Tackling corporate fraud in the Middle East
Corporate fraud in the Middle East
Tackling corporate fraud in the middle east has become even more challenging during the pandemic. ICAEW Insights sat down with our founder and chief executive, Zafar Anjum, to discuss the rising levels of corporate fraud in the middle east during the pandemic and how CRI Group is using AI to investigate wrongdoing.
From fake degrees and doctored CVs to false insurance claims and bogus bills, corporate fraud investigators in the Middle East have seen it all. Founder and chief executive of Corporate Research and Investigations Group (CRI) Zafar Anjum told ICAEW his firm was busier than ever as the pandemic triggered a rise in white-collar crime cases across the region.
From its base in London, Zafar’s team has been helping firms in middle east regions like Qatar, Dubai, Abu Dhabi and Saudi Arabia, where Anti-fraud frameworks are still being built out inside the embryonic corporate regulatory regimes that govern the Middle East.“We’ve seen a lot of insurance fraud claim investigations, fake bills, fake debts and fraudulent certificates designed to cheat insurance companies,” Zafar said. “Covid is definitely affecting this because internal controls are relaxed in this environment; people are working from home, so the usual check and balances are missing.”
Nascent regulatory regime
Last year, PwC research found corporate fraud was on the rise across the region, with nearly half of all local companies reporting at least one occurrence in 12 months.
Zafar said the lack of counter-corruption model legislation such as the UK Bribery Act 2010 often meant policing the business areas such as the Dubai International Finance Centre (DIFC) fell to private companies as the regulator doesn’t have the resources to cover the scale of the problem.
“In the Middle East, the issues relating to fraud and corruption are of concern because there isn’t the legislation when compared to developed countries. The definition of fraud and fraudulent activities are different across the Middle East,” he said.
The DIFC was established in 2004 to create a safe and constant upward regulatory environment for companies to do business. One of its aims was to attract investment from London and Wall Street firms and other corporates from both continents. A regulator was created to monitor the market, and the set-up was replicated for the Abu Dhabi and Qatar financial business districts.
The economic “free zones” have relied on firms themselves to help shape the regulatory framework, Zafar said, which has created a mixture of frameworks as standards are broadly aligned with the UK or US markets.
“It’s not national-level legislation, which carries its own problems. There have been scandals, and a lot of that centres on fraudulent financial statements, investment scams,” Zafar said. “A prevalent problem is vendor/third-party screening and false claims, especially during the bidding process. Some firms exaggerate their capabilities and are not able to deliver.”
Investor scams on the rise
A big part of CRI’s work is analysing financial statements, checking backgrounds, and working with compliance teams to root out bad actors.
Zafar said investors scams were also on the rise across the UAE; because the country is ripe for development, some fraudsters had found it easy to prey on foreign victims who are drawn to the opportunities but unwilling to carry out proper due diligence.
The UAE’s family offices are a driving force of industry, and the name carries significant weight regarding deals.
“It’s very risky to invest without carrying out the proper checks, and unfortunately, a lot of people come in blind,” Zafar said. “Fake property claims are rife. It can be individuals who are targeted or small groups of foreign investors. One case involved a handful of US investors who wanted to invest in some economic and humanitarian projects. They wanted to create jobs, other activities, but fell in with people who weren’t with the families they claim to be a part of.”
Family names are often taken by scammers and used to convince investors to part with their cash fairly frequently, Zafar said.
“Because many people don’t care about due diligence, it can end up costing millions of dollars,” he said. “It’s so hard to recover the money, to catch the fraudster. If the victims don’t have local consultants or experts, it can be hard to trace back and recover the damages.” An investor group puts its trust — and its funds — in the hands of an outside business partner without considering a due diligence check on the individual.
Eighteen months into the partnership, the individual has succeeded in fleecing the group of more than $6 million and is still at large.
Investigators such as CRI are increasingly turning to artificial intelligence and machine learning tools to help with screening. Zafar said great strides had been made in tackling corruption and bribery.
Public and private investigation partnerships
Databases of politically exposed individuals, or persons with links to crime, on watchlists or have criminal activity linked to their name or accounts are rapidly being populated for use by regulators and private investigators.
“We’re trying to prove that there is a role for AI in detecting crime and that it can be a part of the investigative process. Machines will scan publicly available databases, criminal cases and the like, and we can check if firms have been blacklisted by authorities such as the Asian Development Bank, IMF or World Bank, which is really helpful.”
In the past, these checks would have to be carried out by hand, one by one.
“It’s hard, almost impossible! Name matches are probably the largest problem in the Middle East. You cannot find a person with the first name Mohammad or last name Khan; you’ll get billions of matches, so we need to develop a database that builds on this with other information. There isn’t a nationwide electoral database in any Middle East region, so you can see how much work still has to be done.”
Credit history, employment checks and previous addresses are a handful of ways the files can be built out, Zafar said, and his team is working on ways to streamline that process.
There was no concept of background screening in 2008 when Zafar’s team started, and despite having come a long way, he said they still encounter fraud on a massive scale.
However, they still encounter fraud on a huge scale, he said.
Alarming numbers
“Sometimes applicants try to falsely fill the gap in their CV, which is dangerous because we don’t know if they’ve spent time in jail,” he said. “More common red flags are fake degrees and fake previous employment references. We found one in 20 applications for a job had fake degrees, experience letters, or fake references in some regions. It’s a huge number, and some of the universities were prestigious too, which makes it quite alarming.”
Another big area of focus is auditing gifts and donations passed through a company concerning projects carried out. His team works with companies to ensure their anti-bribery controls are as robust as possible, given the tough penalties on offer.
“It’s a criminal liability for a company, and the directors will be liable if they don’t have the proper anti-bribery procedures in place,” Zadar said. “Accounts and financial teams are critical to making sure firms have proper internal controls.”
CRI is also on a mission to stamp out “box-ticking” compliance, which has traditionally been a problem across the Middle East due to the nascent regulatory framework.
“If you’re conducting audits, nothing will happen if this is the way; you’ll never spot the problem,” he said. “The role of accountants, whether internal or external, to shape the controls and make sure they are implemented effectively.”
He said bribery through sales commissions, waste for public service, sexual extortion or sextortion as a form of corruption could be rife in some sectors. It was up to companies to ensure money wasn’t being paid outside official channels to staff.
“We understand it’s a process for some firms who are not used to doing it this way, but we’re here to help,” he said. “Companies need to establish their compliance documentation and make sure it’s up to the standard. The most important areas are due diligence and anti-bribery policies. This should not be a paper-based box-ticking exercise, it has to be implemented, and every employee must know the company believes in zero-tolerance of corruption.”
Visit ICAEW’s Fraud hub for related articles and case studies, or to see the original article, click here. Fraud help sheets prepared by ICAEW Technical Advisory Service to assist you in your day-to-day work.
Meet our CEO
Zafar I. Anjum is Group Chief Executive Officer of CRI Group (www.crigroup.com), a global supplier of investigative, forensic accounting, business due diligence and employee background screening services for some of the world’s leading business organisations. Headquartered in London (with a significant presence throughout the region) and licensed by the Dubai International Financial Centre-DIFC, the Qatar Financial Center-QFC, and the Abu Dhabi Global Market-ADGM, CRI Group safeguards businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. CRI Group maintains offices in UAE, Pakistan, Qatar, Singapore, Malaysia, Brazil, China, the USA, and the United Kingdom.
Contact CRI Group to learn more about its 3PRM-Certified™ third-party risk management strategy program and discover an effective and proactive approach to mitigating the risks associated with corruption, bribery, financial crimes and other dangerous risks posed by third-party partnerships.
CONTACT INFORMATION
Zafar Anjum, MSc, MS, CFE, CII, MICA, Int. Dip. (Fin. Crime) | CRI Group Chief Executive Officer
37th Floor, 1 Canada Square, Canary Wharf, London, E14 5AA United Kingdom
t: +44 207 8681415 | m: +44 7588 454959 | e: zanjum@crigroup.com
Who is CRI Group?
Based in London, CRI Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, CRI Group launched the Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301:2021 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.
5 Reasons To Run Employee Screening
Being HR professional, we have to deal with rigorous recruitment cycles, and for this, we must meet with several candidates before closing the vacancy. Every HR person has their style of evaluating the candidates, but one thing that needs to be kept in mind before making the final hiring decision is to “Never judge a book by its cover” (Stonehouse, 2017), since at times we might overlook some critical points, perhaps due to a fancy resume or qualification. Every HR professional should consider a crucial step before taking a candidate on board: run employee screening.
According to Business Week – 16% of executive resumes contain false academic claims and/or material omissions relating to educational experience. The U.S. Department of Labor estimates that the average cost of a bad hiring decision can equal 30% of the first year’s potential earnings.If you are an HR professional and reading this article, then I can assure you that other HR professionals must be thinking, “is it worth investing additional time and money in pre-employment background screening service?” Let me tell you the key benefits that you can gain from conducting pre-employment background screening services:
1. Better Compliance: it keeps you out of legal issues
Let’s suppose one of your employees commits fraud in your company, and after investigations, you came to know that the employee did the same with previous employers. At this point, you will regret not conducting their background check, as if you had conducted their employment and criminal check, then you wouldn’t have hired them in the first place.
2. Ensures credibility when performing sensitive tasks
In addition to legal issues, some background checks can verify a candidate’s creditability in performing their on-job duties. For instance, when a candidate is being hired for the accounts department where petty cash and the company’s account handling are their primary responsibilities, their employment check may come across that his previous employment has concluded due to mishandling of accounts.
3. Safer Work Environment: keep employees and clients safe
Conducting Background checks can also convey a message throughout the company’s stakeholders, especially its clients, that all employees hired in the company have gone through rigorous checks. Therefore, the data shared by the clients are in safe hands, thus increasing the overall integrity of the company and its staff.
4. Verifies education and certification
The increase in the number of fake degrees has amplified the importance of pre-employment check of educations. Therefore, all degrees and certificates of the applicant under consideration should be verified. The outcome of verification is not just about checking an applicant’s honesty but also verifying the legal status of the degrees and their issuing authorities.
5. Stronger hires, more savings: it gives an overall picture of the applicants
Apart from the interviews, pre-employment background checks can help the interviewer to make their hiring decision accordingly. For instance, candidates may have successfully cleared the interview process, but in their employment checks, the company found that they had resigned from their services after they were accused of sexual harassment by colleagues. Irrespective of how competent a candidate is for the vacancy, such red flags regarding the candidate’s behaviour can completely change the hiring decision and safeguard the company from future issues.
It is indeed worth spending extra time and money on pre-employment background screening because making a wrong hiring decision can not only increase recruitment cost and time but may also incur the cost of damage that employee has given to the company, whether in the form of litigation’s or damaging the company’s goodwill.
So, if your company is not conducting background screening! Think Again!
Being in HR, you might be creating liability for the company by making the wrong hiring decision. It’s never too late to correct your actions, so contact us, and we can provide our employment background screening services. As it is rightly said, I quote, “better safe than sorry” (Bateson, 2008).
CRI Group, based in London, works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management and Due Diligence solutions provider. We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
References
- Bateson, J., 2008. Building Hope: Leadership in the Nonprofit World. United States Of America: Greenwood Publishing Group.
- Stonehouse, R. A., 2017. You’re Hired! Job Search Strategies That Work. 1st ed. s.l.:eBookIt.com.
How to conduct background screening in the Middle East?
Background screening is critically important for business worldwide. Providing such service is a complex process, and it is different for every country and region. In the United States, investigators have a web of databases at their disposal and a vast network of local resources that provide a wealth of information at the mere click of a mouse. It’s a different world in the Middle East. Technology is limited in many parts of the region. Privacy legislation varies from country to country and from jurisdiction to jurisdiction. Cultural differences can impact the flow of information. Language barriers can contribute to inaccurate reporting.
Background Screening in the Middle East
Instead of database-driven investigations like those conducted in the U.S, professionals in the Middle East must conduct large parts of their investigations literally on foot, travelling to remote regions to scour records and interview sources. If you’re looking for accurate, reliable information in the Middle East you need to turn to qualified, professional sources that are familiar with the countries, cultures, terrain, languages, resources and – most of all – the laws that govern personal privacy. In this part of the world, your contacts and resources are your greatest assets.
Discovering Hard-to-Find Facts in Hard-to-Reach Locations
The biggest challenge in conducting background investigations in the Middle East is collecting reliable information most efficiently. This requires a well-trained and diverse group of professional investigators who are multilingual and multi-cultural, are familiar with those geographic regions and can easily traverse the obstacles that often impede international investigations. Those obstacles include:
- Working with local customs offices.
- Complying with data protection laws and mandates.
- Knowledge level of local investigative researchers.
- Lack of centralised information resources and databases; and
- The proliferation of multicultural environments that are particularly influenced by locals who vastly differ in their approaches to investigative screening and public record searches, particularly with information collected via database sources.
The Obstacle of Background Investigators in the Middle East
To address these obstacles, successful background investigators in the Middle East are often required to work deep in the field, travelling to remote destinations to conduct interviews, develop resources and enlist local assistance to verify the information. Leading background screening firms will conduct investigations that regularly involve a thorough review of local press records, using online and proprietary databases augmented by manual field research to locate the appropriate public records.
This in-depth investigative approach is necessary to bring to light any instances of malfeasance or notable, publicly aired criticism. These professionals will also research all public records that are available within the respective government institutions such as a region’s trial courts, police and SEC sources, and global sanctions lists. The goal of providing this level of investigative legwork is to collect timely, well-documented and substantiated information which will measure up to the high standards often required by our U.S. partners.
Partner With Reputable Background Screening Firms in the Middle East
As the world economy shrinks and the pool of foreign job applicants expands, a partnership with a reputable international employee screening service provider to conduct investigations abroad is essential for maintaining a safe hiring program for your clients. To ensure you’re using the best providers available, a little investigating of your own will result in big benefits down the road.
Checklist on Securing Reputable Background Screening Service:
- Research the listing of expatriate background screening firms provided by the Professional Background Screening Association https://thepbsa.org/.
- Ask your provider how they comply with local and regional laws governing individual privacy protection; the methods they utilise in protecting information.
- Make sure your service provider’s physical address is in the region they’re conducting investigations. If not, they could be simply outsourcing their cases to a third party.
- Ask about the manner in which your service provider conducts investigations. Avoid firms that investigate exclusively through media searches.
- Inquire about the internal policies and procedures the service provider uses to monitor the protection of data and if it conducts regular audits to ensure compliance with regional privacy mandates.
- Specifically, the provider should be in compliance with GDPR and must maintain Information Security Management System ISMS (ISO27001).
- Don’t settle for firms that say they specialise in providing checks of the International Terrorist Watch List and the OFAC watch list. Those lists are available online to anyone at no cost.
- Avoid firms that won’t supply you with the source of the records they obtain, were available from public record resources. Also, be sure to ask how old the information collected is.
- Reputable firms will combine in-depth field investigations with routine public records searches. Make sure your provider is doing both. Background checks involve investigative research and not just press clippings.
- Service delivery is critical in foreign investigations. Ask about average turnaround times and get commitments for delivery in advance of the investigation.
- Find out what other U.S. companies use as a service provider. Ask for references.
How do you know the candidate you just offered a role to is the ideal candidate? Are you 100% sure you know that everything they’re telling you is the truth? 90%? They showed you a diploma, how do you know it’s not photoshopped? Did you follow the correct laws during your background checks process? Employee background checks and necessary screenings are vital to avoid horror stories and taboo tales that occur within HR, your business, or even your brand – simply investing in a sufficient screening can save you time, money and heartbreak.
CRI Group has developed EmploySmart™, a robust new pre-employment background screening service, certified for BS7858, to avoid negligent hiring liabilities. Ensure a safe work environment for all – EmploySmart™ can be tailored into specific screening packages to meet the requirements of each specific position within your company. We are a leading worldwide provider, specialised in local and international employee background checks, including pre-employment and post-employment background checks.
Based in London, CRI Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, the CRI Group launched the Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.
Personal Due Diligence, Tips You Need to Know
Personal Due Diligence In Everyday Transactions
In the business world, due diligence refers to the investigation and steps were taken by organisations to satisfy all legal requirements before buying or selling products/ services or entering into a contract or a financial arrangement with another party. An Integrity Due Diligence allows an organisation to reduce risks – including risks arising from the FCPA (Foreign Corrupt Practices Act) and the UKBA (U.K. Bribery Act), to make informed decisions and pursue takeovers or mergers with more confidence. Due diligence is vital to prevent many types of fraud. While in some cases, it is also up to the consumer to do their own personal due diligence. Due diligence sounds complicated, but it is merely the process of doing your homework before you make a significant commitment.
Most of us practice personal due diligence even though we may not think of it that way (i.e. research on the internet before making a purchase or deciding what restaurant to go to). In this process, we are doing our “due diligence” to get the best deal. The level of proper due diligence should be proportionate to the level of commitment involved and your specific status. So when buying a house, the due diligence ought to be more extensive (i.e. a family with children may want to check out the rating of the schools in the area). Another personal area to conduct due diligence involves a new job offer (i.e., the organisation known to treat its employees well). These areas involve a significant amount of due diligence on your part before accepting a new position at a new company.
Due Diligence Makes Trust Possible
In the U.K., the lack of clarity from the Government has already caused problems. Many landlords are averse to letting their properties to non-UK nationals if they are in breach of the Right to Rent rules post-Brexit. The Government is under increased pressure to give clear guidance on post-Brexit Right to Work and Right to Rent checks. Whether you are renting a property, having home renovations done, buying insurance, getting a mortgage, or even entering a new romantic relationship, you can use due diligence to protect yourself. Due diligence can prevent potential fraud and some other types of scams.
The following are tips on how to avoid fraud:
- Know who you are dealing with, ask questions and verify the information;
- Check with the governing body for licensing and insurance requirements;
- Scammers pressure you to act immediately. Don’t sign anything you don’t understand;
- Don’t sign anything for large amounts of money without having it reviewed by your lawyer;
- Scammers say there’s a problem or a prize. Do not give out your personal information without verifying who is getting it;
- Be cautious if you are asked to make up-front payments;
- Get company information, including name and address and ensure that a written contract backs all verbal promises;
- Have a contract in place for things like construction work;
- Never give an unsolicited caller access to your computer;
- Do not give out a credit card or online account details over the phone unless you made the call and the number you are calling came from a trusted source;
- Scammers tell you to pay in a specific way. Never wire money unless you’re absolutely confident that you’re sending it to someone you know;
- Be suspicious of any calls from supposedly distressed relatives who don’t give their names. After hanging up, try calling the family member with the phone numbers you have to see if they actually need help;
- Scammers pretend to be from an organisation you know. Be suspicious of any calls from a supposed government agency or other businesses demanding payments; and
- Landlords should check references (in some cases, a police criminal record check), credit reports, and employment information of potential tenants.
Online Fraud is on the rise
In a time of crisis, we often see the best in people. Even before COVID-19 was officially classified by the World Health Organisation (WHO) as a global pandemic, citizens and government leaders alike praised the selfless sacrifice of doctors, nurses, first responders and others putting themselves in harm’s way to help treat and limit the spread of the disease. Unfortunately, a crisis can also bring out the worst in some people; fraudsters prey on fear and confusion.
The research shows that online fraud is on the increase too. Fraudsters are using the surge in online activity to target unsuspecting consumers. Online retailer sectors saw rising transaction volumes in March 2020 compared to the previous year, with 97% in Home products and furnishings, 136% in DIY products, 163% in garden essentials, and 26.6% in electronics.
Online Due Diligence Tips:
- Change online passwords regularly and make them secure (don’t use standard information about yourself);
- Don’t post personal info such as date of birth or mailing address on social media sites;
- Have the most current firewall and anti-virus software on your computer;
- Don’t send financial or any other type of personal information by email or text;
- When purchasing online, make sure the site is secure. It should begin with HTTPS;
- Don’t open links that appear in an email asking you to start a financial transaction. Go directly to the organisation’s website;
- Don’t download software programs or apps from an unsecured source; and
- Don’t use unsecured WiFi (such as in a coffee shop) if the device you are using has personal information on it.
Don’t fall prey to unscrupulous business dealings and outside threats. At CRI Group, we specialise in Integrity Due Diligence, working as trusted partners to businesses and institutions worldwide. Our people work with energy, insight and care to ensure we provide a positive experience to everyone involved – clients, reference providers and candidates.
Our DueDiligence360™ expose vulnerabilities and threats that can cause serious damage to your organisation and can significantly reduce business. The world’s largest corporations trust CRI Group and consultancies – outsource your due diligence to an experienced provider, and you will only ever have to look forward, never back.
Based in London, CRI Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, CRI Group launched the Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301:2021 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.
Ethics and Compliance Hotline is an anonymous reporting mechanism that facilitates reporting of possible illegal, unethical, or improper conduct when the normal channels of communication have proven ineffective or are impractical under the circumstances. At CRI Group, we are committed to having an open dialogue on ethical dilemmas regardless. We want to introduce a new Ethics & Compliance Hotline. This hotline is available to all employees and clients, contractors, vendors, and others in a business relationship with CRI Group and ABAC Group.
If you find yourself in an ethical dilemma or suspect inappropriate or illegal conduct, and you feel uncomfortable reporting through normal channels of communication, or wish to raise the issue anonymously, use CRI Group’s Compliance Hotline in below mentioned ways or provide us with your complaint online on the form below. The Compliance Hotline is a secure and confidential reporting channel managed by an independent provider. When reporting a concern in good faith, you will be protected by CRI Group’s Non-Retaliation Policy.
What Can You Report?
Feel free to report any known or suspected noncompliant behaviour or violations with any regulatory mandates and/or local policies, including but not limited to:
Ethical standards Violations
Violation of laws and Company Policy and internal control
Risk and Safety
Theft, embezzlement or misappropriate of assets and fraud
Bribery and corruption
Employee Rights, Employee Relation, Work Environment
Privacy laws or security of personal information
Discrimination
The dispute related to Supervisor, H.R. and other Departments
Physical and Verbal Harassment on Workplace
Issues related to job responsibilities
The report related to a suspicious activity being a witness
Unfair dismissals
Our Compliance Hotline is accessible by both phone and online. If you make a report directly by telephone, you will speak with the Compliance Department directly. If you submit a report online, the system will guide you through the reporting process, and a PIN generated automatically once you complete the report.
How is COVID-19 Radically Transforming the New-Hire Experience
The COVID-19 pandemic has been a challenging time for industries, organisations and their teams on every level. HR leaders had to adapt to a new normal quickly. Along with coping with the closing of workplaces and adjusting to working from home, many organisations had significant recruitment, vetting and onboarding activities. With two-thirds of employers reporting increased productivity for remote workers than in-office workers, businesses also discovered the benefits of a remote and flexible workforce. With the human element of HR almost vanishing overnight, HR leaders had to learn how to leverage the “digital” aspect of their jobs, ramp it up and implement it across their processes to deliver a new-hire experience and an overall good employee experience. And these changes are very likely to stay for the long haul.
This article explores how COVID-19 radically transformed the new-hire experience from recruitment to background screening, onboarding, and retention. We also explore some of the advantages of these changes and how you can leverage the new normal into your employee experience and increase retention.
The new normal
When COVID-19 struck, companies were faced with the difficult task of hiring quickly and economically, continuing effective onboarding processes, and changing the overall new-hire experience whilst managing the day-to-day risks and ever-changing challenges. COVID posed a lot of challenges when it comes to recruitment, such as:
- Navigating the new realm of virtual recruitment.
- High demand for recruitment in specific sectors (e.g., pharmaceuticals, retail supermarkets, delivery companies, transportation, retail banks, healthcare).
- The need to hire employees with a specific skill set (e.g., digital marketing, IT teams, customer service).
- Accommodating for existing staff working from home.
- Considering the long-term and short-term economic impact of hiring during the uncertainty of the pandemic.
There was also the onboarding process. Before the pandemic, some would say the process of onboarding an employee begins when the candidate is offered the position and continues until the new employee is considered productive – which could be anytime from the end of a probation period, for example, to a full year and the first appraisal. However, according to a recent survey by CareerBuilder, 25% of employers reported that their onboarding process took a day or less. In comparison, 26% spent a week, 21% over a month, and 11% said their onboarding process extends over three months or longer.
Furthermore, during the pandemic, the number of cases of employee fraud and misconduct grew substantially. In a survey conducted last year by CRI Group, an overwhelming number of respondents said the COVID-19 pandemic is affecting human resources at their company. There are also concerns about fraud, and the protection of confidential information, as much of the workforce has gone virtual in work-from-home (WFH) arrangements. CRI Group’s survey measures the pulse of human resources during a challenging time in business worldwide. The largest number (38%) of survey participants were human resources professionals, but respondents also included managers (19%); executives, directors and administrators (27%); and other roles.
Being digital in a COVID world, where face-to-face interaction is no longer possible, is mostly about optimising the end-to-end employee experience and leveraging data to deliver a somewhat personal employee onboarding experience. Outlined below are ten fundamental tips that support it:
1. Integrate employee information from screening to onboarding and deployment
Managing data is a challenge, but it is essential to ensure that the monitoring and engagement of the new hire remain consistent throughout the onboarding lifecycle. Integrate a system that includes Applicant Tracking System (ATS), recruitment, background screening, onboarding, and performance management, and learning/development systems.
2. There are no shortcuts in recruitment; background screening is more critical than ever
Many companies are hiring at an accelerated rate – especially in the medical profession and industries dealing with infectious diseases, medical supply, pharmaceutical companies and research facilities. A need for quick and effective pre-employment screening has arisen, but that is precisely why proper background screening is critical during COVID. Take the revised BS7858:2019 standard: When establishing policies and practices around the standard and vetting new hires against the standard, organisations can show that they place a high value on hiring individuals who possess integrity. Organisations can then task their new hires with responsibilities designed to keep their co-workers, customers and information safe from the negative forces that have become more prevalent in today’s ever-changing COVID-19 world.
3. Reduce insider fraud or misconduct risk and increase employee integration success rate from the get-go
Unfortunately, during the COVID-19 crisis, employee fraud has increased. According to a 2020 report from the Association of Certified Fraud Examiners, 5% of all revenue generated by organisations – some three and a half trillion pounds globally – is lost every year through fraud committed by employees. Effective background screening for candidates and employees is an essential and effective countermeasure.
4. Leverage HR technology, social media and remote working to elevate the employee experience
Remote working is very much a given in this era, so you must leverage technology to not only facilitate your new hire now but their job as a future permanent employee. It will also reduce the need for face-to-face support while at the same time encouraging proactivity and self-service. In today’s reality, employee experience is not just about boosting employee engagement but more about employee support effectiveness as a whole – while reducing dependencies on HR at the same time.
5. Engage new-hire from the get-go
Employee onboarding starts not just when the employee joins the organisation. Your very first email is the first experience the candidate has with your organisation. In the fast world of recruitment, too many sure candidates drop your process or reject your offers for a better one. It is essential to keep the candidate engaged while at the same time initiating a slow process of integrating her/him into the organisation asap — by doing so, you will improve the offer-to-join ratio.
6. Accelerate the time-to-competency for new hires by reducing the learning curve
It is important to establish expectations, set clear goals for the new hire, and monitor them consistently. Investing in employees’ professional development has always been an attractive “benefit” of any luring organisation. With COVID and the inability to learn on the job, this is more important. Why? Employees at all levels worldwide have been flung into a different and new way of working, which requires a very different skill set. According to Gallup, organisations that invest in employee development report 11% greater profitability. Every individual has his/ her learning style and ways of retaining information, so leverage all the digital tools available such as on-demand videos, live chats, virtual assistants, and other forms of interactive self-paced learning options.
7. Up-skilling your people by providing learning and knowledge retention tools on demand
Learning is key to making an employee productive. Training new and current employees to cope with the ongoing changes from the COVID-19 pandemic will help them remain productive. Employee retention like this is invaluable, especially as recruitment has become that bit trickier in a remote world. Do not lose top talent, knowledge and experience, for lacking that extra level of support.
8. Mental health is critical; it is time to acknowledge and practice it
The turbulence of today’s dual health and economic crises is unprecedented and is affecting employees. PwC’s 2020 Global Consumer Insights survey shows a shift in the consumer’s priority, with 69% saying they are caring more about their mental health and physical fitness, and 63% saying they want to eat healthier as a direct result of the COVID-19 pandemic. A study from Tilburg University in the Netherlands (commissioned by the IOSH – Institution of Occupational Safety and Health) estimated around 12.8 billion working days are lost due to anxiety and depression. The study concluded that organisations could help prevent mental health problems from becoming more severe and achieve a more sustainable workplace by paying attention to each individual’s situation and conditions. Employers must emphasise meeting individual needs and finding a more tailored approach where the new reality can safely “cohabit” with a desired new future. Leveraging social media to provide a robust peer support system is equally helpful – these will aid the onboarding process.
9. The employee continuously due diligence
Conduct a periodic review of existing employees. Investing in due diligence is vital to mitigate the risks and identify fraud. Periodically screening and vetting existing employees can protect and enhance the overall security of your organisation.
10. Cut costs drastically
Leveraging these new changes and integrating them into your onboarding cycle can help reduce expenses drastically across your business. It eliminates the cost that comes when placing the wrong candidate.
EmploySmart – take the first step towards transforming your employee background screening!
Businesses have to adapt quickly to survive, which can mean cutting steps in their hiring process, and no one knows how this will play out. Using a vendor to conduct your background screening effectively will invaluably make your onboarding process more scalable. It will allow you to focus on delivering consistently superior services to new hires across the board and, more importantly, focus on the fun stuff like supporting the new hire on their continued improvement.
We understand how important it is to monitor all stages from recruitment to onboarding and from onboarding to learning and development; that’s why our employee screening reports are easy to “transcribe” to whatever HR ecosystem you use. Our reports will essentially complement the effectiveness of any employee onboarding process and, therefore, your HR department.
Mitigate the employee risk impact! Learn how with this FREE ebook. Taken as a whole, this ebook is the perfect primer for any HR professional, business leader and company looking to avoid employee background screening risks. It provides the tools and knowledge needed to stay ahead of COVID-19 effectively. Read more or DOWNLOAD now!
How do you know the candidate you just offered a role to is the ideal candidate? Are you 100% sure you know that everything they’re telling you is the truth? 90%? They showed you a diploma, how do you know it’s not photoshopped? Did you follow the correct laws during your background checks process? Employee background checks and necessary screenings are vital to avoid horror stories and taboo tales that occur within HR, your business, or even your brand – simply investing in a sufficient screening can save you time, money and heartbreak.
CRI Group has developed EmploySmart™, a robust new pre-employment background screening service, certified for BS7858, to avoid negligent hiring liabilities. Ensure a safe work environment for all – EmploySmart™ can be tailored into specific screening packages to meet the requirements of each specific position within your company. We are a leading worldwide provider, specialised in local and international employee background checks, including pre-employment and post-employment background checks.
Based in London, CRI Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, CRI Group launched the Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301:2021 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.
Q&A on how corporate fraud and corruption affect businesses in the UAE 2021
CRI Group and its ABAC® Center of Excellence were featured in Financier Worldwide’s InDepth Feature: Corporate fraud and corruption 2021. In this edition, CRI Group’s CEO Zafar Anjum and ABAC®’s Scheme Manager Huma Khalid talk about how corporate fraud and corruption affect businesses not only in the UK and UAE, but across the globe, and provide solutions and insights for businesses to become better protected from corporate fraud, bribery and corruption.
Q. To what extent have you seen a notable rise in the level of corporate fraud, bribery and corruption uncovered in the UAE?
A. The United Arab Emirates (UAE) remains the least corrupt country in the Middle East and North Africa region. It was perhaps fitting that the United Nations (UN) held its anti-corruption conference in the UAE just over a year ago. At the conference, delegates drafted anti-corruption resolutions and discussed asset recovery, international cooperation, and other topics in preparation for an upcoming special session of the UN General Assembly against corruption. Of course, there is still much work to be done. Fraud, bribery and money laundering are still problems in the UAE that require a united focus to overcome. Of special concern is the real estate sector, which some have called a haven for stashing and laundering cash. In some cases, these funds are linked to terrorist financing, raising the alarm beyond just the balance sheet for typical financial or corporate fraud.
Q. Have there been any legal and regulatory changes implemented in the UAE designed to combat fraud and corruption? What penalties do companies face for failure to comply?
A. The recent Anti-Commercial Fraud Law in the UAE strengthened rules around counterfeiting and intellectual property (IP) theft, among other areas. In addition, lawmakers and regulators are applying an anti-fraud focus to other laws. A perfect example is the UAE’s Insolvency Law 2020. The Ministry of Finance announced that penalties will be imposed on those who fraudulently abuse the law. This could include making a fake claim or a sham debt against a debtor or illegally increasing a debt amount. Such offences are punishable by jail time and fines. An awareness campaign by the UAE Banks Federation (UBF), the Central Bank of the UAE (CBUAE), Abu Dhabi Police, and Dubai Police was the first such collaboration in the UAE and it comes as both corporate and consumer fraud have increased. Companies are expected to protect their stakeholders’ investments, and failure to do so can lead to regulatory and legal punishments.
Q. In your opinion, do regulators in the UAE have sufficient resources to enforce the law in this area? Are they making inroads?
A. There are at least two daunting tasks facing regulators in the UAE at present: detecting and preventing money laundering and stemming the growing threat of cyber crime. While these problems are not unique to the UAE, they do require significant investment and increased investigation and enforcement efforts. Recent reports allege that illicit funds flow through ‘free trade zones’ and into real estate deals, such as luxurious properties in Dubai and other locations. The laws are in place to punish such crimes, but more inroads will need to be made to bring this under control in a country that largely succeeds at fighting fraud in other areas. Cyber crime is also a constant challenge that has been exacerbated by the COVID-19 pandemic. Many fraudsters have sought to take advantage of companies having to transition to different employment models, such as remote working. Fraud fighters are working hard to stay ahead of the curve in this regard.
Q. If a company finds itself subject to a government investigation or dawn raid, how should it respond?
A. If a company finds itself under investigation, one of the first things it must do is mandate down the chain of command that employees cooperate fully with investigators. Any efforts to the contrary may be considered obstruction, and lead to more punishments or a higher likelihood of penalties at the end. In contrast, engaging in a good-faith effort to assist an investigation may weigh in the company’s favour.
Questions will arise, such as: Was this a surprise? What are the facts of the case? How did this occur? Legal counsel must be engaged immediately, but it is also important to speak with compliance officers, risk management, executives and the board in a transparent way to help the company move forward. Communicate a zero-tolerance policy toward fraud, and if employees are proven to have engaged in such behaviour, they should be terminated and prosecuted.
Q. What role are whistleblowers playing in the fight against corporate fraud and corruption? How important is it to train staff to identify and report potentially fraudulent activity?
A. Some business leaders falsely believe that audits, account reconciliation and other procedures offer the best protection against fraud. They are important functions, but they are not the most effective detection method. Fraud is often uncovered by tips, according to the ACFE’s Report to the Nations on Occupational Fraud and Abuse. Employees are truly the front line of defence for companies, and the first to throw up warning flags about unethical behaviour. The question is whether companies listen to their employees. And is there an easy, anonymous way for employees to submit tips, without fear of retaliation? Companies should educate employees about the red flags of fraud, and then make sure they know they can and should report it.
Q. What advice can you offer to companies on conducting an internal investigation to follow up on suspicions of fraud or corruption?
A. If the company does not have an experienced team of anti-fraud professionals on staff, it is crucial to enlist the help of an outside firm with experts who specialise in this area. There are mistakes companies make at the beginning of an investigation that can haunt them later. For example, most countries, including the UAE, have laws that govern the proper collecting and handling of evidence. With most evidence in a digital format, following the right protocols is more important than ever. There are also important guidelines for interviewing witnesses and those suspected of fraud which, when disregarded, could lead to a failed investigation. The bottom line is: do not go it alone – get expert professional help. And if criminal conduct is discovered, contact the authorities.
Q. What general steps can companies take to proactively prevent corruption and fraud within their organisation?
A. Preventing and detecting fraud starts with a company’s employees, so training and communication are key. First, employees must be trained on what constitutes fraud, bribery and corruption, how to recognise it, and how to report it. Second, the company must communicate that fraud will not be tolerated on any level, and those who commit fraud will be terminated and prosecuted if they are found to have broken the law. Companies should also have anti-corruption and anti-fraud controls in place, including an employee code of conduct, regular and surprise audits, and a fraud reporting system available to employees, contractors and even customers. Achieving certification in internationally recognised standards, such as ISO 37001 ABMS, is a good practice too. When it comes to fraud and corruption, an ounce of prevention is worth a pound of cure. Being proactive is truly the only practical option for protecting the business and its assets.
Meet Zafar ZAFAR ANJUM, Group Chief Executive Officer
Zafar Anjum is founder and group CEO at CRI Group, and its ABAC Center of Excellence. He uses his extensive knowledge and expertise in creating stable and secure networks across challenging global markets. For organisations needing large project management, security, safeguard and real-time compliance applications, Mr Anjum is the assurance expert of choice for industry professionals.
Corporate Research and Investigations | t: +44 (0)7588 454 959 | e: zanjum@crigroup.com
Meet HUMA KHALID, Scheme Manager
Huma Khalid, as scheme manager, is responsible for leading ABAC. Ms Khalid’s responsibilities include planning and overseeing all aspects of the ABAC programme, which include certification and training. Additionally, she oversees the compliance department for the implementation, management and internal audit of CRI Group’s and ABAC compliance programmes
ABAC Center of Excellence Limited | t: +44 (0)777 652 4355 | e: huma.k@abacgroup.com
About CRI Group
CRI GROUP works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international risk management, employee background screening, business intelligence, due diligence, compliance solutions and other professional investigative research solutions provider. CRI Group has the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Its global presence ensures that no matter how international your operations are, the company has the network needed to provide you with all you need, wherever you happen to be. For more on our Risk Management solutions just check out our brochure:
View Risk Management Solutions Brochure
Other contacts:
RAZA SHAH Business Development and Marketing Executive | t: +92 300 501 2632 | e: raza.shah@crigroup.com
AYESHA SYED Lead Auditor | t: +971 4 358 9884 | e: ayesha.s@abacgroup.com
Corporate Fraud and Corruption: affect on UK businesses in the 2021
CRI Group and its ABAC® Center of Excellence were featured in Financier Worldwide’s InDepth Feature: Corporate fraud and corruption 2021. In this edition, CRI Group’s CEO Zafar Anjum and ABAC®’s Scheme Manager Huma Khalid talk about how corporate fraud and corruption affect businesses not only in the UK and UAE, but across the globe, and provide solutions and insights for businesses to become better protected from corporate fraud, bribery and corruption.
Q. To what extent have you seen a notable rise in the level of corporate fraud, bribery and corruption uncovered in the UK?
A. The COVID-19 pandemic has created increased opportunities for fraud worldwide. The UK is not immune, unfortunately, and such a disruptive event as the pandemic increases the likelihood that normal safeguards and risk management controls can be bypassed and subverted. There has been an increase in reported fraud and corruption cases over the past year. A survey of fraud experts by the Association of Certified Fraud Examiners (ACFE) in August 2020 showed that 77 percent were seeing an increase in fraud. Perhaps not surprisingly, cyber fraud is the fastest-growing problem area, but there has also been an uptick in unemployment fraud. This is bad news in the UK, where fraud is our most common crime, costing the country £190bn annually, according to the Royal United Services Institute (RUSI).
Q. Have there been any legal and regulatory changes implemented in the UK designed to combat fraud and corruption? What penalties do companies face for failure to comply?
A. There is proposed legislation, supported by the secretary of state of the UK’s Department of Business, Energy and Industrial Strategy, that would increase accountability for corporations that produce falsified financial statements. This includes a provision that would require company directors to personally sign off on their corporation’s financial statements, under penalty of fines and possible prison time. Under the Sarbanes-Oxley Act in the US, the penalty for falsely certifying such statements is steep: up to 20 years in prison and up to $5m in fines, and the UK is looking at similar measures to step up its fight against fraud and corruption. The UK also recently approved the formation of an audit, reporting and governance authority (ARGA) that should come into force within the next two or three years. Accordingly, the UK is taking a stronger stance against fraud going forward.
Q. In your opinion, do regulators in the UK have sufficient resources to enforce the law in this area? Are they making inroads?
A. Combatting fraud is never straightforward. When looking at progress in detecting and preventing fraud, it sometimes feels like a question of whether the glass is half full or half empty. For example, the Serious Fraud Office (SFO) brought 13 fraud defendants to trial in 2019 and 2020, with a 95 percent fouryear success rate by case. Many of these represent large frauds, and they are meaningful wins, but how many more fraudsters are out there undiscovered? Other bodies, including Her Majesty’s Revenue and Customs (HMRC), among others, also have key roles to play in investigating fraud, but a considerable amount of fraud is still investigated and prosecuted at the local level. It is important for leaders in the UK to know what resources law enforcement have and where they need training and support in the fight against fraud.
Q. If a company finds itself subject to a government investigation or dawn raid, how should it respond?
A. Any investigation, and especially a raid, can be an incredibly stressful time for a company and its employees. The important thing is to not panic – the investigators have a job to do, and the sooner they get to the truth of the situation, the better for everyone. Companies should direct their management and their employees to cooperate fully, while also engaging legal counsel to properly protect the corporation from future litigation. If fraud is detected, it is a criminal matter and the company should make a good faith effort to work with prosecutors and regulators, while making sure to document all control measures and prior steps taken to manage fraud risk. Having a track record of meeting compliance requirements and having proper internal controls in place at the time fraud occurs could have a mitigating effect in terms of potential prosecution and penalties down the road.
Q. What role are whistleblowers playing in the fight against corporate fraud and corruption? How important is it to train staff to identify and report potentially fraudulent activity?
A. Employees are a company’s first line of defence against fraud and corruption. But training them to recognise the red flags of fraud is only half of the process. The company must also implement a reporting system that is anonymous and easy to use, so that employees are encouraged to report any suspicions. Then, the company must follow through and fully investigate any reports that do come in. If it does not, whistleblowers will believe that combatting fraud and corruption is not a corporate priority, and the tips will stop coming in. How important are those tips? According to the ACFE, they are by far the highest detection method for fraud, well above audits and other means. The company should communicate that a whistleblower hotline or online reporting system is available, and that there is a zero-tolerance policy for any type of retaliation against whistleblowers. Over time, the tips will come in.
Q. What advice can you offer to companies on conducting an internal investigation to follow up on suspicions of fraud or corruption?
A. Investigations can be challenging, and they require expertise. For example, there are rules for collecting and handling evidence, including physical evidence and witness statements, that must be followed for such evidence to be admissible in court. There are also laws in the UK dealing with privacy and the rights of the accused. The bottom line is that a company already dealing with a potentially costly and damaging fraud scenario should not risk adding more legal trouble through a faulty investigation. Hire experts who deal with corporate crime and specialise in fraud and corruption cases. Like any other area of expertise, they will have the knowledge and resources to help proceed with an investigation and lead it to the most favourable outcome for your company. If you already have anti-fraud professionals on staff, let them take the lead, but provide outside resources as needed.
Q. What general steps can companies take to proactively prevent corruption and fraud within their organisation?
A. A fraud prevention strategy has many different elements, and the sooner companies implement them, the sooner they can begin to work together in a proactive way to prevent fraud. Mandating employee training, such as ISO 37001 ABMS, having an ethical code of conduct signed by every member of staff, providing regular and surprise audits, and implementing a fraud reporting system are all effective ways to help prevent and detect fraud and corruption. None of these methods is strong enough on its own to properly protect organisations. But together, they can be very effective. It is also important to set a ‘tone at the top’, from ownership, directors and management on down, that fraud will not be tolerated. Anti-fraud controls only work if the company sees them through and thoroughly investigates every report. When fraud is confirmed, any perpetrators should be terminated and potentially prosecuted, sending a message of zerotolerance.
Meet Zafar ZAFAR ANJUM, Group Chief Executive Officer
Zafar Anjum is founder and group CEO at CRI Group, and its ABAC Center of Excellence. He uses his extensive knowledge and expertise in creating stable and secure networks across challenging global markets. For organisations needing large project management, security, safeguard and real-time compliance applications, Mr Anjum is the assurance expert of choice for industry professionals.
Corporate Research and Investigations | t: +44 (0)7588 454 959 | e: zanjum@crigroup.com
Meet HUMA KHALID, Scheme Manager
Huma Khalid, as scheme manager, is responsible for leading ABAC. Ms Khalid’s responsibilities include planning and overseeing all aspects of the ABAC programme, which include certification and training. Additionally, she oversees the compliance department for the implementation, management and internal audit of CRI Group’s and ABAC compliance programmes
ABAC Center of Excellence Limited | t: +44 (0)777 652 4355 | e: huma.k@abacgroup.com
About CRI Group
Based in London, CRI Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301:2021 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.
Other contacts:
RAZA SHAH Business Development and Marketing Executive | t: +92 300 501 2632 | e: raza.shah@crigroup.com
AYESHA SYED Lead Auditor | t: +971 4 358 9884 | e: ayesha.s@abacgroup.com
BS 7858:2019 | The new way to mitigate employee risk during COVID-19
Mitigate employee risk during COVID-19 with BS 7858:2019
The far-reaching impact of the COVID-19 outbreak has affected virtually every business and economic sector worldwide. Depending on the global region, the far-reaching implications have hampered (on various levels) the ability to conduct proper and thorough background screening investigations. In the United Kingdom and the United Arab Emirates, the countrywide lockdowns forced leaders to close sites and send their workforce home. Many have to learn how to manged people working from home (WFH) or remotely for the first time. The previous concerns about productivity, privacy and protecting sensitive information only grew more with the practice of WFH. They highlighted the vital importance of pre-employment background screening and background investigations. BS 7858:2019: the revised standard for screening individuals working in secure environments offers a complete solution.
Unfortunately, conducting such investigations in a reliable and timely manner has brought its struggles. The closure of public information sources has dramatically impacted accessing public records to verify previous employment, education and criminal charges. Drug screening tests have been delayed or postponed until such companies are permitted to reopen their doors for business. On the applicant side, it’s been widely reported that individuals are concerned (and rightly so) about participating in face-to-face interviews. Applicants are concerned with leaving their homes to do a drug test and, ultimately, returning to a work environment that may or may not appear healthy, protected and safe.
Recruitment fraud and how BS 7858:2019 provide the solutions
Investigators themselves have hesitations about venturing into the field to complete their assignments, which in many countries may require a high degree of boots-on-the-ground research and in-person interaction. Fortunately, the background screening industry is resilient. It is steadily working around these obstacles to ensure that workplaces are safeguarded, workers, customers and property are protected, and sensitive information doesn’t fall into rogue hands. This is particularly important in those sectors that rely heavily on vetting personnel working in secure environments responsible for people, property, data and critical systems. And it’s important for the mere fact that a trending increase in recruitment fraud is creating additional challenges for already over-burdened employers. Last year recruitment fraud cost £23 billion in the UK alone.
The recent update of the BS7858:2019 standard, “Screening of Individuals Working in a Secure Environment – Code of Practice,” emphasizes the risk assessment of secure environment workers. The code focuses on the need for tighter controls over the pre-employment screening – and periodic re-screening – of individuals, who in their positions could potentially benefit from illicit personal gain, become compromised, or take advantage of other opportunities for creating breaches of confidentiality, trust or safety.
Written by the British Standards Institute, which is recognised as the UK’s national standards body, BS7858:2019 lays out the scope of “obtaining personal background information to enable organisations to make an informed decision, based on risk, on employing an individual in a secure environment.” Those workers include business owners, directors, partners, silent partners and shareholders holding more than 10% of the business; managers, area managers, department managers, screening managers and staff; installers and service crew; security personnel; and office supervisors and staff with access to customer and system records.
The amended guidelines of the standard put the onus on the organisation’s top management to demonstrate that they are focused on the aspects of the business where the most risk lies and the particular personnel roles involved within those risks areas. This is particularly important because, as the standard states, the “organisation retains ultimate responsibility for an outsourced screening process and is required to review the completed screening file.” Risks assessment includes examining certain roles that involve financial tasks, data security, management of goods, property risks or any number of “people risks” such as roles with direct access to vulnerable adults and children.
To that end, management is charged with ensuring that the organisation has proper and adequate resources and infrastructure to manage the adequate vetting of high-risk personnel. Management is tasked with the response and that there is a firm commitment at the top level to manage and support the coordination required to execute the screening process. Finally, management is tasked with ensuring that such responsibilities are appropriately assigned and communicated throughout the organisation. The guideline also eliminates its original text in 2012, a requirement to produce character references as part of the screening process. This decision was based on the supposition that such references are now deemed potentially weak and difficult to verify.
Price of a bad hire
The price of a bad hire has far-reaching consequences for any business, including productivity loss, decreased employee morale, risks to employee safety and increased exposure to costly negligent hiring claims and potentially devastating litigation. The premise behind the standard is to safeguard employers from harmful or fraudulent hires. Cases of organisations that forego conducting due diligence on a new hire – especially a hire with high-risk exposure – often end badly for those organisations.
The revised BS7858:2019 standard enables organisations to demonstrate a commitment to safeguarding their businesses, employees, customers and information utilising widely accepted methods that focus on risk assessment and top-down management involvement in the company’s employment policies and practices. In establishing policies and practices around the standard, organisations can show that they place a high value on hiring individuals who possess integrity. Organisations can then task them with responsibilities designed to keep their co-workers, customers and information safe from the negative forces that have become more prevalent in today’s ever-changing COVID-19 world.
The price of a bad hire has far-reaching consequences for any business, including productivity loss, decreased employee morale, risks to employee safety and increased exposure to costly negligent hiring claims and potentially devastating litigation. The premise behind the standard is to safeguard employers from bad or fraudulent hires. Cases of organisations that forego conducting due diligence on a new hire – especially a hire with high-risk exposure – often end badly for those organisations.
At CRI Group, we know how important is your background screening to your company’s success and to give you an idea of what is new, we have produced this playbook detailing the differences between the BS7858:2012 standard and the new BS7858:2019 standard.
Managing people through COVID-19
The COVID-19 pandemic is undeniable affecting the world. And the situation is changing at an hourly rate as we go into a second global lockdown. Businesses have to adapt quickly to survive, i.e. cutting steps in their hiring process, and no one knows how this will play out. However, there are ways you can mitigate the impact, learn how from this free ebook.
Taken as a whole, this ebook is the perfect primer for any HR professional, business leader and companies looking to avoid employee background screening risks. It provides the tools and knowledge needed to effectively stay ahead of COVID-19. Read the answers to the following questions:
Does a candidate have to give consent to process a background check/screening?
How long does it take to conduct a background check?
When should I conduct pre-employment checks?
How often should I screen employees?
How to collect references and what to ask?
How much does it cost to conduct background checks?
What is the difference between employment history verification and employment reference?
The price of a bad hire has far-reaching consequences for any business, including productivity loss, Get answers to frequently asked questions about background checks/screening cost, guidelines, check references etc.
Taken as a whole, it is the perfect primer for any HR professional, business leader and companies looking to avoid employee background screening risks. It provides the tools and knowledge needed to make the right decisions. This eBook is a compilation of all of the background screening related questions you ever needed answers to:
Does a candidate have to give consent to process a background check/screening?
How long does it take to conduct a background check?
When should I conduct pre-employment checks?
How often should I screen employees?
How to collect references and what to ask?
How much does it cost to conduct background checks?
What is the difference between employment history verification and employment reference?
How do I check on entitlement to work?
How to conduct identity checks?
What will a financial regulatory check show?
Is it possible to identify conflict of interest during checks?
What is a bankruptcy check?
What about directorships and shareholding search?
Can I have access to a criminal watch list?
Anti-money laundering check?
Can we conduct FACIS (fraud and abuse control information system) searches?
BS7984:2008 accredited companies, such as CRI Group highlight to their clients that their security personnel are staff that can be trusted and relied upon to complete a high-quality job as the screening process highlights the level of conduct that they have presented in the past. This reassures the safety of the people, goods and property that they have been hired to protect.
Based in London, CRI Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
If you have any further questions or interest in implementing compliance solutions, please contact us. CRI Group has safeguarded businesses from any risks, providing investigations such as insurance fraud, employee background screening, investigative due diligence, business intelligence, third-party risk management, forensic accounting, compliance and other professional investigative research services.
In 2016, the CRI Group launched the Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 19600:2014 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. Contact ABAC® for more on ISO Certification and training.
Zafar I. Anjum is Group Chief Executive Officer of Corporate Research and Investigations Limited “CRI Group” (www.crigroup.com), a global supplier of investigative, forensic accounting, integrity due to diligence and employee background screening services for some of the world’s leading business organisations.
Headquartered in London (with a significant presence throughout the region) and licensed by the Dubai International Financial Centre-DIFC, the Qatar Financial Center-QFC, and the Abu Dhabi Global Market-ADGM, CRI Group safeguards businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. CRI Group maintains offices in UAE, Pakistan, Qatar, Singapore, Malaysia, Brazil, China, the USA, and the United Kingdom.
Zafar Anjum, MSc, MS, LLM, CFE, CII, MABI, MICA, Int. Dip. (Fin. Crime), Int. Dip. (GRC)
CRI Group Chief Executive Officer
37th Floor, 1 Canada Square,
Canary Wharf, London, E14 5AA,
United Kingdom
t: +44 207 8681415
m: +44 7588 454959
e: zanjum@crigroup.com
Background Investigations: One-on-one interview with Zafar Anjum
Having dedicated his career to fraud prevention, protective integrity, security and compliance, Zafar Anjum is a distinguished and highly respected professional in his field. As Group Chief Executive Officer at Corporate Research and Investigations Limited, he uses his extensive knowledge and expertise in creating stable and secure networks across challenging global markets. For organisations needing comprehensive project management, security, safeguard testing, background investigations and real-time compliance applications, Anjum is the assurance expert of choice for industry professionals.
Q: To what extent have you seen an increase in corporate fraud in recent years? What are some of the common themes and underlying causes?
Anjum: Fraud always seems to be increasing. No matter how sophisticated our attempts to prevent it become, perpetrators are always adapting with new methods. According to the 2020 Association of Certified Fraud Examiners (ACFE) Report to the nations, asset misappropriation is the leading type of occupational fraud. It makes up 86% of fraud cases and causes a median loss of $100,000. On the other spectrum, financial statement fraud schemes are the least common (10% of cases) but are the most costly, causing a median loss of $954,000. A typical fraud case can last 14 months before detection and cause a loss of $8,300 per month – a whopping 5% of an organisations revenue is lost to fraud each year. There are various factors at play here, but it starts with ‘tone at the top’. Basically, corporate culture often sets the tone for how strict or lax an organisation is when preventing or detecting fraud. Combine a lax approach with a country or jurisdiction where corruption is still prevalent, even considered ‘business as usual, and there will likely be fraud.
Q: Could you outline the benefits of using background investigations to reduce potential fraud? Under what circumstances is it prudent to undertake a background investigation?
Anjum: It should be a priority to conduct thorough background investigations when engaging in a merger or acquisition, an initial public offering (IPO), engaging suppliers, contractors or new clients – your client relationships can affect your organisation’s reputation and your ability – just to name a few situations. This can help you avoid becoming entangled with third parties that have hidden fraud and other legal issues. It will also make you aware of a potential partner who has a credit risk, has claimed bankruptcy or is faced with debtor filings, for example. In one case, a company was seeking to engage a new supplier for medical supplies and equipment. A background investigation revealed that the warehouse’s physical location – claimed by this ‘supplier’ did not exist. The company’s principal had previously been charged with ‘criminal breach of trust’. Three other civil damages claims against the principal were discovered, with millions claimed in liabilities.
Q: What are some of the best practice approaches to conducting a background investigation?
Anjum: One of the most important aspects of thorough background investigations is having a ‘boots on the ground approach. Online database searches can only take you so far. When conducting due diligence on entities or individuals, red flags that pop up often warrant further checking before they can be truly weighed as part of the decision process. For example, if you are considering partnering with another company and they provide information for their physical location, do you have agents who can visit that location to make sure it is legitimate? Investigations sometimes discover that purported ‘headquarters’ is actually an abandoned home or vacant lot. Also, if certain credentials are claimed, you need to make phone calls or possibly a visit to the school or accrediting bodies to verify them. These are the important details that help you established facts that help guide your decisions.
Q: What kinds of legal or regulatory issues might complicate a background investigation?
Anjum: Privacy laws are probably the most important issue, and they need to be carefully understood and followed for every jurisdiction. In the UK, for example, the pandemic has created new data privacy issues, but prudent organisations are constantly evaluating their data protection strategies under the General Data Protection Regulation (GDPR). When it comes to background investigations, similar privacy considerations apply. You might want to check an individuals’ financial or credit history – relevant information if they own a business you seek to partner with or acquire, or if you are considering them for a high-level position at your organisation. Accessing such information is permitted in some jurisdictions and restricted by law in others. The last thing you want is to end up in court for violating someone’s privacy. It is best to engage a professional due diligence background screening firm. They will be trained and up-to-date on the laws governing your background investigations, plus they will have access to resources that most companies do not have.
Q: To what extent are background investigations more challenging in a cross-border or multi-jurisdictional context? How can these additional challenges be overcome or avoided?
Anjum: This goes back to the importance of having investigators in various locations, your ‘boots on the ground’, in your approach to due diligence. The world is much smaller these days as organisations seek to expand across international borders. And the COVID-19 is teaching leaders invaluable lessons in business efficiencies and future strategy. This can lead to obvious challenges – both with following the laws and regulations in various jurisdictions and overcoming language and cultural barriers. That is why it is important to have access to locally-based agents – including certified fraud examiners and similarly credentialed professionals – to help with your checks, whether investigating a potential third-party partner or an individual being considered for employment. Another advantage is to have a set, written policy and process for conducting background investigations that you can reference and rely upon when undertaking key business decisions. In this way, your organisation is less susceptible to someone convincing you to bypass proper due diligence simply because it might seem logistically difficult to conduct an overseas investigation.
Q: Once the background investigation results are collated, what are the key points to analyse?
Anjum: If red flags are uncovered, the best way to proceed is to investigate further to understand discrepancies. For example, suppose you are conducting background screening on a potential employee, and something comes up in their criminal record, rather than eliminating them from consideration. In that case, you should ensure that there was not an error in your background check, investigate the discrepancy and gather all relevant information and ask the person to explain what you found and why they did not disclose it. They might have an explanation that affects your decision process. In other words, do not overlook potential talent. According to Nacro, more than 11 million people in the UK have a criminal record – that’s 1 in 3 men – however, just over half of these had been convicted on only one occasion, and 85% were convicted before they were 30 years old. Not all of those have a prison record, however. Most convictions are for motoring offences, such as speeding or unpaid tickets.
Q: What essential advice would you offer to companies on developing internal policies and processes to combat fraud? should intensive background investigations form part of their standard procedures?
Anjum: Intensive background investigations should be a part of an organisation’s standard procedures. It should be part of a greater risk management plan, be set forth as written policy that owners and director approve, and be reviewed and understood by management and other relevant personnel. Engage risk management professionals when developing your policies and procedures. They can help tailor a plan based o your organisation. Key questions to address should include; who will implement the plan, how an investigation is conducted, who evaluates and reports the results, and so on. Sometimes organisations put forth a thorough, excellent programme for background investigations and then, six months or a year later, nobody is following it. The key to success is following through with it and making sure your entire organisation understands the process and why it is so important. The security of your company depends on effective risk management.
The security of your company depends on effective risk management
Background investigations are critical to any company’s success because working with qualified, honest and hard-working employees and other businesses is an integral part of thriving in the business community. What you don’t know can hurt you, and the simple act of one bad decision can result in an unprecedented loss for your company.
From vendor and third-party screening to employment screening, CRI Group recommends background investigations as critical proactive measures to help keep your business safe. An effective background screening investigation will help screen for bad apples that can cause havoc down the road. Because we maintain a diverse talent base comprised of multilingual and multi-cultural professionals, CRI can traverse obstacles that often impede international background investigations. That’s why we are frequently contracted by our competitors to conduct background investigations in geographic regions not serviced or accessible by larger investigative firms.
Meet our CEO
Zafar I. Anjum, is Group Chief Executive Officer of CRI Group (www.crigroup.com), a global supplier of investigative, forensic accounting, business due diligence and employee background screening services for some of the world’s leading business organisations. Headquartered in London (with significant presence throughout the region) and licensed by the Dubai International Financial Centre-DIFC, the Qatar Financial Center-QFC, and the Abu Dhabi Global Market-ADGM, CRI Group safeguards businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. CRI Group maintains offices in UAE, Pakistan, Qatar, Singapore, Malaysia, Brazil, China, USA, and the United Kingdom.
Contact CRI Group to learn more about its 3PRM-Certified™ third-party risk management strategy program and discover an effective and proactive approach to mitigating the risks associated with corruption, bribery, financial crimes and other dangerous risks posed by third-party partnerships.
CONTACT INFORMATION
Zafar Anjum, MSc, MS, CFE, CII, MICA, Int. Dip. (Fin. Crime) | CRI Group Chief Executive Officer
37th Floor, 1 Canada Square, Canary Wharf, London, E14 5AA United Kingdom
t: +44 207 8681415 | m: +44 7588 454959 | e: zanjum@crigroup.com
Who is CRI Group?
Based in London, CRI Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301:2021 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.
Cyber security: how to maintain GDPR compliance?
The European Union’s (EU) General Data Protection Regulation (GDPR) came into force in 2018. The GDPR was a response to massive worldwide data breaches that were undermining the trust and security of private citizens whose personal information was at stake. As this data was exposed by both hackers and, in some cases, simply through poor security measures, governments of the EU felt it was time to create a strong piece of governance to bolster protection. While the initial rollout of GDPR held some uncertainty and unknowns for organisations subject to its guidelines, there is now a much clearer picture of how its standards apply. The punishments for being caught out of compliance can be severe: Violators of the GDPR may be fined up to €20 million or up to 4 percent of the annual worldwide turnover of the preceding financial year in case of an enterprise, whichever is greater.
Cybersecurity is a priority for the management
Even with extremely high fines and stringent requirements, GDPR violations and data breaches have been skyrocketing across the world. In 2020, the overall increase of fraudulent activities has been detected, based on ACFE’s “Fraud in the Wake of COVID-19: Benchmarking Report”: 77% of survey participants have seen an increase in the overall level of fraud as of August, compared to 68% who had observed an increase in May. Earlier we wrote how the COVID-19 crisis triggered fraudulent activities and what can businesses do to support anti-fraud movements in their organisations and to strengthen their immunity to fraud. However, cyber-attacks are on the rise – the survey by the gov.uk continues to show that cybersecurity breaches are a serious threat to all types of businesses and charities. 39% of businesses and 26% of charities reported having cybersecurity breaches or attacks in the last 12 months. Like previous years, this is higher among medium businesses (65%), large businesses (64%) and high-income charities (51%).
The study suggests that the risk level is potentially higher than ever under COVID-19 and that businesses are finding it harder to administer cybersecurity measures during the pandemic: 35% of businesses compared to 40% last year are now deploying security monitoring tools. This reduction suggests that these organisations might simply be less aware than before of the breaches and attacks their staff are facing.
However, among those that have identified breaches or attacks, around 27% of businesses experience them at least once a week. The most common by far are phishing attacks (83%, and 79% in charities), followed by impersonation (for 27% and 23%). Based on a survey by the gov.uk, despite COVID-19 stretching many organisation’s cybersecurity teams to their limits, cybersecurity remains a priority for management boards. But it has not necessarily become a higher priority under the pandemic. Three-quarters (77%) of businesses say cybersecurity is a high priority for their directors or senior managers, while seven in ten charities (68%) say this of their trustees.
The most notable data breaches
In the climate where organisations are putting more emphasis on strengthening their online security systems, there is no shortage of data breaches or GDPR violations. Our experts have noticed and shortlisted a few most notable cases in any order for you to be aware:
1. Booking.com
The very recent case, when travel booking website Booking.com has been hit with a €475,000 ($560,000) fine after failing to report a data breach within the time period mandated by the GDPR. It happened back in 2018 when telephone scammers targeted 40 employees at various hotels in the United Arab Emirates (UAE). The hackers were able to get login creations for the booking system and to access the personal details of more than 4000 customers who booked hotel rooms via booking.com. The scammers exposed the credit card details of 283 customers, and in 97 cases the CVV code was also compromised. Based on GDPR, the data breach must be reported within 72 hours. Booking.com was late for 22 days (!) to report the breach to the Dutch Data Protection Authority and was issued a fine in April 2021, as reported by Forbes.
2. Twitter
Another company that was late to report the security flaw is Twitter – it was discovered in December 2018 but the social media giant did not report it to Ireland’s Data Protection Commission (DPC) until the following month. As a result, Twitter has been told to pay a €450,000 GDPR fine by Ireland’s data regulator for failing to report a 2018 data breach in the legally required timeframe. The DPC also determined that Twitter failed to adequately document the breach, another requirement under GDPR.
3. Vodafone
The firm that has been warned or fined smaller amounts on at least 50 occasions between January 2018 and February 2020, is in the news again: the Spanish data protection authority has fined Vodafone €8.15 million (approximately £7 million) for aggressive telemarketing tactics and repeated data protection failures. The fine was issued as a result of an investigation that was prompted by hundreds of complaints, with the regulator discovering a system that held up to 4.5 million contact lists purchased from third parties without user consent.
4. Facebook
And another social media giant – Facebook. Ireland’s data protection watchdog is demanding answers from Facebook over the release of records on 533 million people that appeared to stem from the social media site. As reported in April 2021, a spokesman for the Data Protection Commission (DPC) – which regulates Facebook in the European Union – said “a dataset, appearing to be sourced from Facebook, has appeared on a hacking website this weekend for free and contains records of 533 million individuals.”
5. H&M
The Data Protection Authority of Hamburg, Germany, fined clothing retailer H&M €35,258,707.95 — the second-largest GDPR fine ever imposed. H&M’s GDPR violations involved the internal monitoring of employees. After employees took vacation or sick leave, they were required to attend a return-to-work meeting. Some of these meetings were recorded and accessible to over 50 H&M managers. It has violated the GDPR’s principle of data minimisation — don’t process personal information, particularly sensitive data about people’s health and beliefs, unless you need to for a specific purpose.
6. Google
The biggest penalty (€50 million) was issued to Google for its alleged failure to provide notice in an easily accessible form, using clear and plain language, when users configure their Android mobile devices and create Google accounts, and obtain users’ valid consent to process their personal data for ad personalisation purposes.
COMPLIANCE & ETHICS HOTLINES, REPORT NOW
How to maintain GDPR compliance
What can we learn from these case studies? Maintaining GDPR compliance is a complex process, and requires a lot of diligent work. At CRI Group, we recommend looking at it as a part of your risk management strategies, together with your compliance policies and procedures.
To help you with maintaining compliance with GDPR, our integrity due diligence experts created the following top 10 GDPR best practices for any business or entity that deals with collecting, storing or using personal information:
1. Employ a Data Protection Officer (DPO)
It is a GDPR requirement that entities who carry out regular and systematic monitoring of individuals on a large scale, or large-scale processing of certain special categories of data, have an assigned DPO. It is also recommended, however, for all other entities to help ensure data security. While the GDPR does not specifically list the necessary training or qualifications of a DPO, the regulation does require the DPO to have “expert knowledge of data protection law and practices” (Digital Guardian, 2019). Implement thorough background screening processes and make sure they are trained and qualified to be your DPO.
2. Train your employees
Ensure that all personnel are aware of the GDPR and your organisation’s commitment to compliance. Make sure that all leaders, and especially key personnel charged with collecting, handling or storing data, understand their responsibilities under GDPR. Make date protection training a regular part of your employee curriculum.
3. Confirm the legality of your data collection
GDPR requires that you have a legal basis to collect personal data. For most businesses, the following are the most likely to be applicable:
- The information is necessary to perform a contract between the organisation and the individual;
- You have a legal obligation to process the data (such as a court order);
- The organisation has a legitimate interest in collecting and processing the data – in other words, there needs to be a relationship and business reason to collect the date (it cannot be random);
- The individual has provided direct consent to the processing of the data.
4. Maintain thorough records
For larger organisations (more than 250 employees), GDPR requires that records of data collection and processing be maintained. Again, this is also a best practice for smaller organisations, as well. It can help establish that the organisation is dutifully complying with the data protection principles in GDPR. Take inventory and make a record of the data you have collected and are storing to date. Create a detailed matrix to understand what types of data you are holding, where/how it is collected, how and where it is held, and whether it is still needed. Based on this information, you can also develop a data-retention policy to govern how long personal data is kept and stored. Keeping data on file longer than needed is a liability, and serves no business purpose.
5. Establish consent policies for data
For some of your records, consent is your lawful basis for holding it. Under GDPR, it is no longer acceptable to assume consent in your collected data, or treat silence as consent. Create clear and unambiguous consent forms for your data collection that demonstrate adherence to GDPR principles. And remember, under GDPR, you must make it a simple process for an individual to withdraw their consent at any time.
6. Perform due diligence on third-parties
Under GDPR, your organisation is responsible if third-party partners collect, store or manage data for your organisation. You must ensure their compliance with GDPR as if it is your own since they are responsible for your data. This is the time to update your contracts with them to include compliance measures, as needed. It is also important that you review their control systems and their data handling processes. They must be comprehensive and meet all of the GDPR requirements to keep data secure. CRI Group’s third-party risk management experts can help you conduct effective reviews of your partners and their processes.
7. Be responsive
Under GDPR, your organisation must respond to requests from individuals whose data you have collected and/or are storing. These requests are spelt out as individuals rights in regards to their personal data and they include the following:
- Right to be informed about what data is collected and why;
- Right of access to data that has been collected;
- Right to rectification/correction of inaccurate data;
- Right to erasure of data (“right to be forgotten”);
- Right to restrict processing of personal data;
- Right to data portability;
- Right to object to use of data; and
- Right not to be subject to automated decision making, including profiling.
Have a process in place to timely respond to requests and provide data when requested in order to stay in compliance.
8. Have written policies in place
Develop your internal policies in regards to GDPR and how you protect personal data, and communicate them across your organisation. Take special note to spell out policies on data retention, cross-border processing of data, and how you collect and handle data for persons under the age of 16, as GDPR has special requirements in regards to children’s data.
9. Conduct risk assessments
GDPR requires Data Protection Impact Assessments in certain cases. These assessments measure your organisation’s ability to protect personal data and risks associated with that protection. If your data processing is considered high-risk, uses new technology, or deals in large-scale processing of data in certain categories, the assessments are required – but for any organisation, they are recommended. Data protection experts at an outside firm like CRI Group can help you prepare robust risk assessments and follow-up plans to address their results.
10. Be prepared for a breach
A worst-case scenario in data security is a breach that exposes personal information. Under the steps above, your organisation should be well-positioned to prevent or limit any breach to your data security. However, you should always have a contingency plan in place to immediately respond to a breach should it occur. Understand that GDPR requires that the applicable EU data protection supervisory authority be notified within 72 hours of a breach. Gone are the days where a company can announce it weeks or even months after the fact. Be ready to notify the affected individuals that their data has been compromised, so that they can take the appropriate steps to respond.
Organisations don’t like to think about the impact of a data breach – but major cases have pushed governments to act in the public’s interest. Perhaps nowhere is this more true than in the EU, where the GDPR is now the governing policy for organisations that deal with individuals’ personal data. By being proactive with the steps above, your organisation can be better prepared and maintain compliance with the GDPR. Most importantly, you will have the confidence and trust of your consumers through effective best practices in handling and protecting their data. CRI Group’s experts are here to help. Contact us today so that we can walk you through the steps of GDPR compliance. If you have any further questions or interest in implementing compliance solutions, please contact us.
Who is CRI Group?
Based in London, CRI Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301:2021 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.
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CONTACT DETAILS
LONDON:
Corporate Research and Investigations Limited
2nd Floor, 5 Harbour Exchange Square South Quay, London E14 9GE United Kingdom
Tel: +44 207 8681415 | +44 758 8454959
Email: london@crigroup.com
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Tel: +971 43588577 | +971 43589884
Toll Free: +971 800 274552
Email: cridxb@crigroup.com
Publications
Resources | EU Directive Corporate due diligence and corporate accountability
Download the study on Corporate due diligence and corporate accountability by EPRS (European Parliamentary Research Service)
DownloadIndepth Feature on Anti-Money Laundering (AML) in the UK & UAE 2021 with our CEO and Scheme Manager
Interview reprint in Financier Worldwide's InDepth Feature: Corporate fraud and corruption 2021
DownloadQ&A: Anti-Money Laundering in UAE 2021
CRI Group and its ABAC® were featured in Financier Worldwide's InDepth Feature: Anti-Money Laundering 2021.
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