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2 Catherine Place
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SW1E 6HF
2 March 2017
Federation of Small Businesses (FSB) response to Draft Police and
Crime Plan for London 2017-2021 – Consultation Document
Introduction
The Federation of Small Businesses (FSB) is the UK’s leading business organisation. It exists
to protect and promote the interests of the self-employed and all those who run their own
business. The FSB is non-party political and is also the largest organisation representing small
and medium sized businesses in the UK.
Small and micros businesses make up 98 per cent of all private sector businesses in London,
and make a huge contribution to the UK economy. They contribute 44 per cent of London’s
GDP and employ 39 per cent of the workforce 1.
Background
The FSB in London welcomes the opportunity to feed into the draft Police and Crime Plan for
London 2017-2020.
We know that business crime2 affects all businesses. It is often the smaller firms who are hit
the hardest because they cannot absorb the cost. FSB research reveals how smaller firms are
being affected3.
• 48 per cent have been a victim of offline (non-cyber) crime, with an average cost of nearly
£5,898.
• 66 per cent have been a victim of cyber crimes, with an average cost of nearly £2,976.
Business crime has wide-ranging consequences beyond the direct financial cost of the loss or
property damage. It can increase the cost of insurance premiums, damage the ability of a
business to meet customers’ needs, cause reputational damage with both customers and
suppliers, negatively impact employees, jeopardise future work and waste valuable time. 4
Reducing all business crime is fundamental to greater business prosperity.
1
https://www.london.gov.uk/moderngov/documents/s22201/SMEs%20in%20Londons%20Economy.pdf
‘Business crime’ is used in this consultation as a term to describe both offline crime and cyber-crime perpetrated against
businesses, the owner(s) or their staff during the course of business. For the purposes of this response: ‘cyber-crime’ describes
crimes that take place using networked information technology. This includes the new crimes which computers and associated
devices have enabled and traditional crimes committed using ICT. ‘Offline’ or non-cyber crime describes traditional crimes i.e.
committed in the physical world.
3 In January 2016 the FSB surveyed 1006 members on their perceptions and experiences of crime against their business,
themselves and their employees (during the course of business) over the preceding 2 years (24 months).
4 Negative impacts on employees might include psychological trauma which requires an employee to take time off and get
counselling
2
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Commitments:
We are pleased to see the following commitments in the plan:
Bring the police closer to communities, providing a minimum of two dedicated
Police Constables (PCs) and one Police Community Support Officer (PCSO) for
every ward in London.
Small businesses are at the heart of communities and can be the eyes and ears of a local
area. They want to play their part in ensuring their community is safe for their families,
employees and customers. Knowing who are their local PCs and PCSOs in their area (and how
to contact them) is important, as are clear communication channels for small businesses to
report concerns.
Involvement of the local business community is essential in enabling a two-way exchange
of intelligence, information and crime prevention best practice between businesses and law
enforcement agencies.
FSB Recommendations:
• Act as an effective interface between the business community and the police.
• As part of the Crime Plan, devise and implement a strategy for increasing the regular
interaction between the small business community and the local police force.
• Encourage more small business participation in local Business Crime Reduction
Partnerships.
• Work with City Hall and LEAP so that tackling business crime also becomes a key local
economic priority.
• Use such partnerships to develop and exchange best practice towards tackling crime
against business and disseminate the results to all small businesses in the area.
• Ensure small businesses are aware of and can use the Community Trigger5 to ensure
action is taken to address an anti-social behaviour problem.
End the inflexible ‘MOPAC 7’ targets set in the previous Mayor’s Police and Crime
Plan and agree annual crime and policing priorities at a local level, on volume
crime, vulnerability and harm.
Development of crime and policing priorities at a local level is important and we hope that
the necessary mechanisms to allow small business to feed into these priorities will be set up
and effectively communicated to the local business community. FSB London will be pleased
to assist with this.
Support the work of the Night Czar to deliver a safe and enjoyable night time
economy.
The appointment of a Night Czar was welcomed by FSB and we are pleased to see a
commitment to support work that delivers a safe and enjoyable night time economy. The
night time economy should not be seen as separate from the rest of the economy. Ensuring
an area is still accessible and pleasant to be in each morning is important for businesses
operating near entertainment and leisure operations for attracting and retaining customers
and staff.
5
The Community Trigger’ was introduced in the Anti-Social behaviour, Crime and Policing Act 2014.
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Work together with the Metropolitan Police Service (MPS), Transport for London
(TfL), British Transport Police, City of London Police and other enforcement
partners to keep our transport network and roads safe.
The transport network in London is one of the most important infrastructures supporting
businesses. It brings in customers, is used to deliver goods and services and enables
employees to travel to and from work. A safe and efficient network is vital to supporting the
small business economy which contributes 44 percent in GDP and provides employment for
39 per cent of the workforce6.
Work with businesses to help protect them from crime, making our city a safer
place to work and do business.
FSB London are particularly pleased to see this commitment in the Police and Crime Plan
because it is the smaller firms who are hit the hardest, often being unable to absorb the
costs associated with crime compared to larger businesses.
Business crime has wide-ranging consequences beyond the direct financial cost of the loss or
property damage. It can increase the cost of insurance premiums, damage the ability of a
business to meet customers’ needs, cause reputational damage with both customers and
suppliers, negatively impact employees, jeopardise future work and waste valuable time. 7
We want to see a specific strategy developed to deal with business crime, with clearly defined
objectives, outcomes and measures of success. The strategy should not only focus on
sophisticated crimes such as cyber and fraud but deal effectively with the perennial problems
of theft and anti-social behaviour. In our recent survey theft was experienced by a third of
respondents.
Strategic prioritisation should be focused on the crimes that most impact small businesses.
We are pleased to see recognition that local businesses have specific needs and make an
important contribution to the safety, prosperity and wellbeing of communities (page 16 of
the Consultation document).
We ask that FSB is made a designated a consulting stakeholder representing the small
business community as standard engagement practice for the MPS and all London Business
Crime Reduction Partnerships.
FSB is pleased to see that victims of crime will be put at the heart of local policing (page
19) and that work will be undertaken to reduce the number of officers dealing with an
investigation. We hope this approach will include small and micro businesses who are
victims of crimes.
6
https://www.london.gov.uk/moderngov/documents/s22201/SMEs%20in%20Londons%20Economy.pdf
Negative impacts on employees might include psychological trauma which requires an employee to take time off and get
counselling
7
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Strategic Policing Capabilities
Information Sharing
FSB works closely with the Cross-sector Safety and Security Communications (CSSC)8
group and London Resilience Business Sector Panel (LRBSP), who work to help provide the
capital’s business community with information to assist them develop robust resilience and
emergency preparedness plans about major incidents.
We support the sharing of information with relevant specialist partners and hope that the
relationships developed to date between CSSC, LRBSP and MPS will continue to be
encouraged and supported (page 24).
London is Open
FSB supports the Mayor’s campaign ‘London is Open’ and we recognise the challenge of
public order policing in the capital. It is important that there is effective co-ordination with
the local small business community when policing planned major events such as New Year’s
Eve celebrations, to allow small businesses to trade safely.
The default position must be that businesses should be able to continue to trade unless
there is a clear and accountable reason to prevent this.
Small businesses should receive clear and timely information about nearby and relevant
road closures and pedestrian access restrictions, so they can make appropriate trading
plans for staff, suppliers and customers (page 25).
Cyber Crime and Fraud
The Mayor’s Office for Policing and Crime (MOPAC) identified cybercrime as an important
issue in 2014. They have further stated that, in 2013, the UK economy lost an estimated £52
billion through fraud – some £27 billion of which was enabled by computers. British police
also received 58,662 online crime reports and 9,898 computer misuse crime reports.
Our own FSB research suggests that cybercrime costs our members around £785 million per
year and that almost 6 in 10 small businesses (59 per cent) have limited or zero awareness
of current scams or vulnerabilities affecting London. Almost 9 in 10 FSB members (88 per
cent) in the capital believe that small businesses should be offered free or low-cost external
test services to see how easy it is for hackers to access their information – which could save
the insurance industry millions in fraud and online crime.
The FSB in Greater London is working closely with MOPAC and the London Digital Security
Centre (LDSC) to promote better awareness of cyber security and to support small
businesses in finding safe ways to operate in the digital world. We are pleased to see
continued support for the London Digital Security Centre (LDSC), to provide specialist cyber
security advice to small businesses and organisations across the city at an affordable price
(page 26).
More than half (55 per cent) of FSB members in London are using the cloud. When asked
whether small businesses felt confident using social media channels such as Twitter, Facebook
and LinkedIn from a privacy perspective, 52 per cent answered either ‘unsure’ or ‘not at all’.
8
http://www.vocal.co.uk/cssc/
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A 2012 European Commission report found that as a result of the adoption of cloud computing
80 per cent of organisations could potentially reduce their costs by around 10 – 20 per cent.
There are also significant potential green benefits as well, with one study indicating that the
energy footprint of small firms can be reduced by up to 90 per cent by moving tasks online.
Cyber crime is a big threat to a small firms’ ability to fully exploit the benefits of the digital
economy. Small firms rely more and more on online means to attract customers, sell
products and run their businesses. As a result, the threat of online crime and its
consequences requires particular attention. The risk of cyber crime increases the costs of
doing business and can even put a business out of action for periods of time. This can have
devastating consequences for the ability of a business to serve their customers’ needs.
FSB research found that the top three cyber-crimes experienced by FSB members were:
• Phishing attacks – 48 per cent
• Spear phishing attacks – 37 per cent
• Malware – 28 per cent (on the receiving end of at least one attack)
Recent reports by Her Majesty’s Inspectorate of Constabulary (HMIC) have identified a lack
of local and regional capability among police forces to deal with cyber-crime. There is an
inconsistent patchwork of performance and standards of response and investigative
capacity9. Fraud and cyber crime have in many ways become synonymous. Fraud is also a
significant and growing issue for small businesses. Nearly 10 per cent of FSB respondents to
our business crime survey had been the victim of ‘card-not-present’ fraud. Both fraud and
cyber crime strike at the very heart of the business world, reducing levels of trust in
commercial activity.
The City of London Police have suggested, based on recorded incidents by the National
Fraud Intelligence Bureau (NFIB), that 70 per cent of fraud is committed online10. The
existence of these crimes on a significant scale increases the cost of doing business for
small businesses. The cost is not only the direct financial losses but includes indirect costs
such as the negative impact on business reputation and associated reduction in customer
confidence and trust. It can also result in higher costs for accessing vital small business
services such as insurance, banking and loans.
While many FSB members are taking basic preventative measures (80 per cent are
installing security software on their business ICT) many of the available cyber security
standards are failing to make an impact with FSB members (only 2 per cent had taken up
either ISO 27001 or the Government’s Cyber Essentials Scheme).
Recommendations:
• Make cyber crime a priority for MPS.
• Encourage national government to keep cyber crime and fraud at the top of the crime
policy agenda and develop an effective national policing effort to tackle it.
• Work closely with government cyber-resilience initiatives such as the National Cyber
Security Centre, Cyber Essentials Scheme, Cyber Aware, Get Safe Online and business
9
HMIC (2014). ‘The Strategic Policing Requirement: An inspection of the arrangements that police forces have in place to meet
the Strategic Policing Requirement’, can be accessed at: https://www.justiceinspectorates.gov.uk/hmic/wpcontent/uploads/2014/04/an-inspection-of-the-arrangements-that-police-forces-have-inplace-to-meet-the-strategic-policingrequirement.pdf HMIC (2015). ‘Real lives, real crimes: A study of digital crime and policing’, can be accessed at: https://www.
justiceinspectorates.gov.uk/hmic/our-work/digital-crime-and-policing/real-lives-real-crimes-a-study-of-digital-crime-andpolicing/
10 City of London (2014). ‘Commissioner Speaks out on Cyber Security’.
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representative bodies such as the FSB to help inform and educate small businesses about
the preventative steps needed to reduce the risk of cyber attacks.
• Encourage significant improvements to the support available to victims of cyber crime,
e.g. by training all frontline staff in how to more effectively handle incidences of such crime.
• Ensure that the MPS Cyber Crime Unit has a cyber-investigation capability with the ability
to leverage to get adequate funding and outside expertise when needed.
• Ensure MPS take advantage of the planned improvements in the capabilities of the
National Fraud Intelligence Bureau and Action Fraud to instigate a ‘step change’ in the
identification, investigation and prosecution of fraud by prioritising fraud against business
and investing in the capacity of their local force to investigate fraud.
• Improve partnership working with other Constabularies through:
– Strengthening Regional Organised Crime Units (ROCUs) with more capability and
capacity.
– Supporting more inter-regional joint-working.
– Contributing pro-actively towards ensuring a seamless and more effective nationwide
exchange and analysis of intelligence on fraud and cyber-crime against business.
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A Better Criminal Justice Service for London
The Police and Crime Plan’s stated aim ‘to see that London is served by a criminal justice
service that gets the basics right – bringing offenders to justice and putting the victim first’
(page 29) is welcomed by FSB.
Too often offenders have not been brought to justice because the theft from or damage to a
business was deemed to be of small value. However, it should be remembered that so
called ‘petty theft’ can easily wipe out the daily or even weekly profit of a small business,
endangering the survival of the business and potential amenity loss to the community.
We hope the remit of the proposed Independent Victims Commissioner for London will
recognise small business owners who have been victims of business crime (page 31).
We hope that the pledge to work with businesses to ensure that the laws prohibiting the
sale of alcohol to minors will include supporting retailers and licensed premises to comply
with their legal obligations.
Recording Business Crime
In order to tackle business crime, the police need an idea of its scale and scope. The move
to record incidents against businesses separately from other types of crime is essential to
allocating resource to deal with business crime. We are pleased to see that MPS use the
National Police Chiefs’ Council (NPCC) specific definition of business crime and hope that the
Business crime dashboard11 on the Mayor of London/London Assembly website is kept
updated.
In addition, too few businesses currently report incidents of crime. Business owners are
fatalistic about the interest of the police in crime against business and the capacity of police
forces to do much about it. Recent FSB research from small businesses revealed:
• 24 per cent do not report any crime against their business or staff.
• 33 per cent only report the most serious crimes.
• Only around one in five reported all the crimes their business and employees experienced.
Many reasons were given by FSB members for this reluctance. However, the most
frequently cited reason was a feeling that reporting the crime would not achieve anything
(46 per cent). Other reasons that were offered, included a perception that the police would
not be able to find/mount a successful prosecution of the perpetrators (38 per cent),
reporting a crime would be too time consuming (26 per cent) and a negative experience of
previously reporting a crime to the police (21 per cent).
Recommendations:
• Encourage small businesses to report every crime. Take measures to break down some of
the negative perceptions such as by widely publicising how and where to report crime,
making the process as easy and user-friendly as possible with minimum service user
standards and seamless access to victim support services.
• Keep the Business crime dashboard12 on the Mayor of London/London Assembly website
updated.
11
https://www.london.gov.uk/what-we-do/mayors-office-policing-and-crime-mopac/data-and-research/crime%20/businesscrime-dashboard
12 https://www.london.gov.uk/what-we-do/mayors-office-policing-and-crime-mopac/data-and-research/crime%20/businesscrime-dashboard
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• Continue to conduct the ‘MOPAC Business Attitude Survey’ and use the data to improve
the service provided to the small business community.
• Publish nationally comparable data on business crime (reported and detected) to enable
businesses to compare the performance of the MPS with other forces.
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