“Project Waxwing” dropped into the public domain https://www.documentcloud.org/documents/4318165-Project-Waxwing.html some time in 2020.
“Waxwing” is the Investigation Plan completed for FBME Bank Limited in October 2014 by Barrington London Limited.
The Association of British investigators has its share of lovable rogues – principle actors are Tony Imossi and Nigel Brown (Directors of Barrington London Limited) who came close to breaching the ABI’s Code of ethics:
Principle 9 – Keep data Confidential
All members of The Association of British Investigators are to treat information (with which they are entrusted) during the course of business with respect and only access or disclose it for the purposes for which it is intended; attending to all instructions within the principles of the prevailing privacy legislation and in particular if processing or controlling personal data to be registered with the Information Commissioner’ Office (ICO). All ABI members should when processing personal data adhere to, operate and think within the scope of the General Data Protection Regulations (GDPR) in everything they do
Tony and Nigel skated on “Thinnish ice” by almost breaching the ABI’s by laws – DPA2018 sec 170. Previously known as DPA Section 55.
(1) It is an offence for a person knowingly or recklessly— (a) to obtain or disclose personal data without the consent of the controller, (b) to procure the disclosure of personal data to another person without the consent of the controller, or (c) after obtaining personal data, to retain it without the consent of the person who was the controller in relation to the personal data when it was obtained.
As Tony Imossi is the Data Protection Officer for the Association of British Investigators Limited (Company number 00998568) and manages data through the secretariat, matters caught members attention – how can, Tony in particular, preach to the rest of us about DPA and GDPR best practice?
My petitions to the GC began when, they had full knowledge of the outcome of the civil case in the High Court, incredibly, they reemployed Tony Imossi for another three years – processing members data, acting as the Associations Data Protection Officer. Indeed, to put a “Top hat” on matters they put Tony Imossi in exclusive charge of all GDPR/ DPA training and best practice. The latest, “Window dressing” is the ICO Code Membership drive for A.B.I personnel.
I was so shocked and surprised by the inertia and lack of spine to actually confront these issues (By the GC) that I became proactive and formally asked Tony Imossi and Nigel Brown to consider their positions and do the “decent thing”.
The General Council replied
- “If you are in possession of any proof of that statement, such as a report of findings in a criminal court, or even a current criminal investigation, we would ask that you produce that to us immediately and you can be assured the GC will instigate whatever urgent action it is within its powers to take”.
That shut me down. But, how can we use the disciplinary procedure of the A.B.I to make a complaint – the GC control the process and have pre judged the matter – they will only act if criminal proceedings apply… please note the incredible “Double Standard” that the GC created when they expelled an ABI member for displaying a badge that was similar to the ICO’s logo on his website – was that a criminal offence?
The GC will not adjudicate on their own errors of judgement regarding their own appointed, salaried, employee (Tony Imossi). The GC don’t actually pay that salary – we, the members, pick that bill up – so we have a legitimate and salient interest.
Unquestioning loyalty from the GC – but no regard for the membership and their remit to uphold professional values.