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IOM Strategic Overview v3 March 2018 of 20

TRADING STANDARDS INTELLIGENCE OPERATING MODEL

STRATEGIC OVERVIEW

Version 3 March 2018

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Page

Page

1. Executive Summary 3

2. Introduction and background 4

3. Aims and objectives 5

4. Roles and responsibilities 6 - 7

5. Tasking structure 8 - 14

6. Assessment process 15

7. Tasking for action 16

8. Review principles 17

9. Glossary of terms / definitions 18 – 20

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 Intelligence Team, Regional Intelligence Analysts and Regional Coordinators

Consumer Protection Partnership members

Government Departments and other public authorities with enforcement responsibilities

Issue No: 3 20 March 2018

Review date: As required

Change summary: December 2016 - Considerable minor changes throughout the document, including changes of

reference to NTS, the NTS Teams, and the National Tasking Group, in order to provide more clarity

on roles and responsibilities and tasking arrangements.

March 2018 – Tasking structure flowchart (page 8) changed to show region to region tasking. 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.

CONTENTS

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

(NTS) for the benefit of the trading standards profession. It introduces a national intelligence framework to support

NTS to deal with national and regional enforcement 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 national structure. There were also insufficient professional analysts available and

support and training for officers was inadequate.

In 2012 the NTS Board saw this as one of the most important opportunities that trading standards had to enhance

the service. NTS consulted on and developed the IOM, which consists of several components:

this 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,

an 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 are effective and appropriate, and to

ensure that the model can evolve in the future.

1. EXECUTIVE SUMMARY

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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.

2. INTRODUCTION AND BACKGROUND

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The aim of the IOM is to enhance the ability of trading standards services, at all levels, to work together and

effectively tackle the issues causing significant detriment to consumers and businesses.

The IOM provides a framework to:

identify and understand what a local, regional and national problem is,

increase understanding of how to deal with these problems effectively,

provide clearer and more consistent tasking arrangements,

deliver informed decision making,

adopt a problem solving approach,

coordinate enforcement nationally, regionally and locally,

achieve significant sustained reductions in consumer and business detriment in prioritised work areas, and

ensure effective allocation of resources.

The benefits of these aims and objectives to trading standards’ management, staff, regional intelligence analysts

and local intelligence liaison officers include:

a recognised and credible intelligence framework,

a structured approach to dealing with information and intelligence,

clarity of roles and responsibilities,

clarity of purpose and work prioritisation,

a consistent, transparent and accountable approach to problem solving and resource allocation,

a clear understanding of the decision making process,

a standardisation of processes and terminology that can assist when working with other agencies,

identification of existing and potential enforcement gaps,

a structured, consistent, coordinated approach to tackling local, regional and national problems,

a means to develop strategic and tactical assessments, to identify threats that fit in with local objectives

and priorities,

ability to influence regional and national work, and

a resource to underpin successful investigations.

3. AIMS AND OBJECTIVES

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Everyone is essential to the success of the IOM. Each piece of information collected through the whole

investigation process and all other enquiries is vital in collation of the overall intelligence picture.

Therefore the collection and submission of information is the responsibility of all staff working within local

authorities, regional trading standards groups and NTS Teams and projects.

Information should be recorded according to local procedures on an intelligence report, either in a paper format or

on an intelligence database, in a universally recognised format. It should be available for local, regional and

national intelligence functions to see and use against identified and emerging threats and risks.

Local Intelligence Liaison Officers

Each local authority is encouraged to have a local intelligence liaison officer, although it is recognised that

resources are constrained and this role may be carried out in addition to other duties. These officers are the day

to day point of contact between the authority’s staff and the regional intelligence analysts and their exact duties will

be for local authorities to set. Local authority trading standards services should carefully consider who they

choose as their local intelligence liaison officer because the importance of this role must not be underestimated.

Ideally this role should report to a member of the senior management team to maintain objectivity and ensure they

have capacity to fulfill this function. They should work closely with the regional intelligence analyst(s) and will

influence the wider regional issues.

Regional Intelligence Analysts

NTS has agreed that each regional trading standards group will receive funding to appoint regional intelligence

analyst(s) to be deployed in each region and embedded into regional structures. The regional intelligence

analysts will support the regional trading standards group and will be responsible for producing the regional

strategic and tactical assessments and intelligence products to support local, regional and national investigations.

They will be tasked by the regional tasking group to undertake strategic and tactical regional and local intelligence

work.

The regional intelligence analyst(s) will also support the strategic objectives and priorities of the NTS and may be

tasked to undertake national intelligence work. This work will support local authorities in England and Wales and

the NTS Teams and projects. They will act as the single point of contact for the NTS Intelligence Team and other

partner agencies in relation to data sharing and intelligence work. They will help implement and effectively support

the IOM.

NTS Intelligence Team

The NTS Intelligence Team provides a national intelligence function across the NTS areas of work that helps NTS

to identify current and future problems and assess risk. The Team works with the regional and local intelligence

functions and other enforcement agencies. The Team is not a decision making function and will not decide any

operational activities. It helps inform the tasking and prioritisation carried out by the NTG and the coordination and

intelligence support functions that the NTS Programme Office provides.

4. ROLES AND RESPONSIBILITIES

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The NTS Intelligence Team will, as required:

produce the NTS national strategic assessment,

provide the intelligence function for the National Tasking Group and undertake referral reviews,

produce national tactical assessments and intelligence products for the National Tasking Group,

providing intelligence support for the regional intelligence analysts,

provide intelligence support for the control strategy areas of work (including support for the NTS Teams

and projects),

provide national intelligence support for the Consumer Protection Partnership on the NTS areas of work,

and

engage with enforcement agencies and partners to help improve intelligence led working for trading

standards.

The Team will research open and closed national sources of data. It will work in partnership with the regional and

local intelligence functions. National information from the NTS Teams and projects and other enforcement

agencies can be sent directly to the NTS Intelligence Team, particularly because of the dynamic nature of much of

this work. If it is a national issue, the NTS Intelligence Team should record this information on both intelligence

databases, irrelevant of whether or not it is within the current national priority areas. This will ensure that all

regional groups and trading standards services are aware of key issues and possible new trends.

Action Manager

Decisions taken by tasking groups (see later) need to be overseen by an independent responsible officer who will

ensure that any actions the tasking group has agreed are being delivered. Actions need to be managed with clear

accountability and realistic timescales.

Staff in this role will monitor the progress of any agreed tasks and will report to the tasking group on:

how investigations and any actions are being delivered,

ongoing intelligence development,

delivery against agreed timescales,

how the agreed funding is being spent, and

progress against projected outcomes.

This officer may be responsible for the administration of the tasking group at any level. They play a key role in the

review process to ensure that tasking decisions have been completed and evaluated.

At a national level the NTS Programme Office will act as the NTG Action Manager to co-ordinate actions resulting

from the Group and will provide updates on the progress of actions at each NTG meeting. At a regional level this

could be the regional co-ordinator or a member of the regional management group. At a local level this role could

be fulfilled by an officer who has a reporting mechanism to the senior management/executive group or team.

These roles should be independent of the NTS Intelligence Team, regional intelligence analysts and NTS teams

such as the NTS Regional Investigation. The Action Manager will help prevent intelligence professionals

becoming involved in operational planning and tasking, thereby preserving their objectivity.

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At all levels strategic and tactical tasking is at the heart of the intelligence process. Effective tasking is essential to

obtain the maximum value from the planning and direction, collection, evaluation, collaboration, and analysis of

information and intelligence.

NTS, NTG, local authorities and regional trading standards groups will be guided by the principles of good

enforcement, as set out in the Legislative and Regulatory Reform Act 2006 and the Regulators’ Code, the

Enforcement Concordat, the Code for Crown Prosecutors and any other legislation, guidance and codes of

practice that may currently be relevant. They will take account of the Human Rights Act 1998 that has the effect of

codifying the protections in the European Convention on Human Rights into UK law and the Equality Act 2010.

‘Enforcement' includes any action taken that is aimed at ensuring businesses or individuals comply with the law.

These actions include preventative action such as offering advice, gathering intelligence and information, issuing

public warnings, cautioning and instituting criminal and civil proceedings.

The following flowchart shows the tasking processes and requests for support.

5. TASKING STRUCTURE

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The strategic assessment is a long term, high level analysis of problems that will generally be produced annually.

Each strategic assessment, at whatever level, should link to the strategic assessments at other levels. It will be

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

sources. Information should not be restricted to trading standards’ information held on intelligence databases and

case management systems. It should also include, where available, external information from a range of sources

including political priorities, external partnerships, public perception and discussion fora, public satisfaction

surveys, investigator reports, witness statements, the media, and other open source material. Arrangements

made to capture the effect of consumer and business detriment can provide a valuable insight to the strategic

assessment. It can also assist officers at all levels to understand the impact offences can have and how to

effectively deal with the problems.

It is understood that many of these functions are already taking place. An example of existing equivalents are

stated in the table below:

IOM processes Local Regional National

Strategic

tasking group

Local authority business

planning meeting

Regional trading standards

heads of service executive or

management board

NTS Board

Strategic

assessment

Senior management

assessment of data

sources to determine

annual priorities

Regional strategic

assessment (produced by

regional intelligence analyst)

National strategic


NTS Intelligence Team

Control

strategy

Business plan/service

delivery plan - identifying

priorities and work

Regional control strategy National control strategy

Tasking group Operational team meetings Regional tasking groups with

members from the regional

trading standards group who

are in a position to commit

local authority resources.

National tasking group

members are NTS board

members/deputies and

regional representatives

(heads of service from

regional tasking groups)

Tactical

assessment

Team meeting action plan Regional tactical assessment

(produced by the regional

intelligence analyst)

National tactical


the NTS intelligence Team)

Intelligence

requirement

Request to provide information/intelligence 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’.

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The following provides a brief summary of the recommended arrangements for this tasking locally, regionally and

nationally; more detail is provided in the IOM Operational Procedures document.

STRATEGIC TASKING GROUPS

There should be a strategic tasking group at each level that will consider the strategic assessment to set a control

strategy and establish intelligence requirements. The control strategy sets the agenda for prevention, intelligence,

and enforcement priorities. The control strategy will only ever be amended by the strategic tasking group. The

strategic tasking group at all levels should only meet once a year.

At each level the Strategic Tasking Group is responsible for considering strategic trends, including future and

emerging trends to develop and set a robust control strategy, outlining priorities for prevention, intelligence, and

enforcement activities.

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.

National Trading Standards

The NTS Board act as the national strategic tasking group. NTS will provide leadership, direction, policy and an

agreed set of priorities based on a national strategic assessment. NTS will require the NTS Intelligence Team to

produce an annual strategic assessment, which is informed by identified and assessed threats/risks from regional

trading standards groups and local authorities in England and Wales, as well as other intelligence, complaint data

and open source research.

Regional trading standards groups

Regional trading standards groups should have a regional strategic tasking group made up from local authority

heads of service who can determine and commit to regional priorities, for example, a regional executive or

management board.

The regional intelligence analysts or intelligence capacity will be responsible for producing an annual strategic

assessment that outlines the significant threats that should be managed through the regional strategic tasking

group process. This must take account of any locally produced strategic assessments.

Regional strategic assessments are used to inform the regional strategic tasking group who commission a control

strategy outlining actions to be undertaken and an intelligence requirement to enhance any identified gaps. The

regional intelligence analysts should submit the completed strategic assessments to the NTS Programme Office

and NTS Intelligence Team, who will use it to inform the trading standards national strategic assessment.

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Local Authority Trading Standards Services

Local authority trading standards services are encouraged, where practical, to have a strategic tasking group or

equivalent, that will consist of senior officers who can identify and address local priorities and to produce a

strategic assessment, that can assist in the production of business plans.

TACTICAL TASKING GROUPS

Tasking groups can commission the intelligence functions to produce research/analytical reports (subject and/or

problem profiles) to inform and support further operational activity. High risk issues and emerging trends that fall

outside the control strategy or intelligence requirement will also be considered for action.

Tactical assessments and recommendations prepared by the intelligence functions drive the business of Tasking

Groups by identifying the short term issues locally, regionally and nationally. The tactical assessment should be

informed from a wide range of sources. It will identify emerging patterns and trends and provide a review of recent

performance against the actions set at previous Tasking Group meetings.

The Tasking Groups will 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 (see below) for each identified

threat/risk. Following this process ensures that decision making is clear, managed effectively, transparent,

accountable, risk based and co-ordinated. Further information can be found in the IOM Operational Procedures.

National Tasking Group (NTG)

NTS has established a NTG that tasks intelligence development, assigns investigations and enforcement work to

be undertaken nationally and regionally and takes decisions based on the intelligence and information it receives,

for example, where there is:

• complex cases,

• cross-boundary activity,

• multiple defendants,

• high levels of consumer and business detriment, and/or

• significant breaches of trading standards legislation or extensive fraud.

It proactively tasks work around the NTS’ priority areas and considers requests for support that come via trading

standards regional tasking groups, NTS Teams and other enforcement agencies who will complete a

referral/request for support on the standard form. This ensures there are no enforcement gaps or duplication

between national, regional and local consumer and business protection enforcement (subject to available

resources). The NTG will follow the processes and use the documents set out in the NTG protocol and the IOM

documents.

The NTG will align its tasking decision making and its provision of other support in line with the control strategy

priorities once set. Trading standards services will continue to address local problems or threats under local

political control.

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The NTG is made up from three NTS members or deputies and three regional representatives (who are heads of

service from regional trading standards tasking groups) who should alternate after 24 months and ideally should

not be from the same regional group as the NTS members/deputies. Members from regional tasking groups are

not there to represent their region. They are there to act in the national interest of NTS. No region or country will

have a standing place on NTG but effort will be made to ensure as wide a possible allocation of places over the

cycles of membership. Representatives may remain longer at the request of the NTG Chair if there are no other

nominations from the regions.

All of these members have full voting rights, and can take formal decisions on matters before the NTG. Other

members may be invited to attend but will have no voting rights. NTG will be chaired by a member or deputy of

NTS. A quorum of 3 voting members is required for all NTG meetings.

The NTG Members must have the knowledge and experience to make tactical decisions. Where an NTG Member

has a regional or local interest in a matter (i.e. a referral or tasking), then the Member must declare their interest

and may be asked either not to participate in any discussion or to leave the room, so that they are not party to any

decisions being made on that matter.

When a vacancy occurs, the Programme Office will advise regional tasking groups and seek nominations. If more

volunteers are put forward than places available, nominees will be asked to submit a brief statement which

confirms their position as a head of service from a regional tasking group and demonstrates their knowledge and

experience of making tactical decisions. The final decision will then lie with the NTG Chair, taking into account the

above.

NTG should meet every 8 weeks, or more frequently should the need arise. A fast track process may be used for

urgent matters that cannot wait for the next NTG meeting.

The NTS Intelligence Team will undertake a referral review or initial assessment on any referrals that are received

from regional tasking groups using an intelligence scoring matrix. They will also produce a tactical assessment as

assessed problems need to be prioritised in terms of the threat, risk and harm, and ownership or management

should be allocated at the correct level.

NTG will consider the tactical assessments, referral reviews and intelligence scoring matrices using a tasking

matrix to determine the level of priority scored for each criteria, to enable the assessments to be qualified and

compared against previous and future assessments. It will determine the allocation of resources based on the

NTS control strategy priorities, the assessed risk/harm and any other available intelligence.

NTG may refer matters to another external agency if they believe it is a more appropriate body to deal with it.

The Programme Office can request the NTS Intelligence Team to support specific problems or on-going

investigations outside the NTG process, where for example the Consumer Protection Partnership has identified a

problem of significant national importance. This would be done under the direction of NTS or a NTS Governance

Group and NTG would be advised and kept informed of developments.

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Regional tasking groups Regional tasking groups should be chaired by a head of service or trading standards manager with operational

experience. Members will be taken from the regional trading standards group and should be in a position to

commit local authority resources. Regional groups should use their regional control strategy and the national

control strategy to help inform their own decision making.

Regional intelligence analysts will undertake initial assessments on any referrals that are received from local

tasking groups using a scoring matrix. They will also produce a tactical assessment as assessed problems need

to be prioritised in terms of the threat, risk and harm, and ownership or management should be allocated at the

correct level.

The regional tasking group will consider the tactical assessments and referrals/intelligence scoring matrix. It will

determine the allocation of resources based on the NTS control strategy priorities, the assessed risk/harm and any

other available intelligence.

The regional tasking group may may refer matters to another external agency where they believe they are the

more appropriate body to deal with a matter.

The regional tasking groups should meet every 8 weeks, or more frequently should the need arise, ideally prior to

the NTG meetings to enable any referrals to be made to the NTG.

Local Tasking Group

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

local tasking arrangements, which helps them prioritise work, approves significant enforcement interventions,

feeds into the intelligence system and where appropriate, makes referrals to the regional tasking group. Local

authorities should 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.

However, it is recognised that at this level local political priorities will take precedence.

If a local authority wants to make a regional/national referral or request support they should initially contact their

regional intelligence analyst and/or regional action manager, who can provide advice and guidance to help the

local authority to progress any referral/request for support. A local authority must complete a referral/request for

support on the standard form for their regional tasking group to consider if it is suitable for regional or national

support. There should always be intelligence to support this form and this should be input onto an intelligence

database. To inform the work of the regional tasking group the intelligence functions can conduct basic research

and complete an initial assessment against a scoring matrix (see the IOM Operating Procedures). Initial

assessments are to determine what further work is required.

The regional tasking groups may approve a request for support or referral to the NTG, in accordance with the NTG

Protocol (available on the ACTSO/NTS website).

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NTS Teams and projects

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. In the first instance any referral/request should be submitted to

the Team’s respective NTS Governance Group for approval 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.

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Identification Principles

It is essential that officers continue to use all available intelligence sources to capture this information.

Identification of problems can be based on numerous sources of information/intelligence including:

open source,

casework,

Citizens Advice database,

other agencies,

professional judgement,

public reporting, and

tasking group reviews etc.

It is vital that local authority officers submit information and intelligence. Without information coming in, any

intelligence framework will fail.

All trading standards staff (including frontline enforcement staff, managers and support staff) should record

information according to local procedures. This could be on an intelligence report via a paper copy or directly onto

an intelligence database.

Assessment Principles

The main purpose of the assessment process is to analyse all information/intelligence, in order to identify

problems. Identified problems should be assessed and prioritised in terms of impact. This will be completed by the

intelligence functions at all levels looking at available sources of information/intelligence.

It is recognised that many cases will be managed locally or regionally but there will still be a need for

information/intelligence relating to such investigations to be collected and submitted on whatever intelligence

database is being used.

It is vital that officers do not feel that the information and intelligence they have submitted has been ignored or lost.

All pieces of information/intelligence will be useful. However, it may be some time before specific pieces of

information/intelligence can provide the vital piece required during analysis or investigation. Therefore it is

important to ensure that officers get feedback on the work they are doing and the information and intelligence they

have submitted to promote good communication between local, regional and national levels.

6. ASSESSMENT PROCESS

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The tasking for action stage is where work is handed over to a named individual, appropriate resources are

allocated and governance arrangements are established. It is where appropriate resources and governance are

allocated by the tasking group to manage assessed problems.

Ownership/management should be led at the correct level of governance. This may involve the referral of an

identified problem to a more approriate level of governance.

The IOM acknowledges that not all problems can have a full operational response. If the tasking group accepts

that they can provide the correct level of governance and provide resources to deal with the problem, then one of

five responses is required in terms of priority and expectations:

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

coordination of multi agency activities and/or support from other areas of local authority trading standards

services)

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

standards services resources only)

– Tier 3: Develop further knowledge led by the level of governance making the decision (this may include

coordination of multi agency activities and/or support from other areas of local authority trading standards

services)

– Tier 4: Monitoring the relevant intelligence function (regional intelligence analyst(s) or NTS Intelligence

Team) is responsible for maintaining a watching brief, and escalating the issue if the assessement of

threat/risk changes (or if a new opportunity to intervene is identified)

– Tier 5: No Further Action for matters that will never be developed, for example where they are not a

priority or are outside the remit of work.

7. TASKING FOR ACTION

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The review stage commences as soon as work is allocated by the tasking group. It is linked to the assessment

and tasking stages of the IOM, and will determine the operational effectiveness in line with the IOM.

Debriefing of previous (or ongoing) activity, and assessing its impact can be overlooked. It is important that this

does not happen because without the review phase, the IOM does not effectively operate. Consequently,

national, regional and local tasking groups will be unable to make evidence-based decisions or enhance their

ability to identify, assess and manage regulatory threats/risks and protect consumers and businesses from harm.

All findings from the review process should inform future strategic and tactical assessments, to help managers to

make informed decisions.

Further detail on the review stage is contained in the IOM Opertating Procedures.

8. REVIEW PRINCIPLES

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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.

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 (i.e.

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,

threats, 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 locally, regionally and nationally.

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

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

strategic and tactical decisions are made.

9. GLOSSARY OF TERMS / DEFINITIONS

OFFICIAL


Term Meaning

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

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.

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 for

consideration identified emerging patterns and trends.

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

OFFICIAL


Term Meaning

the management principles for each identified threat/risk. It implements and

oversees 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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