework with practical guidance on how trading standards staff and managers can

use the procedures locally, regionally and nationally.

Working locally, regionally and nationally

The IOM can work at all levels. All trading standards staff have a role to play in intelligence and ensuring

compliance or enforcement. All local trading standards services, regional groups, and NTS Teams and

enforcement projects are encouraged to follow the IOM which is designed to be a flexible framework that can be

developed for their individual needs.

Regardless of the size of a local authority trading standards service, regional resource or national area of

responsibility, it is essential that the principles of the IOM are embraced by everyone, irrespective of where they sit

in the IOM network or framework.

The following diagram shows how important everyone’s role is within the IOM.

THE IOM STAGES

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The benefits of the IOM includes the provision of a coordinated response to identified and assessed problems.

This allows them to be managed at the correct level and in a commensurate manner. If an issue is nationally

significant it can be given national oversight and coordination unless it might be more appropriate to be resourced

and managed locally and/or regionally. If it is within one region there will be regional oversight and coordination

unless it might be more appropriate to be resourced and managed locally. If it is within one authority there will be

local oversight and coordination.

The purpose of shared knowledge enables trading standards to establish which problems require what response,

as without shared knowledge, numerous parties may believe they have an isolated issue.

A connectivity between local, regional and national intelligence resources and Tasking Groups is essential to the

success of the IOM, as is the ability to escalate identified and assessed problems.

Intelligence cycle

Intelligence functions work to the ‘intelligence cycle’. It consists of six steps (planning and direction, collection,

evaluation, collation, analysis, dissemination and back to planning and direction) as illustrated in the graphic

below. This shows the circular nature of this process, although movement between the steps is fluid.

Planning and direction is essential to set clear terms of reference for what is required.

There must be a methodical and directed process for the collection of information, to identify what is needed and

where to collect it from (collection plans can be used). Data should be collected according to the scope,

parameters and methods decided on during the tasking and direction stage. Collection is more than just an

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intelligence report being completed and submitted. It is about the retention and future use of the intelligence, and

consideration needs to be given as to the sharing and dissemination of the document. More information is

contained in the IOM Management of Intelligence Material and Data document regarding the management and

handling of intelligence related material.

Evaluation should take place to translate material into

meaningful information. This involves the translation of raw

information into intelligence by critically evaluating the

relevance and reliability of the raw information. Value is

added to the raw data through summary, assessment

and/or interpretation. Information is processed to exploit

and maximise its potential. It is essential to avoid any

potential bias and to objectively review the value of the

information. Evaluation is critical to the analytical process

and the development of inferences.

All trading standards staff and NTS Teams (including

frontline enforcement staff, managers and support staff)

should collect and record information according to local

procedures, either directly onto an intelligence database

(i.e. Memex or IDB) or via an intelligence report.

Information will need to be collated to make it more usable

and easily retrievable. Collation involves organising material into a variety of formats that best facilitate research,

comparison and analysis (e.g. association charts, timelines, maps, frequency charts, flowcharts, schedules etc.).

There should be analysis and assessment, that identifies facts and draws meaning, conclusions and inferences

from the information. It can make recommendations for focusing resources, further data collection,

preventative/proactive targeting and potential enforcement activities. Very simply analysis is determining the who,

what, where, when, why and how!

The dissemination of intelligence reports and intelligence products is a vital part of the IOM and analytical

process and should be tailored to the needs of the audience, taking account of legal gateways and information

sharing protocols. Dissemination may involve intelligence products being passed to the relevant Tasking Group

for it to take decisions and allocate resources, and if required to undertake actions in response to the information

laid before it. Those tasks will require regular activity reports to be produced to update and review the allocated

tasks and an overall Post Activity Review should be completed once the task has been completed.

This brings the process back to planning and direction, which is the cyclic process of the actions and products

produced.

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The IOM is a business planning model that offers a tried and tested methodology for prioritising action at a

strategic and operational level against areas of the greatest consumer detriment and the worst offenders.

Planning and direction is essential in order to set clear terms of reference for what actions are required, within

what timescales and the exact requirements and objectives of the task.

There should be:

Clarity about the goals, relative priorities and desired outcomes.

A good understanding of the changing environment in which NTS and its’ teams, trading standards

services, and regional trading standards groups are operating, e.g. trends in government policy, the

nature of the local economy, opportunities and threats to services, control strategies etc.

A realistic understanding of what is possible, i.e. not just a strategy that works well on paper.

The planning should be developed with, and communicated to, all those with a stake in implementing it, using new

possibilities and innovative ways of working where appropriate.

This is the first stage and within an evolving process there will be some movement between the stages and it will

be essential to ensure that those managing the process are happy with the progress and direction taken.

Key Information Points

There should be clear planning and direction to ensure there is clarity of the aims, objectives and desired

outcomes.

It is essential to continually review and revisit the planning and direction stage as part of the IOM in order to

reflect any necessary changes of approach.

STAGE 1 – PLANNING AND DIRECTION

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It is essential that officers continue to gather information or data from all available sources. This information must

be obtained legally. Information gathering should follow but not be exclusive to the prioirities identified in the

control strategy. There will be a range of open and closed sources of information that may be used including:

OPEN SOURCES

Anything in the public domain;

Media, newspaper, press, television, radio reports;

Internet;

Online discussion forums;

Social media;

Publically accessible databases and registers; and

Public reports etc.

Please note these are inexhaustive lists

CLOSED SOURCES

Anything not in the public domain;

Investigator reports/cctv/covert surveillance;

Information and complaints from the public;

Intelligence databases;

Resticted access databases including those locally held;

Test reports/witness statements;

Intelligence from other agencies;

Data obtained using RIPA1 such as communications data,

account information; and

Financial intelligence etc.

Recording and collating information gathered in a standard format allows it to be processed and retrieved

efficiently. There should be an initial assessment to determine the reliability of both the source and the

information, the validity of the information content and the level at which the information can be disseminated. At

this stage an officer can consider how the information should be recorded on an intelligence database.

Intelligence Report

Intelligence reports enable an agency to assess the continuous risks to the source of the information or the use of

the material, in order to protect individuals and operations to which the information relates. The use of an

intelligence report also starts an audit trail. It ensures consistency in recording, evaluating and disseminating

information between law enforcement agencies thereby enabling them to share intelligence more easily.

A national intelligence report was developed to allow UK law enforcement agencies including the police, local

authorities, National Crime Agency, Food Standards Agency, Her Majesty’s Revenue and Customs, Gambling

Commission, Environment Agency, etc. to record, evaluate and disseminate information. The IOM will support

whatever is adopted as the ‘standard’ universal format for intelligence to be reported.

In August 2013 the Association of Chief Police Officer’s National Intelligence Model Working Group (now the

Intelligence Innovations Group) commissioned a review of the 5x5x5 intelligence report to identify opportunities to

reduce bureaucracy, improve intelligence recording and encourage greater partnership working. A new

intelligence report was agreed in 2015 and trading standards services will use this intelligence report from April

1 Regulation of Investigatory Powers Act 2000

STAGE 2 - INFORMATION GATHERING

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2017 and guidance is provided on the College of Policing web site2. The intelligence report is used to submit and

evaluate information, and to manage dissemination of intelligence. It protects the source and contributes to an

audit trail of the intelligence. Standardisation of reporting provides a shared confidence between law enforcement

communities and partner agencies. This will simplify partnership intelligence sharing, improve consistency and

accuracy in intelligence reporting. The term ‘intelligence report’ rather than ‘5x5x5’ should be used now.

Intelligence reports are used to record any information for a consumer or business protection purpose (see

Appendix 1). Guidance on completing intelligence reports is provided in Appendix 2 and an intelligence report

guidance leaflet is provided in Appendix 3. Case studies or examples of completed intelligence reports with

common mistakes are proivded in Appendices 4a (officer input) and 4b (intelligence function input),

4c (officer input) and 4d (intelligence function input).

Information reports should include information:

Obtained by trading standards staff in the course of their duties;

Given to trading standards, in confidence, by a consumer or business or from anonymous sources;

Of a personal or confidential nature received from someone who has access to it because of their position;

Obtained by covert means, for example, technical recordings or other surveillance activity;

From other law enforcement or partner agencies;

It is important for officers to ‘flag’ any interest they have in an entity, so that others with an interest can

contact them before taking action to avoid any potential ‘blue on blue’ incidents. The National Flagging

Service can also be used.

Intelligence reports should not generally be used to record intelligence where the information is easily accessible

through other systems such as the Citizens Advice Consumer Services etc.

All local, regional and national intelligence functions should have a single point of contact or single email address

to receive intelligence reports from other enforcement agencies or bodies. Trading standards services and NTS

Team managers are encouraged to support this work and integrate intelligence led processes into all trading

standards work.

Individual users will complete intelligence reports, grading the intelligence they record and providing a handling

code and the justification for these codes.

All trading standards services and NTS Teams will now need to have a local intelligence function whose role is to

review; the grading, ensure the source is not revealed, the content is appropriate, and the handling code is

justified. In addition the intelligence function will have the responsibility of assigning the action and sanitisation

coding. Part of the intelligence function’s role is to also disseminate as necessary and proportionate, and where

legally appropriate, ensuring they follow the duty of care principles for the intelligence. The local intelligence

liaison ofifcer is likely to carry out this local intelligenc function although NTS recognises that due to limited

2 http://www.app.college.police.uk/app-content/intelligence-management/intelligence-report/

http://www.app.college.police.uk/app-content/intelligence-management/intelligence-report/

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resources the local intelligence function may be the same officer that submits the initial intelligence as most

authorities do not have a full time local intelligence liaison officer.

Scanning

At all levels the intelligence functions are also encouraged to do regular scanning to identify current, predicted and

emerging problems as well as horizon scanning.

Horizon scanning is used as an overall term for analysing the future: considering how emerging trends and

developments might potentially affect current decisions, policy and practice. This helps decision makers take a

longer-term strategic approach, and makes decisions more resilient to future uncertainty.3

Examination of political, economic, social, technological, environmental, legal, organisational and media

(PESTELOM) factors can assist with the strategic horizon scanning. Research and horizon scanning should

encompass all available data sets including, intelligence databases, complaint databases, and other closed and

open sources.

Horizon scanning forms part of tactical and strategic assessments. It is recognised that in view of the limited

resources within local authorities this might not always be possible and assistance may be sought via their

Regional Intelligence Analyst.

Key Information Points

All staff are involved in this stage regardless of rank, role or location. Managers and intelligence functions,

should encourage trading standards staff to complete intelligence reports.

All intelligence functions should have a single point of contact or single secure email address to receive

intelligence reports from other bodies.

All intelligence functions have a key role to review intelligence reports and to ensure the handling code is

justified. They also have responsibility for assigning action and sanitisation codes and disseminating legally

and appropriately, ensuring they follow the duty of care principles for the intelligence.

3 https://www.gov.uk/government/news/horizon-scanning-programme-a-new-approach-for-policy-making

https://www.gov.uk/government/news/horizon-scanning-programme-a-new-approach-for-policy-making

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“Information that has been recorded and evaluated using an intelligence report4 needs to be processed along with

other information, so that it becomes intelligence which directs decision making. This is achieved through research

and analysis that is conducted by trained staff” in the intelligence functions.

“Analysis is the process of collecting, reviewing and interpreting a range of data and making inferences and

recommendations. Intelligence analysts use defined analytical techniques to identify and explain patterns of crime

and incidents, and infer who or what may be responsible … Analysis supports strategic decision making and the

tactical deployment of resources to prevent crime, detect and disrupt criminal activity, and solve problems.” 5

A strict definition of the term ‘analysis’ involves a seperating of something into its componant parts, evaluating

those parts and, as a result of this process, identifying the general principles that govern the ways in which those

parts interrelate. A good analysis will go beyond the stated facts and provide meaning and significance from the

pieces of information in the visual form of a schedule, chart or map.

There are a range of analytical techniques that are helpful for analysts to use6. It is the analytical inferences and

recommendations that the analyst produces to help guide decision makers, as part of the intelligence function.

Ideally this analytical function should be carried out by a suitably trained intelligence analyst. However there will be

instances locally where this role is shared with other functions. There should be a continual process of analysis, as

it is not simply a document produced each year or data period.

There are four intelligence products; strategic assessments, tactical assessments, problem profiles and subject

profiles. There are also a range of analyst products such as geographical analysis, association charts, schedules,

sequence of events, charts etc. These tools enable the analyst to reach inferences and make recommendations.

Methods to assess potential problems

This is where the information gathered is utilised to identify and assess potential problems. These problems could

be identified by managers, all trading standards staff, the intelligence functions, and other agencies locally,

regionally and nationally. They can be based on numerous sources of information/intelligence including open

source material, professional judgement, Citizens Advice database, etc. The identification of problems needs to

be guided by the priorities set in the control strategy which is informed by the strategic assessment. Problems

might also be identified through horizon scanning and other emerging issues that are being monitored.

Locally, regionally and nationally there must be a process to assess and analyse identified problems. The

intelligence functions work under supervision of the senior manager of the intelligence function, the Chair of the

Tasking Group or Action Manager. For example the details of the host arrangements for the NTS Intelligence

Team are detailed in Appendix 5.

4 Originally referred to as a ‘5x5x5’ 5 ACPO Practice Advice Introduction to Intelligence Led Policing 2007 page 14 6 http://library.college.police.uk/docs/npia/practice_advice_on_analysis_interactive.pdf

STAGE 3 – ASSESSMENT AND ANALYSIS

http://www.fairplayforchildren.org/pdf/1291430265.pdf

http://library.college.police.uk/docs/npia/practice_advice_on_analysis_interactive.pdf

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The NTS Intelligence Team and/or Regional Intelligence Analysts should share relevant information/intelligence

with trading standards services and any other agencies, as appropriate, ensuring an audit trail and any conditions

on future use is recorded.

Analysts will be tasked through the tasking and coordination stage, so that the Tasking Group can understand the

scope and nature of the problem. Intelligence products may be produced for specific subjects, problems, or a

combination of the two to show how the outcomes can contribute to the key priorities and objectives. Terms of

reference for analysis should capture the work to be undertaken. This can vary from a paragraph agreed by email

to a detailed document recording and defining the direction of the product and will be detailed at the tasking and

coordination stage. This will ensure the intelligence function is clear and focused on the aims and objectives of the

task required by the local or regional Tasking Group. A template for an Intelligence Product Specification or

Analyst Tasking Proforma (Appendix 6) can be used to clearly detail what is required. Any analytical product

needs to be timely, focused, forward looking, understandable and provide future solutions.

There must be a methodical and directed process to collect information to identify what is needed and where to

collect it from and collection plans can be used (see Appendices 7 and 8).

A request for intelligence can be used to ‘fill’ any intelligence gaps that have been identified for the assessment or

production of intelligence/output products (see Appendix 9). However, before searching for and obtaining

information, trading standards staff should consider the type of information that may already be available and the

likelihood of it having value as intelligence.

A composite intelligence report (Appendix 10) plus additional analysis can be produced by the intelligence

function. These could be utilised when a referral/request has been forwarded to the Tasking Group and additional

information/intelligence has been added by the NTS Intelligence Team or Regional Intelligence Analysts, even

though the problem is deemed a local or regional problem. The rationale for this product is that the referrer will

always receive back a value added product and not purely their original referral/request.

Intelligence Products

There are two assessment products; strategic assessments and tactical assessments that are used to help inform

decision making nationally, regionally and locally.

Strategic Tasking Groups

Locally Local authority trading standards business setting meeting

Regionally Regional group who can determine and commit to regional trading standards priorities, for

example a regional executive or management board

Nationally The NTS Board

Strategic assessments are a long term, high level analysis of problems. A strategic assessment will generally be

produced annually by the intelligence function at each level from research and analysis of a wide range of

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information sources. It acts as the review of the previous control strategy and is commissioned, on behalf of, and

considered by the leadership team that acts as the Strategic Tasking Group. Information should not be restricted

to trading standards’ information held on intelligence databases and case management systems.

The national strategic assessment will be made available to all local authority trading standards services to ensure

that decision making is transparent. Likewise, regional strategic assessments should be shared nationally, with

other regional trading standards groups and locally with all trading standards services within that region. This will

ensure there are links to the strategic assessments at other levels. Appendix 11 provides an example of a

strategic assessment outline and Appendix 12 a control strategy template.

Tactical Tasking Groups

Locally Operational team meetings.

Regionally Regional tasking groups with members from the regional trading standards group who are in a

position to commit local authority resources.

Nationally National tasking group members are NTS board members/deputies and regional

representatives (heads of service from regional tasking groups).

A tactical assessment is produced by the intelligence function for the Tactical Tasking Group to help drive its

business. The assessment identifies current issues which are also in keeping with the priorities set in the control

strategy (see Appendix 13).

The tactical assessment is a short term review of recent actions, preventative measures and the progress of

current operations agreed at the previous Tasking Groups by way of ongoing and post activity reviews. It also

identifies emerging patterns and trends as horizon scanning issues and provides recommendations for future

tasking and direction.

The national strategic assessment and control strategy cover the work of the NTS Teams. If any NTS Team

produces strategic assessments, tactical assessments or control strategies these should be shared with the NTS

Intelligence Team, NTS Programme Office and Regional Intelligence Analysts. Regional Intelligence Analysts

should receive copies of all nationally and regionally produced strategic assessments, tactical assessments and

control strategies and those produced by local authorities within their regional group.

On behalf of NTS, the NTS Intelligence Team and NTS Programme Office should receive copies of all regionally

produced strategic assessments, tactical assessments and control strategies.

Tasking Groups can commission the production of subject profiles and problem profiles (see Appendices 14

and 15), which are key intelligence products that are used to inform and support further operational activity.

Problems that may fall outside of the control strategy may be considered for action e.g. problems causing

immediate risk to public safety or problems identified to be of regional or national significance.

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An intelligence product should enable action to occur from it. If it is determined that an intelligence product such

as a full problem profile or subject profile is required then this should be tasked to the intelligence function, working

in line with the Problem Analysis Triangle (PAT) principles and SARA (Scanning, Analysis, Response and

Assessment). Any products should cover the following inexhaustive list:

Highlight problems.

Timescales.

Highlight weaknesses and disruption opportunities.

Target departmental assets and resources for the most effective outcome.

Highlight intervention opportunities.

Identify any other agencies interested/involved.

Identify any intelligence or evidential gaps.

Identify possible ways to ‘fill’ any intelligence gaps.

Make recommendations.

Note who could deal with the problem based on:

- Geographic impact of the criminality,

- Impact on consumers and local businesses,

- Complexity of the problem,

- Which parts of the assessment are actionable and which are not, and

- Identifying who the product can be shared with.

When articulating the findings from this full assessment phase, the analysts may be asked to provide a verbal or

written document which should be displayed in a format that can be clearly understood to cover:

What is known.

What is unknown.

What is believed.

What options are available to the recipient of the assessment7.

For an intelligence product to be useful, and relevant, the intelligence functions and Tasking Group should liaise

with colleagues who have knowledge of the issues (particularly when considering the options available). The

intelligence functions should not decide which operational activity to take as it is a matter for the National or

Regional Tasking Group or local managers to determine. Further information on problem solving approaches

such as PAT, SARA is contained in Appendix 16.

For the production of any national problem or subject profiles NTG expect that the NTS Intelligence Team will use

all available open source material and, as part of their closed source research, that they will contact the Regional

7 “Become a Problem Crime Analyst in 55 small steps by Ronald V. Clarke and John Eck is a helpful guidance document for any analyst. http://www.popcenter.org/library/reading/pdfs/55stepsUK.pdf

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Intelligence Analysts (who will contact their local authorities to find out if they are dealing with a matter); relevant

agencies; and any other sources of information such as the Sanctions Information Database.

Intelligence and information sharing

Many intelligence products are now being produced nationally, regionally and locally as part of the tasking

processes. Generally information and intelligence products should be shared between local authority trading

standards services, regional trading standards groups, NTS Teams, NTS Programme Office staff and partner

agencies, where necessary and appropriate to do so, in accordance with the legal gateways, to help inform local,

regional and national strategic and operational activities.

Further information is provided in the NTS Intelligence Sharing Protocol and the IOM Management of

Intelligence Material and Data document that provides a framework to facilitate the management and handling

of intelligence related material.

Key Assessment and Analysis Points

All local authority trading standards services should be able to identify and highlight potential problems

within their local authority.

Strategic and tactical assessments should be produced to help inform decision making nationally,

regionally and locally.

Staff from the intelligence function are responsible for the assessment and analysis stage.

The intelligence functions at all levels should not decide on any operational activities, as this is a

matter for the National or Regional Tasking Groups or local allocated managers to decide.

If an intelligence product (i.e. a problem profile or subject profile) is required then this assessment

should be conducted by the Regional Intelligence Analyst or NTS Intelligence Team working in line

with analytical techniques available.

Regionally and nationally assessed problem profiles, regardless of outcome, should be shared with the

Regional Intelligence Analysts and NTS Intelligence Team to enhance corporate knowledge and

identify potential crossovers and where possible with the wider trading standards services.

Generally intelligence products should be shared between local authority trading standards services,

regional trading standards groups, NTS Teams, NTS Programme Office staff and partner agencies,

where necessary and appropriate to do so, in accordance with the legal gateways, to help inform local,

regional and national strategic and operational activities.

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Overview

The IOM Strategic Overview summarises the tasking structure, roles and responsibilities and the NTG protocol

provides more details on the national tasking processes. The NTG Protocol also provides copies of the

referral/request forms to be used and guidance on the use of the forms. These are not provided in the

appendices.

At all levels of operation there should be a tasking function, this will cover NTS and the NTS Teams, regional

trading standards groups, and trading standards services. Problems need to be prioritised in terms of the threat,

risk and harm, and ownership or management should be led at the correct level; this may involve the referral of an

assessed problem to a more approriate level of management.

Although the tasking process is about reviewing what has been presented and making decisions on the allocation

of resources to the identified issues, it must be remembered that all other phases do not stop. The continued

cycle of collection, evaluation, collation, analysis and dissemination of intelligence will enhance what has been

presented and should continue to be reviewed and assessed.

NB – records of tasking meetings refer to the referrals/requests that go to the next level and the associated records for them.

At a regional and national level there will be a Tasking Group, whereby the Chair of the Tasking Group and

attendees discuss the assessed problems (current/emerging/predicted) and allocate a response.

It is recommended that all local trading standards services in England and Wales should have their own local

arrangements that enables them to prioritise work and feed into the regional intelligence and tasking processes.

STAGE 4 – TASKING AND CO-ORDINATION

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Local authorities could use the regional and national control strategies to help inform their own decision making.

As local authorities have regular management meetings, these could form the basis for local Tasking Group

meetings.

There should also be an allocated Action Manager that will act as the independent responsible officer to ensure

that the Tasking Group’s agreed actions are being delivered. Actions should be ‘SMART’ (i.e Specific,

Measurable, Achievable, Realistic, Timebound) in appearance and managed with clear accountability.

The Regional Action Manager or National Action Manager (NTS Programme Office) should be advised as early as

possible that a referral/request is likely to be submitted and should be sent a copy of the referral/request when it is

made. This will help business planning with regard to tasking arrangements. The intelligence function will be sent

the referral/request form to undertake the referral review before submission to the Regional or National Tasking

Group.

It is standard practice that problems may be presented within a tactical assessment. The role of the Tasking

Group is to consider tactical assessments. They oversee the actions from the control strategies and make

decisions on submitted referral/request for support and proactive tasking so that appropriate resources and

management are allocated to manage assessed problems.

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Trading standards referral or request to Regional Tasking Groups

The following diagram shows the referral/request process:

If a trading standards service wants to make a regional/national referral or request for support they should initially

send a completed referral/request form to their Regional Tasking Group for them to consider if it is suitable for

regional or national support. There should always be sufficient intelligence to support this request and this should

be referenced on the intelligence database(s). If there is a local intelligence liaison officer it may help if they can

conduct some basic research to enhance the information being provided on the form.

Upon receipt of a referral/request form, the Regional Intelligence Analyst will undertake an initial assessment or

regional referral review and should use the referral review form and intelligence scoring matrix templates (see

Appendices 17 and 18). The intelligence scoring matrix will help tasking groups to determine the level of priority

scored for each criteria, to enable the assessements to be qualified and compared against previous assessments.

The initial review assessments can determine what further work may be required.

Regional Tasking Group referral or request to the NTG

Referral/requests for national support for consumer enforcement action should only be submitted to the NTG if it

has been agreed by the Regional Tasking Group to endorse the request. It is a matter for each regional trading

standards group to determine how they endorse or ‘sign off’ any referral/request they receive through their

Regional Tasking Group before submitting referral/request forms to the NTG for consideration.

The Regional Tasking Group Action Manager must send any national referral/request form, together with a

supporting regional referral review document, intelligence scoring matrix and tasking matrix when submitting to

NTG. Regional Tasking Groups must provided related intelligence for all referral/requests. It will be important for

the submitting Regional Tasking Group to show that it has considered tasking their NTS Regional Investigation

Team Team and what support they can or have provided. Early engagement with the NTS Programme Office

should take place before any referral/request is formally submitted for consideration by NTG.

The national referral/request should have been completed in conjunction with the NTG Guidance Notes and:

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Demonstrate the case is appropriate for Level 3 (national) consideration and response, and meets the

prioritisation criteria detailed in the NTG protocol;

Provide intelligence (including details of intelligence reports, charts, intelligence products and other relevant

information) so that a decision can be made on what action to take;

Detail any financial support they require to undertake the proposed action;

Consider whether it is more appropriate to be tasked to the regional NTS Regional Investigation Team; and

Confirm the date that the referral/request form was approved by the Regional Tasking Group.

Referral/request forms must be submitted to the National Action Manager and NTS Intelligence Team within the

deadlines set within the NTG forward programme.

Upon receipt of the completed referral/request forms, the NTS Intelligence Team may carry out a referral review to

ensure that the form contains all of the information that NTG will require to conduct a full assessment of the

referral/request. As Regional Tasking Groups provide more detailed referral reviews there is an expectation that

the NTS Intelligence Team will not be required to produce referral reviews, unless they are able to add any

additional value or intelligence. The NTS Intelligence Team will continue to check the datasets to verify the

information provided and will continue to score the referrals they receive. There will be no need for the NTS

Intelligence Team to reproduce them as it is helpful for the NTG to see the referral reviews being provided by the

regional groups. Therefore, unless there are serious concerns from the NTS Intelligence Team about what they

have seen, they should only add any data from sources not available regionally and make any overarching

comment, rather than producing an almost entirely new product.

Any completed reviews will be circulated by the National Action Manager to the NTG Members together with the

referral/request form for NTG Members to consider at the next NTG meeting.

Region to Region Tasking

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A Regional Tasking Group, may, on occasion, have cause to refer cases or work to another Regional Tasking Group. This

should be discussed between Regional Action Managers, who will refer the referral/request to their Tasking Group for its

consideration/acceptance. Where a Regional Tasking Group accepts a case or work from another Regional Tasking Group,

it must ensure that appropriate information is captured in the Regional Tactical Assessment. The originating Regional

Tasking Group must be advised that the case/work has been accepted and must be regularly kept appraised of the progress

via the relevant Regional Action Managers.

If, for whatever reason, the Regional Tasking Groups are unable to accept the Region to Region referral/request for tasking,

the originating Regional Tasking Group should refer the matter to NTG by way of the normal referral review process. NTG

will then decide where the case/work is best tasked and whether it should be tasked with resources. Where appropriate,

NTG will utilise the fast-track process to obtain any such decision. If this happens, then the NTG Action Manager will then

take responsibility for keeping the originating Regional Tasking Group and NTG appraised of progress.

Referral or request for support from NTS Teams

On occasion, it may be necessary for one of the NTS Teams (apart from the NTS Regional Investigation Teams)

to submit a referral/request for support to NTG. The referral/request should be submitted to the NTS Action

Manager and NTSIT in the normal way, and also copied to the respective Team’s respective NTS Governance

Group for information by email. This should be accompanied by appropriate information or intelligence that can be

provided by either the Team, the Team’s regional intelligence analyst or the NTS Intelligence Team.

Referral/requests from NTS Teams do not require approval from Regional Tasking Groups, but should, as a

matter of courtesy and information, be sent to the Chair and Action Manager of the relevant Regional Tasking

Group for their information. The NTS Regional Investigation Teams must submit any referral/request for support

via their Regional Tasking Group.

Referral or request for support from external agencies

From time to time Tasking Groups will receive referrals or request for support from external agencies such as the

Competition and Markets Authority, Intellectual Property Office, Advertising Standards Authority, OFCOM etc. The

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referral/request form and guidance notes include specific sections relevant to such agencies that should be used

by them to make submissions to Tasking Groups.

Meetings

The timings for a Tasking Group will vary dependent upon the level of operation:

On a national basis this should occur every eight weeks

On a regional basis this should occur (as a minimum) every eight weeks (to fit in with the NTG forward

programme of meetings)

On a local basis this should occur (as a minimum) monthly (to fit in with the Regional Tasking Group

forward programme of meetings)

Each Tasking Group is recommended to establish terms of reference for the group. The NTG protocol provides

the referral/review forms, the terms of reference and guidance for the Group and partners (see the NTG protocol

for more information).

Tasking Group decision making

Following an assessment of a referral review being conducted, all referral/request should be discussed at relevant

management or Tasking Group meetings, along with the recommendations made by the assessor that relate to

the next stages. When and what resources or decisions have been agreed, tools and methods to be used to

investigate a problem. There are various options that can be considered in order to identify the most effective way

to address the identified problem and on occasions it may be helpful for an investigation or project action plan to

be used (see Appendix 19).

Where it is felt that there is an issue, but it is not considered a significant current problem this information should

still be included in the tactical assessment with the recommendation that the intelligence function maintains a

watching brief. The Tasking Group should either sanction this or agree an alternative course of action.

Urgent or significant problems requiring immediate action would be referred to the relevant parties to be dealt with

as a matter of priority without the need for a Tasking Group.

Where there is an issue that is considered to be impacting at a level beyond the identifiying one, the assessing

intelligence function refer the referral/request form, along with their completed assessment, to the intelligence

function/unit at the appropriate level of operation for consideration at their next Tasking Group. This would be

recorded as referred to the next meeting.

To ensure the Tasking Group Chair is aware of all activity linked to their area, all referred problems should feature

within the referring Tasking Group for information purposes.

Following the assessment phase, the originator of the referral/request form, that has been forwarded to an

intelligence function, should always receive feedback from the Tasking Group and a copy of any intelligence

products produced.

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All received, and assessed, request/referral forms should be collated in a central system managed nationally by

the NTS Programme Office and the NTS Intelligence Team and regionally by the Regional Intelligence Analysts

and the Regional Tasking Groups.

Following any referral review, the Tasking Group will determine if any specific intelligence development should be

taken. If there is insufficient intelligence or information to support the referral/request then the originator would be

asked to provide more detail and it will be given a pending status until this information is provided.

Once a Tasking Group has all the necessary information, the Group will decide what action to take based on the

following tiered responses:. Obviously not all problems can have a full operational response.

Tier 1: Full operational response led by the level of management making the decision (including

coordination of multi agency activities and/or support from other areas of trading standards).

Tier 2: Limited response led by the level of management making the decision (local authority trading

standards resources only).

Tier 3: Intelligence development led by the level of management making the decision (this may include

coordination of multi agency activities and/or support from other areas of trading standards services).

Tier 4: Monitoring. The relevant intelligence function (regional intelligence function or NTS Intelligence

Team) is responsible for maintaining a watching brief for a defined period of time, and escalating the issue

if the assessement of problems (or if a new opportunity to intervene) is identified .

Tier 5: No further action to occur, for example, this may be where the identified problem does not meet

any of the control strategy priorities or where there is no consumer or business detriment.

Factors a Tasking Group should consider when allocating a response include:

How harmful is the assessed problem?

Is the problem in line with the control strategy priorities?

Whether there is capability/capacity to manage the problem?

What other activities are ongoing in the area?

The Tactical Tasking Group can determine the appropriate perceived level of tactical response i.e. a national,

regional or local response. The Tasking Group may also consider that a more detailed project or investigation

plan is required in support of certain tasking, for example projects, complex investigations, etc. which would also

aid the Tasking Group in its review role and in measuring outcomes.

The Tasking Group should consider the continued amount of intelligence support required for any specific

operation. All Tier 1, 2 and 3 responses should be reported into the Tasking Group for the duration of the activity.

Tier 4’s should be highlighted in line with problem solving approaches. The submission of intelligence reports

should be relevant and timely to assist all trading standards functions and Teams.

By adopting a tasking matrix, a Tasking Group can ensure that decisions about priorities and resources are made

based on the best available assessment of problems. It enables managers to weigh competing demands and

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establish a rationale for decision making. This can also be useful for auditing purposes and helps to monitor the

requests (see Appendix 20).

The tactical assessments and referral or request for support should provide enough material to help inform this

decision making. Tasking Group decisions should be recorded on the tasking matrix, minutes from the meeting

and/or a consolidated referral form that includes tasking decisions can be used (see Appendix 21). Regardless of

what tier of response is allocated, the Tasking Group is responsible for ensuring ‘SMART’ objectives are set and a

lead officer allocated to own the management of the assessed problem and to co-ordinate actions. All completed

documents, including recorded decisions, should be retained in line with disclosure principles.

At a national level, the NTS Intelligence Team and the NTS Programme Office should liaise on at least a monthly

basis to discuss current activity and new/emerging problems. At a regional and local level the Regional

Intelligence Analysts and local intelligence liaison officers should regularly liaise and discuss activities with their

managers.

Fast track process

Nationally and regionally if the matter is urgent and cannot wait for the next Tasking Group meeting, a ‘Fast Track

Tasking Group’ may be set up to agree to a full assessment being carried out prior to the next full Tasking Group

meeting to avoid delays in the process. It will be a matter for each Tasking Group to consider who should be

involved in the process, and may include the Chair of the Tasking Group and any project leads such as the NTS

Programme Manager or the senior manager for the regional intelligence capacity. Any decisions by this Fast

Track Tasking Group should be confirmed in writing and reviewed by the full Tasking Group at the next

opportunity, ideally their next meeting.

Key Tasking and Coordination Points

Senior managers are responsible for making resourcing decisions, and aligning resources with assessed

problems

Assessed problems requiring a response should be presented to the Tasking Group for appropriate

prioritisation within a tactical assessment

Tasking Group attendees (Strategic and Tactical) should be conversant with the principles of the Tasking

Group processes and understand the required outcomes from the meetings

In line with the tiers of response, Tasking Group chairs need to allocate a priority of response for all

assessed problems.

All actions should be SMART i.e. Specific, Measurable, Achievable, Realistic and Timebound.

Documents should be retained in line with disclosure principles.

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Where tasking involves the deployment of significant resources or has a high level of risk, the Tasking Group may

determine that it would be helpful to have a detailed review of the project/investigation to ensure it is being

delivered as required.

The review stage commences at the point that activity is tasked, not once it is completed. It commences as soon

as a priority is allocated by a Tasking Group. Ongoing and end of year or post activity reviews/reports are required

for all tasked issues (see Appendices for templates of these documents).

The review stage concludes the cyclic process and links to the assessment and analysis, and tasking and

coordination stages of the IOM. It is the one that will determine the effectiveness of how trading standards

services are operating in line with the IOM and any performance indicators.

Once operational activity is completed resources are often moved into new activities without a debriefing of

previous (or ongoing) activity or assessment of the impact it has had.

Without the review phase, the IOM does not operate effectively; consequently trading standards services will not

be able to make evidence-based decisions or enhance their ability to identify, assess and manage regulatory

problems to protect consumers and businesses.

Nationally and regionally, any trading standards service, NTS Team or regional trading standards group that

receives funding or other support through the Tasking Group will be required to provide regular updates on how

their investigation, project or activity is progressing and how any funding has been used. Regular feedback will be

requested, in advance of each National and Regional Tasking Group meeting for that period and should be

provided in the format of the Ongoing Review or Post Activity Review templates.

Appendix 22 provides an example of the ongoing activity review document and Appendix 23 provides an

example of the post activity review document.

NTS Regional Investigation Teams will be able to provide regional and national updates as part of their normal

quarterly reports and will not have to complete separate activity reports for their Regional or National Tasking

Group, unless this is specifically requested by the Tasking Group.

Accountability for reviews rests with the party that is tasked to undertake the action(s). They are responsible for

ensuring the review documents are completed along with the Action Manager, who will ensure this role is fulfilled.

Reports should be provided to the relevant intelligence analyst and Tasking Group, which will consider the

findings, as this will inform any future tasking or assessment reviews.

Ongoing review

Any activity that is has a Tier 1 or 2 response should be subject to continuous review, and should be reported (via

tactical assessments or activity reports) into the relevant Tasking Group for the duration of the activity. The

reviews and reports should include whether objectives have been met and whether the tactics have been effective.

STAGE 5 – REVIEW

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Activities that are subject of a Tier 3 or 4 response should also be subject to a review to ensure the response is

still appropriate. A Tier 3 response should be reported every six months and a Tier 4 every 12 months (these are

as a minimum, unless new information that may affect the level of response comes to light). If it is determined that

the level of response is no longer appropriate, the Tasking Group chair should reallocate a new tier of response.

At the specific request of NTG or Regional Tasking Group a review may be carried out, for example where the

tasking involves the deployment of significant resources or has a high level of risk. These will be subject to a full

(structured) debrief and recorded for comparison against previous and future reviews.

Post activity review/debrief

Any activity that has been subject of a Tier 1 or 2 response should be subject to a full (structured) debrief at the

end of the activity to enable the work to be evaluated and thus compared against previous and future reviews. It

should include; the impact of the activity, what lessons have been learnt and the appropriateness of resources.

Information pertaining to such questions should be collected throughout the activity by the intelligence function and

any lead officer. The feedback of intelligence as part of the review process is essential and all findings should be

used to inform future strategic and tactical assessments, with a view to enabling Tasking Groups to make

evidence-based decisions.

Key Review Points

Senior managers/allocated action owners are responsible for ensuring reviews occur. The Action

Managers, are responsible for conducting these reviews and will report to the relevant intelligence function

and Tasking Group which will consider the outcomes and actions.

For a review to be effective, SMART objectives are required at the start of any activity. Performance

management frameworks should be linked and informed by the review process.

Assessing impact is a key component of the review process, including factors such as return on

investment. All involved, at any stage of the activity, should help inform the review process and equal time

should be allocted to establishing what did/did not work.

Review findings should be shared throughout as appropriate.

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Example 1 – local case

Local identification and local delivery

A local authority trading standards service referred a case to the Regional Tasking Group about a horse dealer

they had received a complaint about. The horse was allegedly misdescribed when sold. The dealer was known to

the local authority as she had previously been prosecuted by them for similar matters. The dealer and her partner

were believed to live at an addresses in a neighbouring Local Authority and thought to keep her horses in another

Authority in the region. The lack of complaints meant that it was not adopted by the NTS Regional Investigation

Team as a ‘regional issue’. However, the Group tasked the Regional Intelligence Analyst with creating an

intelligence package on the trader. The package helped focus the addresses to target and strengthen the

applications for warrants. Entry warrants were subsequently obtained and executed by the Local Authority and as

a result details of other customers were obtained. The target(s) were also found and arrested. The upshot is that

the local authority have the suspects on bail and a series of new leads to follow, with the potential to identify other

victims. There is also the opportunity to take the case back to the Regional Tasking Group for further support if

necessary.

Example 2 - Regional case

Local identification, regional delivery

A referral/request for support was received by a Regional Tasking Group from a local authority trading standards

service in relation to a known ‘emergency locksmith’ which generated a high volume of complaints over a wide

geographic area. It was known that the trader had previously been tackled by a number of trading standards

services over the previous 10 years. The initial request to the Regional Tasking Group for regional support was to

assist in gathering evidence to pursue civil enforcement action under the Enterprise Act. It was agreed that the

NTS Regional Investigation Team should provide support and a number of victims were visited and evidence

gathered. During the investigation, offences were suspected under the Fraud Act and further investigated.

Numerous victims’ accounts were evidenced across the two regional trading standards groups with over 40

separate victims. Two ‘test purchase operations’ were also conducted. Following a six week contested trial the

jury found the defendant guilty of all 15 charges of fraud and he was sentenced to four years imprisonment.

Further to this, Proceeds of Crime investigations initiated during the criminal investigation resulted in a confiscation

award.

Example 3 – National case

Local identification resulting in national coordination and regional delivery

A number of local authority trading standards services received complaints from consumers regarding household

products they had purchased over the internet. The supplier’s websites had possible Consumer Protection from

Unfair Trading Regulations 2008 breaches and associated misleading advertising. One trading standards service

CASE STUDIES (EXAMPLES OF THE IOM IN PRACTICE)

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took the lead as they were the Home Authority for the supplier businesses and identified that there was a national

problem as complaints were spread across a number of regional trading standards groups. The trading standards

service referred the matter to their Regional Tasking Group who assessed the referral/request and identified high

levels of consumer detriment, ongoing risks to consumers, and cross border activity. They referred the matter to

the NTG who assessed the request for support and decided:

- The identified problem fell within their remit.

- This particular case had been identified as a problem through discussions with regional trading standards group

and the Competition and Markets Authority and linked to the previous control strategy priorities.

- There were high levels of consumer detriment and complaints across three regional trading standards groups.

- It was an ongoing problem, currently happening and enforcement action was considered as the best opportunity

to identify the controlling mind and stop the activity happening.

- There was a reputational risk to local authority trading standards services if no action was conducted because of

the high level of complaints.

- It was not an industry-wide or cross-market problem and there was no deterrent effect to support any established

means regime.

Therefore the NTG tasked one regional trading standards group to investigate the matter, providing funding to

enable the NTS Regional Investigation Team to conduct an investigation of a company operating on an national

basis and committing numerous consumer protection offences.

Example 4 – National case

National identification resulting in national coordination

A large scale internet fraud was identified through liaison with external partners that was causing significant

consumer detriment from potential breaches of the Consumer Protection from Unfair Trading Regulations 2008

and the Fraud Act 2006.

Intelligence was identifed from a number of different sources, initially assessed, forwarded to the NTS eCrime

Team and subsequently selected for further development by the NTS Intelligence Team.

A full inteligence product was produced and returned to the NTS eCrime Team for investigation.

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A second-hand car trader case study

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Term Meaning

Control Strategy The control strategy sets the agenda for prevention, intelligence, and enforcement

priorities. The control strategy is produced by the Strategic Tasking Group, after the

production of the strategic assessment and will only ever be amended by this Group.

Actions from the control strategy are allocated and overseen by the Tactical Tasking

Group.

Enforcement Priorities This is a statement by a Strategic Tasking Group to identify which specific problems

are high priorities for tackling in the forthcoming period. Resources are allocated to

these high priority problems, away from lower priority threats to consumer and

business welfare.

Harm Physical, financial or psychological injury, damage or loss – consumer/business

detriment, negative impact on fair and equitable trading environments.

Horizon scanning To identify predicted and emerging problems across all available data sets including

open source, intelligence databases, complaint databases etc.

Information Information refers to all forms of data obtained, recorded or processed by an

organisation, including personal data.

Intelligence Intelligence is information that has been subject to a defined evaluation process in

order to assist with decision making. Intelligence is not what is collected; it is what is

produced after collected information is evaluated and analysed.

Intelligence function

Intelligence professionals who are responsible for assessing identified problems (ie

threats and/or risk), developing and assessing knowledge, supporting enforcement

activity. Dependent on size of the unit this may include people conducting distinct

functions such as intelligence officers, intelligence analysts, intelligence researchers

and intelligence managers. Whilst they are separate roles that require specialist skills

in smaller units the researcher and analyst can be operated as a hybrid role.

Intelligence led Intelligence led is a business process for systematically collecting, organising,

analysing, and utilising intelligence and information to guide operational and tactical

decisions. Intelligence-led aids in identifying, assessing and managing subjects, and

problems at the local, regional and national level.

Intelligence Operating

Model (IOM)

The process by which Trading Standards operates to prioritise and tackle identified

problems.

Intelligence product There are four intelligence products; strategic assessments, tactical assessments,

problem profiles, and target profiles. They provide the information upon which

strategic and tactical decisions are made.

Intelligence report This is a nationally recognised form that is used by the majority of law enforcement

entities in the UK. It is used for recording and disseminating intelligence and

GLOSSARY OF TERMS / DEFINITIONS

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Term Meaning

provides for an audit trail as to where and for what reason.

Intelligence

requirement

The request to provide intelligence or information to fill any identified gap between

what is known and what is not known. Generally it will cover ‘who, what, where,

when, why and how’.

NTS Teams and

projects

There are a number of teams including; the NTS eCrime Team; the NTS Estate

Agency Team, the NTS Intelligence Team; the NTS Safety at Ports and Borders

Teams; the NTS Scams Team; the NTS Regional Investigation Teams; and any

other projects that may commissioned.

Problem Misconduct which is causing harm to consumers and businesses.

Problem profile These can be used to better define established criminal activity and/or emerging

crime, hot spots and any intelligence gaps. It will generally include suggested

opportunities for various forms of intervention including preventative work. It is used

to gain a greater understanding of a problem, and to target the problem tactically

through prevention, intelligence and enforcement opportunities. A problem profile is

a continuously evolving product which is added to and updated until the problem is

resolved.

Risk Probability of the misconduct occurring which causes harm to consumers and

businesses.

Strategic Assessment This document is a long term, high level analysis of problems. It is produced by the

intelligence functions and utilised by the strategic tasking group to set the control

strategy. It will be updated and considered annually by the leadership team, acting

as the Strategic Tasking Group.

Strategic Tasking

Groups

The Strategic Tasking Group meet once a year to consider the strategic assessment

and to set the control strategy. This group is responsible for considering strategic

trends, including future and emerging trends in order to develop a robust control

strategy, outlining priorities for further prevention, intelligence and enforcement

activities.

Tactical assessment Tactical assessments drive the business of Tasking Groups. The assessment

identifies the short term issues locally, regionally and nationally in accordance with

the control strategy. They provide a review of recent performance against the actions

set at previous Tasking Group meetings. Tactical assessments also highlight

identified emerging patterns and trends.

Subject profiles These provide a detailed picture of (potential) offenders, their behaviour/activity and

their associates. It can include the victim type or location and is used to gain greater

understanding of an individual and to target or protect the individual(s) through

prevention, intelligence and enforcement opportunities. The subject profile is a

continuously evolving product which is added to and updated until the subject is


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Term Meaning

apprehended or protected. It is then stored to enable it to be retrieved, especially if

the subject reoffends.

Tasking Group

attendance

This will vary dependent upon the level of operation. Attendees will have

responsibility for enforcement in their area. A senior manager should act as the

Chair. The group should also include an Action Manager, the intelligence manager

and intelligence analyst.

Tactical Tasking

Groups

Consider tactical assessments and determine the allocation of resources based on

the assessed risk/harm, other available intelligence and the control strategy. Each

group, at whatever level, may determine one of the tiered responses as outlined in

the management principles for each identified problem. The group implements and

overseas the allocation of actions against the control strategy.

Threat An approaching, emerging or imminent issue or conduct which is or may cause harm

to consumers and businesses.


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