WMT Digital Fraud Team

[SCDR_WMR]

Just to clarify a couple of things from recent posts...

The majority of cases seem to be from either TrainLine or Conductor led intel.

We're told this team is for long term repeat offenders only, whether this changes as the repeat offenders stop or are caught I couldn't say.

As we see on this forum daily, the intimidation of being accused of something offenders know they have done and the threat of court action seems to be enough to persuade them to pay up. I don't know how far down the evidence trail they are currently going, but I do know ticket blocks are put in for repeat offenders from conductor intel so would imagine this would be no different for data driven intel.

I have worked with the RPIs who are now the Digital Fraud Team and can assure you that they do know ticketing extremely well, as well as NRCoT and RoRA, and have used discretion in the RPI roles so I can't see any cases being investigated for things which aren't clearly fraudulent.

Hopefully there is a push within the industry to get this type of operation in place.

 

[RPI]

Just to clarify a couple of things from recent posts...

The majority of cases seem to be from either TrainLine or Conductor led intel.

We're told this team is for long term repeat offenders only, whether this changes as the repeat offenders stop or are caught I couldn't say.

As we see on this forum daily, the intimidation of being accused of something offenders know they have done and the threat of court action seems to be enough to persuade them to pay up. I don't know how far down the evidence trail they are currently going, but I do know ticket blocks are put in for repeat offenders from conductor intel so would imagine this would be no different for data driven intel.

I have worked with the RPIs who are now the Digital Fraud Team and can assure you that they do know ticketing extremely well, as well as NRCoT and RoRA, and have used discretion in the RPI roles so I can't see any cases being investigated for things which aren't clearly fraudulent.

Hopefully there is a push within the industry to get this type of operation in place.

Most TOc's have been investigating these since around 2018, certainly the case for GWR.

 

[fandroid]

My point was that Trainline had better be clear how much analysis of personal data it allows on behalf of TOCs, or it might find itself speaking nicely to the Information Commissioner and having to explain its policies. A blanket assumption that it's all there for the prevention of crime is unlikely to be regarded as legitimate.

What I'm thinking of is searching through the ticket buying behaviour of customers who otherwise haven't come to the attention of TOC revenue protection.

 

[SCDR_WMR]

My point was that Trainline had better be clear how much analysis of personal data it allows on behalf of TOCs, or it might find itself speaking nicely to the Information Commissioner and having to explain its policies. A blanket assumption that it's all there for the prevention of crime is unlikely to be regarded as legitimate.

What I'm thinking of is searching through the ticket buying behaviour of customers who otherwise haven't come to the attention of TOC revenue protection.

I would imagine many companies process it's user data in such a way under a very wide data handling policy. I would imagine the relevant legalities have been checked in some detail prior to this sort of information sharing taking place.

But just so I'm understanding your point, you're happy for a TOC to approach a retailer and say 'can we information on this person, we suspect fraudulent behaviour'.
But you're not happy for a retailer to say 'we believe this person is fraudulently using tickets on your trains, if you wish to investigate we can supply details'?

Obviously I'm not part of the fraud team, but the things they are (supposedly) looking out for, or being sent, are not things which law abiding passengers do and could be caught up in.

 

[fandroid]

I would imagine many companies process it's user data in such a way under a very wide data handling policy. I would imagine the relevant legalities have been checked in some detail prior to this sort of information sharing taking place.

But just so I'm understanding your point, you're happy for a TOC to approach a retailer and say 'can we information on this person, we suspect fraudulent behaviour'.
But you're not happy for a retailer to say 'we believe this person is fraudulently using tickets on your trains, if you wish to investigate we can supply details'?

Obviously I'm not part of the fraud team, but the things they are (supposedly) looking out for, or being sent, are not things which law abiding passengers do and could be caught up in.

No. I meant that a retailer shouldn't do searches for particular ticket buying behaviours across its customer base, in response to a general request from a TOC. ie a "fishing expedition". They should require a TOC to justify handing over data for named individuals. I've no idea whether the fishing expeditions do take place or not, but I'm sure that some TOCs would love them to be possible.

 

[AdamWW]

I've no idea whether the fishing expeditions do take place or not, but I'm sure that some TOCs would love them to be possible.

Presumably they do. Otherwise what was meant by "Trainline...led intel"?

 

[Haywain]

I expect there will be data sharing arrangements with all ticket retailers. Trainline is the largest retailer and so this is why they often get mentioned.

Train operators have access to comprehensive information about ticket sales and refunds and can see where retailers are issuing refunds and the volume of those refunds. However, all that information is anonymous so they will need to work with the retailers to establish whether there is anything dodgy going on. Trainline being the largest retailer means that working with them will inevitably yield good results. Similar work with smaller niche retailers (no offence intended to Trainsplit) may not prove cost effective.

 

[AlterEgo]

Presumably they do. Otherwise what was meant by "Trainline...led intel"?

Probably anonymised data, and also “leads” about individual customers with suspicious booking or refund patterns.

 

[AdamWW]

Probably anonymised data, and also “leads” about individual customers with suspicious booking or refund patterns.

Which looks like the "fishing expeditions" that some people are objecting to.

How do you find suspicious patterns without looking at everyone's data?

Of course this is something that anybody with a credit or debit card is subject to all the time for fraud prevention.

 

[SCDR_WMR]

No. I meant that a retailer shouldn't do searches for particular ticket buying behaviours across its customer base, in response to a general request from a TOC. ie a "fishing expedition". They should require a TOC to justify handing over data for named individuals. I've no idea whether the fishing expeditions do take place or not, but I'm sure that some TOCs would love them to be possible.

The other side of the argument being that a company that suspects illegal behaviour should investigate or pass on to the relevant body to take action. Presumably the retailer bares little risk, with them taking just a cut of sales and being reimbursed for refunded tickets (which is currently one of the major areas of fraud) and therefore is acting responsibly in reporting to TOCs.

 

[Cloud Strife]

I suppose it doesn't need to if you can either:
1) Catch the passenger in the act
2) Get them to incriminate themselves

2) is usually more effective than 1). There's an example with TV Licensing, who never go further than having people threaten others on their doorsteps. It's not the place to go into huge detail about their methods, but they generally rely solely on people getting afraid of 'inspectors' who use big words.

1) is where digital intelligence can pay off.

Being suspected of an offence for merely using split tickets is out of order solely on the basis of a lack of scan.

It is absolutely out of order. I once had a situation where I had two advances at either side of a journey with an Anytime ticket, and the Anytime ticket was bought in the train station. It looks to anyone as if I merely had one advance to open the barriers in London and another to open them in Dundee, but in reality I had cheap advances from London to York and from Edinburgh to Dundee, and the middle section was bought as a walkup ticket for cash.

 

[fandroid]

The other side of the argument being that a company that suspects illegal behaviour should investigate or pass on to the relevant body to take action. Presumably the retailer bares little risk, with them taking just a cut of sales and being reimbursed for refunded tickets (which is currently one of the major areas of fraud) and therefore is acting responsibly in reporting to TOCs.

Yes, I can see that a pattern of refunds might initiate an investigation without the TOC immediately knowing who is involved. They'd see the money heading back to the retailer and I guess that if it looks oddly repetitive, then it's legitimate to ask the retailer for more information about the claimants.

 

[Fawkes Cat]

. I once had a situation where I had two advances at either side of a journey with an Anytime ticket, and the Anytime ticket was bought in the train station. It looks to anyone as if I merely had one advance to open the barriers in London and another to open them in Dundee, but in reality I had cheap advances from London to York and from Edinburgh to Dundee, and the middle section was bought as a walkup ticket for cash.

Isn't this why the initial letters tend to be worded something like

'Having investigated your ticket buying patterns it seems that you might be failing to buy tickets for your complete journey: we would like you to comment on this '

I.e. a definite allegation is not made, and an opportunity is given for the recipient to explain the pattern that the railway finds to be suspicious.

 

[Gaelan]

Is there any reason to reply to such a letter? Especially if you know you haven't done anything wrong, it seems like running the risk of incriminating yourself on a technicality for no benefit. Presumably if they had enough evidence to prosecute in the first place, they'd go straight to doing so.

 

[AdamWW]

Is there any reason to reply to such a letter? Especially if you know you haven't done anything wrong, it seems like running the risk of incriminating yourself on a technicality for no benefit. Presumably if they had enough evidence to prosecute in the first place, they'd go straight to doing so.

I expect they'll make it sound as if you have to.

 

[Haywain]

Is there any reason to reply to such a letter? Especially if you know you haven't done anything wrong, it seems like running the risk of incriminating yourself on a technicality for no benefit. Presumably if they had enough evidence to prosecute in the first place, they'd go straight to doing so.

As such a letter is likely to follow a ticket inspection which has provided firm evidence of misusing tickets there will, almost certainly, be enough to prosecute. Evidence of short faring or doughnutting cannot be obtained from sales data alone as no offence is committed in buying tickets - they have to be (mis)used for an offence to be made out.

 

[Cloud Strife]

I.e. a definite allegation is not made, and an opportunity is given for the recipient to explain the pattern that the railway finds to be suspicious.

It's a very typical way to catch someone out when you don't have any evidence. People have a strong tendency to blab everything, even when they're under no compulsion to do so, especially if it's worded/designed in a threatening way. It's why TV Licensing design their letters in that way, because it makes people fear the consequences even when there are none.

It's why, for instance, people make the mistake of voluntarily going to police stations for an interview without a solicitor being present. The police assure them that it's 'just a friendly chat', but in reality without a solicitor, they're highly likely to incriminate themselves in some way.

The correct and best advice is not to engage with such letters if you haven't done anything wrong, and if you have done something wrong, then it's best to obtain legal advice before replying.

Evidence of short faring or doughnutting cannot be obtained from sales data alone as no offence is committed in buying tickets - they have to be (mis)used for an offence to be made out.

I assume, however, that there is nothing stopping them from asking someone to explain their journey history?

 

[Haywain]

I assume, however, that there is nothing stopping them from asking someone to explain their journey history?

Probably not, but I don't think we've any evidence of that having happened. It would be better to mount a revenue block and get the evidence to back up their suspicions.

 

[AdamWW]

Probably not, but I don't think we've any evidence of that having happened. It would be better to mount a revenue block and get the evidence to back up their suspicions.

We have seen someone asked to justify their historical purchase of railcard discounted tickets over a considerable period.

The justification seemed to be that the passenger having failed to show a valid railcard on a single occasion (even though they held one and there was a problem with the app) the TOC was then entitled to look through their purchase history and then require evidence that they had done nothing wrong.

 

[Haywain]

We have seen someone asked to justify their historical purchase of railcard discounted tickets over a considerable period.

The justification seemed to be that the passenger having failed to show a valid railcard on a single occasion (even though they held one and there was a problem with the app) the TOC was then entitled to look through their purchase history and then require evidence that they had done nothing wrong.

But it still resulted from them having been stopped first.

 

[Skymonster]

From trainline’s website

We may also share your personal data with travel operators to prevent and detect fraud against either you, Trainline or the travel operator.

Detect seems to be a highly pertinent word.

 

[AlterEgo]

Is there any reason to reply to such a letter? Especially if you know you haven't done anything wrong, it seems like running the risk of incriminating yourself on a technicality for no benefit. Presumably if they had enough evidence to prosecute in the first place, they'd go straight to doing so.

In most cases the best course of action will be to to ignore the correspondence entirely.

But it still resulted from them having been stopped first.

That’s a completely ridiculous thing for the company to do, though. Proof of purchase isn’t the same as committing an offence. If I’m stopped by the cops for having a light out do you think the police check ANPR to see all the other times I might have the light out as well?

It’s disproportionate and only happens in the Wild West of Railway companies who have far too many powers to prosecute things.

 

[[.n]]

I know that and would robustly defend my position but many won't. I am the 'go to' person in my family for rail tickets and legitimately purchase a variety of tickets for friends and family, many with railcards. My online booking history for the past couple of years will show tickets purchased with an Annual Gold Card, a Netwrok Railcard, a Disabled Persons Railcard, a Senior Railcard and a Family & Friends Railcard as well as undiscounted tickets.

Anyone looking at my online booking history might think there was something fishy going on....


Totally agree with this. I purchased some two-together railcard discounted Advance tickets at my local station last year. The tickets were purchased a couple of months ahead of travel, when they went on sale to get the best price. I used the station because I needed to purchase the railcard. The ticket clerk sold the tickets but said 'no need to buy the railcard today as you'll lose a couple of months validity, just make sure you've bought it before you travel'. Excellent service and I purchased the railcard from the ticket office on the day of travel.

Exactly - I'm in a similar position for being a go-to person for ticket purchase etc - not to mention that I personally have had several different railcards (sometimes simultaneously), as there are different use cases for which they are handy.

Along with as noted you only need the railcard to travel not to purchase - I've done that several times in the past, bought tickets on advance of travel and then the railcard on the day (or met the railcard holder along the way for tickets I'd purchased on their behalf)