ANNUAL BUSINESS PLAN 2015 2016
Foreword I am pleased to present the National Trading Standards Business Plan for 2015/16 The National Trading Standards Board ( the Board ) is formed from a group of senior and experienced local government heads of trading standards, representing all trading standards services across England and Wales. Its purpose is to provide leadership, influence, support and resources to help combat consumer detriment, locally, regionally and nationally. National Trading Standards (NTS) has been in operation since 2012 undertaking a range of regional and national consumer protection functions funded by the Department of Business Innovation and Skills. In 2014-15, NTS took on the delivery of a 3 million funding programme, funded by the Food Standards Agency (FSA), to commission Trading Standards services to deliver a programme of feed inspection, sampling and related projects in order to address EU concerns and improve the integrity of feed hygiene enforcement and the safety of the food chain. This year we are in discussion with the FSA to see if they wish to commission some previously directly funded food standards work. I believe we have made excellent progress and I am very pleased with the continuing confidence that has been shown in us by Government. In 2014/15, we had to take challenging budget decisions to begin to reprioritise the balance of funding to our priorities. 2015/16 will be a challenging year for NTS with both a new Government and a National Audit Office review. Our Business Plan for 2015-16 will affirm the trust placed in the Board and in Trading Standards Services to establish a consumer protection regime that protects consumers and safeguards legitimate business. This has been my second year as Chairman and I would like to extend my thanks to all those organisations and individuals the Board has worked with for their support and vision and confidence in driving the Board forward over the last year. Without their commitment, enthusiasm and drive, we would not be in the strong position we find ourselves in. This applies in particular to all the local authorities in England and Wales, who are themselves facing significant resource cuts in their local services, and in particular those that host teams, take on cases causing serious consumer detriment, and carry out commissioned work on behalf of the Board. I am very pleased to have been asked to stay on as Chair for a further two years and have accepted this position. Lord Toby Harris Chair - 2 -
Strategic Objectives This Business Plan sets out how we plan to achieve our objectives. It is presented at a time of continued change with an impending general election and continuing stringent budget cuts in local trading standards services. This is a clear risk to the work of NTS, which is dependent on the intelligence provided and experience and competence of officers on the ground, beyond those staff it provides and funds directly as part of the NTS Teams. Last year we set five main themes that allowed us to ensure the establishment of the governance arrangements for the delivery of national and cross-boundary consumer protection services; create systems to share intelligence more effectively and efficiently in order to identify and tackle emerging threats; to commission regional and national teams for cross boundary enforcement; to develop effective arrangements to maximise coordinated and collaborative work; and to deliver a programme of animal feed hygiene enforcement to improve the UK enforcement landscape and help ensure the safety of the food chain. The principles behind objectives are maintained for 2015-16 as they were all long term objectives and functions of the Board. The underpinning activities for each objective change as progress is made. Protecting Consumers Safeguarding Businesses Objective 1 Objective 2 Objective 3 Objective 4 Objective 5 Ensure effective governance arrangements for the work of NTS, which will also enable us to clearly demonstrate the importance and effectiveness of NTS to our partners, a new Government and the National Audit Office. Provide a framework for sharing intelligence effectively and efficiently in order to identify and tackle emerging threats Ensure effective delivery of national and cross boundary enforcement projects Lead the coordination, collaboration and communication of local, regional and national consumer protection enforcement Deliver a programme of animal feed hygiene enforcement to improve the UK enforcement landscape and help ensure the safety of the food chain. Figure 1 Strategic Objectives 2015-16 We will continue to lead the national enforcement agenda and implement better intelligence systems locally, regionally and nationally. A National Strategic Assessment was undertaken last year, using the evidence provided. The Board agreed that this year the following key priorities 1 would apply: Doorstep Crime; Fair Trading issues Mass Marketing Scams; e-crime; Product Safety; 1 These are not listed in priority order, they are all key priorities. - 3 -
Illegal Money Lending; and Intellectual Property. Detailed actions to address the above priorities are contained in our National Control Strategy which has been supplied to all NTS Teams, all local trading standards services and all partners. This determines how NTS funds will be allocated to deliver specific outcomes and activities. NTS hopes the National Strategic Assessment and Control Strategy will also inform Regional Trading Standards Groups and local authorities when they are determining what priority areas they will support during the coming year. Local Authority Trading Standards Services will continue to address local threats and those issues under local political control in accordance with the priorities set by individual local authorities. All of this activity is designed to achieve: a more effective consumer protection landscape; protecting people against unsafe goods and helping ensure a safe food chain via our work at ports and on feed; tackling regional and national consumer detriment, ensuring legitimate businesses are protected from the impact of those causing regional and national consumer detriment, and either directly, or via partners, supporting work to educate and prevent future detriment. The FSA has allocated a budget of 2.97 million for the feed work. This includes a 1% reduction in funds compared to last year. BIS has allocated a budget to the Board of 13.24 million core grant for 2015/16. This is the same level of grant as provided last year. In addition 225,000 was provided, in the budget announcement, for e crime work related to copycat websites. A full breakdown of funding is shown in Annex 1. The Board inherited a range of historical funding arrangements, and up to this point, has largely kept those intact while the first two years of full operations were completed. In allocating its budget for 2015/16, the Board made changes to how its deployable budget is allocated against its priorities. This has meant significant changes, with growth in certain areas (mass marketing scams and safety) and reductions in others (particularly funding for the Illegal Money-Lending Teams). A comparison between percentages of deployable budgets is shown in Annex 2. A list of the detailed performance indicators that have been set by the Department for Business, Innovation and Skills (BIS) to measure the success of the Board are contained in Annex 3. To succeed we will need an effective working relationship with key players and other enforcement partners across the UK. This is done both bi-laterally and through the Consumer Protection Partnership (CPP). The CPP has already identified its priority work areas for 2015-16 which include travel, on line markets and unfair contract terms. NTS will lead the work in relation to on-line markets and, in particular, the detriment caused by subscription traps and will support other groups as appropriate. Whilst NTS operates in England and Wales, we will continue to work with our counterparts in Northern Ireland and Scotland and with other enforcement partners across the UK to ensure that the consumer regime is as effective as it can be. It is important therefore that the Board have a coherent strategy that will deliver value for money. To meet this aim we have developed a series of objectives within our 5 objectives but we will take a flexible approach that focuses on the outcomes of our work and the impact it has made. - 4 -
Objective 1 Ensure effective governance arrangements for the work of NTS, which will also enable us to clearly demonstrate the importance and effectiveness of NTS to our partners, a new Government and the National Audit Office. We will do this by Using the experience of the Chairman and Board members and their role regionally to enhance regional buy in for NTS and accountability of it. Working closely with LGA and WLGA to ensure we support their activity where appropriate and to reinforce the message that the NTS does not affect the local political accountability for resourcing and prioritising trading standards locally. Ensure the governance arrangements for NTS are transparent. Providing clear direction by taking the lead in tackling the problems encountered by consumers Engaging effectively with government departments to influence and educate them in the work of Trading Standards. Working with other government departments interested in the NTS model for the commissioning of trading standards work that is best delivered regionally and nationally. Launch a website for NTS with all public business plans and reports, links to the work of relevant teams and up to date media links. Creating a comprehensive national picture of the achievements of the NTS and regional groups and communicate these effectively. Be open to scrutiny via the agreed mechanism, at both a political, and senior officials level. Objective 2 Provide the framework for sharing intelligence effectively and efficiently in order to identify and tackle emerging threats. We will do this by: Making informed decisions on our work by capturing, analysing and using all the information and intelligence that is available to us. Use the findings of the National Strategic Assessment to determine the focus of work by the NTS Teams 2. Identify any gaps in consumer protection enforcement and work with partners to address them Support the CPP s Intelligence work by helping ensure they have up-to-date information and the analysis is influencing partners work. Provide continued support to local authorities to use the Intelligence Operating Model locally and use it regionally and nationally to ensure that issues are managed, coordinated and prioritised effectively. 2 Detailed operational activities are in the National Control Strategy - 5 -
Improve the functionality of, and automated links between, the two leading Trading Standards Intelligences Databases. Provide a NTS Intelligence Team and network of Regional Intelligence Analysts to support NTS teams and local authorities in their use of intelligence. Undertake a review of the Safety Single Point of Contact System and further develop the riskbased approach at ports of entry into the UK to reduce dangerous imports. Produce an updated National Strategic Assessment and Control Strategy ready to be used to plan NTS' work for 2016-17. Review Intelligence held across the NTS Illegal MoneyLending Teams and the NTS Intelligence Team to identify to what extent there is any overlap in potential offenders and/or organised crime groups. Objective 3 Ensure effective delivery of national and cross boundary enforcement projects We will do this by: Providing NTS Illegal Money Lending Teams for England and Wales to tackle consumer detriment caused by illegal moneylenders, ensuring those engaged in criminal activities are punished, victims are supported, and vulnerable consumer and communities are educated and supported not to use illegal moneylenders. Work with BIS, HM Treasury and the Financial Conduct Authority to explore alternative funding streams for the Illegal MoneyLending Teams. Providing regional NTS Scambuster teams and resource other projects to tackle regional and national consumer and business detriment and ensuring those engaged in criminal activities are punished and/or their activities disrupted or stopped. Improve the reporting framework for NTS Scambuster Teams so that performance and capacity can be maximised across the country. Providing a NTS E-crime Team to tackle consumer and business detriment caused by e-crime and to support local authorities who are tackling e-crime at a local level Providing resources at key ports to prevent consumer detriment caused by the import of unsafe goods, to stop goods entering the UK market and to help local authorities deal with those engaged in criminal activity. Providing a National Trading Standards Scams Team to support local authorities and coordinate the tackling of mass-marketing scams by gaining and providing intelligence on repeat victims, advising local authorities on issues in their areas, and working with partners to disrupt activity. Providing the National Trading Standards Estate Agents Team to fulfil the statutory functions under the Estate Agents Act to tackle consumer detriment caused by unacceptable practices by Estate Agents. Provide the Advertising Standards Authority with a backstop enforcement regime to ensure that its current, very successful, self-regulation model, is seen to be enforceable on the few occasions where this is required. Ensure that the legacy from the 2014-15 CPP project on doorstep crime is maximised and lead the CPP work for 2015-16 in tackling consumer detriment caused by on-line markets. - 6 -
Provide funding via a National Tasking Group to support any further work required to tackle significant areas of consumer detriment in the priority areas. Objective 4 Leading the coordination, collaboration and communication of local, regional and national consumer protection enforcement. We will do this by: Supporting the regional Trading Standards infrastructure. Providing technical policy support for a range of trading standards groups, and strategic policy support to heads of trading standards to enable sharing of best practice and improved coordination and consistency of approach. Use the enhanced communications work to show the demonstrable impact of trading standards at a national level. Provide improved access to all NTS information for local trading standards staff via the website, in order to share good practice etc. Assisting the CMA as Single Liaison Body for EU Consumer Protection Cooperation by forwarding requests for assistance to relevant Local Authorities where appropriate. Objective 5 Deliver a programme of animal feed hygiene enforcement to improve the UK enforcement landscape and help ensure the safety of the food chain. We will do this by- Creating, overseeing and administering an Animal Feed inspection and sampling programme which is funded by the FSA in the financial year 2015-16. Undertaking other projects as directed by the Feed and Food Governance Group to include work to support authorities to develop regional capacity and to develop an intelligence model for feed. - 7 -
ANNEX 1 - FUNDING 2015/16 NTS has a total of 16.21 million in core funds for 2015-16, broken down as follows Figure 2 Total NTS Funding 2015/16-8 -
The grant from BIS is 13.24 million, broken down as follows Figure 3 BIS Grant funding 2015/16 E crime received an additional one off grant of 225,000 announced separately in the budget. This is not included in the above core grant figures. Other Central Support Intelligence Sanctions database 40,100 Programme Office 468,223 NTS Intelligence Team 507,384 ASA Liaison 18,400 Chair Costs 50,000 Regional Intel Analysts 357,000 TSI Conference 13,500 TSI Finance 114,453 Other Intelligence 67,840 Contingency 67,683 Comms Grayling 114,600 Local Intelligence Dbases 99,600 Value for money 40,000 Comms TSI 14,352 Memex/I2/IDB/PNC 188,900 Regional Coordination 255,000 Comms Other 10,000 Crimson Case 42,000 434,683 771,628 1,262724 Figure 4 Additional Breakdown of Costs - 9 -
The funding from FSA for feed work is 2,966,000 and is broken down as follows Figure 5 Feed Funding 2015/16-10 -
ANNEX 2 BREAKDOWN OF NATIONAL TRADING STANDARDS DEPLOYABLE ENFORCEMENT BUDGETS 2015/16 Figure 6 Breakdown of Deployable Enforcement Budgets 2015/16 These figures apply to the BIS element of the National Trading Standards funds only. It include all non ring fenced team budgets, National Tasking Group money and other flexible resource available to the Board for front line work. It excludes funds provided for national, regional and local intelligence systems/databases and central and regional infrastructure costs. - 11 -
ANNEX 3 Impacts and Outcomes Strategic Objective 1 Ensure effective governance arrangements for the work of NTS, which will also enable us to clearly demonstrate the importance and effectiveness of NTS to our partners, a new Government and the National Audit Office Activity Performance Measure How a. Developing strong, trusted relationships with key stakeholders. Demonstrate that the Board has the trust of stakeholders. Demonstrate that stakeholders believe that the Board has improved the consumer landscape. Evidence that the Board is communicating effectively with its stakeholders. Perceptions survey of key stakeholders to show: At least 72.5% of stakeholders trust in the Board At least 65% of Stakeholders agree the NTSB has improved the national/cross regional enforcement landscape At least 78% of Stakeholders feel that the Board is effectively communicating with them b. Supporting CPP in its work in tackling consumer detriment. c. Creating a comprehensive national picture of achievements of the NTSB and regional groups and communicating these effectively. Demonstrate that the Board is making a contribution to the Partnership which adds value for all. Demonstrate that the Board is actively involved in Working Groups and is taking the lead in tackling specific problems encountered by consumers. Evidence that the Board is influencing the Consumer Protection Partnership to support NTSB delivery. Demonstrate that the media plan is having impact and that the NTSB is using resources available (e.g. Ministers) to promote its work. Demonstrate that the Board s enforcement data is being made available publicly through quarterly and annual reports. Demonstrate how the Board is working with others joined up working - to lever support and increase the impact of enforcement activities. Feedback from CPP Chair. Annual report to include evidence demonstrating how the Board is influencing the CPP to support NTSB delivery. CPP Strategic/ Operational/ Working Group minutes to evidence the NTSB s input. Through annual and quarterly reporting evidence impact through narratives which: Provide examples of high-impact positive case studies and the coverage they generated. Show the impact of the communications strategy and examples of resources being used to promote their work. Show that enforcement information is freely available. Highlight joined-up working with other interested parties. Strategic Objective 2 Provide the framework for sharing intelligence more effectively and efficiently in order to identify and tackle emerging threats Activity Performance Measure How a. Capture, analyse, and use all the information and intelligence that is available to the NTS. Demonstrate that quality assurance measures are in place to ensure the information is defensible in Parliament and in a Court of Law. Demonstrate that information and intelligence is being made available across Trading Standards and that steps are being taken to - 12 - In the annual report provide evidence that shows: Quality information and intelligence is being made available across Trading Standards.
b. Enhance the intelligence gathering systems. identify and address information gaps and check whether the information is being used consistently and effectively. Demonstrate the impact the investment the Board is making to enhance and quality assure the intelligence gathering systems. Demonstrate the benefits of the enhanced intelligence gathering systems; what value this is adding; and whether the system mitigates against the enforcement gap. Demonstrate that the system is being regularly tested for secure and compliance with data. Positive steps are being taken to identify and address information gaps. Examples where information has been used consistently and effectively. In the annual report provide evidence that shows: The Impact of investment to enhance and quality assure the intelligence gathering system. The added value of the enhanced intelligence gathering systems and whether the system mitigates against the enforcement gap. Strategic Objective 3 Ensure effective delivery of national and cross boundary enforcement projects Activity Performance measure How a. Operational delivery of regional Scambuster Teams, to tackle consumer detriment (Outputs). b. Operational delivery of E- Crime Unit to tackle consumer detriment (Outputs). b Provide support to local authorities to identify Mass Marketing Scams and work with victims; and work with local partners to disrupt scams activity. (Outputs). c. Operational delivery of Illegal Money Lending teams to tackle consumer detriment (Outputs). d. Provide resources at key Ports and Borders to prevent consumer detriment caused by the import of unsafe and non-compliant goods Number of operations commenced in the period. Number of consumers affected. Number of successful prosecutions. Value of detriment avoided. Number of operations commenced in the period. Number of operations where the team gave assistance to another local authority/ agency. Number of successful prosecutions. Number of successful disruptions/ enforcement actions. Number of pieces of advice provided to local authorities/other organsiations. Estimated savings to consumers from interventions. Actual savings to consumers. Number of operations commenced in the period. Number of illegal lenders identified. Value of detriment. Number of victims affected. Number of successful prosecutions. Court compensation awarded to victims. Evidence of increased awareness of dangers of loan sharks following IML educational events Number of samples taken. Number of unsafe and non-compliant samples identified. value of potential harm prevented by ensuring unsafe and non-compliant goods not released into supply chain. - 13 - Through quarterly and annual reports (including case studies) demonstrate that consumer detriment is being tackled. Through quarterly and annual reports (including case studies) demonstrate that consumer detriment is being tackled. Through quarterly and annual reports (including case studies) demonstrate that consumer detriment is being tackled. Through quarterly and annual reports (including case studies) demonstrate that consumer detriment is being tackled. Through quarterly and annual reports (including case studies) demonstrate that consumer detriment is being avoided.
(Outputs). e. Managing the National Tasking Group to assess and resource appropriate cases. Demonstrate how the Board is taking on large, complex and national investigations and assessing by costs and risks involved. An annual assessment of impact to demonstrate that the resource invested providing good value for money. Demonstrate the impact the NTG activity is levering local Trading Standards to take better tactical decisions. Through quarterly and annual reports (including case studies) provide evidence that shows: That the Board is tackling big cases, evaluating the funds and risks. The impact of NTG work is encouraging local Trading Standards to make improved decisions. f. Provide enforcement of the Estate Agency Act. Number of warning and prohibition orders issued. Demonstrate that Powys is effective monitoring the estate agent redress schemes and addressing the issues identified in the OFT s Feb 2014 review of the Estate Agents Schemes. Through quarterly and annual reports which demonstrate that the Lead Enforcement Authority is regulating the Estate Agents Act effectively. Strategic Objective 4 Leading the coordination, collaboration and communication of local, regional and national consumer protection enforcement Activity Performance Measure How a. Support regional trading standards infrastructure. b. Establish improved coordination of the enforcement teams. Demonstrate that the is Board is effectively co-ordinating Trading Standards enforcement activity across Local Authority boundaries and effectively influencing the regional and local trading standards. Demonstrate that local and regional trading standards are effectively working with the Board. Demonstrate that the Board is using the Officials Oversight Group as an opportunity to demonstrate there is effective co-ordination, collaboration and clear responsibilities between national and local enforcement. Demonstrate how the Board is improving the coordination of the enforcement teams and how they are providing value for money. Through the annual report, and the results of the perceptions survey show evidence of: the Board s performance in managing TS enforcement work across local authority boundaries and levering Trading Standards locally and regionally. Trading Standards Community and the Board working well together. The Board making good use of the Official s Oversight Group to its advantage. Feedback from BIS officials in attendance at the group on whether the Board is using the Officials Oversight Group effectively. Through quarterly and annual reporting show evidence that the Board is enhancing the enforcement teams and is cost effective. - 14 -