Concerns Over The Requirements Of Independent Adjudication

ABI Logo

Tony Imossi, immediate past President of the ABI, is concerned that companies who are being audited to the BS102000 standard are not being audited consistently in relation to independent adjudication.  Lynn Watts-Plumpkin, Director and General Manager at IQ Verify, who chaired the drafting panel that wrote this standard, said that consistency of audits is crucial, to ensure that all companies who meet this standard follow the correct processes and meet the requirements intended by the drafting committee.

Tony highlighted reference to the wording in para 4.1 of the BS102000 standard: -

The investigative service provider should operate a complaints management system. This should include recourse to independent adjudication.

Tony would like to ensure there is understanding and consistency among the Accredited Auditors how a service provider might satisfy the requirement.  

In Lynn’s capacity as the Chair of the Standard panel and Tony who also sat on the drafting panel understood that it was intended by the BS102000 drafting panel that a complaints management system would require a external facility, independent of the service provider, in the event of a complaint escalating beyond the internal management system.  The service providers T&Cs should explain the complaint handling.

Tony said “From experience I can say that membership of, or affiliation to a sector specific professional body alone is unlikely to be sufficient”.  There are only a few properly set up sector specific organisations and Tony very much doubts any, other than the ABI, have developed a suitable complaints process with the independent ingredient. 

In brief, and as an example, Tony has set out below the ABI complaints system:  

  • A disciplinary process to deal with non-compliance or breaches of the Bye-Laws, which includes a members’ right to be heard.
  • A disciplinary process to fully investigate any complaint received about a member, with the right to be heard before a disciplinary panel and the opportunity to appeal to the GC, at no cost, any decision reached by the panel.
  • Each complaint is referred to an Independent Adjudication Officer (retired solicitor) to establish whether or not there is a case to answer and if so to guide the disciplinary panel on punishment applicable.

Without that last point the handling of a complaint will probably be no more than notional scrutiny by the service providers peers.  This in Tony’s opinion falls short of what the panel intended.

Lynn has been in communication with SSAIB, NSI and the SIA about this point. Also when BS102000 is reviewed Lynn has requested that additional clarification under 4.1 of BS102000 is added by the drafting panel, which will assist investigative services organizations to understand the requirements of independent adjudication and assist with the standardization of the audit process.