SIR060 C1627001

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Professional Doctorate Social and Public Policy (SPPD)

Andrew Passenger C1627001

03.01.18

SIR060 Draft Research Proposal

Trading Standards Financial Safeguarding Interventions: A health and social care

perspective.

1.0. Background

The Social Services and Wellbeing (Wales) Act 2014 (SSAWW14) recognises financial abuse as a

form of abuse and in doing so imposes a new focus on prevention, early intervention and joint

working. Revised assessment criteria lowers the eligibility threshold for accessing social care

services and removes the requirement for the perpetrators of financial abuse to be persons in

positions of trust.

Prior to the introduction of SSAWW14, I dealt with a number of cases of elderly and

vulnerable victims who were continually exploited by unknown criminals and consenting to

give away large amounts of money to various types of fraud. It became evident that without

support, such victims would remain at risk and would continue to engage with the criminals

and accrue further financial losses.

I approached Social Services to express my concerns and request support, however found

they were restricted in what support they could offer (in particular where victims were

deemed to have mental capacity for the purposes of the Mental Capacity Act 2005) as

victims were ‘free to make decisions regardless of whether or not these were reasonable or

wise decisions’ (Department for Constitutional Affairs, 2007).

In addition to this limitation, many victims concerned were not considered vulnerable adults

for the purposes of the (then) national safeguarding arrangements, as perpetrators were

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not deemed to be persons in positions of trust for the purposes of the Wales Interim Policies

and Procedures for the Protection of Vulnerable Adults (In Safe Hands Guidance, 2000). I

felt this identified a service void and could leave many victims at risk of further exploitation.

The lack of support further seemed contrary to the general requirements to safeguard

vulnerable people from abuse found in the In Safe Hands Guidance (2000) where: ‘all

vulnerable adult client groups were to be protected from abuse and supported in seeking

treatment and redress in the event that they had been abused.’

A review by the University of Glamorgan (2010), found the guidance to be ‘only partially

effective, no longer appropriate nor sufficiently robust,’ the review further concluding that:

‘Primary care, health services, the criminal justice system and financial institutions were not

working together with local authorities as well as they might’ (Review of In Safe Hands,

2010).

Indeed, the removal of the requirement for perpetrators of financial abuse to be persons in

positions of trust could potentially increase pressures on Social Services through increased

demand for services.

Reporting these concerns to line managers, I was subsequently tasked to review Trading

Standards initiatives and to look at the policies and procedures of stakeholders such as

health and social care, the police and third/ private sector organisations to see how the

work of Trading Standards might assist the authority in light of the SSAWW14.

2.0. Research context. The Financial Exploitation Safeguarding Scheme

To understand the research design it is essential to understand the outcome of my review

and the subsequent creation of the Financial Exploitation Safeguarding Scheme (FESS)

FESS is a multi agency initiative drawn out of my review and designed to detect and support

victims, prevent fraud victimisation and support local authority objectives by tying the work

of Trading Standards to policy developments brought about by the SSAWW14.

FESS consolidated Carmarthenshire Trading Standards’ portfolio of ten financial

safeguarding initiatives into a single underlying financial safeguarding theme, subsequently

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creating a financial safeguarding network that promoted a portfolio of initiatives as a

reciprocal voluntary participation scheme, where private, third sector and local authority

partners agreed to work with Trading Standards to develop policies and procedures to

identify, refer and support victims of financial abuse.

In return, partners receive access to a priority referral gateway, priority officer response,

specialist training and specialist technical measures to support victims.

The ten initiatives consolidated into FESS were:

1. Truecall Nuisance Call Blocking

2. National Scams Hub Intelligence Led Visits

3. No Cold Calling Zones

4. Registered Traders Schemes

5. Debt and Mental Health Interventions

6. National Trading Standards Friends Against Scams (Scams Awareness Initiative)

7. Vulnerable Consumer Advice and Advocacy

8. Moneywise Financial Literacy Project

9. Financial Services, Private and Third Sector Safeguarding Protocol

10. Regulated Financial Advisor - Assured Advice Referral Scheme

The ten initiatives were compared against six objectives found within the SSAWW14 to

determine if such initiatives could hypothetically be attributed to fulfilling compliance with

the SSAWW14 namely:

1. Promoting social and economic wellbeing

2. Protecting people from abuse

3. Giving people control over their day to day lives

4. Reducing the need for care and support in the authority area

5. Contributing towards preventing people from suffering abuse or neglect

6. Enabling people to live their lives as independently as possible.

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The exercise indicated that hypothetically, the initiatives could fulfil compliance with the

SSAWW14 on the basis that that each initiative was hypothetically capable of meeting all six

objectives of the act.

As such, the ten initiatives could be consolidated into one intellectual vehicle, which gave

rise to the singular idea of creating and promoting Trading Standards’ financial safeguarding

initiatives as a financial safeguarding network. The perceived benefits being that victims

receive a multi agency response to financial abuse calling on multiple specialisms and that

Trading Standards tie their initiatives to policy development giving the work a statutory

footing. Furthermore, the portfolio is more easily promoted on the basis of the simple

underlying financial safeguarding theme as opposed to promoting ten individual initiatives.

The reciprocal nature of FESS brings together known Trading Standards initiatives with those

of partner organisations, to deliver a multi agency response to imbed the work of Trading

Standards within the new legislative framework.

The multi agency aspect provides further evidence of hypothetical compliance, when we

consider the provisions of the act in relation to joint working strategies.

Combined, these arguments provide the basis for my hypothesis that the work of Trading

Standards can be placed within the realm of health and social care (areas not traditionally

perceived as within their remit).

FESS has been promoted and presented in high profile arenas1 as well as achieving several

national awards2 yet the hypothesis is unproven and no other studies exist exploring this

notion. Therefore in order to make the hypothesis more resilient to legislative and academic

scrutiny, further research is required.

1 Senedd,Welsh Government (2017) – Wales Heads of Trading Standards (WHOTS) Position Statements

Launch; Care and Social Services Inspectorate for Wales (CCSIW) 2017 – Chief Executive Presentation; Action

on Elder Abuse (AEA) Conference Presentation – Cardiff City Hall (2016).

2 Municipal Journal Awards, (2016) – Highly Commended - Innovation in Partnership; Municipal Journal Awards

(2016) – Moneywise – Winner - Trading Standards and Environmental Health; Chartered Trading Standards

Institute (CTSI) Conference (2016) – Winner - Best Local Authority Exhibitor; Wales Public Health Conference

(2016) – Winner - Poster Competition; Association of Directors of Social Services (ADSS) Poster Competition

(2015, 2017) – Shortlisted Poster Competition.

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3.0. Research Aims/ Questions

The fundamental aims of the research are to explore whether:

• Trading Standards’ financial safeguarding initiatives/interventions consolidated

within a FESS initiative could be deemed social care interventions for the purposes of

fulfilling compliance with the SSAWW14;

• There are any ethical constraints posed by disruptive intervention under a FESS

initiative, where requisite capacity exists under the Mental Capacity Act 2005 and

what, (if any) human rights/data protection issues might stem from the dichotomy

existing between safeguarding liberty and preventing and detecting criminality;

• FESS initiatives are effective in supporting victims and whether there is evidence to

promote FESS as the foundation for a national model, and to begin formally

recognising Trading Standards’ financial safeguarding initiatives as instrumental to

local and national safeguarding policy;

• Data gleaned from the FESS initiatives in the course of the research could be used as

a foundation to begin determining potential social and economic cost saving benefits

to a local authority implementing a FESS initiative in their authority area.

4.0. Literature Review

In a report undertaken by the Office of Fair Trading (2006) it was estimated that every year 3.2

million UK consumers lose £3.6 billion to scams. Figures released by the Office for National

Statistics reveal that fraud and cybercrime are the most prevalent crimes committed against

people in England and Wales in 2014/15. “There was an increase of 9% in the volume of fraud

offences referred to the National Fraud Intelligence Bureau (NFIB) at the City of London Police.

Nearly 600,000 offences were referred to the NFIB in 2014/15” (Office for National Statistics,

2015). An evidence review undertaken by Age UK (2015) found that: “over half (53%) of people

aged 65+ believe they have been targeted by a fraudster and whilst only one in twelve

responded to a scam 70% of all age groups who responded said they had personally lost money

– this could mean that a staggering half a million people have fallen victim to losing savings”

(Age UK, 2015). These figures relate to reported incidents however there is widespread concern

that many scams go unreported (National Fraud Authority, 2013). It has been estimated that

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fewer than 5% of people reported scams to the authorities (Office of Fair Trading, 2006). It has

further been estimated that up to 20% of the UK population could be particularly vulnerable to

scams, with previous victims consistently more likely to show interest in responding again

(Office of Fair Trading, 2009). In 2008, 18% of the population of Wales was over 65; by 2033 this

is expected to rise to almost 26% (National Assembly for Wales, 2011). With the proportion of

elderly people in Wales set to increase, the combination of factors presents a worrying picture

for the future.

I propose that financial abuse is detrimental to the health and wellbeing of victims. There is

widespread acknowledgement in the literature that the victims of crime, especially violent

crime, often experience severe psychological distress and subsequent mental health

problems (Weaver and Clum 1995; Mezey, 1996; Adshead, 1996; Brewin et al, 1999, cited in

Robinson and Keithley, 2000). Older victims of doorstep crime decline in health faster than

non-victims of a similar age (Donaldson, 2003), and older adult crime victims experience

significant financial, educational, medical and social stresses, which impact negatively on

their mental health (Gray and Acierno, 2002). Other studies have found that psychological

and physical abuse leads to higher odds ratios for negative health outcomes (Olofsson et al,

2012). Park et al (2011) suggest that fear of crime and victimisation in the elderly is

detrimental to their quality of life and levels of daily activity, whilst Beaulieu et al (2004)

conclude that those who experience chronic or consistent long term fear of crime are

significantly more likely to suffer psychological distress than those in the same demographic

who do not.

The University of Glamorgan’s 2010 review of the In Safe Hands Guidance (2000) found it to

be ‘only partially effective, no longer appropriate nor sufficiently robust.’ The review made

16 recommendations as to how the guidance could be improved and reference is made to

consultation and development on ‘financial abuse especially in relation to adults with

mental capacity’ (Review of In Safe Hands 2010: 180).

5.0. Research Design and Methodology

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The research will primarily be undertaken within a positivist framework ‘an epistemological

position that advocates the application of the methods of the natural sciences to the study of

social reality and beyond’ (Bryman, 2016).

Given that the research is carried out with a specific hypothesis in mind, it will therefore be

a deductive study understood as ‘an approach to the relationship between theory and

research in which the latter conducted with reference to hypotheses and ideas inferred

from the former ’ (Bryman, 2016).

The research will draw upon data obtained from 30 Trading Standards Services who have

agreed to promote a FESS initiative based on the Carmarthenshire model within their authority

area.

The research will analyse the data obtained against the six objectives of the SSAWW14

referred in point 2.0 to explore the research aims outlined in point 3.0.

The parochial nature of local authority delivery of Trading Standards’ services means that

authorities may not operate all ten initiatives consolidated by FESS.

In order to overcome this, promote the initiative and obtain project buy in, it was

determined that I would offer to share Carmarthenshire Trading Standards’ experiences and

knowledge in the field and create a set of modular resources that other authorities could

use to implement their own initiative.

The modular design means an authority can use resources relating to initiatives it operates

(or would like to operate), saving cost in resource design, whilst at the same time picking up

an off the shelf compliance model.

To provide the resources to other authorities and to gather the data for the research, a

website was commissioned3 and produced in association with Canolfan Peniarth.4

3 https://fess.carmarthenshire.gov.uk/en/about/terms-and-conditions

4 Canolfan Peniarth – A graphic design company based at the University of Wales (Trinity St David) Carmarthen

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The website provides a secure private account function5 and a secure private members area,

where participants log in to access FESS resources.

As part of the registration process, participants complete an application questionnaire. The

questionnaire is administered through the website by linking to a third party secure server

using the data analytics software Snap Surveys 6

Participants are subsequently placed on a programmed list to receive quarterly operational

questionnaires and quantitative case study requests through the Snap Surveys software

package.

Participation is therefore a contractual agreement in which participating authorities provide

data to the project in exchange for access to FESS resources.

30 local authorities have agreed to participate and the research will consist of the collation

and analysis of primary data received from those authorities implementing a FESS initiative

using the scheme model and resources.

The multiple project strands from which FESS is made up each provide direct links and

access to appropriate financial abuse victims to obtain targeted data samples to enable

research cycles.

Analysis of primary data will be used to explore the research aims and will be broadly broken

into three parts.

Firstly, the research provides for a cross sectional study of 240 quantitative case studies

whereby the 30 participating authorities have agreed to obtain data from two financial abuse

victims on a quarterly basis over the course of 12 months.

5 The FESS Web Portal https://fess.carmarthenshire.gov.uk is encrypted using HTTPS and SSL certified via

QuoVadis approved provider (https://www.quovadisglobal.co.uk).

6 Snap Webhost is certified by Bureau Veritas as being compliant with ISO 27001, the internationally recognised gold standard for information security systems:

https://www.snapsurveys.com/survey-software/security-accessibility-and-professional-outline/

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This data will take the form of a quantitative questionnaire and seeks to explore the health

impact of financial abuse in relation to symptoms contained within the International

Classification of Diseases and Related Health Conditions (ICD10); in particular Clinical

Depression, Anxiety, Panic Attacks and Post Traumatic Stress Disorder.

Secondly, the research provides for a longitudinal study of 30 local authority Trading Standards

departments who have each agreed to respond to 4 quantitative operational questionnaires

over the course of 12 months (120 questionnaires in total).

The operational questionnaire pertains to operational issues such as integration with local

stakeholders, scale and scope of the problem within authority area, recognition of Trading

Standards Services within an authority as partners to address financial abuse, Trading

Standards’ engagement for the purposes of local policy formation as well as general day to day

operational issues such as financial resources and staffing models.

Thirdly, in addition to the positivist approach, both the questionnaire and the quantitative

case study templates will provide for the submission of qualitative data within the

interpretivist framework, understood as ‘a strategy respecting the differences between

people and the objects of the natural sciences, which therefore requires a grasp the

subjective meaning of social action’ (Bryman, 2016).

Such data is collated to compliment the positivist approach and to provide for a more

rounded and holistic picture of findings.

Further qualitative interviews will be undertaken with professionals in the field to obtain

subjective opinion and to harness further interpretive data to explore and inform the

research aims.

6.0. Data Analysis

Primary data will be collated in contingency tables to create datasets for quantitative

analysis in SPSS.

The analysis will use multiple quantitative methodologies including cross tabulation, central

tendency, dispersion, one way anova, multi layered cross tabulation, chi square tests,

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regression analysis, r square, anova, beta and correlation analysis to identify significant

statistical relationships in the datasets and explore the hypothesis.

Data analysis will subsequently be broken down into four parts.

1. SPSS analysis of the ‘quantitative case study dataset’ seeking to establish significant

statistical relationships between categorical and numeric variables to identify statistical

correlations with clinical definitions of known health issues such as Depression, Anxiety,

Panic Attacks and Post Traumatic Stress Disorder (deferring to symptomatic classification

under ICD10).

This element provides for cross sectional findings to be presented in isolation, for example:

a significant proportion of financial abuse victims reported experiencing four or more

symptoms, symptomatic with a diagnosis of clinical depression in accordance with ICD10

indicating a significant relationship between financial abuse and symptoms of clinical

depression…

2. SPSS analysis of the ‘operational questionnaire dataset’ seeking to establish significant

statistical relationships between categorical and numeric variables pertaining to operational

issues such as: Trading Standards engagement with local policy formation, Trading Standards

resources and the progress of an individual FESS initiative over the duration of the study.

This element provides for longitudinal findings to be presented in isolation, for example: those

Trading Standards Services who had low engagement with the local policy formation process at

the beginning of the study were significantly more likely to be under resourced… However after

utilising FESS resources to promote to engage with local policy formation, by the end of the

study the department had been able to secure more resources…

3. The synthesis and analysis of both the quantitative case study and operational questionnaire

datasets in SPSS.

The datasets from both the case studies and the questionnaires will be integrated within Snap

Surveys to enable cross tabulation of the case studies and operational questionnaires to analyse

operational matters in relation to victim impacts. For example, victims who reside in authority

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areas where Trading Standards services receive high levels of engagement with local policy

formation processes are significantly more likely to experience three or less symptoms of

depression…

Such synthesis may also provide for elements of cross sectional data to be analysed

longitudinally and vice versa.

4. Qualitative and unstructured findings obtained from the case study template and

qualitative interviews will be collated in Snap Surveys and exported and analysed using

multiple qualitative methodologies such as discourse analysis, conversation analysis and

grounded theory analysis in the NVIVO qualitative data analysis (QDA) software package.

7.0. Ethics

Access to financial abuse victims for case study research comes about through natural

referral processes and daily work of Trading Standards. I will use such privileged access to

victims for the purpose of the case study feedback subject to ethics clearance from the

University Board.

Consent forms and case study guidance forms have been drawn up to instruct participants

in the research process as it is recognised that officers undertaking case study

questionnaires with victims may have no experience conducting research and will need to

be mindful of basic research principles and methodology such as reflexivity, understood

methodologically as ‘a reflectiveness about the knowledge generated about the social world

by researchers of methods, values, biases and decisions’ (Bryman, 2016) , as well as the

mere presence and impact of the researcher on the behaviour of persons being researched

– ‘the Hawthorne effect’ (Oxford, 2017).

Furthermore it is recognised that majority of case study respondents have been the victims

of crime and may be elderly and/or vulnerable so care must be taken that participants are

not be subject to any harm through the research process, harm being defined by Diener and

Crandall (1978: 19) as ‘physical harm, harm to a participants’ development, loss of self

esteem; stress; and inducing subjects to perform reprehensible acts.’

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Researching officers should also be mindful of their obligations as law enforcement officers

investigating criminal issues (in particular the European Convention on Human Rights (ECHR)

1950 and the Police and Criminal Evidence Act 1984 (PACE) Codes of Practice.

Officers undertaking case study questionnaires with victims will further be required to

manage the expectations of victims and provide details of how the data will be used to

inform the research.

Personal identifying data will not be collected as part of the research, however data in

relation to the victims’ demographic profile such as age, sex and postcode along with basic

details surrounding victims’ socio -economic status as well as any psychological or physical

impact the financial abuse might have had on the victims health or wellbeing will be

collected.

Researching officers are further reminded of their professional status as Local Government

Officers subject to the regulatory data protection requirements of the Data Protection Act

1998.

Issues may arise where victims do not have mental capacity to consent to be part of the

study. In such cases participants are instructed as part of case study template guidance

notes to seek advice from the victims social work professional and/or their power of

attorney. Reference should be made to Mental Capacity Guidance 2005 in this regard.

Further instruction will take into account guidelines issued by Cardiff University as well as:

• The British Sociological Association (BSA) Statement of Ethical Practice, (2017)

• The American Sociological Association (ASA) Code of Ethics, (1999)

• Social Research Association (SRA) Ethical Guidelines, (2003).

8.0. Timetable

January 2018 - Commence Wave 1 operational questionnaires and quantitative case study

requests

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February 2018 - Arrange to visit other departments/ teams to identify key people and

undertake relationship building with a view to undertaking qualitative interviews.

March 2018 – Data Analysis of Wave 1 operational questionnaires - Provide local authority

feedback – Design Wave 2 operational questionnaire.

April 2018 – Commence Wave 2 of operational questionnaires and quantitative case study

requests.

June 2018 - Data Analysis of Wave 2 operational questionnaires - Provide local authority

feedback – Design Wave 3 operational questionnaire.

August 2018 - Commence Wave 3 of operational questionnaires and quantitative case

study requests

October 2018 - Data Analysis of Wave 3 operational questionnaires – Provide local authority

feedback – Design Wave 4 operational questionnaire.

December 2018 – Commence Wave 4 of operational questionnaires and quantitative case

study requests

January 2019 - Arrange to visit other departments/ teams to with a view to undertaking

follow up qualitative interviews

February 2019 – Export full datasets from Snap Surveys into SPSS/ NVIVO and begin full data

analysis

April 2019 - Commence writing thesis

October 2019 – Submit thesis

7.0. References

Adshead G. (1996) Psychological trauma and its influence on genuine and false

complaints of sexual assault. Medicine Science and the Law, 36, pp. 95-99.

Age UK. (2015). Only the tip of the iceberg: Fraud against older people. Evidence

review. Retrieved from http://www.ageuk.org.uk/documents/en-gb/for-

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professionals/consumer-

issues/age%20uk%20only%20the%20tip%20of%20the%20iceberg%20april%

02015.pdf?dtrk=true

American Sociological Association. (1999). The Code of Ethics of the ASA Committee

on Professional Ethics – Retrieved from:

http://www.asanet.org/sites/default/files/code_of_ethics_aug_2017_2_1.pdf

Beaulieu, Leclerc; Nancy ; Dubé; Micheline (2004), Chapter 8 Fear of Crime Among

the Elderly: An Analysis of Mental Health Issues Journal of Gerontological Social

Work, 12 January 2004, Vol.40(4), p.121-138

Brewin, C.R., Andrews, B., Rose, S. and Kirk, M. (1999) Acute stress disorder and

post-traumatic stress disorder in victims of violent crime, American Journal of

Psychiatry, 156, pp. 360-366.

British Sociological Association. (2017). Statement of Ethical Practice - Retrieved

from:

https://www.britsoc.co.uk/media/24310/bsa_statement_of_ethical_practice.pdf

Bryman, A. (2016) Social Research Methods 5th Edition, Oxford University Press, New

York.

Button, M., Lewis, C. and Tapley, J. (2014) Not a Victimless Crime: The Impact of

Fraud on Individual Victims and their Families. Security Journal, 27(1) 36- 5410.

Crime Survey England and Wales (2014) CSEW Fraud and Cyber-crime Development:

Field Trial - TNS BMRB - JN123456

Council of Europe, Convention for the Protection of Human Rights and Fundamental

Freedoms (European Convention on Human Rights, as Amended) (ECHR) Art 8, 1950.

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Department for Constitutional Affairs. (2007). Mental Capacity Act 2005. Code of

Practice. London: TSO

Department of Health. (2000). No secrets: Guidance on developing and

implementing multi agency policies to protect vulnerable adults from abuse. London:

TSO

Department of Health. (1998). Modernising social services. Promoting

independence, improving protection, raising standards. Presented to Parliament by

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TSO

Department of Health. (2014). Positive and proactive care: Reducing the need for

restrictive interventions. London: TSO

Donaldson, R. (2003) Experiences of older burglary victims. Home Office, Crown

copyright 2003 - ISSN 1473-8406

Diener, E, and Crandall, R. (1978). Ethics in Social and Behaviuoral Research. Chicago:

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Gray, Matt J ; Acierno, Ron (2002) Symptom presentations of older adult crime

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Great Britain (1998) Data Protection Act: London. Stationary Office.

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Guide to Data Protection The Information Commissioners Office 2017 – retrieved

from: https://ico.org.uk/for-organisations/guide-to-data-protection/

International Statistical Classification of Diseases and Related Health Problems

Version (2010) World Health Organisation – Retrieved from:

http://apps.who.int/classifications/icd10/browse/2010/en

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in-past-year-oct16 Calculated as the amount of money lost in 2015/16 to fraud and

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Office of Fair Trading (2006) Research on impact of mass marketed scams - A

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