Scams prevention, awareness and enforcement strategy: 2021 to 2024

Chapter 3: A New Strategic Framework

In order to address scams effectively we must advocate and support the adoption of a new, coordinated and comprehensive approach in Scotland. We know that good work is already underway across partner organisations, from local to nation level. We recognise that we are not starting at the beginning – we must build on good practice, share learning and continue to draw on experience and assets in the landscape, if we are to be successful.

As the previous chapter sets out, we also know that there are perennial challenges to be overcome if we are to truly deliver improved outcomes for people living in Scotland at risk of, or victimised by scammers.

If we are to achieve our vision - to establish Scotland as an inhospitable environment for scammers to operate and exploit people, where people feel safe against the risk posed by scams and can readily access effective support to meet their needs – then we must realise the full potential of the existing enforcement and support landscape.

We talk about the value of taking a “whole person, whole system” approach to tackling scams, but what does this mean?

In practice, this means attending to the multiple needs of the individual who may be at risk or, or has been directly impacted by a scam, by building more joined up services across all stages of scams prevention work. Individuals need to be well-equipped to deal with the risk posed by scams, they must be resilient. And those in vulnerable circumstances must feel listened to and a part of the decision-making process to determine the best preventative measures for their situation. As victims of a crime, those who have experienced a scam must be treated with compassion and respect, and should not feel judged or discriminated by circumstance.

Box 5: Example of a pilot project demonstrating a person-centred approach to scams prevention amongst those living with dementia

The Life Changes Trust awarded £406,590 to three local authorities from 2016 and 2019. East Renfrewshire, Angus and South Ayrshire used the funding to work together to develop, pilot and evaluate a preventative approach to protect people with dementia from financial scams, so that they can better maintain their confidence and ability to continue living independently at home […].

This work involved the development and delivery of a package of preventive measures to offer people with dementia an individualised, person-centred approach to safeguard them from financial exploitation on the doorstep, by telephone, mail or online, including practical solutions and assistive technology, for example call blockers and ‘no cold callers’ badge for their front door. They also produced awareness-raising materials and a training programme for organisations working with people with dementia, developing a good practice model which can be rolled out across Scotland.

In June 2020, the Life Changes Trust published the evaluation report of the Scams Prevention Project; and at the same time, Trading Standards also produced a report 'Blocking Scam and Nuisance Calls for People Living with Dementia'. Both can be found on the website cited below.

*This example has been taken from The Life Changes Trust website

A good example of how such an approach has been piloted at a local level can be seen through the recent success of The Life Changes Trust’s funding to three local authorities, focused on introducing a package of person-centred support to combat scams amongst those living with dementia.

To achieve this over the long term, we have developed a strategic framework that seeks to introduce a more integrated approach across the scams prevention and support landscape – see Figure 5.

Pillar (1): Prevention & Disruption

• Work with partners across private, public and third sectors to attempt to proactively deter, disrupt and, ideally, stop scams from reaching victims, using digital technology, innovation, and improving processes and protocols.

Pillar (2): Education & Awareness Raising

• Focus on enabling people through building resilience, vigilance, knowledge and skills to avoid the risk that scams pose

Pillar (3): Advice, Support & Enforcement

• Work with frontline advice services and enforcement bodies to streamline the scams reporting and advice landscape, including through facilitating better data and intelligence sharing, in order to develop a “whole person, whole system” approach to provision of support and effective intervention.

This framework supports both proactive and reactive activities that seek to reduce the ability of scammers to target and carry out scams; and also reduce the severity of consequences when a scam is successful.

The framework will encourage and facilitate greater capability and capacity building at a national policy level, at a stakeholder operational level, and at an individual level.

By identifying key enablers – to achieve successful prevention, education/awareness raising and enforcement action – and cross-cutting principles, the framework aims to provide shared focus for investments and policy alignment to combat scams across partner organisations.

Implementing the Framework – Partnership Oversight

We will continue to work closely with a range of partners to implement this strategic framework over the long term. In order to achieve this, we will establish a new Scottish Scams Prevention Partnership, (“the Partnership”).

In its early days of operation this group will be treated as a natural evolution of the current Advisory Group, akin to a de facto Strategy Delivery Group. Specific sub-groups will be formed, as appropriate to oversee and support first steps in delivery of key work-streams set out in this strategy – see Table 2.

Membership will be determined through consultation with stakeholders – and relevant Scottish Government policy teams – according to shared interests and delivery objectives.

The Scottish Government will Chair the Partnership in its inaugural year, in line with the group’s initial remit to lead implementation of the new strategic framework in practice. Partners will then be consulted to determine an appropriate model for future chair and secretariat functions to be put in place, and when, with the aim being for the group to take on its own standalone identity within the wider Scottish scams prevention landscape. The Scottish Government will remain supportive and will engage with the Partnership moving forwards.

The following sections outline the steps that we are already, or will take with partners in order to implement the three pillars of the strategic framework – and begin monitoring impact – over the next three years, 2021-24.

Implementing the Framework – Actions

The main strategic areas of activity the Partners will oversee and support, are as follows:

Pillar (1): Prevention & Disruption

Sector-based Prevention Interventions

In close consultation with relevant regulatory bodies, we will establish a set of working-groups with key partners to take forward specific sector reviews, or deep dives to explore and better understand potential opportunities for piloting projects that support improvements in service provision, processes and/or protocols within, for example: banking and finance, and tele-comms. This may be achieved through procuring research, and facilitating the sharing of good practice approaches, greater innovation and use of digital technology, within existing regulatory frameworks.

The purpose will be for partners to consider and assess feasibility of discrete options for change, building on initial insights to date, including for example: removing the three-digit security code on the back of bankcards owned by those in vulnerable circumstances and integrating with “power of attorney” or independent advocacy services so as to promote increased use of two-step verification processes for payment authorisations, as supported by third party networks.

A central tenet of considerations that partners will be encouraged to make as part of this work will include how best technology can be used to reduce the onus on the individual to be able to spot, and react to potential scam attempts within key sectors.

For example, initial discussions have already been had between the current Advisory Group and expert digital tech organisations such as Vistalworks^[27], to understand the principles and potentials of online based digital solutions in the scams prevention space. There are potential options for existing technological interventions used to combat online illicit trade to be adapted to also auto-defend against single-point scams, i.e. those perpetrated via one specific medium, like a false URL, at one point in time against a victim. At present, frontline, public-facing digital anti-scams software that can detect and protect against multi-platform – or long-term evolving – scams is likely to be less feasible.

Significant digital innovation can come with high initial development costs. For this reason, any considerations of this type that identify new pathways for technological solutions will need to be accompanied by work to model the long term financial sustainability of such interventions, and opportunities to share costs and benefits.

We will work with partners across sectors, as appropriate in order to make these determinations as and when required, including considering existing funding innovation programmes, such as CivTech^[28], as potential ways forward.

We anticipate membership to the sector-focused working groups expanding beyond that of the overall Partnership, in order to ensure representation of key stakeholders across specific sectors. We will liaise with key sector representative bodies – such as UK Finance – as well as recognised consumer bodies with a unique focus on particular sectoral issues – for example the Communications Consumer Panel^[29] as part of preliminary work to identify those best placed to input to working group discussions.

Pillar (2): Education & Awareness

Communications

The newly established Scottish Scams Prevention Partnership (“the Partnership”) will be embedded as a standalone, formalised partnership group – with a clear identity and position within the wider stakeholder landscape – to act as a collective voice when it comes to communicating both key preventative messages on scams to members of the public; and advocating for further change in policy or operational approaches as they relate to all three pillars of the strategic framework.

By seeking to create a shared identity across frontline advice service providers, enforcement agencies, wider regulators and industry representatives, we aim to foster more formal and productive means of collaboration and coordination between stakeholders. In turn, this should translate into more impactful, coherent and harmonised communications to members of the public, regarding new and emerging scams and scam tactics identified through shared data and intelligence.

In addition, and as set out earlier in this strategy, “scams” are a criminal activity and do not represent a solely consumer-based issue. There are specific nuances and enforcement based considerations relating to scams that are discrete, and separate from purely consumer based detriment. In this sense, we do not feel it appropriate to expect the responsibility for coordination of the wider scams prevention stakeholder and intelligence landscape in Scotland to inevitably fall to the upcoming national strategic consumer advocacy body, Consumer Scotland^[30].

This is not to say that there may not be a role for the new Scottish Scams Prevention Partnership to help to inform and support shared ambitions with Consumer Scotland, as and when appropriate. But the extent to which Consumer Scotland chooses to engage with this agenda will be one for its independent Board to decide when setting its inaugural work-plan priorities in due course.

The Partnership will agree a set of key voluntary principles of collaboration to combat scams in Scotland to help engender real ownership and shared action around the work of the group.

This may include establishing a recognisable brand and an online presence – or “hub” – for the Partnership, where key research, insights reports, commentary, media messages and wider intelligence sharing can be posted collaboratively for wider dissemination. We will discuss with partners who may be best placed within the existing landscape to take on hosting and maintenance of this platform, if such an approach is adopted. The advantage of this model is that it would then allow the Partnership to also participate – and engage – on an equal footing with corresponding groups operating in related fields, such as the newly created Cyber Scotland Partnership. By drawing on the collective authority, legitimacy and expertise of its members, the Scottish Scams Prevention Partnership will be able to seek representation at wider UK – or even international – fraud prevention groups, ensuring that Scotland is plugged in to key intelligence and operational initiatives.

We envision the Partnership meeting on a regular basis throughout the year – likely quarterly – as a way of extending, and maintaining the momentum and dialogue that the current Advisory Group has facilitated between organisations. The discussion space that such a platform can provide to partners to be able to continue to share good practice approaches, learn from one another’s experiences, and work to take forwards new joint initiatives, is invaluable.

It will be for members to decide, but the Partnership may choose to operate a rotating Chair model, allowing the opportunity for different strategic partners from across sectors to help shape and steer the collective voice of the group over time.

As part of its function, the Partnership will lead on development of a shared Anti-Scams Strategic Communications Plan, and accompanying calendar of events, in order to support a more coordinated approach to campaign work delivered by a range of partners across the year. This work will be supported by the Scottish Government as appropriate.

As has already been highlighted, there is currently an absence of consistent year-round coordination of cross-organisational communications in Scotland relating to scams prevention and awareness raising. It is also unclear to what extent there is consistency in messaging on key scam topics between all relevant Scottish based organisations and UK wide organisations, such as National Trading Standards. As has been touched on earlier in this strategy, scams are not limited by geography – many transcend regional, national and even international boundaries. Both the Scottish Government and other partners have already, or are actively looking to take steps to engage broader stakeholder groups for this reason, such as Project Etherin^[31] led by the National Economic Crime Centre – and the UK Multi-Agency Communication Group – managed by the City of London Police – in order to best understand how such initiatives can further help to inform Scottish scams prevention messaging.

In taking forward development of a new co-owned Anti-Scams Strategic Communications Plan, we will further support partners to consider and agree how best they can work together strategically to introduce a greater degree of consistency to scams awareness messaging and campaign activities in Scotland, where appropriate.

Different partners will have different levels of reach to particular groups of individuals; they will also have different levels or types of expertise concerning scam tactics that can be lent to certain communications.

A first step in achieving this may include conducting a review of existing scams campaign work in Scotland, over the last three to five years. The focus of this review could be to identify any key gaps in either:

• Coverage of content included in mainstream (annual) anti-scams or awareness raising campaigns; and / or the different groups of people in vulnerable circumstances whose needs are consistently being met, or not through existing national campaign projects. This can include – but is not exclusive to – the elderly, young people, those who are socially isolated, those who are not digitally literate, and those with underlying mental health conditions.
• The key resources available across the Partnership, and the development of a set of underpinning communication principles – akin to a strategic messaging protocol – relating to certain scam types, or tactics that can then be rolled out coherently, according to context.

An accompanying shared calendar of events will allow partners to align campaigns in-year to avoid any risk of potential duplication, or cluttering of the media space, so as to ensure integrity of key messages and information for the target audience. It will also support partners in developing shared narratives, or themes throughout the year, in recognition that scams are a year-round challenge, not a one-off issue at any one point in time.

There are existing communication toolkits that partners can draw on to help inform this work. For example, in 2018 Citizens Advice produced a Scams Communication Toolkit – via a third party consultant – that was based on both a review of behaviour science literature, and qualitative findings from public engagement across London, Leeds and Cardiff^[32].

The real test will be putting any new Anti-Scams Strategic Communications Plan – and shared calendar of events – into practice. Initial discussions have been had between partners – including Advice Direct Scotland, Which? and Trading Standards Scotland – to consider options for delivery of a wider joint campaign programme later in 21/22 focused on providing tangible support to people, such as call blocker installations and scams awareness material.

Campaign activities could include road shows, online events, parliamentary work, and media releases. Timing of this campaign is subject to the easing of lockdown restrictions in order to ensure high impact through face-to-face and community based engagement. Wider partners have indicated their general willingness to further support such a campaign when the time is right.

As a lead-in to this type of partnership led campaign focused on providing real-world practical offers of support and intervention to people on the ground, Trading Standards Scotland recently launched access to over 700 call blocker units across Scotland, supported in part by £60,000 of Scottish Government grant funding. These will now be available throughout 21/22 for dissemination to those in need.

Strategic Education Action Plan

Through consultation with the new Partnership, we will develop a set of specific actions to address any gaps in existing education materials and approaches available to people across different settings (from schools to work to communities) and risk groups, to build resilience against scams and their impacts.

An initial desk based review of capacity building activities already underway in related areas, such as cyber resilience, will be undertaken to support these considerations; and case studies of good practice approaches will be developed to be shared across education providers.

Through engagement with the Partnership, we will also explore ways to embed within education providers the principles and skills required for individuals to effectively assess the level of risk associated with potential scams, and appropriate responses.

Our focus will be on capacity and capability development, enabling but also empowering people to be able to take more control over a situation and be confident in pursuing online – and offline – activities because they are aware of the risks and are able to manage them.

We recognise the need to find an appropriate balance in approach between making people sensitive to the issues, and ensuring that those in vulnerable circumstances do not become over-sensitised to the extent that they become overly concerned about the risks, potentially causing distress and withdrawal from positive engagements.

Pillar (3): Enforcement

Streamlining the reporting and advice landscape for scams

Conduct an options appraisal to better align the work of enforcement and advice bodies, including: considering the value of introducing consistent protocols for the handling of reports for scams by a wider range of third sector organisations to ensure effective enforcement action is taken; and exploring the operational feasibility of developing a ‘single point of contact’ or ‘one stop model’.

A Streamlining the Landscape Steering Group – led by enforcement bodies – will be established to review outputs of current on-going work being funded by the Scottish Government to:

1) Map the existing scams prevention landscape.

Work has been procured to carry out a review of the existing scams prevention landscape in Scotland, focused on mapping key enforcement, advice and support organisations in terms of their roles and responsibilities and current partnership working. A key output of this work will be citizen flow charts, or user journeys that will demonstrate how people currently access the landscape through different channels and what feedback, if any, they receive after reporting a scam and to who. The work will also culminate in a stakeholder toolkit – including a visual representation of existing channels of communication and engagement between key stakeholders in the scams prevention landscape (see Figure 6) – focused on helping clarify how different organisations’ remits, resources and current package of scams prevention work complement one another. This work is due to complete end of March 2021.

2) Research what a single point of contact or one stop shop for scams might offer for both users and practitioners, especially enforcement bodies.

Advice Direct Scotland has been awarded a Scottish Government grant to support preliminary work focused on exploring the practical dimensions of development of a ‘single point of contact / one stop shop’ model to help inform on-going discussions with partners; and to review their existing advice coding models in order to identify how they might best align these with enforcement bodies such as Police Scotland and Trading Standards Scotland for purposes of categorising scam incidents and sharing relevant data for action to be taken.

Based on this starting material and the outputs of public engagement work set out further as below, the Steering Group will identify and assess options for improving the landscape overall that align with user needs before making a decision on next steps. All options are considered within scope, but it will be for the Steering Group to develop a work-plan of activities over the coming months that will enable them to then make a decision on the most appropriate strategic course of action.

As part of improving the immediate frontline offer of support available to people, Trading Standards Scotland (TSS) are now working with East Renfrewshire Trading Standards to consider how best to nationalise a new Financial Harms Toolkit developed by the latter. This is a good example of the important role that local trading standards departments continue to play in not only taking effective, evidence-led enforcement action, but also innovating support packages in response to the needs of their local communities.

Moving forwards, we will continue to engage key representative organisations, such as the Society of Chief Officers of Trading Standards in Scotland (SCOTSS), in order to understand potential implications on local capacity of any changes agreed to by partners to streamline the wider scams prevention landscape.

Figure 6: A draft indicative representation of the existing, complex scams prevention stakeholder landscape covering examples of the main organisations involved at both a Scottish and UK level, from enforcement to frontline advice providers. Channels of
engagement represented have been informed by desk based research – including online webpage signposting between organisations – and interviews with relevant partners regarding the nature of their work, and relationships with other supporting agencies,
bodies and wider organisations. This "map" is not exhaustive, and does not represent the final outputs of the commissioned research currently underway – it is provided for purposes of illustration only at this time.

• Please note that this diagram is currently available to view in the PDF version of this strategy. An updated version of this diagram will be uploaded shortly.

This will ensure that people living across Scotland have access to standardised information and advice concerning the financial impact of fraud, including signposting to tailored local support services according to where they live.

Cross-Cutting

Public engagement programme

A programme of engagement will be developed to increase the impact and effectiveness of strategic interventions across the full user journey of education, awareness raising, and accessing advice and support.

The purpose of this engagement work will be twofold:

1) To better understand people’s needs and barriers when attempting to report scams and access the right support, at the right time; and

2) To identify key knowledge gaps related to scams, including how best to avoid the risk that they pose and what an individual’s consumer and citizen rights are if they become a victim; and to tackle the stigma currently associated with scams and the shame or embarrassment felt by those who become victims of this criminal activity.

As part of this work-stream, we will also explore with partners the potential value of taking forward social research to more fully assess key factors that can lead to someone being more susceptible to being scammed, based on personal circumstances. This work could offer a means for further enabling frontline advice services – and enforcement bodies – to create more holistic packages of support, and communications, based on joined up service provision and reflecting a person-centred approach to scams prevention.

Strategic positioning of scams as tied to a Community Safety and Public Health narrative

Linked to development of a partnership Strategic Communications Plan and wider Strategic Education Action Plan, we will promote key messages that emphasise the broader criminal nature of scams and their impacts in order to develop and embed a stronger – and shared – mind-set amongst a wider range of stakeholders and the general public that scams prevention work is intrinsically about questions of security, safety, health and wellbeing.

To complement the Partnership, we will seek to establish an internal Scottish Government Scams Prevention Policy Reference group, to support on-going awareness raising of how different policies can contribute to reducing the risk of being scammed or the level of detriment experienced by those who are victimised. We will draw on the community safety and public health narrative in order to effectively communicate added value of certain interventions to wider policy outcomes; and vice versa as related to key scams prevention activities; as part of building a more integrated strategic policy approach. We will use this platform to spot new opportunities for cross-policy development and collaboration, including through conducting an internal mapping exercise of existing policies and programmes that contribute to shared outcomes.

Through this group we will engage with cyber resilience, organised crime, safer communities and adult support and protection colleagues, amongst others.

We will use the language and shared outcomes of scams as being tied to community safety and public health narrative as a way of also bridging the gap with other potential stakeholders, so as to most effectively draw on a wider range of advice, support, and enforcement services. In this way we will further promote a “whole person, whole system” approach to tackling scams and their impacts in Scotland.

Building Resilience Against Scams

Figure 8 provides an overview of what we mean when we talk about “personal resilience” in this context, and sets out the contribution of each step we are taking along the way – under the new strategic framework – to build, strengthen and embed this for people across Scotland.

Wider Policy Landscape

This strategy both supports and is supported by many other government policies and programmes in Scotland – see Table 3 for some examples.

Monitoring, Reporting & Future Delivery

18-24 Months

We will support the new Scottish Scams Prevention Partnership to develop an appropriate approach to monitoring impact over time against the actions set out in this strategy. This is likely to include surveys and focus groups, campaign evaluation reports, evaluation of frontline advice statistics on number of scams reported; as well as wider Scottish Government official statistics, such as the Social Justice & Crime Survey.

We will aim to provide an initial progress update in light of the forthcoming development work and key considerations of the Partnership at an appropriate time within 18-24 months of publication. This will be used as an opportunity to further clarify, or confirm any further necessary actions agreed by the group or its constituent sub-working groups, to be taken forward in terms of next steps in implementation of the strategic scams prevention framework in practice.

We will also use this point to determine what appropriate future governance arrangements should look like for overseeing on-going delivery of key strategic actions; and/or any appropriate next phase(s) of delivery in implementation and embedding of the strategic framework established under this strategy; up to the three year mark set out for this strategy.

36 Months

Reflecting co-ownership of development and delivery of this strategy, the new Scottish Scams Prevention Partnership will oversee a review of overall progressof strategic actions – and outcomes – by 2024 . The Scottish Government will work closely with the Partnership – providing secretariat functions – to support this. The final outputs of this evaluation will be presented to Scottish Ministers for consideration.

This review will be achieved using the agreed approach to monitoring and assessing impact that will be developed during the first 18-24 months of delivery, as above. It will include assessing the value added and impact of the soon to-be-developed: Scottish Scams Prevention Partnership; shared Strategic Communications Plan, and associated calendar of events; the Scams Prevention Education Action Plan; partnership led sectoral reviews and identification of pilot intervention pilot projects, within the existing regulatory framework; and any agreed operational changes to streamline the reporting and advice landscape.

Beyond the lifespan of this strategy, it is anticipated that the Partnership will continue to conduct longer term monitoring of scams intelligence and outcomes of scams prevention, awareness and enforcement actions in Scotland, reporting on relevant trends and impacts to appropriate bodies to inform policy and operational responses. This work will be supported by both the monitoring and reporting framework to be developed, and appropriate secretariat arrangements.

Following its establishment later in 2021, discussions will also be had with Consumer Scotland to consider what role it may play in this space moving forwards. For example, it may be determined that the Partnership could provide a bespoke annual impact, data and intelligence report on consumer-specific scams and scams prevention work to the new advocacy body to inform its work on assessing wider consumer detriment priorities in Scotland.