POL00105190
POL00105190
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:
Investigation related courses
Research, interpretation, preparation, development and publication of investigation procedures
Evaluation of criminal misconduct complaints and subsequent internal investigations
Forensic examination of computers for investigation/prosecution
Safe Systems of Work (SSoW) and near miss evaluation
Tape recording, playback and copying machines
Copying of CCTV tapes for investigation/prosecution
NOW WNP
>» 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.
¢ Focus Group formed (Graham Ward (Lead), Paul Southin, Dave Posnett, Helen Dickinson, Paul
Whitaker)
¢ 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
The following pages detail the outputs.
Index
POL00105190
POL00105190
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)
e 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
4. Requirement for a POL computer forensic team (or access to existing RMUK team?)
2. Migration of existing Investigation / Prosecution forms from RM Sharepoint to POL Sharepoint (and
to include editing RM entries to POL)
3. POL to have a 24 hour standby officer (or continue with inclusion on the existing POL Incident
Management Process)
4, POL to have access to the PNC. Secure link required.
POL00105190
POL00105190
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
Provides continuity for succession planning,
VVVVVY
<7 Liaison Required with
¥ ¥ ¥ ¥
Websites & publications I
Home Office > hip www legislation gov uk/ I
http:/Inomeoffice gov.uk I I> tow lawsociety org uk/
‘National Policing Improvement Agency (NPIA)
> NPIA Digest - http://www. npia police uken/
6288 htm
>
tower I Id (NPIA Trainer):
¥ = I
Qutputs
mn ia > New Criminal & Proceeds of Crime
Police Legislation identified » _ RMUK Casework Recording &
» Post Office Ltd Casework & Crime > — Identification of amendments & updates to Feedback I
Risk Team existing Criminal & Proceeds of Crime > Royal Mail Group Policy
> — Security Operations Team Leaders & Legislation I
Financial Investigators > — Training requirements reviewed
> POL Legal Services > — Refresher Training identified for existing staff
> Bespoke Courses required following
amendments to Legislation
Identification of a full time POL training
manager
> POL continues to be recognised as a leading
professional investigation team.
> Recruitment of staff
> _ POL Training policy
»
New Slaff Recruited — ‘Ongoing ‘in-house’ - ae
Induction Training Required » "Mentoring -
__--- Investigation Training Courses Identified —
< (In-House or External Company)
4 — a
> -
¥ *
I 02 - Administration — Case fle submission,
01 - Investigation Induction Workshop > Prosecution Proce.
¥ :
’
I04 - Proceeds of Crime 2002 ~ Financial Investigations “I 03- Court Process ~ Giving evidence, court etiquette
A L
¥ ¥
05 - Conflict Management / Disengagement
(qcredioton required) > 06 - Interviewing skills advanced
‘ « ‘Ongoing Review of all Training « 07 - CVIT training / Supply training
issues / Requirements (SIA licence received)
POL00105190
POL00105190
L_ Separation Project — P3 — Research. interpretation.
development and publication of investigation procedures
reparatio:
VYVVY
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 I
‘Supports business objectives on recovery of losses
red - RATI
Rob G Wilson
Mobil
> — John M Scott Head Of Security
> Dave Pardoe ~ Security Operations
‘Senior Manager
Royal Mail Group Policy
Royal Mail Group will investigate
crime and suspected crime against
the organisation, identify offenders,
highlight factors that facilitated
crime and take appropriate action -
not excluding prosecution.
(See App 3A)
>
¥ ¥
Outputs 5
Further Inout from; i
Eurther Inout from FOL iesigatar Polbies & Stanaards > _ RMUK Casework Recording &
> Post Office® Ltd Casework &
Crime Risk Team
» Security Operations Team
Leaders & Financial Investigators
> —NPIA Digest - hitp://
www.npia. police uk/en/6288.htm
> Louise McDonald,(NPIA Trainer)
Manager / support
>» Amendments to Legislation noted and
applied to existing procedures / policies
» New procedures / policies created where
appropriate
» Designated SPOC role (Operational)
>» GS forms transferred to POL sharepoint
site and renamed / branded ?
> — Royal Mail Group Policy
Feedback
> — RMUK Investigation Policies &
Procedures — all policies /
procedures can be found on
RMUK Security Sharepoint site
https’//portal royalmailgroup.com!
sites/A177/default.aspx
¥
Reporting Of Crime to POL >, Initiating an Investigation
{see 3A) {see 3A)
¥.
Conducting an Investigation I Prosecution
see 3B) (see 3B) see 3B)
Es Es
Financial investigations
ication of f Crime stati
Supporting Money Laundering Investigations & applying for
Confiscation Proceedings post conviction
POL00105190
POL00105190
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
VVYVY
HMRC /) Grapevine
Al suspicious incidents
4 to be reported via e-mail to ®
post.otice. security
Police PNC » 4} orTet
Grapeuinel
require a
/ ‘contact (business protection team 7)
« Royal Mail Group
‘Anonymous
‘Crimestoppers: bal (Le. whistleblower)
—
Post Office® Ltd Internal
I (e.g. SPOC)
Other +
(eq local councils,
Trading standards, DWP) I Assessment of information undertaken
I by Casework Manager
Case Raised ?
»_ Information recorded for Inteligence
only
Case enquiry categories & timescales
{for progress recor
(eee grd below) & App 3A(1) Case Raise (all in one document)
» Enquiry form sent to
Team Leader via e-mail
‘Triggers’ for raising case met ol
fe
Z i : : 5 ‘ i i
immediate Open Enquiry I Where mmediate response 's spropnate and few pre- I Interview on day of notification (where possible)
interview enquiries are needed or practicable minimum within 48 hours and case submitted to
hortmal report timescales (12 days)
Major Enquiry 3E75,000 (or major Customer/ chent / reputation impact) Case to be at Suspect offender Interviewed within 7
where immediate response is not possible due to the month of raise
requirement to perform pre-interview enquiries / analysis
‘Open Enquiry ‘Where interviews within 2 month are appropriate and few I Able to progress almost mmediately
pre-interview enquiries are needed Case to be at “suspect offender” interviewed stage
within 2 months of raise
‘Standard Enquiry ‘Ail other enquiries not included in the above - where Case to be at Suspect offender interviewed and
immediate response is not possible due to the requirement I submitted / closure stage within 2 months of raise
to perform pre-interview enquiries ‘Should enquiries indicate increased loss or impact,
status must be amended to Major Enquiry immediately
Tiaison ‘Any case where Tawson with another investigative body Case to be updated monthiy via the monthiy
leading enquiries into criminal activity at POL branches spreadsheet process
POL Separation Project — P3B — Research, interpretation, preparation, development
lication of investi
ition pré
edures
POL00105190
POL00105190
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
> Provides a consistent approach towards progression of cases
> — Supports business policy for prosecution of offenders
> — Supports business objectives on recovery of losses
————_£____ ¥ ¥
Partie a > Sasework Reporting &
¥ ¥ ¥ ¥
ineliance Pedant Bata evidence & Forensic Sevites Casework procedures are
already in place within POL.
> — GS208 - equifax, vehicle, e- > — Witness statements Those below need to be POL prosecution
: be uke sce pesca » — Notes books (small supply at managed by POL post procedures are already in
fob 148 Old St) separation place.
Act 1998 principles ee A
is PNG Aucaka recuired > Forensic Science Services
} spoc website - htto/ Case file submission to Liaison with Criminal
a) access to RMUK www forensio.gov.uk/htmi/ Criminal Law Team (will Law Team
‘employee data (Pt 1, Chpt 2 > — RMUK CCTV contact — Mark existing process apply?) I I» NC Access for
of RIPA) NPA Process witness checks
b) acquisition of Comms Data Formal Adult cautions
c) SARS / Elmer intel > Debarment (GS120)
> — Forensic Science Services
website - http!
www forensic.gov.uk/htmiy,
5 POL require a dedicate
Computer Crime Team ?
¥
t GS Forms on RMUK Sharepoint site
(see Appendix 3B(2) for glossary of all
¥ RMUK forms and amended POL forms
I Investioation (only those needed for a ‘tackle kit’ have
Investigation
S been prepared)
I _ Existing process
Stores / Equipment required
a : > ID Passes (Romec)
> — Tape Seals & Tapes (Visual
Investigation dealing with Systems) File jackets, Enclosure
the suspect & searching informants nvelopes & exhibit bage (St ives)
ae (CHIS Policy) > — Gloves (Bunzl)
xisting 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
POL Separation Project — P4 — Evaluation of criminal misconduct complaints and
u nt internal inve: ie}
t mal I 5 I
> — Provides Framework for investigating complaints relating to the conduct of POL Security I
Personnel. I
» — 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.
POL
John M Scott ~ Head Of Security
Dave Pardoe - Security Operations
Senior Manager
vv
»
¥ ¥
- — - ‘Outputs will be dependant on the nature of the
complaint made. The initial assessment may be a
made in conjunction with the Criminal Law Team Royal Mail Group
io or, in the case of complaints made via the Bullying Complaints &
Post Office® Ltd Line ‘® & Harassment procedure, the Regional Case « é nalts tie
Management Manager. ebevien Paley,
(App 4)
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
Manager).
» Investigation into senior
» Management, bribery and
Se, corruption, complex/sensitive
—< I cross BU allegations
<< Griminal Offences/improper Conduct 4 L :
SE Identified a
Yes No.
¥ x 5
Refer to Line Manager to follow discipline process and to consider
Refer 69 FOL Head of Security referral to Grievance & Bullying & Harrasement processes
¥ ¥.
Grievance Process Has the complainant been the victi
hittp:/iplatform intranet pointrmg/Services/ htto:/iplatform intranet pointirmg/Services!
HR+Help/Royal+Mailt HR+Help/Grievance.htm HR+Help/Parcelforce/Process/
Bullying_and_Harassment.htm
POL00105190
POL00105190
POL00105190
POL00105190
POLs ion Project — P5 — F. ; ination of for i sot
VVVYVVY
Supports business policy for Prosecution of offenders
Identify evidence to prosecute crime
‘Substantiate evidence to prosecute crime
‘Support additional charges
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, od’s
Intelligence gathering
~ Liaison Required with >
prosecution
Forensic examination of computers for investigation/prosecution - RATIONALE
¥ ¥ x
External agencies I MUK
Software provided extemally bee
Computer Forensic Team Leader
GRO
{inc training) ~ Financial
Toolkit (FTK) re forensics
External software company
(inc 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.
Internal Agencies I
Internal software company (but
‘other companies out there) National Grime Agency
Pointsec re decryption keys, (currently NPIA, SOCA etc)
monitoring web use, I_I in relation to bigger/wider
Internal software company (but I aime
‘other companies out there) —
CSCre details of TP calls, email
activity, internet history
Forensic support required
Currently via submission of >~€
GS308 to intel
Mobile {
a sn
RMUK Group Policy
Appendix P5(1)
—_¥___,
. Hardware & Software
>» Witness statements requirements fora
> Evidence/exhibit production iconipueartoranele
> Court appearances (live evidence) Team
> Liaison point for computer is: ‘Appendix P5(2)
> — Procedure/standards for handling digital
evidence
> ACPO guidelines re best practice
> Liaison, comms, presentations re
electronic evidence
> — Computer Misuse Act
> — Research (new cases, etc)
POL00105190
POL00105190
POL Separation Project — P6 — Safe Systems of Work (SSoW)
&near miss evaluation
VV
itis 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 re-fresher training requirements
‘Safe Systems of Work (SSoW) and near miss evaluation - RATIONALE
¥ ¥ ¥
UK Health & Safety Executive - 8
> hittp:/Awww.hse.gov.uki Keith X Scott Alean Angus
legislation/hswa.htm
¥
Qutputs
> — Royal Mail Group Policy
» _ RMUK Security SSoW
» POL ‘SSoW’ & ‘Near Miss’ Policy Policy - (imbedded
® Refresher SSoW Training identified for existing staff y
ne : i below) - see - P6 App A
>» Bespoke training courses required following le .
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
¥
x. Risks to Security Staff include
< ~ >» — Out of Office enquiries
A . > Surveillance
SSoW & H&S Training Courses Identified ~ > Court attendance
(In-House or External Company) > Approaches to suspects
~ - > — Offender interviews
a > — Searching persons, premises, vehicles
~ > — Serving summons, cautions, restraint
orders
¥ hd
Conflict Management / Completion of Post Office® Risk
General H&S awareness training Disengagement ‘Assessments
{accreditation required)
(PORA workshop - rationale)
POL00105190
POL00105190
POL Separation Project — P7 & P8
Tape recordi La Cc copyii chines
Tape recording, playback and copying machines - RATIONALE
Supports business policy for Prosecution of offenders.
Professional copying service for field investigators throughout Royal Mail
Security
Assist investigators in producing evidence for court
Service includes audio tape, video tape and DVD recording formats
Identify evidence to prosecute crime
Substantiate evidence to prosecute crime
Support additional charges
Assist recovery process (e.g bank account info, gambling/spread betting I
signs) I
Includes other digital media ~ mobile phones, cameras, pen drives, hard I
drives, sat nav's, cd's
> Intelligence gathering
VY
VVVYVY
v
“ ¥
External Companies to be sourced
RMUK on the Internet RMUK
Andy Brown > eg, Diskiabs Computer Forensics, Dave Brassington
Prosecution Suinnoct Qffioa Team Computer Forensic Service, Kroll
‘Ontrack, QinteQ,
GRO
Mobile
v
¥
PSO use a stand alone laptop,
not connected to the network for Eurther Input from;
copying purposes > Police
Some DVD platforms will not > Post Office® Ltd Casework & Crime
allow copies to be made, or Risk Team
played using anything but the > Security Operations Team Leaders &
software embedded within the Financial investigators
specific DVR system
a
Qutouts
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
Vv
VV
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POL00105190
POL00105190
P9 - Separation Project
A- Police Almanac & POL Listing as Non-Police Prosecuting Agency
Rationale
e Provides a listed point of contact for all security agencies to contact correct POL personnel
«Raises awareness of the POL Security Team throughout the industry
e 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
e Improved use of team resources
° 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
© To enable Post Office Ltd to conduct full financial investigations and recoveries through the powers provided
by the Proceeds of Crime Act 2002 legislation
e POL can continue with it’s robust approach to the recovery of business losses as a result of crime
on required with
e Home Office (see e-mail below from Steve Guilbert dated 15t Aug ***) (Steve Guilbert - Postal Policy -
Department for Business, Innovation and Skills;
Will Gibson, Shareholder Executive
Tel “GRO I
*** As far as is concerned, we did clear the separation with Home Office and the modification Order to account
for the split and the naming of Royal Mail Group Limited and Post Office Limited will be made to allow for the
continued operations of POL.
Outputs
e Enable effective recovery of monies stolen from the business
e Expand the brief of the Financial Investigation Unit to conduct full intelligence enquiries
e Listed separately from RMUK under JARD (Paui Southin dealing with Geoff Hussey NPIA)
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.
11