Scams prevention, awareness and enforcement strategy: 2021 to 2024

Chapter 2: Strengthening Our Approach

Having established that tackling scams is important in our ambition to create a Fairer Scotland for all, the following section outlines the primary gaps that we have identified – through engagement with the Advisory Group – in the existing approach to doing this in practice, and where we aim to introduce strategic change to add best value to outcomes. Areas for improvement are presented according to:

1. What is not working as well as it could for people on the ground in terms of being able to avoid scams, and access support from frontline services; and

2. What is not working as well as it could for advice and enforcement bodies to be able to take effective action, both to deter or disrupt scammers and to support those in need when they are victimised.

In being transparent about the processes and systems in place at present, and what can be done to further strengthen their effectiveness, our aim is to build on good work to date being delivered by partners to combat scams.

Being Proactive

When people think about scams, first instinct is often to consider what happens when someone becomes a victim. This is important, but equally so is how we can actively remove, reduce or disrupt the connection pathways between scammers and members of the public in the first place. This means understanding the gaps and / or barriers to effective communication and education provision.

Awareness Raising Campaigns

As is demonstrated in the previous section, there is a whole host of work underway across partner organisations to raise awareness of scams and the cunning tactics used by criminals to target people. In order for people to avoid a scam, they must know about it and what signs to look out for that can indicate risk. There is a lot of good work already being delivered by stakeholders to ensure that people have the right information on new and emerging scams, as soon as possible and that people remain vigilant. During the current global pandemic this has almost become more important due to the quick and ready proliferation of scams in recent months.

Speed is essential. The ability of relevant organisations to be able to swiftly identify, share and disseminate information on new scams as and when they are first spotted is generally acknowledged as being highly important to the effectiveness of proactive scams prevention communications to members of the public. The sooner people can be made aware of any change in tactics being deployed, then the fewer are likely to fall victim. They will be prepared, ready to recognise key indicators. A good example of how this is done in practice through the use of technology is the targeted Neighbourhood Alert system run by Neighbourhood Watch Scotland. This system delivers targeted local safety information alerts and advice – via text, phone or email – to self-registered recipients, including advice on the latest scams.

At a national level, the truth is that the impacts of Covid-19 on the number and nature of scams in Scotland has, in fact, driven and accelerated a new level of partnership working. This is now enabling a much faster rate of turnaround of intelligence into meaningful and widely communicated messages to the general public. The Scottish Government is actively collaborating with Police Scotland, the Scottish Council for Voluntary Organisations (SCVO), and the Scottish Business Resilience Centre (SBRC), to produce the monthly CyberScotland bulletin. The bulletin is designed to provide information on the latest threats, scams, news and updates covering cyber security and cyber resilience topics and training resources. Due to the pandemic, the bulletin currently also includes information about a much wider range of scams, including doorstep and nuisance or scam calls.

Trading Standards Scotland (TSS) have also developed the Scam Share bulletin, which is a weekly bulletin that provides information on the latest scams reported by people across Scotland. The bulletin is distributed through various networks, and people can sign up to the receive the latest bulletin direct by email.

In taking forward larger campaign based activity, advice and enforcement delivery partners have also been quick to adapt their methods of communication to a predominantly digital format, due to social distancing rules brought in due to the pandemic.

For example, Trading Standards Scotland (TSS) and Police Scotland launched the annual Shut out Scammers campaign online, in June 2020. Each year the campaign aims to draw attention to doorstep crime as well as nuisance, or scam calls. In its most recent form, the campaign focused in particular on scams that are linked to rogue traders and cold callers. Other partners, including Advice Direct Scotland, Neighbourhood Watch Scotland and the Scottish Fire and Rescue Service, also supported its delivery. Another recent discrete campaign around scams that took place was Advice Direct Scotland’s (ADS) ‘Stop Scams Calls’ social media initiative, launched in December 2020. The campaign sought to encourage consumers to activate existing call blocking services available through their telecommunication service providers, such as BT, Sky and TalkTalk.

However, despite all the genuine added value that the aforementioned types of scams awareness raising initiates create, the considerations made by the Scams Prevention Partnership & Advisory Group have shown us that still greater impact can be achieved through addressing some outstanding challenges. The focus must be on fostering collective and collaborative approaches to proactive awareness raising work as default.

While not always the case, in general at present it can be said that:

• Delivery of multiple scams prevention campaigns by different organisations at a similar time can create a cluttered landscape. For example, last year two major anti-scams campaigns ended up running across the same time frame, namely Shut Out Scammers, and the national Scams Awareness Fortnight, in June 2020. Each campaign had its own particular area of focus, with slight differences in the range and coverage of signposting to reporting and wider support channels in a Scottish context;
• Messaging across scams prevention campaigns conducted at similar times, and / or focused on a related issue, are not always consistent;
• There is no organised approach to the delivery of education based scams prevention capacity building across different groups of people in vulnerable circumstances across Scotland as a whole.

What does all this mean in practice for real people on the ground who stakeholders are trying to help?

There is general consensus amongst frontline advice service providers, enforcement bodies and wider advocacy organisations that effective messaging on scams prevention demands a year-round process of communication. A crucial tool in fighting scammers is for members of the public to remain vigilant at all times to spot the signs of a potential scam, so that they can actively avoid them. Those who carry out scams against the unsuspecting have no set timetable for when they operate, and will always be on the lookout for new opportunities to exploit. This means that while some scam types may be seasonal in nature, there is no real “down time”, or the absolute absence of the risk posed by scams at any point in the calendar year.

Some partners have already taken steps to expand their campaigns work to reflect this. UK Finance – a representative body for the UK finance and banking industry – has introduced the ‘Take Five to Stop Fraud’ campaign as a longstanding initiative. As well as running standalone campaign awareness raising activities linked to particular ‘high risk’ events, or periods in the year (such as Black Friday^[16]); as a whole, the campaign initiative seeks to also embed a degree of consistency across the finance sector regarding messaging, protocols and processes to support people at risk of financial fraud^[17]. While the campaign is not tailored to a Scottish context, the model provides one example of delivery around a central campaign programme that can be used to easily, effectively and consistently distil key messages throughout the year.

In a similar vein, the Financial Conduct Authority (FCA) now runs the ScamSmart campaign, which focuses on protecting people from investment and pension based scams. Again, by using clear branding and associated marketing techniques such as standard social media tags, the campaign initiative seeks to raise awareness throughout the year around the same topic with a degree of consistency and recognition^[18].

There is an opportunity to use a consistent approach towards awareness raising that is applied across all types of scams, and for different groups of people.

Education Programmes

Building greater vigilance against scams – of all types – can also be achieved through embedding the right skills and knowledge as part of systemic education programmes across different settings.

Much good work has already been done to help progress this agenda, for example in relation to online safety and cyber resilience in Scotland, through the Cyber Resilience Learning & Skills Action Plan 2018-20^[19]. In previous years in Scotland, there have also been bespoke initiatives trialled such as the “Young Consumers of the Year Competition” – delivered by the Chartered Trading Standards Institute and local Trading Standards Officers, to improve general knowledge among school children of consumer rights and law.

The challenge is that because scams are not solely perpetrated through online platforms, we recognise that more work needs to be done to ensure a comprehensive package of educational materials are available so that no one is left behind or made more vulnerable by an absence of tailored support.

Doorstep and/or phone based scams can be as detrimental to those affected as a scam that has been committed over the internet, using email or other platforms. Often times a scam can also start out in one form in order to “hook” the individual, such as a text message, before then evolving into something more complex that involves multiple platforms, from phone calls to fake URLs. This means that education provided to proactively protect people from falling victim to scams needs to cover a spectrum of scam tactics.

Based on the considerations made by the Advisory Group, it is evident that while pockets of valuable local to national level awareness raising activities are already underway on various fronts, there is no overarching plan to help coordinate these efforts. Alongside public sector bodies such as Police Scotland, TSS and local authority trading standards departments, we need to continue to support the work of many third sector charities and community level organisations. And we need to find ways of better integrating the awareness raising activities of each with one another so that scams prevention education across Scotland is:

• more consistent;
• wider ranging in content; and
• delivered through the most appropriate way, in terms of purpose, content, and channel, in order to maximise impact for target audiences.

Key to the targeting of strategic communications is the use of evidence. The more that we are able to support the sharing of research findings and intelligence between key scam prevention organisations to inform education and awareness raising work, then the more likely it is that the approach to delivery can be designed to match the interests and needs of different groups of potential scam victims. For instance, in delivery of the 2019 national Scams Awareness Month campaign in Scotland, Citizens Advice Scotland – working in partnership with TSS – drew on a range of evidence from surveys, to bureaux data and TSS scams intelligence, in order to develop a robust Communications Plan that took into account both young and elderly demographics, as well as types of scams^[20]. This then helped to shape the tactics used on the ground, and the key partners that CAS sought to engage as part of disseminating the campaign messages.

Streamlining Advice & Enforcement

Being proactive in the fight against scams is challenging for enforcement bodies that seek to stop or disrupt criminals engaged in scams. One of the main difficulties relates to data sharing.

• In line with the fourth pillar of Scotland’s Serious Organised Crime Strategy (2015)^[21] namely to disrupt serious organised crime groups – improving access to, and the transparency of key information and intelligence between multiple enforcement agencies is important in being able to identify and pre-empt scammers.

And in order for us to establish a “whole person, whole system” approach to scams prevention in Scotland, we need to ensure that the shared wealth and power of data from across the landscape is being drawn on to identify and intervene against scammers.

What makes this hard is the current disconnect between the internal data management systems of frontline consumer and citizen advice services’ and relevant enforcement bodies.

There are many different organisations that a person may reach out to for help if they feel they have been victimised by a scammer in Scotland, this means there is a high level of rich data to be tapped into beyond the immediate call records of enforcement bodies such as Police Scotland.

However, how these organisations code – or categorise – a call relating to a scam incident is variable. This means that it is not straightforward for intelligence between advice providers and enforcement bodies to be readily collated on a like for like basis. In turn, this can lead to a poorer experience for victims, and a reduced ability to identify, track and enforce scams prevention at a strategic level.

Overall, without changes being made to how certain data can be accurately and safely shared between partner organisations, the wider national picture of scams in Scotland may be difficult to fully capture or verify.

Where data collection can be effectively aligned and shared then organisations may be able to more quickly identify and disrupt, or ideally apprehend scammers; and interventions or required investment can be more efficiently identified and justified.

Admittedly, regardless of what improvements can be made to the existing system, we will never know for sure if the picture painted is complete. But the more we can do to support partners to engage and liaise with one another to pool data and use this effectively to spot trends and derail emerging scams, then the more likely it is that collectively we will be able to help protect more people through proactive intervention.

Scams Reporting and Supporting Victims of Scams

Complexity of the Landscape

In the first instance, a victim of a scam needs to know how they can report the incident and to who.

There are already various reporting channels that provide options for different user groups to notify someone of their situation, with varying levels of feedback or further support on offer.

For example, both Citizens Advice Scotland (CAS) and Advice Direct Scotland (ADS) have developed online scam tools. The Scams Action online web-chat service delivered by CAS provides specialist one-on-one help for people who are worried they are being scammed, and those who have already lost money. The CAS website also provides a checker service, where people can answer some basic questions and the system will help determine whether something might be a scam and what to do if the individual has been scammed. ADS’ ScamWatch Quick Reporting Tool is available 24 hours a day to report suspected scams and suspicious activity. Where further investigation is required relating to a consumer regulation violation, information is referred by ADS directly to Trading Standards Scotland. Individuals can also be directed to phone Police Scotland 101 for non-emergency calls, where an assessment of any appropriate criminal enforcement action is then made.

At a local level, bespoke reporting initiatives have been introduced in certain areas in order to safeguard particular groups. Working in consort with the police, Angus Council has established the Financial Abuse Support Team (FAST)^[22]. The purpose of this team is to take quick action in response to local reports of financial scams against people in vulnerable circumstances, with a particular focus on supporting elderly residents who may already be known to the local authority’s adult protection team.

Looking more widely at the UK / GB landscape, the consumer body, Which?, is also in the process of developing a scam reporting tool, to be informed by research looking at how consumers describe scams and scam enablers. People living in Scotland can also use the National Cyber Security Centre’s open source Suspicious Email Reporting Tool to report suspicious emails (report@phishing.gov.uk); and notify their mobile phone providers of suspicious text messages by forwarding any to the free-of-charge phone number, 7726.

Unfortunately, given the breadth of scam types and their impacts, a perennial problem is:

• People can struggle to navigate what is in effect a very large, complex and sometimes convoluted reporting and support landscape.

Industry specific research – such as in the financial services sector – shows that a lack of knowledge of where to go in order to report a scam is a very common reason for why cases go under-reported^[23].

Wider European level research evidences that the extent to which the person believes that reporting the scam will make a difference and that they will hear about it influences their likelihood of reporting^[24]. In other words, what matters includes effective feedback loops.

However, it is not enough to assume that everyone might be looking for the same type of support or outcome when actively seeking to report a scam, or scam attempt. In some cases, a person might simply want to be a “good citizen” and let the right authorities know that they have been approached by a scammer – but the actual level of harm, and therefore need for support or redress, may be minimal.

Box 4: Stigma and the Downward Spiral – repeat victims of scams

Case Study: East Renfrewshire Council Scam Prevention Team, Age Scotland

This case study is a real-life example of what has happened to someone living with dementia because of a scam.

John is a proud retired professional who is living independently with dementia. His wife died several years ago and his only daughter lives 30 miles away. A home carer arrived at his house one day and saw that 3 men were working on the roof of his property. They had cold called having noticed a loose roof tile from the road. They initially quoted £80 but had since claimed that the roof needed emergency repairs and the cost had rocketed to £7,500. John was upset and confused and indicated he just wanted to pay the men to get them to go away as he felt threatened and embarrassed. The carer contacted the Police and Trading Standards scam prevention team. The workmen cleared off when they realised that the Police were investigating. The Trading Standards scam prevention team then visited John to give him advice on avoiding scammers in future. John was also being targeted by scammers on the phone and through large amounts of mail claiming he had won various prizes.

Sadly, John had responded to a large number of fraudsters and had taken over £100,000 of his savings from his account to pay scammers from all over the world. The Scam Prevention Team worked with adult protection and third sector partners to look at the best way to safeguard John and improve his life.

What happened next:

• His daughter became his Power of Attorney for welfare and financial matters.
• John received a free nuisance call blocker to stop all unwanted sales or scam calls.
• A No Cold Calling Sticker was displayed on his front door.
• A community alarm/telecare system was installed.
• His mail was redirected to his Power of Attorney.
• A list of Trusted Traders was supplied to him and his family for future use.
• A claim went in via the banking ombudsman to reclaim the money lost to scams.
• He has joined a local supported art class and feels less isolated.
• John has lost no more money to scams and his anxiety levels have reduced. His daughter is also more confident in John’s ability to maintain independent living.

*This case study has been drawn from Age Scotland’s 2019 publication, “Scam prevention: Information for carers of people living with dementia”, available for download at https://www.ageuk.org.uk/globalassets/age-scotland/documents/ia---factsheets/dementia/dem-14-scams-carers-of-someone-living-with-dementia-aug-19.pdf

In light of these challenges, there is scope to streamline the user journey from first point of contact, through to provision of support and feedback. And as part of this, there is scope for us to further consider how we work together with partners to reduce the onus on the individual to have to understand the nature of the scam they have been faced with in the first instance, in order to know who the right organisation is to go to for advice.

To achieve this, through engagement with the Advisory Group it has become clear that more work is also needed to support relevant advice and enforcement bodies in developing a coherent and shared understanding of each other’s specific: roles, corporate remits, responsibilities, levers of change and resources available to combat scams in Scotland.

Only by clarifying the existing landscape for those who participate in it can we begin to identify new opportunities for further improving the system as a whole, and simplifying the journey for individuals reporting scams and looking for advice and support.

The more that can be done to promote an assets-based approach to streamlining of scams reporting and support provision in Scotland, then the more we might be able to facilitate identification of potential new ways of doing things at an operational level, improving services or providing resource savings.

Under-Reporting of Scams

Not everyone who is faced with a scam will actively look to tell anyone about it, not even their own friends and family.

One significant – and well recognised – reason why people may avoid discussing their experience of having been victimised by scammers is the stigma that can be associated with it. Research shows that people can attribute a sense of shame, embarrassment or self-blame to having engaged with scammers, feelings that are sometimes more prominent amongst older individuals^[25]. As a result, some victims of scams remain silent. They feel unable or unwilling to admit that they did not spot what was happening, as they fear it reflects badly on their own abilities to safeguard against crime, as if in way they failed to apply common sense and reason.

This means that advice and enforcement bodies may not have a full understanding of the extent of the issue in Scotland. It also means that there is a strong likelihood that many people in vulnerable circumstances are at more risk of falling into a downward spiral of victimisation by scammers. Those who have been scammed can be more likely to experience repeat scam attempts. If they do not report in the early stages then they run the risk of being drawn in further by the scammer. Sometimes this goes to the point where they become unable to see a way out, and become not only financially, but emotionally drained over a longer period of time.

Box 4 provides an example of the extreme level of financial detriment that someone can experience as a result of repeat scam attempts, and a failure to talk about things with support networks. The case study also demonstrates the importance of joined up public services for the provision of holistic support to victims of scams.