1.1 Norwich City Council has adopted this policy as a key policy to address anti- fraud and corruption issues in conjunction with welfare reform messages and enhancing public confidence in the council’s administration of taxpayers’ money.
1.2 The anti-fraud policy and particularly this publicity section aim to:
- make clear the connection between saving public monies and the fraud work that achieves this.
- dispel the belief held in some quarters that fraud is a victimless crime
- demonstrate consistent action is taken for both complex frauds and the perceived lower level frauds
- ensure that tough action taken against persons who commit fraud is utilised as an effective deterrent to others
- alter perceptions of this area of work to move for an image of petty bureaucracy or snoopers to one of professional public funds watchdog.
- ensuring that action taken is consistent with Norwich City Council policies and legislative provisions as well as being in the public interest
1.3 This policy covers the methods by which the work of the anti-fraud services within Norwich City Council will be promoted including the publicity associated with specific cases.
2 Publicity categories
2.1 Publicity takes many forms including leaflets, posters, press releases / articles, advertisements, intranet or internet media
2.2 It is imperative that all available forms are maximised to promote an anti-fraud culture throughout the organisation and to the public. However great care is needed to ensure that publicity in relation to anti-fraud work is positive and does not undermine the service or reinforce the negative perceptions of this area of work.
2.3 Thus publicity needs to focus on three key areas:
- Proactive work of anti-fraud services
- Specific cases pursued by anti-fraud services, e.g. specific prosecutions / convictions sought
- Reactive responses to media enquiries.
3 Proactive publicity
3.1 This area of work is essential to promote the work of the services and ensure that others are aware of this work and thus deterred from attempting fraud. The aim of this publicity is to increase the profile of anti-fraud work across Norwich City Council and the wider community in order to promote the referral processes and deter fraud.
3.2 An internet / intranet site shall be maintained which sets out details as to how to contact the internal audit Investigators and how to report fraud. The site will also provide links to relevant policies.
3.3 Any leaflets and posters used for fraud awareness purposes shall be reviewed annually to reflect any necessary changes.
3.4 It is intended that fraud awareness training shall be part of the council’s corporate training / induction system.
3.5 In addition to the above the work of anti-fraud services shall be promoted periodically both within the council and to the general community.
3.6 For high profile cases prosecuted the publicity shall consider whether the work of anti-fraud services shall be promoted eg volumes of cases referred, investigated, prosecuted, convicted etc.
4 Specific cases
4.1 Great care must be taken when publicising any specific case of fraud, theft or corruption. Data Protection Act and Human Rights Act provisions are key legal protections provided to those suspected of committing such offences and must not be breached by the council’s attempts to promote anti-fraud work.
4.2 However the publicity attached to any specific case is a necessary element of promoting the deterrent effect of anti-fraud work as it demonstrates actual instances and consequences to individuals.
4.3 Any decision that the council should prosecute an individual, individuals or organisation must be taken following a formal quality assurance procedure.
4.4 Any decision to pursue prosecution will be taken on the basis of professional advice, the merits of the case itself and any applicable guidelines relevant.
4.5 All prosecutions should include a consideration of publicity issues and ensure that the council’s communications team are involved / aware of the issue so that the council can adopt a proactive publicity strategy and avoid the need to react to press enquiries.
4.6 A specific decision will be taken and recorded by the head of service to issue a press release for any specific case. In all other cases a press statement / position shall be prepared to address any potential press enquiry.
4.7 Press releases shall be prepared that promote the council’s anti-fraud policy and maximise the deterrent effect of prosecutions.
5 Reactive responses to media enquiries
5.1 Ideally the above measures aim to minimise the need for this where the council proactively provides relevant information to promote anti-fraud through local, and possibly national, media.
5.2 Press queries will arise on some occasions and it is essential that they are responded to in such a way as to promote the anti-fraud policy of the council.
5.3 Responses to press queries regarding specific individuals must not breach data protection or human rights legislation.