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Conduct integrity checks and suitability assessments

Type of countermeasure

This is a prevention countermeasure. Prevention countermeasures are the most common and cost effective way to stop fraud. They prevent or limit the size of the fraud risk by reducing the likelihood and consequences of fraud.

Summary

Assess the integrity of new employees, contractors or third parties such as by having entry level checks, probationary periods, suitability assessments or security vetting.

Why this countermeasure matters

Fraud is committed by individuals, not organisations. Fraud can be carried out or facilitated by:

  • individuals delivering a service on behalf of government
  • employees operating within a service provider
  • owners or directors who run a service provider
  • corrupted officials within government.

How to put this countermeasure in place

Some ways to implement this countermeasure include:

  • referring to Policy 12 of the PSPF
  • conducting entry checks, police checks and/or ‘fit and proper person’ tests for all new staff and contractors
  • undertaking suitability assessments of all vendors or service providers
  • having probationary periods for all new staff, contractors, vendors or providers
  • requiring staff and contractors to have and maintain security clearances for designated roles.

How to measure this countermeasure's effectiveness

Measure the effectiveness of this countermeasure by using the following methods:

  • Refer to Policy 12 of the PSPF Eligibility and Suitability of Personnel.
  • Review the process for undertaking integrity checks or suitability assessments for new staff, contractors, vendors or providers as required by Policy 12 and 13 of the PSPF.
  • Analyse data on integrity checks or suitability assessments and confirm these are always completed.
  • Review completion rates of induction training.
  • Review probation results.
  • Review cases of fraud and non-compliance to determine why integrity checks and suitability assessments did not work in those circumstances.
  • Undertake a staff census and particularly ask questions relevant to staff integrity and performance management.
  • Review APSC Census Results if you are Commonwealth entity.
  • Review positions that require a security clearance and confirm staff and contractors have the required clearance.
  • Where available, analyse data related to the Australian Government Security Vetting Agency declarations/notifications.

Related countermeasures

Establish governance, accountability and oversight of processes by using delegations and requiring committees and project boards to oversee critical decisions and risk. Good governance, accountability and oversight increases transparency and reduces the opportunity for fraud.

Collaborate with strategic partners such as other government entities, committees, working groups and taskforces. This allows you to share capability, information and intelligence and to prevent and disrupt fraud.

Make sure to confirm the identity (an attribute or set of attributes that uniquely describe a subject within a given context) of the person making the request or claim using evidence.

Coordinate disruption activities across multiple programs or entities to strengthen processes and identify serious and organised criminals targeting multiple programs.

Related Fraudster Personas

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