March 2026 ~ IPFGB is “Code Ready” for UK GDPR Code of Conduct
IPFGB takes Data Protection seriously. As such, since 2018, each case instructed to IPFGB is subjected to a Data Protection Impact Assessment; not least a KYC test. In most instances, personal data will naturally be controlled and/or processed without the express consent of the data subject, and it is not unknown for an instruction to fail these tests, and the assignment declined.
In conjunction with the Information Commissioner’s Office, the Association of British Investigators’ UK GDPR Code of Conduct for Investigative and Litigation Support was launched in November 2024, since when we have awaited the ICO’s authorisation of the monitoring body. We understand that that SSAIB has now been appointed, and as IPFGB successfully completed a guineapig examination by SSAIB as long ago as January 2025, we anticipate we will be one of the first companies to be officially accredited.
That process demands a regular update of training and, to that end, IPFGB has this month attended and successfully passed the assessment for the ABI UK GDPR good practice workshop and assessment for investigative and litigation support service providers hosted by the ABI. That training covered the topics:
Roles and responsibilities,
Lawful bases,
The data protection principles,
Data protection impact assessment,
Legitimate interests,
Processing for domestic & household purposes,
Invisible processing,
Consent to share in locate cases.
Unsurprisingly, news of the imminent introduction of the code has been welcomed by The Law Society, it is hoped that the legal profession in England and Wales as a whole will warmly embrace this Code of Conduct, demonstrating a preference for investigators who have proved that they understand and adhere to DP legislation; thereby assuring their clients that every step has been taken to ensure contractors operating on their behalf are doing so within legal margins.
February 2026 ~ Abandon the ‘Dead Horse Syndrome’
In favour of collaboration between professionals and law enforcement
Well done, the Met! That sort of teamwork is so encouraging, I have just read on LinkedIn this morning a posting by a police sergeant, drawing attention to the cooperation last night between a private security firm [MyLocalBobby] and the Met’s West End Town Centre Team. The exercise, described as a ‘partnership’, led to the arrests of mobile phone thieves.
So, what’s the Dead Horse Syndrome, and what does it have to do with cooperation?
The saga of the dead horse, found at the beginning of a night shift on the boundary between two police districts, goes back to Victorian times. As each beat man arrives at the scene throughout the night, he struggles to push the expired beast firmly off his patch; only for his opposite number from the neighbouring district to reverse the process an hour later. And so it goes on throughout the night as they complete their patrols; all to save having to fill out a report. In the morning, the local knackers yard turns up and carts off the animal’s remains, the police having succeeded in doing nothing.
A similar myth from a bygone era, and local to this area, recounts that a human corpse floating in the River Avon was consistently barge-poled to the opposite bank . . . neither Bristol nor Somerset cops choosing to do their duty.
Sadly, we can compare this fictional activity to the modern way UK police forces actually approach fraud. Rarely are the fraudster and his many victims in the same force area, so in order to avoid taking on the cost of preparing the prosecution, each force to whom the reports are made will strenuously push the “dead horse” back over the boundary line, the corpse eventually falling into a pothole, [to provide a contemporary analogy]. .
So often, IPFGB has provided police with results of a full and successful investigation, comprising a detailed covering report which explains the crime and methods of approach, together with robust s9 witness statements, and properly recorded exhibits; all proving the criminality of those responsible. Reports to the police now have the reputation of being routinely met with ambivalence; so often victims, be they commercial companies or individuals, choosing to turn to professional investigators who have the credibility and skill to consider the evidence and viability to progress.
Probe, Prove, and Pursue
Commercial companies falling victim of fraud have learned that reporting oft-substantial crimes to the police is counter-productive; the cost-effective route being to engage professional investigators from the outset, to probe, prove, and pursue through the civil process.
In a utopian world, it would be simpler for forces to expend less time and energy dodging fraud cases, and consider engaging with professionals who can provide the evidence they need. And, of course, just as in this enthusiastic and welcome street offence collaboration in Leicester Square last night, the victims would benefit. Now, there’s a novel thought!
Dick Smith QPM
IPFGB
[Edited version published on ABI website 08-Feb-26