ࡱ>  bjbj=G=G 4_-_-ф8lz JBJDJDJDJDJDJDJ,L_ORpJpJPHJPPPBJPBJPPNfCHP!dPE0.JJ0J>EOPO`HPHpJpJPJO :   ACTSO (2014) Summary of Doorstep Crime Report to National Tasking Group, May 2014. Ruth Andrews SUMMARY OF DOORSTEP CRIME REPORT TO NATIONAL TASKING GROUP, MARCH 2014: Introduction: In October 2013, North Yorkshire Trading Standards were tasked by the National Tasking Group of the National Trading Standards Board to undertake a project examining current efforts to tackle Doorstep Crime (DSC) in England and Wales through enforcement, intelligence and prevention. To establish a baseline, the project team undertook the following work between October 2013 and February 2014: Surveyed the 166 local authority trading standards services in England and Wales. Surveyed the 8 regional trading standards Scambuster teams in England and Wales. Introduced a Victim Impact Survey for all new victims of DSC, to examine the nature of victims, the impact of such crime on victims, to identify contributory factors to victimisation, and to identify prevention opportunities. Examined existing trading standards intelligence held on the Citizens Advice database and on Memex and IDB, the two main intelligence systems used by trading standards. Examined the wider intelligence picture including data held by the National Fraud Intelligence Bureau and Operation Liberal. Engaged with the third sector including charities and voluntary organisations with a primary interest of representing the interests of the older adult population or those living with health conditions which are prevalent in the older adult population. Held a national conference for the trading standards profession to share the learning from the project to date. This document is a very brief summary of the full report submitted by the project team to the National Tasking Group in March 2014. Definition of DSC: There is currently no widely accepted definition of DSC, which makes the analysis of this crime area and the response to it more problematic. The following definition was drafted by the project team: Doorstep crime can be defined as offenders cold-calling at the homes of consumers, most commonly older adults and / or vulnerable consumers, offering to carry out property repairs such as roofing, tarmac work, block paving, fascia and soffit installation and gardening work, or to sell products such as fish, furniture, mobility aids, security systems and energy saving products. It often involves charging extortionate prices for the goods or services, including charging for unnecessary goods or services, deliberately damaging property in order to obtain work, leaving work unfinished, substandard and poor quality work, claiming to have done work which has not been done, claiming work is required urgently, and false statements being made about a variety of things including goods and services being required for specific reasons and membership of trade associations. It may also involve intimidating and / or aggressive behaviour on the part of the offenders, or an element of befriending or grooming of victims, to facilitate the offending and / or repeat victimisation. In some cases, the visit to the consumers home may be preceded by a telephone cold call. This is more common with sales of goods. In other cases, the consumer may respond to a flyer received at their home. The offenders involved in doorstep crime are also often associated with distraction burglaries, or sneak-in thefts, and can switch between both offending methods depending on the victim and the circumstances. The impact of DSC: It is widely accepted that DSC is targeted at older and / or vulnerable adults, and can include repeat offending over many months and years. This can involve elements of grooming and befriending, pressure and aggression. DSC can have a serious and detrimental effect on victims, including in the long term. Whilst there is currently no research material looking at the impact on DSC victims specifically, Home Office research studying the effects of burglary on older adults showed that, two years after the incident, older victims of burglary were 2.4 times more likely to have died or to have gone into residential care than their older adult neighbours who were not the victims of burglary. The ageing population is increasing opportunities for offenders, including the associated health issues facing older adults such as dementia, and the issues of social isolation and loneliness. The independence strategy, which aims to keep older adults independent in their own homes for longer, also provides greater opportunities for offenders to access the vulnerable. Offenders: DSC Investigations by trading standards and the police have also identified a number of key features of offenders, as follows: Many OCGs are family gangs who offend together. Often the youngest members of the gang have been involved in the offending from a very early age, including from the age of 10 upwards. When offenders reach early adulthood, they are well practised in this type of crime and in avoiding detection. The offenders use a number of tactics to secure their anonymity, such as failing to provide the consumer with their genuine details, use of accommodation agency addresses, use of mobile phone numbers (many of which are pay as you go phones and therefore often untraceable), failing to provide any paperwork, leaving vehicles parked away from victims homes, insisting on cash payments, changing their appearance etc. Offenders have the ability to swap business identities at a moments notice. This includes use of different business names on magnetic signs on vehicles, clothing and business paperwork, and rapidly changing the vehicles and mobile phones they use. Offenders use a variety of bank accounts, including those in the names of third parties, to avoid detection. Details of victims are passed between offending groups. Offenders sometimes delay targeting a victim in the hope of physical and mental deterioration. The project established that DSC offenders can be split into three distinct categories: Legitimate guise: Such offenders often use a limited company to undertake their offending. They may have a history of convictions, including rogue trading or scams targeted at consumers, which may or may not have previously involved DSC. Some choose and deliberately set out to defraud and mislead vulnerable / older adults, others fall into the offending after identifying the opportunities provided by such a customer base. These businesses may offer general property repairs or specialise in one particular sector, for example roof coatings or double glazing. Alternatively, they may supply other products to customers such as house alarm or emergency response / call systems, mobility aids, adjustable beds and chairs, energy or energy saving devices. Due to the existence of many legitimate businesses in these sectors, the difficulties facing consumers are perhaps increased with this group, as they are unable to distinguish the legitimate businesses from the illegitimate ones. Such offenders are more likely to choose victims from mailing lists or existing suckers lists, customer databases, or from traditional cold calling of whole areas / streets, rather than visiting pre-selected victims or cold calling at houses that cause concern. However, they will exploit opportunities for repeat offending, where that arises. The offenders will advertise through traditional methods, increasing their legitimate appearance, and are likely to have associated websites. These offenders operate on a larger scale, often regionally or nationally, with far greater numbers of customers. These offenders are more likely to be visible to trading standards, as a result of the large numbers of complaints which they generate. Chancers / Apprentices: These offenders can be considered less organised and professional than groups i. and iii. Their offending is of a more sporadic nature, with opportunities being utilised to identify and target new victims through cold calling. They often identify victims by stumbling upon them, rather than targeting pre-existing victims. These offenders may carry out all types of property repairs, including gardening work, and may also include fish sellers. Again, these offenders may have a history of other convictions, including burglary. They will cold call whole streets, looking for new victims, and will take opportunities as they arise to repeat target. They offer poor quality, unnecessary and over-priced work. They can constitute lower level OCGs or subsequently develop into OCGs, but are perhaps more likely to operate on a level one and two basis. This group also includes lone offenders as opposed to gangs. Professional / Career offenders / Organised Crime Groups: This group are highly organised and professional offenders, who have developed their MO and skills over a number of years. They often work in gangs, which can include other family members and associates. The gangs can also include casual labour, including vulnerable young males from deprived areas, those with alcohol and drug dependencies, the unemployed and homeless, immigrants etc. This group includes those OCGs from the travelling community, but not exclusively so. These offenders travel long distances to offend, often staying for short periods in any one area, with the means to do so. They exploit the opportunities which arise from crossing local authority and force borders. In some cases, these offenders are now known to travel into Europe to offend. Evidence also exists of offending taking place in New Zealand, America and Canada. Again, they may advertise using traditional methods, and many have websites to improve their professional appearance. This is exacerbated by the use of accommodation agencies. They share information regarding vulnerable victims between gangs, and often undertake repeat targeting over extended periods of the most vulnerable and affluent. These offenders develop a high level of skill for interaction with vulnerable adults and use tactics such as claimed religious associations to help reinforce their legitimate appearance. This group are often the most difficult offenders to detect and bring to prosecution and are perhaps the most neglected category of offenders from all three groups. They require the most detailed and often protracted investigations to secure convictions. They also adapt their behaviour, learning from other offenders about detection methods used by law enforcement agencies, to alter their behaviour and decrease the chances of them being caught. This group make widespread use of money launderers, to launder the proceeds of their offending. This can include female members of their family groups, or casual acquaintances who accept a small fee to process cheques on their behalf. These offenders can be considered to be one step ahead of law enforcement. Each of these three categories of offenders requires a separate strategy to tackle them. The scale of the problem: There are currently around 17,000 reports relating to DSC made to trading standards annually in England and Wales. Due to established low reporting rates, it is estimated that this represents only 10 - 20% of incidents that are actually taking place. So in fact, the true number of incidents annually is estimated to be between 85,000 170,000. Some estimate reporting levels are as low as 5%, which would mean the number of incidents could be estimated at 340,000. Examination of a sample of reports shows that average amount of consumer detriment per incident is around 1,000. The total annual detriment caused to consumers by this crime area can therefore be estimated at between 85m and 170m. Using the 5% reporting level, the amount of detriment could be as high as 340m. A further 1,000 incidents are reported annually to the National Fraud Intelligence Bureau (NFIB) with an average consumer detriment of 4,650, equating to a further 4.65m of consumer detriment. Using this figure as the average consumer detriment for reports to trading standards, the annual amount of detriment can be estimated at between 395m and 790m. An unknown quantity of further reports are made to Police forces and not passed on to Action Fraud and NFIB, or to trading standards. These include reports which are incorrectly classified as civil matters and non-crimes. These figures cannot be estimated. The primary reason for the inability to assess these figures is the absence of a Home Office crime recording code for DSC. The most complained about trade types are roofing, including fascias & soffits, tarmac and block paving work, general property repairs and gardening work. Low-reporting rates: As detailed above, there are very low reporting rates for DSC. The following factors go some way to explain the low reporting rates: Fear of repercussions from offenders or their associates. Fear of getting involved in the criminal justice system / process. Fear of loss of their independence. Lack of mental capacity. Not understanding / accepting they are a victim. Social isolation and loneliness. Embarrassment / self-blame. Considering it is inappropriate to report. Believing it is futile to report. Not knowing who to report to. Generational issues. Wanting to ignore the incident or forget about it. The current trading standards response: The results from this project clearly demonstrate an existing widespread commitment from the profession to tackling DSC and many dedicated officers within the profession who have developed a specialism / interest in this area. Results from the national survey conducted with 166 local authorities (LAs) in England and Wales (which generated a 95% response rate from 157 authorities) showed 80% give high priority to DSC, 63% give high priority to DSC intelligence, and 58% give high priority to the prevention of DSC. The survey results also showed that 53% of LAs said they allocate between 0 & 10% of their budget to tackling DSC, 36% of LAs said they allocate between 11 & 20% of their budget, and 11% of authorities say they allocate 21% or more of their budget, with only 7 LAs allocating 31% or more. However, the current financial climate is threatening this response. A NTSB Workforce survey of LAs in 2014 showed budgets had fallen by 21.7% between 2010/11 13/14, but with inflation in real terms it is 30.6%. Estimates for 2015/16, are for further reductions of 29.8% (in real terms 39.9%). A further survey of those attending the National DSC conference in April 2014, showed 35% of LAs had less budget to tackle DSC going forward in 14/15 and beyond. In addition, the exact response that any one victim of DSC will receive is a postcode lottery, both in terms of the response from trading standards and from other agencies and organisations. The survey results also highlighted a number of areas where significant improvements could be made, as follows: There is currently very poor monitoring of DSC incidents and data gathering and analysis, both on a local, regional and national basis. The absence of appropriate and widely adopted performance targets for services means efforts to tackle doorstep crime are disparate and sometimes unfocussed. This in turn leads to a failure of services and the profession as a whole to be able to demonstrate the true impact and importance of their work. There is a need to improve the safeguarding response of the profession and in some cases, a failure to address the long term support of victims and the impact of DSC on them. There is a very low level of prosecutions of DSC offenders by the profession. On average, 163 prosecutions are taken each year, which equates to less than one per authority. It can be estimated that prosecutions result in only around 1% of all reports of DSC to trading standards. In reality, there are less than 20 LAs who regularly prosecute DSC offenders out of the 166 authorities in England and Wales, and when the prosecutions for these authorities are removed from the above figures, the average number of prosecutions taking place annually is extremely low. There is a widespread lack of use of the tools provided by the Proceeds of Crime Act, both to develop criminal investigations and to obtain confiscation of assets. This in turn affects the ability to obtain compensation for victims. Due to the current intelligence picture, there is a failure to fully understand the behaviour of offenders and to tailor responses to DSC accordingly. There is a lack of referrals through the existing tasking process in relation to DSC offenders, and more noticeably in relation to DSC OCGs. This results in a low level of investigations and prosecutions by Scambuster teams, again most noticeably in relation to OCGs. There is currently a good response to prevention of DSC, but there is a widespread lack of evaluation of prevention strategies. The current intelligence picture for DSC in trading standards is very weak. There are a high number of intelligence reports submitted on Memex and IDB, but many of the reports are poor quality and have not been submitted in a timely manner. There is also a wholesale failure to undertake comprehensive analysis of the intelligence available. This results in a current inability to identify and target OCGs. Citizens Advice Consumer Service (CACS) data is currently also unhelpful in establishing the nature and extent of DSC and in some cases reports are misclassified. Much of the profession is also missing intelligence and reports by not routinely examining notifications from CACS. The scale of OCGs involved in DSC can be seen from data obtained from Operation Liberal and the National Crime Agency. There are currently 143 OCGs scored with their primary criminal intent being distraction burglary or rogue trading. This comprises of over 1,000 individuals. The Police response: It has already been noted above that police forces are currently unable to report on the number of DSC incidents in their force areas. Research conducted in 2012 also identified the following key issues within forces in terms of their response to DSC (rogue trading): Abrogation of responsibility / no ownership of such crimes. Police and trading standards partnerships with a small p. Filing incidents as civil disputes. Failure to comply with National Crime Recording Standards (NCRS). Provision of poor service to vulnerable victims. Premature finalisation of investigations due to low priority. Premature finalisation of investigations due to complexity. Supervision / management complicit in police practices. Lack of training or knowledge of police powers. Lack of knowledge of the Fraud Act 2006. CPS attitudes mirroring those of the police. Stretched resources, budget cuts and police target mentality. Everybodys problem is nobodys problem as a result of dedicated teams. Inadequate control systems, measurement and monitoring. Poor structure and governance of rogue trader crime. Strategies to tackle DSC: Any strategy to tackle DSC should include six key objectives: To identify the extent of DSC; To manage the project sensitively to prevent an increase in the fear of crime; Raising awareness of potential victims and those in contact with them; Establishing partnerships between private, statutory and voluntary sectors; Dealing more effectively with crime detection; Involving the wider community in prevention strategies. Such a strategy should include four approaches: Enforcement Situational Educational Safeguarding and support of victims Performance indicators should include targets to: Reduce crime Increase reporting Safeguard victims Opportunities: A number of opportunities currently exist which serve to assist efforts to tackle DSC: DSC is widely recognised as being a high priority by the profession, NTSB / NTG, & the Consumer Protection Partnership (CPP); The introduction of the IOM and associated training, together with the trading standards National Intelligence Team, the Regional Intelligence Analysts and the tasking process; Opportunities for closer working with key partners such as the NFIB, Operation Liberal and the National Crime Agency (NCA), particularly in relation to OCGs; The current Government agenda regarding maintain the independence of older adults and their support for the Dementia Challenge; The safeguarding agenda leading to an improved focus on financial abuse of older adults, including as a result of The Care Bill. Strong support from key stakeholders; and Sharing of best practice in the profession. Threats: A number of threats also exist which serve to hamper efforts to tackle DSC: Availability of resources / the current financial situation facing LAs. The weak intelligence picture in relation to DSC; The failure of other agencies to address DSC (for example the police and the Home Office) Victim Impact Survey results: There are a number of key findings in relation to victims of DSC which have been obtained from the results of the Victim Impact Surveys, conducted with newly identified victims since January 2014, as follows: 85% are aged 65 and over, 59% 75 and over, and 18% aged 80-84. There is a 50/50 male / female split (This represents an increase in the proportion of male victims). 62% are living alone. 63% have a physical impairment, 43% a sensory impairment, 15% a mental health condition, 14% a cognitive impairment, 35% a long standing illness such as cancer, diabetes, heart disease etc. 35% take more than 4 medications daily. 36% have falls. 24% have concerns about their memory, or their family or carers have such concerns. 33% have experienced bereavement in the past 2 yrs. 36% have experienced depression in the past 6 mths. 37% miss having people around. 32% experience a general sense of emptiness. 40% feel lonely, with 31 % of those feeling lonely every day. 14% have contact with someone outside their home once a week or less. 48% have contact with their neighbours once a week or less. 33% have an increased fear of crime as a result of a recent DSC incident. 9% are known repeat victims. On a scale of 1 to 10, with 10 being the worst affect, 47% rated the effect of the crime on them as between 6 and 10. 23% said it had affected their health. 40% said it had resulted in them having reduced confidence generally. 28% said it had left them feeling down or depressed. 46% said it had caused them financial detriment. 11% said they felt a lot more afraid of crime as a result, and 22% said they felt a little more afraid of crime. 16% had not told anyone about the crime, with 40% of those saying the reason was due to embarrassment. 48% said they felt the offenders were trustworthy. 65% said they were friendly. And 58% said they were polite. (Just 17.5% said they were suspicious, 16% forceful, and 12.5% untrustworthy.) 35% said they felt comfortable and 30% said they felt in control during the offending. 49% said they felt pressurised. 56% said they felt defrauded or conned after the event, 54% said misled, 49% said angry, 34% disappointed and 26% upset. 15% leave their house once a week or less. Householders leave their homes for the following reasons: 90% to go shopping 75% to attend medical appointments 53% to go to the hairdressers 30% to attend a place of worship 73% to go to the bank or post office 42% for social activities such as lunch clubs, day centres, other clubs etc. Many undertake hobbies in isolation at home, for example 72% watch the television, 75% read books or magazines, 52% listen to the radio. 70% had received doorstep callers at their homes in the past 6 mths, and 61% had dealt with doorstep callers previously. 25% felt they had been the victim of scams in the past. 83% receive unsolicited telephone calls. 88% receive unwanted mail. 90% felt safer and more confident after TS interventions. 71% were happy to take part in further surveys to examine the impact of the crime, and of safeguarding interventions, 6 and 12 months after the incident. The Financial Sector: The financial sector has a vital role to play in helping to protect vulnerable adults from financial abuse, including those working in banks and building societies and post offices. The results above show that 73% of DSC victims leave their homes to visit those providing such financial services. Other than attending medical appointments or going shopping, this is the most common reason for victims leaving their homes. As such, those working in this sector are most likely to have contact with victims and have an opportunity both to make safeguarding alerts when they suspect financial abuse, and to raise awareness and increase prevention through customer education. Partnership working: The following table summarises the responses from the LA trading standards survey in relation to their engagement with partners. Organisation:% of LAs working with organisation:No. of LAs working with organisation:Age UK 60.40% 90Alzheimer's society 18.79% 28Stroke Association 8.72% 13RVS 2.68% 4Health and Adult Services 65.77% 98Police 97.99% 146Memory Clubs/Cafes 10.74% 16Carers 44.97% 67Meals on wheels providers 21.48% 32Church groups 22.82% 34Befriender services 13.42% 20Lunch clubs 24.83% 37Home library delivery services 12.08% 18Banks 54.36% 81Post offices 17.45% 26Neighbourhood Watch coordinators 66.44% 99Victim Support 34.23% 51Other * 22.15% 33 This shows reasonable engagement with some organisations such as Age UK, Neighbourhood Watch and Health and Adult Services and the Police. However, there is currently poor engagement with many third sector providers, including those who are in contact with some of the most vulnerable, such as the housebound. As a result, the project team has engaged with a number of leading key charities and produced action plans for improving joint working on a national basis and awareness-raising amongst their staff and volunteers and the public. There is still a large amount of work to do in relation to this area. Safeguarding: The national survey of LAs showed that only 66% of LAs are currently undertaking safeguarding work with victims. Dealing with a DSC victim should not centre solely around investigating any criminal offence and gathering evidence, or undertaking some initial target hardening work. Officers need to take account of any form of abuse which is apparent and the longer term effects of the DSC incident or the individuals needs. Further risks are posed to vulnerable adults from living with dementia and social isolation and loneliness. Therefore, any approach to DSC needs to take account of these issues and ensure that the vulnerable adult is not left vulnerable after trading standards leave. Further work is required to increase the percentage of LAs dealing with safeguarding issues effectively, including through partnership working with other agencies and the voluntary sector. Key Recommendations: A number of recommendations were made by the project team to the NTG and NTSB. The key recommendations are summarised below: Academic research should be carried out in relation to three key areas: To examine the typology of offenders, primarily through conducting prison interviews with offenders and also with released victims of slavery / forced labour of DSC OCGs, To examine the typology of victims, including through in-depth interviews with victims. Situational analysis of DSC offending, to identify prevention opportunities. Further work should be carried out to establish the true amount of financial detriment caused to victims of DSC, and the harm caused. Evaluation should take place of existing prevention strategies and methods. LAs should improve their response to safeguarding of victims, including in the longer term. This should include consideration of and participation in the national Victim Impact Survey designed and administered by the project team. Efforts should be made to co-ordinate nationally data recording and analysis by trading standards in relation to DSC, including the introduction of an intelligence requirement and annual reporting requirement. LAs should reconsider and refocus their performance measures in relation to DSC to three key areas: crime reduction, increased reporting, and safeguarding of victims and potential victims. A media strategy should be used to increase the levels of awareness, taking advantage of the appetite of the press to report in relation to this area of crime. Partnership working with key strategic stakeholders in the third sector, other agencies and government should be developed and progressed. A national survey of householders should take place to update the results of the survey conducted by TSI in 2002. This should examine consumer attitudes to DSC and cold callers, and the levels of crime and cold calling taking place. A review should take place of prosecutions of DSC to assess the effectiveness of current enforcement efforts. This should explore the levels of prosecutions, the nature of them including the offences prosecuted and the offender types, and the results of the prosecutions including convictions, custodial sentences and confiscation orders resulting. This should also include an examination of the numbers of LAs prosecuting offenders. This should also include examination of whether LAs are prosecuting multi-victim cases and using higher level offences such as conspiracy, fraud, blackmail and money laundering. A review should also take place of the levels and nature of referrals to Scambuster teams for investigation, and of the investigation and prosecution of cases by the teams of DSC offending. A dedicated intelligence resource should be allocated within the NIT to ensure the intelligence received from the profession is of sufficient quality, developed adequately and analysed to identify trends and OCGs who can be tackled effectively. Work should be carried out to improve the quality of data captured by the Citizens Advice Consumer Service and that this data is also being used to inform efforts to tackle DSC. This should also include recommendations to LAs with regards to monitoring and use of the data on a local level and of ensuring CACS notifications are examined. Intelligence sharing with the NFIB and NCA should continue, to explore the data captured by those agencies in relation to DSC and what actions are resulting. Fraud impact indicators should be introduced by trading standards, to further demonstrate the impact if such offending on victims. Joint working should take place the project team and Operation Liberal and the National Crime Agency, to explore opportunities to jointly tackle identified DSC OCGs. Best practice materials should be provided for use by the profession in relation to enforcement, intelligence and prevention. Further work should be carried out to examine the use of and benefits of mapping / population segmentation / customer insight information in relation to targeting resources for DSC prevention. Further work should be carried out to promote the use of community champions / volunteers to assist with educational, awareness raising and prevention work for DSC. Engagement with those accessing hard to reach communities such as the housebound and isolated should be improved, for example with places of worship / faith groups, health services, meals on wheels providers etc. LAs should widen the field of partners with whom they currently engage, including through exploring external funding opportunities, for example with Police and Crime Commissioners, adult services, the police and public health. Further work should be carried out on a national basis with the financial sector, to improve the response to protecting vulnerable customers, identifying offenders accounts and making safeguarding referrals for vulnerable adults suffering from financial abuse. Work should be carried out with third party suppliers to offenders, for example those providing flyers, business cards, and other business paperwork, or those supplying magnetic signs for vehicles, or raw materials such as fascias and soffits, to raise awareness of DSC and educate suppliers regarding their money laundering responsibilities. Engagement should take place with the Home Office and relevant ACPO leads regarding improving the existing police response to DSC, including the number and level of prosecutions of offenders, and recording an analysis of key data. Close working should take place between the DSC project team and the Consumer Protection Partnership (CPP) DSC working group. Links and cross-overs with other NTSB project areas should also be utilised, for example the National Scams Team and the National e-crime Team. Plans 2014 / 15: Funding has now been secured by the project team for 2014/15. The funding will be used to deliver new business plan, incorporating many of the above recommendations. Key areas of work which will be progressed are as follows: Academic research Engagement with the CPP National Consumer Week in November 2014. Intelligence development, particularly in relation to OCGs. Conducting a three month trial in the Yorkshire and Humber region to examine all DSC incidents reported and to develop intelligence and the enforcement response, with a view to identifying OCGs and sending tasking packages to regional and national tasking for allocation to Scambuster teams. Development of data recording and analysis for DSC. Engage with appropriate Government departments including BIS, the Home Office and Department of Health. Develop and share best practice guidance materials with the profession and introduce a DVD training package for officers. Work with the financial sector and third sector to develop and improve a joint response to tackling DSC. 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