Standardising Communications Data Training Initiative

Briefly describe the initiative/ project/service; please include your aims and objectives 

NAFN Data and Intelligence Services proudly counts almost 100% of all Local Authorities, a significant and increasing number of Wider Public Authorities (WPA) and almost 100 Social Landlords in the United Kingdom as members. All Local Authorities must use NAFN to acquire communications data (CD) under the Investigatory Powers Act (IPA (A)) 2016 and we are leaders in providing a widely supported and exemplary Single Point of Contact service in addition to CPD accredited training, advice and guidance. NAFN also Chairs and delivers the WPA CD Forum for all WPAs listed on Schedule 4 of the IPA(A) 2016 and works tirelessly to ensure they are recognised as active members of the Communications Data Community alongside Law Enforcement. We are always seeking to collaborate and work in partnership to maximise public funding and the impact of our activities on the Public Sector. 

Never one to shy away from a challenge, in late December 2023, we called a meeting to bring together key players in the world of communications data acquisition to set a national standard for applications. The end goal of Standardising Communications Data Applications was to provide applicants with training and guidance, providing enough clarity to ensure applications are short, succinct and compliant. They would be furnished with live webinar training, written guidance and an elearning course that could be accessible to everyone at no cost. 

We recognised immediately that this could not be achieved alone. To truly achieve this goal, we would have to collaborate and work in partnership with IPCO Authorisation and Oversight, College of Policing, Home Office (Knowledge Engagement Team) and HM Revenues and Customs. Although some collaborations present a challenge to secure buy-in and commitment of time, money and expertise – everyone involved was immediately on the same page and keen to get started tackling unnecessarily lengthy applications. These applications are not only an ineffective use of time, they also undermine the overall justification for data. By tackling this issue, the benefits from Applicant to SPoC to IPCO Authorisation and then Oversight were abundantly clear. 

The greatest challenge and the reason for the collaboration was the delivery of this training to the WHOLE Communications Data Community. Many organisations have spoken about this community in the past but through this training initiative, the aim was to address this community in fact and not theory. This would mean bringing together Local Authorities, Wider Public Authorities and the Police (Law Enforcement Agencies) in a training session, which had not been done before. Comments from the Met Police included: 

“This looks very generous of NAFN to try to educate the whole applicant community. The lack of a National application process has always struck me as an issue that is within our ability to change so well done and thank you.” 

The first stage involved the development of the guidance and the principles that would underpin the creation of a short, succinct and compliant application for communications data. This underpinned the content of the webinar, the key being that although the purpose for acquiring CD is very different across the community, the principles of creating an effective application are exactly the same. 

Each collaborator worked together to develop the content for webinar training, that would speak to all members of the CD Community. We collated real applications for all types of organisations and sanitised them to produce Requires Improvement examples. We then applied the agreed principles to creating a short, succinct and compliant application to produce examples of Good Practice applications and build the training around the key principles and differences between them. 

Fast Forward to 25 June and we commenced the first phase of sharing the principles of standardising communications data applications in a series of 12 webinars. Sarah Cooper, NAFN Service Team Manager and David Jervis of the College of Policing dedicated six days to deliver two sessions a day to the CD Community. Having never worked together before, they quickly built a strong rapport and the joint delivery was excellent and extremely well received. Following the success of this partnership, we will certainly be working together again, as the benefit to whole CD Community cannot be denied. 

The collaboration supported extending the reach and truly compelling everyone organisation listed on schedule 4 of the IPA(A) 2016 to participate regardless of the type of organisation or agency they were. 

What are the key achievements? 

We successfully delivered the training to over 3,000 attendees (48% Police and 52% Local and Wider Public Authorities) and the feedback to date is phenomenal. The performance of this partnership is excellent. The impact on the communications data community is significant and was been identified immediately. Firstly, through bringing together the CD Community. Identifying in fact that there are different types of organisations seeking the same data for different purposes but very much in need of the same clarity, training and guidance. This recognition by attendees can only serve to strengthen and unify the CD Community, ensuring greater sharing of good practice and developments. 

There has also been an immediate impact on the quality and brevity of applications. Immediately following the 12 sessions delivered in partnership, participants were seeking the training content to refer to in completing pending applications. As the partnership targeted SPoCs, Applicants and Training leads, the knowledge was taken away immediately to be disseminating across organisations and forces. Although over 3,000 attendees were recorded, we are extremely confident the true number is significantly higher and will continue to rise as the content of the training and the true impact of the partnership is realised. 

Following the event, feedback was sought from attendees to better understand the impact of the delivery and if it would in fact change their working practices going forward. From almost 500 responses (45% Police and 55% Local and Wider Public Authorities) 96% stated that the learning outcomes were clearly outlined. They fully understood why we were bringing them together and what should be achieved by the training. 91% agreed the webinar met the outcomes we had intended, which was excellent. 

The impact can be further identified by the development of those in attendance. 45% of responders rated their knowledge novice to advanced beginner before the session and this number was significantly reduced to 28% following the session. Similarly, those rating themselves competent to Expert increased from 55% to an amazing 72%. 

Some of the key factors in understanding if training has been truly effective is the impact on the learner and not just the intended outcomes overall. We are extremely proud to show that 79% of responders felt their confidence had improved following the training. 

One of our proudest achievements in determining whether this training initiative had the desired impact, was 89% of responders confirming the webinar content will have an impact on their working practices. This is fantastic feedback and truly solidifies the value of the activity we have undertaken. 

Just a few of the statements from the attendees who wished to share their thoughts confirm the quality of the webinar content, delivery and the overall impact of the training initiative: 

• “As an IPCO inspector I was observing. I was impressed with the standard of the materials and the work that has taken place to deliver training to 3000+ applicants, which can only benefit the wider ‘community’ by improving the quality of submissions to IPCO-A and reducing returns for re-work” 
• “As a SPoC I really welcomed this topic. It means if an Officer is transferred in form another forces, they don’t have to learn ‘your’ way of doing things” 
• “I wish I’d had this session after I came out of ACFIP. For me it was clear, concise, helped my understanding of what was required. Excellent session!” 
• “Thank you so much, a fantastic initiative and session that will benefit us all” 

We believe the response of the attendees speaks for itself but hope you agree, this partnership is deserving of an award. 

One of the more creative outcomes of the initiative is its role in fostering a culture of shared knowledge. As different agencies and authorities were exposed to the same principles and best practices, there was an increase in the sharing of good practices and new developments within the communications data community. This culture shift is crucial for long-term improvements and better integration of knowledge across sectors. 

The development of accredited e-learning content represents a forward-thinking solution that extends beyond live sessions. By offering ongoing access to accredited, self-paced learning, the initiative ensured that future applicants could benefit from the standardisation efforts without needing to participate in a live session. This makes the initiative sustainable and adaptable for new individuals joining the field. 

How Innovative is your initiative? 

The initiative to standardise communications data applications is exceptionally innovative in several ways, addressing both operational inefficiencies and uniting diverse communities across public authorities and law enforcement. Here are key aspects of its innovation: 

Collaboration Across Stakeholders – The initiative brought together key stakeholders from a wide range of sectors; IPCO Authorisation ad Oversight, the College of Policing, Home Office, HMRC, police forces, local authorities, and public agencies who previously may not have collaborated in this way. This type of cross-sector collaboration was previously rare in the communications data community, as it had only ever existed in theory. This initiative made the CD community a more tangible group and a powerful one. With the collective buy-in of all members of the community it ensured a comprehensive approach to standardising processes and developing what would be accepted as national guidance. By engaging such a broad coalition, the initiative brought together stakeholders with diverse perspectives, creating a shared vision for a more efficient system. 

Addressing the Core Problem – The initiative directly tackled an operational challenge that was long-standing: lengthy, inefficient applications for communications data. Instead of simply addressing the symptoms, for example, errors in applications or slow processing times resulting in delays), it got to the heart of the issue: improving the quality and clarity of the applications themselves. This approach goes beyond traditional solutions by addressing the root cause and streamlining the process for everyone involved. The feedback confirms that the clarity this has provided to applicants supporting them to create better quality applications was long overdue and has had not only operational success but has actually increased the confidence of individuals. 

Comprehensive, Multi-Platform Training – The initiative’s training solution is innovative because it offers a multi-faceted, accessible approach. The content was delivered through 12 live webinars, written guidance, and an e-learning course, making it accessible at no cost and for a broad audience. Training materials were tailored to cater to various community sectors, addressing the specific needs of local authorities, public agencies, and law enforcement. This thorough, inclusive approach ensured that the training would have the widest possible reach. 

Inclusive Training for the Entire Community – A key innovation is the effort to unify a diverse and fragmented community that acquires communications data for very different purposes. A local authority could use it for social housing or blue badge fraud, whereas Police will use it to locate a missing person or investigate a murder. Previous attempts to provide training or set standards typically focused on individual groups or were too fragmented. This initiative reached over 3,000 attendees from police forces, local authorities and public sector organisations. By providing a shared training experience for all, the initiative fostered cohesion and greater collaboration across sectors. The initiative succeeded in demonstrating that the diverse needs for communications data are, in fact, aligned in requiring clarity and standardisation. 

Innovative Application Examples and Real-Time Feedback – By sanitizing real applications and categorizing them into “Requires Improvement” and “Good Practice” examples, the initiative introduced hands-on, actionable training. These examples provided real-world context and allowed participants to clearly see what good practice looks like, making the learning more applicable to their work. The use of real-time feedback from the 500 responses received helped identify the direct impact of the training and its immediate value for the attendees. Not only did the initiative collect feedback, but it measured the improvement in confidence and competency of participants, showing that the initiative made a tangible difference in performance. 

Streamlined Processes to Improve Efficiency – The primary aim was to create a short, succinct, and compliant application process for communications data, which had never been fully standardized before. By reducing the time and effort required for application submissions, the initiative directly increased operational efficiency. This innovation also helped reduce rework due to errors or lengthy submissions, which often undermined the purpose of acquiring data in the first place. 

Training with Immediate Impact – The results were evident immediately following the sessions, with participants actively seeking the training content to guide their ongoing work. The content proved to be so impactful that it influenced their practices right away, highlighting the real-time applicability of the training. 89% of responders indicated that the content would impact their working practices and add practical value. 

What are the key learning points? 

This initiative, aimed at standardising communications data applications, showcases a strong potential for replication and scalability, with several key factors contributing to its effectiveness: 

Replicability: The core components of this initiative – training materials, webinars, and e-learning modules are highly replicable. The approach of developing clear, concise, and compliant application has been accepted as national guidance, endorsed by the Home Office and recommended to be applied by all local government, wider public authority and law enforcement applicants for CD facing similar challenges with data acquisition and application processes. The involvement of the whole CD community demonstrates the broad applicability of the initiative across different organisational types and the ability to realise a theoretical group by focusing on the overarching principles of a matter rather than the detail i.e. ““We are more alike, my friends, than we are unalike.” Maya Angelou. Furthermore, the use of live training sessions and e-learning content makes the program easily adaptable for future audiences. 

Scalability: The training model has already proven to be scalable, having successfully reached over 3,000 attendees across various sectors. This wide reach illustrates that the framework can accommodate large numbers of participants without compromising quality. Within weeks of delivery, we were contacted by the Sensitive Intelligence Network, asking how it was accomplished. We have already therefore shared the learning and from this success to support another organisation with ambitions to deliver a similar project. With further development, the model could be expanded to train even larger groups, including international organisations or other national bodies facing similar issues with data acquisition. The online nature of the training (via webinars and e-learning modules) makes it accessible to a global audience, allowing for both geographical and organisational scalability. 

Collaboration and Stakeholder Engagement: One of the greatest successes of the initiative was the strong partnership between multiple key stakeholders, including IPCO Authorisation and Oversight, the College of Policing, the Home Office, and HM Revenue and Customs. By ensuring everyone involved was on the same page from the start, the initiative overcame initial challenges related to securing buy-in and expertise. This collaboration is a model for how other sectors or initiatives can tackle complex, cross-organisational issues. The lessons learned, especially around aligning goals and creating buy-in can be invaluable to others looking to implement similar large-scale collaborative efforts. 

Training and Knowledge Sharing: The use of practical examples and the sanitisation of real applications to illustrate “Requires Improvement” and “Good Practice” applications played a key role in the training’s success. This practical, hands-on approach ensures that the training resonates with the diverse needs of the attendees, whether they come from law enforcement or public authorities. Sharing these lessons and practical resources can help others design training modules that are relevant and effective across different sectors. 

Positive Feedback and Impact: The overwhelmingly positive feedback and engagement from participants, especially from law enforcement agencies like the Met Police, indicate that the initiative has made a significant impact. The widespread appreciation of the initiative suggests that the principles behind it are highly relevant and valuable. The high attendance rate (3,000+ attendees) also signifies that the demand for such a standardised training program is strong, and other organizations could adopt or adapt it to meet their own needs. 

In conclusion, this initiative has proven to be both replicable and scalable, with valuable lessons for others in terms of collaboration, training delivery, and stakeholder engagement. The principles and frameworks developed here can be applied to other data-related challenges, particularly in sectors where clarity, compliance, and efficiency are critical. By leveraging the successes and overcoming the challenges faced, other organisations and communities can benefit from the resources, strategies, and insights developed in this project. 

Additional Comments 

This initiative was a bold step toward solving a deeply ingrained problem by uniting a diverse range of stakeholders, pushing boundaries to improve application processes, and creating a lasting educational infrastructure. By addressing inefficiencies, promoting collaboration, and providing actionable training, it has set a new precedent for how data application standards can be established and maintained across multiple sectors.