POL00104900
POL00104900
Separation Project - Criminal Investigations
Policy for Post Office® Ltd
Project Objective
To develop & record a process map for the role of
criminal investigations policy within POL post
separation.
> Process maps that have now been prepared are as follows:
1. Investigation related courses
2. Research, interpretation, preparation, development and publication
of investigation procedures
3. Evaluation of criminal misconduct complaints and subsequent
internal investigations
4, Forensic examination of computers for investigation/prosecution
5. Safe Systems of Work (SSoW) and near miss evaluation
6. Tape recording, playback and copying machines
7. Copying of CCTV tapes for investigation/prosecution
>» The 2 areas below have been amalgamated onto a summary bullet point
sheet;
1. Almanac - Annual entry in Police & Constabulary Almanac will need
amending
2. Proceeds of Crime Act - Need to ensure that both RMG and POL are
scheduled under POCA.
>» The following area is under review within Section 5 of the Mails
Distribution Agreement (‘Investigations relating to POL Personnel’) ;
1. Operational Primacy - An MOU will need to be developed on
operational primacy in given situations, e.g. POL counter staff
stealing RM special deliveries.
Those process maps prepared include a description of the task, the
benefits to the business, (i.e. financial, legal, compliance. H&S or
otherwise). The process maps also include inputs (i.e. where does the
info come from, who do we need to liaise with, what forums do we attend,
what organisations must we join) and outputs, (what do we do with the
info, who do we send it to, how do they use it etc).
Project Phases
e Program plan prepared.
e Focus Group formed (Graham Ward (Lead), Paul Southin, Dave Posnett,
Helen Dickinson, Paul Whitaker
e Initial meeting with RMUK Investigation Team to identify RMUK,
contacts, Policies and Baton Passing requirements post separation.
¢ Format for Process maps agreed with POL stakeholders
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The following pages detail the outputs.
Index
Page 3 - Investigation Related Training Courses
Page 4-6 inclusive - Investigation Procedures (Appendix 3A - Royal Mail
Group Investigation Policy)
e P3A - Reporting of Crime / Case Raised - (Appendix 3A(1) - POL
Triggers & Timescales)
* P3B - Progression & Reporting of Investigations / Prosecutions
(Appendix 3B(1) - CHIS) - Appendix 3B(2) Glossary of POL forms.
Page 7 - Criminal Misconduct & Internal Complaints - (Appendix 4 RMUK
Policy)
Page 8 —- Forensic Examination of Computers (Appendix 5(1) - RMUK Policy
/ Appendix 5(2) - Hardware & Software requirements for a Computer Team)
Page 9 - Safe Systems of Work & Near Miss Evaluation (Appendix 6 - RMUK
SSoW Policy)
Page 10 - Tape recording, playback, CCTV and copying machines
Page 11 - Police Almanac & POL scheduled under POCA 2002
Important Areas to be addressed prior to Separation
1. Requirement for a POL
RMUK team?)
team (or access
sisting Investigation / Pr
from RM
entries to
2. Migration of uation
repoint to
POL)
L Sharepoint (and to inc
4 hour standby off inclusion
POL Incident Manag
4. POL to have access to th PNC. Secure link required.
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POL Separation Project — P2 — Investigation Related Training Courses
Investigation Training Courses Required - RATIONALE
> Supports business policy for Prosecution of Offenders / Recovery of Losses.
> Legal requirement to have PACE trained investigators as POL is a non-police prosecuting authority.
> Provides Framework for maintaining & developing consistent Professional Standards of Investigation Personnel.
[> Providing ongoing training for the professional development of individuals,
> Supports business requirement in complying with industry standards & H&S legislation
I» — Provides continuity for succession planning.
¥ ¥ ¥ ¥
Websites & publications 0
fa Git > ipimirlegsetongovaa I > NBA Dest iprpa.plee ue!
hitp/homeoffice. gov.uk/ I I> _ http:diwww.lawsociety org.uk! MeDonald (NPIA Trainer)
home law :
¥. ¥.
I Outputs:
¢ Further > New Criminal & Proceeds of Cnme
> Police I Legislation identified > RMUK Casework Recording &
> Post Office® Ltd Casework & Crime —_\dentification of amendments & updates to Feedback
Risk Team I existing Criminal & Proceeds of Crime > Royal Mail Group Policy
> Security Operations Team Leaders & Legislation
Financial Investigators I > Training requirements reviewed
> POL Legal Services >.> Refresher Training identified for existing staf a ~ ~
+ Bespoke Courses required following
amendments to Legislation
> Identification of a fulltime POL training
manager
> POL continues to be recognised as a leading
professional investigation team,
> — Recruitment of staff
> POL Training policy
x. »
New Staff Recruited — » Ongoing ‘in-house’ - _
eee olning Revie Mearns “Investigation Training Courses Identifie
(n-House or External Company)
i ; oo .
>
¥
02 - Administration — Case file submission,
01 - Investigation Induction Workshop » Tiga Eee:
Y ¥
04 - Proceeds of Crime 2002 — Financial Investigations “ 03 - Court Process — Giving evidence, court etiquette
4 L
¥ ’
05 - Conflict Management / Disengagement
(ecoeaiatin rected: > 06 - Interviewing skills advanced
- ¥ a
{ “ I Ongoing Review of all Training « 07 - CVIT training / Supply training
Issues / Requirements (SIA licence received)
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POL Separation Project — P3 — Research, interpretation, preparation,
development and publication of investigation procedures
I Investigation Procedures Required - RATIONALE
VVVVY.
Protecting the integrity / brand / reputation of the business
Provides a framework to ensure adherence is maintained with Legal requirements
Provides a consistent approach towards progression of cases
‘Supports business policy for prosecution of offenders
‘Supports business objectives on recovery of losses
¥
Post Office® Legal Services
POL
crime and suspected crime against
the organisation, identify offenders,
crime and take appropriate action -
Royal Mail Group Policy
Royal Mail Group will investigate
highlight factors that facilitated
not excluding prosecution.
(See App 34)
> John M Scott — Head Of Security
Repo Lec nal Law > Dave Pardoe — Security Operations
Senior Manager
Ad ¥
Outputs
Eurther Input from: : Pua
S poe ee > POL Investigation Policies & Standards BOL Ge rework Recomipa &
Crime Risk Team Netege eee Royal Mail Group Pol
> Security Operations Team = tenders aoe en es a 3 RMUK lnvestigaion Polcies &
oedars & Frnancal Investigators syplien io elnetity poodles! polis Poo policies /
> NPIA Digest - http:/ = hee rele eee procedures can be found on
a > GS forms transferred to POL sharepoint Goapeoee
site and renamed / branded ?
¥
Reporting Of Crime to POL
Initiating an Investigation
(see 3A) (see 3A)
x
I Pr jon
see 3B) I see 3B) {see 3B)
t - *
Financial Investigations
it
Application of Proceeds of Crime Act 2002 Leaisiation
‘Supporting Money Laundering Investigations & applying for
Confiscation Proceedings post convietion
POL Separation Project — P3A — Research, interpretation, preparation, development
and publication of investigation procedures
= Reporti Crimel =
Protecting the integrity / brand / reputation of the business
Provides a consistent approach towards progression of cases
‘Supports business policy for prosecution of offenders.
‘Supports business objectives on recovery of losses
Provides an Intelligence Database of historical information
2
HMRC Grapevine
Ac
Al suspicious incidents /
4 to be reported; we
Police PNC > : « Royal Mail Group
¥ A O*
/ contact (business protection team 2) * aareeuaneeama
Anonymous
ieleriaad “ (e. whistleblower)
Post Office Ltd Internal
Other ¥. (eg. SPOC)
(e.g. local councils,
Trading standards, DWP)
Triggers’ for raising case met
‘Assessment of information undertaken
by Casework Manager
Case Raised ?
Case enquiry categories & timescales
for progress recorded
(ee grid below) & App 3A(1)
»_ Information recorded for Inteligence
only
Case Raise (all in one document)
>I Enquiry form sent to
Team Leader via e-mail
Immediate Open Enquiry
‘Where immediate response is appropriate and few pre-
interview enquiries are needed or practicable
Interview on day of notification (where possible)
‘minimum within 48 hours and case submitted to
normal report timescales (12 days)
Major Enquiry
£75000 (or major customer / Client reputation impact)
where immediate response is not possible due to the
requirement to perform pre-interview enquiries / analysis
Case 10 be at “suspect offender interviewed within 7
month of raise
‘Where interviews within 2 month are appropriate and few
pre-interview enquiries are needed
‘Abie to progress almost immediately
Case to be at “suspect offender” interviewed stage
within 2 months of raise
Standard Enquiry
‘Allother enquiries not included in the above - where
immediate response is not possible due to the requirement
to perform pre-interview enquiries
Case fo be at “suspect offender interviewed and
submitted / closure stage within 2 months of raise
Should enquiries indicate increased loss or impact,
status must be amended to Major Enquiry immediately
Tiaison
‘Any case where liaison with another investigative body
leading enquiries into criminal activity at POL branches
Case to be updated monthiy via the monthiy
spreadsheet process
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and publication of investigation procedures
3B — Progression & Reporting of investigation & Prosecution cases — RATIONALE __
» Protecting the integrity / brand / reputation of the business
» — Provides a framework to ensure adherence with legal requirements is achieved & maintained I
> Provides a consistent approach towards progression of cases I
> — Supports business policy for prosecution of offenders
> — Supports business objectives on recovery of losses I
¥. ¥ x
Conducting an Investigation I > tanta eae S I >I Prosecution
¥ ¥ ia ¥
Investigation Gathering Investigation Recording
Intelligence & Evidential Data ‘Casework procedures are
already in place within POL.
> GS208 - equifax, vehicle, e- > Witness statements Those below need to be POL prosecution
> PY sence to Date Protection > Notes books (small supply at managed by POL post procedures are already in
fo0 148 Old St) separation place,
Act 1998 principles :
> I PNC Access required > Forensic Science Services
5 spoc website - htto:/! % — Case file submission to > Liaison with Criminal
a) access to RMUK www forensic.gov.uk/html/ I Criminal Law Team (will Law Team
employee data (Pt 1, Chpt 2 > RMUK CCTV contact — Mark existing process apply?) I > NC Access for
of RIPA) Blackwell - mobile » NPA Process witness checks
b) acquisition of Comms Data [ E » — Formal Adult cautions
¢) SARS / Elmer intel » "RMUKTomputer contact — > — Debarment (GS120)
» — Forensic Science Services
website - http://
foren: ik/ntmily t ~
Does POL require a dedicated
Computer Grime Team ?
¥
‘I GS Forms on RMUK Sharepoint site
(see Appendix 3B(2) for glossary of all
x ¥. RMUK forms and amended POL forms
poo SSeover. vsttatedy I 5 (only those needed for a ‘tackle kit’ have
POCA 2002 / other (i.e from Investigation — been prepared
“pension) Surveillance & Testing ae)
Existing Process
Gantact Paul Southin: I Existing process
GRO}
wo > ID Passes (Romec)
a a > Tape Seals & Tapes (Visual
Investigation dealing with Systems) File jackets, Enclosure
the suspect & searching Informants envelopes & exhibit bags (St ves)
a (Cris Foley) > — Gloves (Bunz!)
catiog process ‘See App 3B(1) » Tape Machines, Tape playback &
copiers
> Stab vests
¥ > Notes books (small supply at 148 Old
St)
Records of Interviews
Existing process
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POL Separation Project — P4 — Evaluation of criminal misconduct complaints and
subsequent internal investigations
> _ Provides Framework for Investigating complaints relating to the conduct of POL Security
Personnel.
> _ Ensures POL maintains its professional reputation and is perceived as having staff who are well
trained, professional in their approach and who work with integrity and show respect for others. I
Consider Further input from;
> Police
> Post Office® Ltd Line
Management
Refer to POL Head of Security
POL
» — John M Scott — Head Of Security
> Dave Pardoe - Security Operations
Senior Manager
¥
‘Outputs will be dependant on the nature of the
complaint made, The initial assessment may be
made in conjunction with the Criminal Law Team
or, in the case of complaints made via the Bullying
& Harassment procedure, the Regional Case
‘Manager.
All complaints relating to a breach of PACE, RIPA
powers, CP&I Act and their associated codes and
‘guidelines and/or the unauthorised disclosure of
sensitive information should be logged and
monitored by a Complaint Manager (Line
Standards
Ray Pratt — Mobile I
Royal Mail Group I
Complaints &
Standards of
Behaviour Policy
(App 4)
Manager).
»
- _- ~
Criminal Offences/Improper Conduct
i os
e identified
Yes No.
¥
Refer to Line Manager to follow discipline process and to consider
referral to Grievance & Bullying & Harrasement processes
Investigation into senior
management, bribery and
corruption, complex/sensitive
I cross BU allegations
¥
Grievance Process
http /fiplatform .intranet.pointrmg/Services!
HR+Help/Royal+Mail+HR+Help/Grievance.htm
Bullying & Harassment Helpline
Has the complainant been the victim ?
http://iplattorm.ntranet.poinvrmag/Services!
HR'+Help/Parcelforce/Process!
Bullying_and_Harassment.htm
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POL Separation Project — P5 — Forensic examination of computers for investigation/
Supports business policy for Prosecution of offenders
Identify evidence te prosecute crime
Substantiate evidence to prosecute crime
Assist recovery process (e.g bank account info, gambling/spread betting signs)
Includes other digital media - mobile phones, cameras, pen drives, hard drives, sat nav's, cd's
>
> — Support additional charges
>
Intelligence gathering
¥
Liaison Reauired with >>
prosecution
Forensic examination of computers for investigation/prosecution - RATIONALE
¥
¥
v
External agencies
‘Software provided externally
(ine training) ~ Financial
Toolkit (FTK) re forensics
External software company
(ine training) - Aceso re
mobile telephones
External company — Internet
Watch Foundation re
paedophilia (usually handed
‘over to police)
External companies that offer
‘similar service (but probably
far more expensive); FSS (at
the moment), Disklabs
Computer Forensics,
‘Computer Forensic Service,
Kroll Ontrack, QinteQ.
> Witness statements
>
<
>
>
evidence
iv
Internal Agencies
Internal software company (but
‘other companies out there) —
Pointsec re decryption keys,
monitoring web use,
Internal software company (but
‘other companies out there) —
CSCre details of TP calls, email
activity, internet history
National Grime
(aurrently NPIA, SOCA, etc)
in relation to bigger/ wider
crime
_Porensic support required
Evidence/exhibit production
Court appearances (live evidence)
Liaison point for computer issues
Procedure/standards for handling digital
ACPO guidelines re best practice
> Liaison, comms, presentations re
electronic evidence
> — Computer Misuse Act
> — Research (new cases, etc)
Currently via submission of
GS308 to intel
Team
Appendix P5(2)
RMUK
Dave Brassington
Computer Forensic Team Leader
Mobile!
¥
RMUK Group Policy
Appendix P5(1)
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POL Separation Project — P6 — Safe Systems of Work (SSoW)
& near Ss evaluation
‘Safe Systems of Work (SSoW) and near miss evaluation — RATIONALE
> tis a Legal requirement under the H&S at Work Act 1974
» — Supports business Investigation procedures policy (SSOW)
> Identifies risks to Security staff (i.e. when approaching suspects, searching
premises, interviews, serving summonsicaution, attending court)
> Identifies risks to suspects / other POL staff involved in enquiries
> Identifies protective equipment required
> — Identifies training requirements
> _ Identifies refresher training requirements
Liaison Required with >
— ¥ — &. ¥.
Ok uecie s see RMUK Head of Safety (CSR) RMUK Security H&S
PorrheaT nTpeET Ia PINT hee Gov Keith X Scott Alison Angus
Mobile: ic
legislation/hswahtm
¥ ¥
Cutouts > — Royal Mail Group Policy
> POL ‘SSoW’ & ‘Near Miss’ Policy > oC pasion
> Refresher SSoW Training identified for existing staff os ul Pease
> Bespoke training courses required following le il il alert es
amendments to H&S legislation
> Identification of amendments & updates required for
POL SSoW policy
> Identification of changes in the H&S at Work Act
1974
e
oN Risks to Seourity Staff include
L ~~ > Outof Office enauiries
at ~~ > Suneillance
“SSoW & HES Training Courses Identified,» Court attendance
(In-House or External Company) y > Approaches to suspects
Le - > — Offender interviews
: L > — Searching persons, premises, vehicles
~ ~ » — Serving summons, cautions, restraint
orders
¥ *
Conflict Management / Completion of Post Office® Risk
General H&S awareness training Disengagement ‘Assessments
(accreditation required) (PORA workshop - rationale)
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POL Separation Project — P7 & P8
Tape recording, playback, CCTV and copying machines
Tape recording, playback and copying machines - RATIONALE I
Supports business policy for Prosecution of offenders
Professional copying service for field investigators throughout Royal Mail I
Security I
Assist investigators in producing evidence for court I
Service includes audio tape, video tape and DVD recording formats
Identify evidence to prosecute crime
Substantiate evidence to prosecute crime I
‘Support additional charges
Assist recovery process (e.g bank account info, gambling/spread betting I
signs)
Includes other digital media — mobile phones, cameras, pen drives, hard I
drives, sat nav's, cd's I
> Intelligence gathering I
VY
VVVVVY
v
<< Liaison Required with >>
¥ ¥
External Companies to be sourced
RMUK ‘on the internet
Andy C Brown > eg. Disklabs Computer Forensics,
Computer Forensic Service, Kroll
‘Ontrack, QinteQ.
¥
¥
PSO use a stand alone laptop,
not connected to the network for
copying purposes
Some DVD platforms will not
allow copies to be made, or
played using anything but the
‘software embedded within the
specific DVR system
Further Input from;
> Police
> Post Office® Ltd Casework & Crime
Risk Team
> — Security Operations Team Leaders &
Financial Investigators
z
> — Witness statements
> Continuity of evidence for exhibits
sent for copying
> Court appearances (if required)
>» Copies of audio, video and DVD
exhibits
> — Edited highlights produced from
original exhibits
> _ Image stills produced from original
exhibits
> Copies produced in different formats
to the original exhibits. i.e. DVD
copies from original video exhibits ete
etc
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P9 - Separation Project
A_- Police Almanac & POL Listing as Non-Police Prosecuting Agency
Rationale
¢ Provides a listed poi
correct POL personnel
nt of contact for all security agencies to contact
* Raises awareness of the POL Security Team throughout the industry
* Builds and develops relationships with external agencies
Liaison required with
¢ Thomson Reuters (Producers of the Almanac) - Paul Southin already dealing
via Chris Webb at Reuters
Outputs
° External enquiries directed to correct personnel
* Improved use of team resources
e More effective communication
Other potentially useful info
° The Police Almanac is supplied to all Police forces and other security
agencies within the UK and is updated to reflect changes in each new issue
B - Post Office Ltd scheduled independently under POCA
Rationale
e To enable Post Office Ltd to conduct full financial investigations and
recoveries through the powers provided by the Proceeds of © Act 2002
legislation
e POL can continue with it’s robust approach to the recovery of business
losses as a result of crime
Liaison required with
e Home 0. e (see e-mail below from Steve Guilbert dated 1°* Aug ***)
(Steve Guilb Postal Policy - Department fo: i vation and
Skills, Tel and (William.Gibsor_ To wall
Gibso: Executive
*** As fax as POCA is concerned, we did clear the separation with Home 0
and the modification Ord
Group Limited and Post
operations of POL.
ce
to account for the split and the naming of Royal Mail
ce Limited will be made to allow for the continued
Outputs
¢ Enable effective recovery of monies stolen from the business
* Expand the brief the Financial Investigation Unit to conduct full
intelligence enquiries
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¢ Listed separately from RMUK under JARD (Pau
Hussey NPIA}
Southin ng with Geoff
Other potentially useful info
¢ The separation from Royal Mail Group in relation to POCA has been agreed
by the Home Office and a new statutory instrument listed POL as a separate
entity will be issued in the autumn.