Revision: 01-2006 Effective: 02-22-2006
PREFACEA. DirectivesAssets Protection (AP) Directives are the basic guidelines by which we conduct our business. As an AP team member, you are expected to follow the Assets Protection Directives at all times. Violation of any Directive shall be handled according to the applicable coaching and corrective action policy (see Corporate Policies - Counseling and Corrective Action).Directives are to be followed by all team members and if you are instructed to violate a Directive you must immediately notify your supervisor. If the order involves your supervisor, notify the next level AP team member.
The Directives are in addition to, and not intended to supersede any company policies and procedures. The Directives are not contracts, expressed or implied. Following the Directives does not guarantee continued employment by Target.
NOTE:If you become involved in situations that are not covered by a Directive, you are expected to act in Target’s best interests and in a manner that avoids liability.B. Note, Caution, Warning StatementsNote, Warning and Caution statements are used within the Directives to emphasize important and critical information. AP team members must read these statements to help ensure their safety and the safety of other team members and guests.
1. Note - A Note is a statement used to notify people of information that is important, but not hazard related.
2. Caution - A Caution indicates a potentially hazardous situation that, if not avoided, could result in minor or moderate injuries.
3. Warning - A Warning indicates a potentially hazardous situation that, if not avoided, could result in death or serious injury.C. Revision Number/Effective Dates/Highlighted TextEach directive shall be noted with a Revision Number, the Effective Date of the revision and Change bars.
1. Revision Number - Directive revisions will be sequential indicating the number and year of the revision (example: 01-2006 = the first revision in 2006, 02-2006 = the secondrevision in 2006, etc.).
2. Effective Date - All Directives shall include the date the revision becomes effective.3. Highlighted Text - Highlighted text (red font) is used to indicate changes within the current revision . This allows for easier review so the user can identify areas that havebeen modified.
AP GENERAL POLICIESRevision: 01-2006 Effective: 02-22-2006
A. Confidentiality
AP incidents and cases contain sensitive material that must be treated as confidential. In addition, all AP team members must adhere to the following rules regarding confidentiality:
1. All information regarding investigations is considered confidential and shall not be
discussed with persons not involved with the investigation.
2. Information received from law enforcement is considered confidential and may not be
discussed with persons not involved with the investigation.
3. Information received from background screening, drug screening, previous employers,
proprietary systems, team members’ files and other similar information is considered
confidential and is not to be discussed with any persons not involved in the investigation.
Requests for this information by law enforcement shall be referred to the manager or
District Assets Protection Leader (DAPTL)/Distribution Group Assets Protection Leader
(Distribution GAPTL).
B. Information Security
AP team members are required to ensure the security of Target’s confidential information by using that information appropriately and safeguarding it. All Information that Target creates, stores, transmits, or uses in conducting its business is the exclusive property of Target.
1. Computers/Laptops/PDAs/Treos - Target computers contain sensitive information and steps must be taken to ensure the protection of that information at all times.
a. Passwords - Never share passwords with other people, your password shall be
used for your access only.
b. Computer Access - Ensure access to your computer is locked when leaving it
unattended.
c. Do not leave laptops/PDAs and Treos in exposed areas when traveling
(examples:In a car, hotel room, in checked luggage, etc.).
Target’s Information Security Policy can be found online at TGT under the Company & Culture tab.
C. Knowledge of Wrongdoing
AP team members will immediately bring to the attention of the appropriate Target team member (supervisor, next level supervisor, Human Resources, Integrity Hotline, etc.) knowledge of any:
1. Theft of any Target assets.
2. Falsification of Apprehension/Recovery reports.
3. Deviation from approved apprehension procedures.
4. Failure to report a Non-Productive Incident (NPI).
5. Detrimental conduct in violation of company polices, including but not limited to:
a. Possession or use of alcohol on company property.
b. Possession or use of a controlled substance on company property.
c. Possession or use of a weapon on company property.
6. Harassment.
D. Crimes Against Property/Persons
AP members must report any crimes against person and crimes against property occurring on Target property.
NOTE: This Directive does NOT apply to merchandise vadalism cases. Loss to Target property (including merchandise) is reportable via the Property Loss Program.
1. Documentation - The following documentation shall be required following any crime against a person or property:
a. Enter all cases into Common Incident Reporting System (CIRS) within 24 hours
of the incident, documenting the type of incident, parties involved and any actions
taken by AP and/or Target.
b. Obtain witness statements from all team members who were witness to the
incident.
c. Request copies of any police/mall security reports and retain in the case file.
d. Complete a post Serious Incident Report/NPI Follow-up Report when requested.
Return one copy to HQ and retain a second copy in the case file.
2. Notification
a. Notify the DAPTL/Distribution GAPTL of all crimes against persons and any
recurring crimes against property (i.e. patterns of car theft/vandalism).
b. Notify the STL in all cases of property loss. It shall be the STL’s responsibility to
ensure the appropriate Property Loss Reports are completed.
c. Notify the Guest Reporting Center.
d. Call Alert One (see Emergency Procedures Flip chart).
E. Minimum Age for AP Team Members
All AP team members must be at least 18 years of age at the time they are hired.
F. Conflict of Interest
Target AP team members may have full or part-time employment elsewhere, unless that employment would result in a conflict of interest as defined by Target’s Business Ethics - Code of Conduct and/or any additional items listed in this section.
AP team members shall be aware of the contents of the Business Conduct Guide and the provisions of the Guide with respect to Conflict of Interest, including Target’s policy on vendor gifts and other potential conflicts.
1. Existing Conflict
a. A Conflict of Interest exists when one (1) or more of the following apply:
1. An AP team member is employed by another business that competes
with Target or in a security position with another retailer that involves
apprehending shoplifters or dishonest team members
2. An AP team member’s other employment interferes with the ability to
perform essential functions of the job at Target.
3. An AP team member’s other employment conflicts with scheduling or court
commitments.
4. An AP team member’s other employment is a paid, sworn law enforcement
position where a team member is employed by a government entity (sheriff,
deputy sheriff, peace officer, etc.) in any community (due to the nature of
the work responsibilities).
5. An AP team member’s other employment is with a company with which
Target does business, if interaction with Target would be required or could
occur.
2. AP Team Members working in Non-AP Roles - Due to the unique responsibilities
associated with Assets Protection, AP team members are NOT permitted to work in
Non-AP positions within the same store.
NOTE: AP team members may work additional hours in a Non-AP position at an alternate store or Distribution Center (DC).
G. Court Testimony Payments
1. In some jurisdictions, AP team members may receive a fee from the court for appearing
as a witness on behalf of the State, County or City for cases stemming from or related
to their employment as Target team members.
2. Any witness fee checks shall be turned over to the Executive Team Leader - Assets
Protection (ETL-AP) or Assets Protection Group Leader (APGL) for deposit into the
appropriate account used to off-set business expenses. The DAPTL or Distribution
GAPTL shall provide the ETL-AP/APGL with the appropriate account information.
3. The ETL-AP shall partner with HR regarding payroll related questions for team
members and former team members testifying on behalf of Target.
H. Team Member Package/Locker Checks
Target reserves the right to monitor or inspect work areas or items that team members bring to work, like coats, purses, backpacks, bags or packages. Target also reserves the right to monitor or conduct inspections of work areas and/or personal property at any time.
This section outlines procedures for conducting team member package/locker checks.
1. Team member package/locker checks shall be conducted by an AP team member,
the Leader on Duty or contracted guards (at DCs).
2. Each store/DC shall have a designated location for team members and partner business
team members to secure packages while the team members are working.
3. Package checks of team members/partner business team members shall be performed
at the door as the team member exits after their scheduled shift.
4. A witness (example Leader on Duty, another AP team member, etc.) must be present
when conducting team member package/locker checks.
5. All vendor packages shall be checked at the service desk.
6. Team members shall not be allowed to keep any purchases or personal packages in
their work area or adjacent stockroom.
7. All team members/partner business team members must have the original sales receipt
in the package/shopping bag.
APPREHENSION GUIDELINES Revision: 01-2006 Effective: 02-22-2006
A. Purpose
This section lists the steps that MUST be followed in order for an AP team member to make a shoplifting apprehension. All steps must be observed, unless otherwise noted, and a detailed description of each step documented in the CIRS case narrative.
B. Certification
Only certified AP team members are authorized to apprehend or assist in the apprehension of shoplifters. Certification is received upon the completion of the following AP Academy courses:
1. Nonviolent Crisis Intervention R - must be completed within 30 days of hire date.
2. Position's Basic Training Courses
3. External Apprehension Certification
C. Five Steps for Apprehension
Certified AP team members must observe all five steps prior to making a shoplifter apprehension.
NOTE: If local law enforcement takes independent action and makes an apprehension before all five steps are met, the details must be documented in the CIRS report.
1. Initiation of Observation - The subject must enter the store/area without possession of Target merchandise.
2. Selection - The subject must be observed selecting Target merchandise from the display location.
3. Concealment - The subject must be observed concealing the merchandise, or the AP team member must have NO reasonable doubt based on observations that the merchandise has been concealed by the subject.
NOTE: If the merchandise is not actually concealed, it must be exposed as the subject exits or attempts to exit the store.
4. Maintain Observation - The AP team member must maintain sufficient surveillance of the subject in order to know the location of the merchandise and ensure the subject does not discard the merchandise. NOTE: A Productive Merchandise Recovery (PMR) shall be attempted if surveillance is broken for any reason, or the AP team member can not maintain sufficient surveillance. (See PMR Directive).
5. Failure to Pay for Merchandise/Exiting the Store -AP team member(s) must observe the subject attempt to exit the store without paying for the merchandise.
NOTE: Some jurisdictions allow variances from the exiting requirement to allow apprehensions of concealed merchandise before an individual reaches the building’s exit. In these cases, the requirements must be documented and approved by the Director or Vice President of Assets Protection using the "Variance from Exiting Form" (found on the AP Zone).
SAFENESS - SUBJECT WITH A WEAPONRevision: 01-2006 Effective: 02-22-2006
A. Purpose
The safety of Target team members and guests is our highest priority. Exercising appropriate caution in the process of making an apprehension is critical.
B. Subject with a Weapon
1. Weapon - A weapon is defined as any object that could potentially be used against a
team member or guest. Weapons include, but are not limited to, box cutters, knives,
scissors, screw drivers, hand guns, stun guns, chemical agents and clubs.
2. If a weapon is used or displayed, or if any AP team member has reason to believe a
subject is in possession of a weapon during any of the five apprehension steps:
a. Back away and do not attempt to make an apprehension.
WARNING: Do not put another team member at risk by requesting the subject be "Guest Serviced".
CAUTION: If subject is observed cutting merchandise with an unknown object, treat that object as a weapon and follow steps listed in 2. above.
b. Contact law enforcement and advise:
1. Your name and title,
2. Your phone number,
3. Store location / address,
4. Description and location of the subject, and
5. Type of weapon being used by the subject.
NOTE: If law enforcement cannot respond, allow the subject to leave the store and document the subject’s description,subject’s vehicle description and any merchandise taken from the store, and document the case in CIRS as a Known Theft Report (KTR).
c. Return to the AP office and maintain surveillance of the subject via Closed
Circuit Television (CCTV).
d. Document the case in CIRS using the steps outlined in the Documentation
section:
1. If law enforcement makes an apprehension, document the case as
a merchandise theft.
2. If law enforcement is not available, allow the subject to leave and
document the case in CIRS as a KTR.
3. If you are confronted or threatened by a subject armed with a weapon:
a. Immediately attempt to disengage from the subject.
b. Allow the subject to exit the store.
c. If necessary, use the verbal de-escalation skills taught in
Nonviolent Crisis Intervention R training.
d. Contact law enforcement, your DAPTL and Alert One
1. Any incident that results in a serious injury to a team member, guest or
detained subject must be communicated to Alert One immediately and
reported electronically by the LOD.
e. Document the case appropriately in CIRS (threat or assault) using the steps
outlined in the Documentation section.
NOTE: Following any altercation, the AP team member(s) involved shall review the occurrence with their supervisor and the ETL-HR for safeness and procedural compliance and to determine if any further training is required.
C. Use of Weapons, Chemicals or Body Armor by a Team Member
1. Weapons - AP team members are prohibited from possessing or using any type of
weapon while on company property.
a. Team members are prohibited from using any type of AP/Target equipment
(radio, handcuffs, etc.) as a weapon.
b. Team members are prohibited from possessing or using saps, nightsticks,
billy clubs, blue jacks or other similar devices on company property, which
includes the parking lot, at any time, whether on or off duty.
2. Chemicals - AP team members are prohibited form possessing or using chemical
protection devices, other than for personal protection to and from work. (Examples: Mace,
pepper spray. etc.)
NOTE: All chemical protection devices must be secured in a Non-Assets Protection area during the team member’s work shift.
3. Body Armor - AP team members are prohibited from wearing bulletproof vests or other body armor equipment while on duty.
NOTE: Contracted guard services working on company premises may carry defensive weapons or a firearm only as authorized by the Director/Vice President of Assets Protection.
SAFENESS - REASONABLE FORCE / PHYSICAL ALTERCATIONSRevision: 01-2006 Effective: 02-22-2006
A. Reasonable Force
1. Reasonable Force is defined as the least amount of physical force necessary to make an apprehension, while ensuring the safety of bystanders and yourself. When making an apprehension, Reasonable Force may be used to protect AP / Target team members and guests (bystanders).
2. If an AP team member believes a subject poses a physical threat, handcuffing guidelines (outlined in the Handcuff Directive) shall be followed and law enforcement contacted immediately.
B. Physical Altercation
If an altercation occurs:
1. Immediately attempt to disengage from the subject.
2. Allow the subject to exit the store.
3. If necessary use Nonviolent Crisis Intervention R training.
4. Contact law enforcement and Alert One.
a. Any incident that results in a serious injury to a team member, guest or detained subject must be communicated to Alert One immediately and a Guest Service Report filed.
5. Communicate the incident to the Store Team Leader (STL) and/or Leader on Duty, your DAPTL and HR as soon as possible.
6. Document the case appropriately in CIRS (threat or assault) using the steps outlined in the Documentation section.
NOTE: Following any altercation, the AP team member(s) involved shall review the occurrence with their supervisor and the ETL-HR for safeness and procedural compliance and to determine if any further training is required.
SURVEILLANCERevision: 01-2006 Effective: 02-22-2006A. General Guidelines
1. Surveillance conducted by AP team members of any individual shall be based only on the actions and behaviors of the individual.
2. Surveillance shall not be based on individual characteristics such as age, gender, race, sexual orientation, disability, national origin, religion, etc.
B. Certification
Only certified AP team members are authorized to conduct physical and/or CCTV surveillance. Certification is received upon the completion of the CCTV training outlined in the AP Academy Basic Training.
C. Surveillance Equipment
Surveillance equipment is defined as any audio or video equipment that assists in the monitoring and/or recording of an individual’s actions or words.
1. Surveillance equipment is the property of Target and shall ONLY be used by AP team members for approved company use. Improper use of equipment (example: using cameras to follow guests or team members for non-AP reasons) is prohibited, any AP team member caught using surveillance equipment in an inappropriate manner is subject to applicable coaching and corrective action.
2. Requests to use surveillance equipment for business purposes other than AP-related investigations must be approved by the DAPTL / Distribution GAPTL.
3. The store ETL-AP/APGL is responsible for all surveillance equipment including the proper use, location and maintenance of all equipment.
4. Video Footage - All video footage captured in by AP surveillance equipment is property of Target and shall only be used for evidentiary purposes. Any misuse, misrepresentation or manipulation of video footage by any team member is subject to applicable coaching and corrective action.
NOTE: AP surveillance is confidential and access to view the video shall only be granted to individuals with proper approval. AP team members shall partner with DAPTL (external cases) and DAPTL and HR (internal cases) prior to allowing anyone other than AP team members working on the investigation or law enforcement to view AP video.
a. Old videotapes that are no longer usable shall be destroyed by cutting the tape and removing the ribbon.
5. Public View Monitors
a. Recording of all Public View (and Exit View where applicable) monitors is required 24 hours a day, 7 days a week for digital and non-digital stores.
b. Public/Exit View images shall be retained for a minimum of 31 days for all stores.
6. Fitting Rooms / Restrooms - Target does not allow the use of surveillance equipment in or over fitting rooms or restrooms, or allow surveillance equipment to be positioned in such a way to provide the opportunity to monitor fitting rooms or restrooms.
7. Executive’s / Supervisor’s Office - Audio or video equipment may not be placed in or over an executive’s or supervisor’s office without prior approval from the Director / Vice President of Assets Protection and HR.
8. Tape Recorders - Tape recorders and other listening devices shall not be used by store based AP team members. Recorders may be used by Investigations team members, procedures are outlined in the Investigations Directives.
D. Critical vs. Non-Critical Equipment
AP surveillance equipment is divided into two categories, critical and non-critical. The ETL-AP/APGL shall be responsible for ensuring all equipment is properly maintained and repaired according to the requirements/time lines listed below:
1. Critical Equipment is defined as devices which impact safeness strategies.
a. Critical equipment includes:
1. Exterior cameras, including Pan, Tilt and Zoom (PTZ) and fixed cameras used for parking lot surveillance.
2. Entrance/exit cameras, including trucker’s door, team member entrance (where applicable) and front entrance public view monitors.
3. Other public view monitors including fitting rooms, guest service and where applicable Garden Centers.
4. AP Booking room camera, Cash Office camera, Front Lane and Guest Service Desk camera.
b. Critical equipment must be repaired within 48 hours of the reported breakdown.
c. Any breakdown of critical equipment must be reported to the DAPTL immediately.
2. Non-Critical equipment is defined as all other AP surveillance equipment.
a. Non-critical equipment must be repaired within 72 hours of the reported breakdown.
3. The DAPTL/Distribution GAPTL must be notified immediately if timing for repairs of critical or non-critical equipment exceed the time limits listed above.
E. Off-site Surveillance
AP stores team members are not authorized to conduct off-site (outside of Target property) surveillance. Off-site surveillance may only be conducted by a certified Investigations team member, pursuant to Investigations Directives.
PRODUCTIVE MERCHANDISE RECOVERIES (PMRS) Revision: 01-2006 Effective: 02-22-2006
A. Purpose
In situations where not all five apprehension steps can be observed, and it is safe to do so, the AP team member(s) shall attempt a Productive Merchandise Recovery.
If the AP team member is able to recover the merchandise, the incident shall be documented in CIRS as a PMR - Productive Merchandise Recovery. If the AP team member is unable to recover the merchandise, the incident shall be documented in CIRS as a KTR - Known Theft Report.
WARNING: A PMR shall not be attempted if the subject is in possession, or believed to be in possession, of a weapon. In these cases the AP team member shall ensure the subject is captured on video and shall attempt to get vehicle information (make, model, license plate number) as the subject exits the store.
1. During a PMR an AP team member may:
a. Contact another non-AP team member, wearing red and khaki, to initiate guest service without reveal the reason for the request.
b. Make themselves visible to the guest as a deterrent.
c. Contact a Sales team member or research in store registers to determine if an item was purchased.
d. Ask an uniformed AP team member (TPS or ETL-AP) to stand by the exit doors to act as a deterrent.
2. During a PMR an AP team member may NOT:
a. Initiate a PMR, ask another team member to initiate a PMR or ask a non-AP team member to guest service the subject if they believe the subject is in possession of a weapon.
b. Touch an individual or anything they are carrying.
c. Ask for merchandise or make accusations of theft of merchandise.
d. Ask another team member to accuse, remove merchandise or make inappropriate gestures to the individual.
3. If the guest initiates interaction with an AP team member:
a. Verbally identify yourself as Assets Protection, but do not show identification.
b. If the guest pursues the conversation, refer the guest to store management for resolution.
4. All PMRs shall be entered into CIRS using the steps outlined in the Documentation section.
TARGET PROTECTION SPECIALIST (TPS) MERCHANDISE RECOVERIESRevision: 01-2006 Effective: 02-22-2006
A. Purpose
Uniformed TPS team members may conduct receipt checks and EAS responses at Target store exits when a guest is departing the store with high dollar / high theft exposed merchandise (receipt checks) or when an EAS alarm sounds as the guest exits the building.
B. During a TPS Merchandise Receipt Check
1. The Uniformed TPS may:
a. Check receipts for high dollar / high theft exposed merchandise.
2. The Uniformed TPS may NOT:
a. Check bagged items to determine whether or not something has been concealed or paid for.
b. Create an EAS Alarm in order to check the purchases or bags of a guest or team member. Creating an alarm includes but is not limited to:
1. Turning the system off and back on to cause an audible signal when a guest/team member walks through the pedestals.
2. Affixing or placing a live EAS tag onto or onto a purchase by a guest/team member.
3. An AP team member walking through a pedestal with an EAS tag at the same time a guest or team member is exiting the store.
4. Any other manipulation of the EAS system to cause an alarm.
3. Whenever possible, TPS receipt checks shall take place inside the building.
4. If a guest becomes uncooperative during a receipt check:
a. Apologize and allow the guest to leave with the merchandise.
b. Get a description of the guest and vehicle and document in the CIRS report.
NOTE: TPS Merchandise Receipts checks are only to be conducted by uniformed TPS team members. APS team members may not conduct merchandise receipt checks. If a uniformed TPS is not available, the LOD, GSTL or ETL-AP shall follow the outlined procedures; other team members are not permitted to conduct receipt checks.
C. Documenting TPS Merchandise Recoveries
The following procedures shall be followed by the TPS when documenting any TPS recovery or attempted TPS recovery.
1. Each TPS Recovery must be documented in CIRS.
a. Cases shall be identified as "Other" / "TPS Merch Recovery".
b. Note the time, date and location of the recovery (example: 11:03 am, November 27, Green exit).
c. List all merchandise recovered.
d. Do not add multiple recoveries to the same report; each TPS recovery shall be entered as a single incident with a unique CIRS case number.
NOTE: CIRS reports may be called upon if a case goes to criminal or civil trial and therefore are incident specific and shall only contain a single incident.
D. EAS Alarm Response
If an EAS alarm sounds, the uniformed TPS shall follow the procedures outlined below. If a uniformed TPS is not available, the LOD, GSTL or ETL-AP shall follow the outlined procedures; other team members are not permitted to respond to EAS alarms.
1. Guests with visible purchases:
a. Approach guest and conduct merchandise receipt check to verify purchases and deactivation of EAS tags.
1. If you find the item on the receipt, deactivate the item and allow the guest to leave.
2. If the item is not on the receipt, ask the guest if they would like to purchase the item.
3. If the guest does not have, or cannot find a receipt, ask the guest which cashier rang up their purchase and verify with the cashier. If the purchase cannot be verified, contact another AP team member for assistance.
4. Searches of a subject’s personal possessions (example: purse) for evidence (merchandise) is not allowed unless the subject initiates the search or requests an AP team member to inspect their possessions.
NOTE: If the guest becomes uncooperative, allow the guest to leave. Obtain a description of the guest and guest’s vehicle and enter it in CIRS.
2. Guest with NO visible purchases:
a. Approach guest and conduct merchandise receipt check to verify purchases and deactivation of EAS tags.
1. If the guest does not have any purchases, ask if they have an electronic key - if so ask to see it.
2. Ask if guest has merchandise from another store - if so ask if they would like it deactivated.
3. If the guest does not have merchandise or an electronic key, allow them to leave the store.
4. If guest shows you Target merchandise that has not been paid for, ask if they would like to purchase the merchandise and allow them to purchase the item(s). If the guest refuses to purchase the item, ask for the merchandise back.
5. Searches of a subject’s personal possessions (example: purse) for evidence (merchandise) is not allowed unless the subject initiates the search or requests an AP team member to inspect their possessions.
NOTE: If the guest becomes uncooperative, allow the guest to leave. Obtain a description of the guest and guest’s vehicle and enter it in CIRS.
APPREHENSIONS Revision: 01-2006 Effective: 02-22-2006
A. Purpose
This section covers directives outlining the different types of external apprehensions and the AP team member requirements for each type.
B. Closed Circuit Television (CCTV) Apprehensions
Certified AP team members may make shoplifting apprehensions utilizing CCTV provided each of the following guidelines are followed:
1. The five steps for apprehension have been observed and can be documented by an AP team member.
2. The incident, or any portion of the incident is captured/recorded using non-time lapsed Target CCTV with sufficient surveillance maintained by AP team member(s) to observe the five steps.
NOTE: When two or more AP team members are involved, one team member shall maintain camera surveillance while the second team member makes the apprehension on the floor. If only one AP team member is on duty and is required to discontinue camera surveillance and go to the selling floor, the AP team member can not make the apprehension because sufficient surveillance will have been lost. If appropriate, attempt a PMR.
3. All documentation steps shall be followed to preserve evidence, including retention of all applicable video.
C. Service Desk Apprehensions
Shoplifter apprehensions involving Service Desk transactions shall only be made in the following circumstances.
1. All five apprehension steps have been observed by AP team member.
2. If the subject interacts with the Service Desk, the interaction has nothing to do with the shoplifting apprehension. (Example: After the first four apprehension steps are observed, the subject approaches the Service Desk to ask a team member a question, not related to the shoplifted merchandise. Then the subject attempts to leave the store with the merchandise. AP team member apprehends as subject exits the store.)
3. Single incidents where the DAPTL is contacted for approval prior to making the apprehension. In these cases the following steps must be clearly documented in the CIRS report, in addition to standard requirements:
a. The AP team member must have public view video clearly showing the subject entering the store WITHOUT the merchandise and later approaching the Service Desk with the merchandise.
b. The time and date the DAPTL was contacted for approval.
c. All video footage of the incident including entry of store, selection and apprehension. All video must be retained with case file.
4. Incidents where a person or group of individuals have known theft activity in an area and where the DAPTL
has given prior permission to a SPECIFIC AP team member to make an apprehension. The incident must be
documented as follows:
a. The AP team member must have public view video clearly showing the subject entering the store WITHOUT the merchandise and later approaching the Service Desk with the merchandise.
b. The time and date the DAPTL was contacted for approval.
c. All video footage of the incident including entry of store, selection and apprehension. All video must be retained with case file.
NOTE: Under NO circumstances are AP team members allowed to contact Service Desk team members in order to influence the outcome of a transaction.
D. Restroom / Fitting Room Apprehensions
AP team members are not allowed to conduct surveillance or make apprehensions in restroom and/or fitting rooms.
1. AP team members are not allowed to follow subject’s into a restroom or fitting room to conduct surveillance.
2. AP team members shall not ask another team member to enter a fitting room or restroom to conduct surveillance.
E. Transactional Fraud Apprehensions
Transactional fraud is defined as "using transactional documents dishonestly to cause a loss to Target". Transactional documents include; checks, credit cards, gift cards, merchandise vouchers and coupons.
Certified AP team members may make Transactional Fraud apprehensions only when ALL of the following conditions are met:
1. The AP team member has completed required training listed below:
a. Position's Basic Training Courses,
b. External Apprehension Certification and
c. Transactional Fraud Apprehension Training.
2. The AP team member has verified the transactional fraud. 3. The AP team member has pre-approval to make the transactional fraud apprehension from their Group Assets Protection Team Leader (GAPTL), DAPTL or Assets Protection Investigations Team Leader. 4. The pre-approval must include specific guidelines under which the apprehension shall be made, for example; the subject’s name, description and or account number, verification of the fraud from the account holder or bank or institution issues the transactional document.
NOTE: If the AP team member does not have pre-approval but observes behaviors that indicate an individual may be engaging in transactional fraud, the AP team member must contact one of the partners listed in 3. above and give details of the transaction in order to obtain approval prior to attempting apprehension.
F. Vendor/Partner Business Team Member Apprehensions
1. A Vendor team member is defined as: "A person who delivers a product or provides a service to Target. Vendor team members typically do not wear Red and Khaki. Vendor team members do not receive Point of Sale (POS) training or have access to the POS system." These cases are coded in CIRS as "External" cases. (Examples of Vendor team members: product representatives such as Coke or Pepsi, etc.)
2. A Partner Business team member is defined as a person who works within the four walls of a Target store/DC, but is not employed by Target. These cases are coded in CIRS as "Internal" cases. (Examples of Partner Business Team Members: Optical team members, team members working in Life Touch Studios, Minute Clinic team members, janitorial service team members, etc.)
AP team members are responsible for knowing which Partner Business team members conduct business in their buildings. When investigating a Partner Business team member, it is important to determine who employs an individual and whether Target assets, the Partner Business assets or both are involved. If there is any doubt regarding who employees an individual, contact Human Resources.
3. Vendor/Partner Business team member apprehensions shall be made using the following guidelines:
a. When the five steps for apprehension have been met:
1. The matter shall be handled like an external shoplifting incident.
2. If the vendor/partner business team member is working at a Target store/DC during non-business hours the vendor team member
may be apprehended as they are exiting the store/DC at the end of their work shift.
3. The DAPTL/Distribution GAPTL shall be advised that a vendor/partner business apprehension has occurred.
b. In cases where the five steps for apprehension have not been met:
1. The DAPTL/Distribution GAPTL shall be contacted to discuss the extent of the investigation and determine the
appropriate course of action.
2. The DAPT/Distribution GAPTL will decide whether or not the vendor/partner business team member shall be interviewed
to determine the scope of the theft.
NOTE: All interviews of vendor/partner business team members shall be conducted by the ETL-AP/APGL or DAPTL/Distribution GAPTL.
4. Contacting the vendor/partner business team member’s employer:
a. All contact with employer of the vendor/partner business team member shall be handled or coordinated by the DAPTL/APGL.
b. The DAPTL/APGL may contact the vendor/partner business company to inform them of the team member apprehension.
c. The DAPTL/APGL will inform the vendor/partner business that the apprehended team member is no longer permitted to
provide service to ANY Target store/DC.
NOTE: Target will not request the vendor/partner business terminate any apprehended team member; the call is to only to inform the vendor/partner business that the particular team member is not allowed to return to provide service at a Target store/DC.
NOTE:Target will not participate in any decision by the Partner Business regarding the apprehended team member’s employment.
5. When investigating a cash loss, partner with your Centralized Sales Auditor for assistance with recovery opportunities.
HANDCUFF USE Revision: 01-2006 Effective: 02-22-2006
A. Purpose
AP team members who have successfully completed the Handcuff training shall be provided handcuffs to be used during an apprehension when a subject becomes violent or a danger to others.
B. Handcuff Use
1. AP team members may not carry or use handcuffs unless they have successfully completed the approved Target AP handcuff training program.
2. Handcuffs shall only be used in the following situations:
a. The subject being apprehended becomes violent,
b. The subject attempts to break away from the custody of the AP team member, or
c. There is reason to believe the subject may become violent or may pose a risk to the safety of AP team members, other Target team members or guests.
3. Handcuffs shall not be applied until the AP team member(s) is able to maintain reasonable control of the subject. If the AP team member(s) can not maintain control of the subject while handcuffing, the team member shall abort the apprehension.
4. The subject’s hands shall only be handcuffed behind them, and the handcuffs shall be double locked.
5. A subject shall not be handcuffed to another person or to any object (chair, car, etc.), except for handcuff bars in AP offices that are equipped with them.
6. A handcuffed subject shall never be left unattended.
7. Once a subject is handcuffed, the handcuffs shall only be removed in the presence of a law enforcement officer.
8. Handcuffs and handcuff keys are the property of Target and shall not be taken home by team members.
NON-PRODUCTIVE INCIDENTS Revision: 01-2006 Effective: 02-22-2006
A. Purpose
A Non-Productive Incident (NPI) is defined as an apprehension that is initiated where no Target merchandise is recovered. This section outlines the steps that must be followed after any NPI.
B. NPIs Involving an Adult
The following outlines the steps that must be taken by AP team members after a NPI occurs:
1. Release the guest - Once it is determined that a guest suspected of shoplifting does not have merchandise, the guest must be released immediately. The AP team member(s) involved shall apologize to the guest for any inconvenience, and allow the guest to leave the store. If the guest requests to speak to a manager, refer the guest to the Leader on Duty (LOD).
2. Contact the DAPTL to inform that a NPI has occurred in the store.
3. Document the incident in CIRS as a NPI - Non-Productive Incident.
4. AP team member(s) involved must write out a chronological list of events identifying:
a. The five steps of apprehension observed (as applicable).
b. An attempt to identify where the subject may have discarded the merchandise and, if merchandise can be located, investigate how the AP team member did not observe the discard.
5. Partner with the ETL-AP/DAPTL and ETL-HR on corrective action.‘
6. Retain ALL video of the event as outlined in "Documentation Steps"
NOTE: Video of NPIs shall be retained with case files for a period of 7 years.
C. NPIs Involving a Juvenile
In cases involving a juvenile, all steps in B. above shall be followed. In addition, AP team members shall use good judgement when releasing a juvenile to ensure they may safely leave the premises (example: not allowing a juvenile to leave the store unescorted if the apprehension took place during daylight hours and it has since become dark). In these cases, the AP team member may choose to contact the juvenile’s parent or another responsible party.
SEARCHES OF PERSONS, PRIVATE RESIDENCES OR MOTOR VEHICLES Revision: 01-2006 Effective: 02-22-2006
A. Searches of Persons
1. AP team members are not allowed to conduct physical searches of subjects. Physical searches may only be conducted by law enforcement.
2. Searches of a subject’s personal possessions (example: purse) for evidence (merchandise) is not allowed unless the subject initiates the search or requests an AP team member to inspect their possessions. CIRS narrative must be documented to indicate subject requested possessions to be searched by AP team member.
B. Searches of Private Residence or Motor Vehicles
1. AP team members will NOT participate in a search of a private residence or motor vehicle.
2. At the request of law enforcement, AP team members may provide assistance in identifying company merchandise.
a. GAPTL approval is required prior to AP team members assisting in any search assistance as outlined in B. 2. above.
b. If the assistance criteria listed above is met, the role of the AP team member is to only answer questions and/or verify Target merchandise.
PURSUIT OF SHOPLIFTERS Revision: 01-2006 Effective: 02-22-2006
A. Purpose
Shoplifter apprehensions are to be handled in a professional manner and as discreetly as possible. Safety of guests and team members always comes first.
1. Fleeing Shoplifter
a. If a shoplifter attempts to flee after being confronted, do not give chase in any manner (running, driving, etc.).
b. Store based AP team members shall not use any vehicle to follow or pursue a subject for any reason.
c. AP team members shall not encourage, condone, suggest or ask another Target team member or anyone else to chase a fleeing shoplifter.
2. Documentation
a. If a shoplifter flees, the AP team member shall document the incident in CIRS as a Known Theft Report using the steps outlined in the Documentation section of this manual.
LAW ENFORCEMENT REFERRAL GUIDELINESRevision: 01-2006 Effective: 02-22-2006
A. General Referral Guidelines
1. The ETL-AP shall be responsible for partnering with local law enforcement / prosecutors office annually to determine the prosecution requirements for their jurisdiction and must have a completed Prosecutor’s Questionnaire on file in the Assets Protection office. The Prosecutor’s Questionnaire shall be updated annually to ensure the most current practices are being followed and a copy of the Questionnaire shall be kept in the local AP Office.
2. AP shall refer for prosecution all individuals apprehended for retail theft when the value of the merchandise is $20.00 or greater and the case meets local prosecution requirements.
NOTE: If a case meets/exceeds the $20.00 referral guideline, but is NOT referred, the reason for non-referral must be included in the CIRS narrative. (Example: Local jurisdiction limits require merchandise in excess of $75.00 in order for prosecution.)
3. A team member witness, of the same gender of the suspected shoplifter , must be present in the room at all times during the detention.
B. Juvenile Referral Guidelines
A juvenile is typically defined as an individual who is under the age of eighteen (18).
1. Juveniles apprehended for retail theft shall be referred for prosecution under the same guidelines as adults.
2. In addition to guidelines listed in A. above, the following referral procedures also apply to juvenile cases:
a. When a juvenile is referred for prosecution, a parent/guardian or responsible adult party shall be notified of the incident after responding authorities have arrived and taken custody of the juvenile.
b. AP team members shall make at least two (2) attempts to contact the parent or responsible party. If the juvenile’s parent/guardian cannot be contacted, the juvenile shall be turned over to the police. The CIRS report shall be noted with the time/date of attempted contact, phone number(s) called, and to whom the juvenile was released.
c. If law enforcement does not respond to requests for assistance, contact your DAPTL for guidance.
d. Apprehended juveniles shall not be photographed, unless required by local jurisdiction.
NOTE: Any juvenile NOT referred to authorities must have a parent/guardian or responsible adult party contacted immediately. If the parent or responsible party cannot be contacted within one half-hour (30 minutes) and after three attempts to reach them, contact law enforcement and release the juvenile to them. Document the number of attempted contacts, contact number and to whom the juvenile was released in the CIRS narrative.
C. Team Member Referral Guidelines
In addition to the General Referral Guidelines listed in A. above, the following guidelines apply to team members apprehended for shoplifting:
1. AP team members will refer for prosecution and seek restitution for loss from all team members apprehended for committing crimes that involve Target, a Partner Business or Vendor when the case meets local prosecution requirements.
2. Recommendations to refer for prosecution shall be made by the ETL-AP/APGL. The ETL-AP/APGL will also consult with HR regarding the recommendation to refer for prosecution to determine if there are any mitigating circumstances to be considered regarding the referral.
3. The DAPTL/Distribution GAPTL must approve the recommendation to refer a team member for prosecution. The DAPTL/Distribution GAPTL approval must be documented in the HR cover letter as follows:
a. "Approved for referral",
b. Date DAPTL/Distribution GAPTL approved referral, and
c. DAPTL’s/Distribution GAPTL’s signature.
4. The decision to terminate a team member for shoplifting shall only be made by the appropriate HR team member.
NOTE: AP Director / Vice President approval shall be required for situations where Target has filed a police report and later requests to dismiss the criminal charges filed against the team member. Specific details shall be communicated through the GAPTL.
PHOTOGRAPHING OF APPREHENDED SHOPLIFTERS Revision: 01-2006 Effective: 02-22-2006
A. Photographing Shoplifters
1. Adult shoplifters - AP shall photograph all adult shoplifters unless prohibited by local statutes or ordinances.
2. Team Member Shoplifters - AP will not photograph any team member apprehended for shoplifting during working or non-working hours.
3. Juvenile Shoplifters - AP will not photograph any juveniles apprehended for shoplifting, unless required by local statutes or ordinances.
B. Photograph Retention
1. All photographs shall be retained in the case file.
2. Under no circumstances will any photograph of an apprehended shoplifter be displayed in open view, on any office wall or in any other manner, or removed from Target property for personal use.
TRESPASS NOTICE Revision: 01-2006 Effective: 02-22-2006
A. Purpose
Trespass statutes define what constitutes a trespass. State laws generally provide that remaining on private property without permission is trespassing. An individual is usually trespassing when refusing to leave our store/DC after we have asked them to leave, either orally or by trespass notice.
B. Situations Warranting a Trespass Notice
Trespass notices require the approval from the ETL-AP/APGTL or higher. The use of a trespass notice is appropriate in the following situations:
1. When a subject has been apprehended at any Target location on more than one occasion.
2. When a person apprehended is in possession of a weapon.
a. Follow procedures outline in Safeness Weapons Directive.
b. If a weapon is discovered while the subject is detained, the AP team member shall ensure the safety of all team members and guests first, and if possible, remove and secure the weapon and handcuff the subject. The AP team member shall then contact law enforcement to advise of situation involving a weapon.
CAUTION: If the subject produces a weapon in a threatening manner at any time, the AP team member(s) shall disengage and allow the subject to exit the store/DC. The AP team member shall attempt to get a description of the sub-ject’s vehicle, so long as doing it does not put anyone in danger, and enter descriptions of both the subject and the subject’s vehicle into the CIRS report.
3. When the person apprehended has vandalized property or merchandise.
4. Persons who exhibit lewd or lascivious behavior.
NOTE: If the AP team member(s) feel a trespass notice is warranted, but the incident does not meet the criteria listed above, the team member will partner with their DAPTL/Distribution GAPTL for approval prior to issuing the notice.
C. Issuing a Trespass Notice
1. Location - A trespass Notice shall apply only to the location where the subject was apprehended or the incident took place.
NOTE: A Trespass Notice can be issued for multiple locations with DAPTL/Distribution GAPTL approval. The Trespass Notice must indicate the specific store/DC locations and a specific reason for the multiple locations. The AP team member involved must document the CIRS report to indicate DAPTL/Distribution GAPTL approval and Trespass Notice locations.
2. All Trespass Notices must contain the following elements:
a. The date and time the notice was issued.
b. Name of the person to who the notice is being issued.
c. District or Region of the Target store/DC issuing the Trespass Notice
d. The specific store (or stores with DAPTL/Distribution GAPTL approval) from which the subject is being trespassed.
NOTE: AP team members are NOT authorized to ban subjects from all Target stores/DCs, or ban subjects for life. All multiple location notices must be approved by the DAPTL/Distribution GAPTL prior to issuing.
3. The completed Trespass notice shall be given to the apprehended subject and a copy of the notice retained in the case file.
4. Document the CIRS report to indicate a Trespass Notice was issued.
NOTE: A copy of a blank Trespass Notice can be found on the AP Zone, under the Forms-All tab.
D. Violation of a Trespass Notice
If an individual who has been issued a Trespass Notice violates the notice and returns to the store/DC, ask the individual to leave the property. If the individual refuses to leave, contact law enforcement for assistance and document the incident in CIRS.
E. Team Member Trespass Notices
In situations that warrant the issuance of a Trespass Notice to a team member or former team member, the following shall apply:
1. Immediately contact your DAPTL/Distribution GAPTL to inform them of the situation prior to issuing the Trespass Notice.
2. The DAPTL/Distribution GAPTL will partner with the appropriate Employee Relations / Human Resources contacts at the Regional or Headquarters level
ACCOMPLICES Revision: 01-2006 Effective: 02-22-2006
A. Shoplifter Accomplices
1. Target defines a shoplifter accomplice as:
a. A person who assists another in a crime of retail theft, but is not leaving the store with merchandise.
b. Someone for whom only some of the five apprehension steps have been observed.
2. AP team members may detain all active participants in a shoplifting incident only when all five apprehension steps have been observed for each participant.
3. Since a shoplifter accomplice only participated in some of the five apprehension steps they will not be detained, questioned or referred to authorities for prosecution.
NOTE: If local law enforcement takes independent action and makes an apprehension before all five steps are met, the details must be documented in the CIRS report.
B. Box Stuffing Accomplice
Box stuffing is defined as "When a person puts merchandise inside a box or in packaging of another product, he/she pays for what product should be in the box, but not the correct merchandise."
1. AP team members may apprehend a box stuffing accomplice if:
a. The accomplice is leaving with merchandise
AND
b. The AP team member has no reasonable doubt the accomplice knows the box contains concealed merchandise (example: AP team member witnessed accomplice holding box while second subject stuffed merchandise inside, then accomplice attempted to exit with box.).
c. The case must be documented in CIRS indicating the steps observed to merit the accomplice apprehension.
C. Team Member Accomplice
1. Target defines a team member accomplice as an individual who is not a Target team member and participates in an under ringing or passing merchandise with a Target team member. A team member accomplice may be a guest, Partner Business team member or a Vendor team member.
2. Apprehension - A team member accomplice may be apprehended when probable cause exists to believe the individual is actively participating in the crime, based on the following criteria:
a. An AP team member observes the individual select the merchandise and bring it to a cashier lane.
b. The individual makes the purchase with either a check or cash, thus verifying the individual knew the amount of the purchase.
NOTE: Apprehensions of team member accomplices shall not be made on credit card purchases.
c. The items purchased have been line item voided, zero transactions total or passed outright.
d. The under ringing or merchandise passing must result in a significant difference in the purchase price to support the inference that the subject and accomplice were knowingly participating in a crime. (Example: Purchasing a DVD player for $2.50 can indicate the guest was participating in an under ringing crime.)
e. The incident must be captured on conventional or digital CCTV.
3. Apprehension Procedures
a. Apprehend the individual as they leave the store and process as an external shoplifting case.
b. Contact law enforcement immediately.
NOTE: The subject shall be apprehended only if the AP team member has enough evidence to contact law enforcement immediately and prove that the individual was involved in a crime. Do not wait to contact law enforcement while the team member is being interviewed.
c. In cash cases refund the purchase with cash.
d. In check cases, write "VOID" across the front of the check and retain the original check as evidence.
e. Retain original receipts/refund slips.
4. When the case does not meet the procedures listed in 2 & 3 above:
a. Approach the individual and identify yourself as a Target team member.
b. Politely explain to the individual that the purchase was charged at an incorrect amount.
c. If the purchase was an underring, ask the individual to re-purchase and identical item at the correct price. Obtain the duplicate item(s) for the individual and hold the original item(s) as evidence.
d. If the individual does not wish to re-purchase the item(s), refund the purchase.
e. Retain merchandise as evidence or photograph merchandise as jurisdiction allows.
f. If the individual refuses to cooperate and insists on leaving with the merchandise, allow the individual to do so. Indicate the subject and vehicle description in the CIRS report.
g. After receiving HR approval, an interview may be conducted with the team member. (See Team Member Interviews)
5. Document the case appropriately in CIRS using the steps outlined in the Documentation section.
EVIDENCE Revision: 01-2006 Effective: 02-22-2006
A. Purpose
Any property related to an Assets Protection case, whether Target property, non-Target property or contraband shall be treated as evidence and protected, preserved and documented as outlined in this section.
B. Evidence Documentation
1. Evidence Log - All stores/DCs must maintain an evidence log and the log shall be updated each time a piece of evidence is placed in or removed from the evidence locker. The evidence log shall contain:
a. Date and time of entry or removal of evidence,
b. The name of the team member entering or removing the evidence,
c. The reason for entry/removal of evidence, and
d. CIRS case number related to the evidence.
2. Evidence Locker - Each store shall maintain a designated evidence locker or similar lockable area for evidence retention.
3. Evidence Tag - An evidence tag must be affixed to all items obtained in the apprehension of a subject. At a minimum all evidence tags must contain:
a. AP team member’s name and initials,
b. The CIRS case number, and
c. Date of apprehension
C. Photographing Evidence
All evidence shall be photographed and the photographs properly labeled as evidence. Merchandise shall only be kept as evidence if local jurisdiction requires, any jurisdictions allow certain forms of evidence to be photographed as a method of preservation. The ETL-AP/APGL shall be responsible for partnering with local law enforcement to understand the local jurisdiction guidelines.
1. When photographing merchandise, follow these steps:
a. Take a full shot of the item, accurately depicting the color, features and any other identifying aspects of the item.
b. Take a close up photo(s) of the item depicting the price tag, labels and/or any damage to the item.
c. Label all photographs with the date, time, name of subject and CIRS case number.
d. Retain all photographs in the case file.
2. After photographing, return the merchandise to the owning department, unless local jurisdiction requires merchandise be held, in which case merchandise shall be stored in evidence locker.
D. Company Property
All recovered merchandise, any item the subject may have removed from the merchandise and discarded (packaging, price tags, vendor tags, defeated merchandise protection tags, boxes, etc.), company documents (including but not limited to POS receipts, vouchers, gift cards. gift receipts, refund documents, etc.), and recovered cash shall be treated as evidence.
1. When logging company property as evidence, the following applies:
a. Original documents are preferred; if law enforcement requires an original document, make a copy for evidentiary purposes.
b. If photocopies are used, document the location of the original document in the CIRS report (example: Original receipt retained by Minneapolis Police Officer John Smith).
c. All company documents shall be initialed and dated by an AP team member (in small writing in the corner of the document).
d. Record each item of recovered property in the "Evidence" section of the CIRS report.
e. Complete an evidence tag for any item retained by law enforcement or Assets Protection and affix to piece of evidence.
f. Log all items on the Evidence Log.
E. Non-Company Property
All Non-Company Property (evidence) recovered from a subject shall be recorded in the same manner as Company Property using the steps listed in D. above.
F. Contraband
Contraband is defined as items or goods that are illegal to possess, such as weapons, narcotics, drug paraphernalia, etc.
1. All contraband discovered by AP team members shall be recorded in the "Evidence" section of the CIRS report, marked with an Evidence Tag and turned over to law enforcement.
2. AP team members are forbidden from retaining/possessing contraband.
G. Preserving Evidence
Following an apprehension, preserve all evidence in the following manner:
1. Affix an Evidence Tag to all merchandise, non-company property and contraband recovered during the apprehension.
2. Prior to turning over any evidence to law enforcement, ensure the evidence is properly tagged and that a law enforcement officer signs for each item using their name, initials and date on the Evidence Log.
3. Store all physical evidence (merchandise, company documents, tags, etc.) in a bag or container and seal the bag/container to protect the item(s) from tampering.
4. Attach the evidence property tag to the sealed container.
5. If AP will be retaining the evidence, place the sealed bag or container in the evidence locker or similar lockable area in the AP office.
AP INCIDENT DOCUMENTATION Revision: 01-2006 Effective: 02-22-2006
A. Purpose
All incidents must be properly documented by an AP team member in the Common Incident Reporting System (CIRS). All on-going investigations shall be documented in the Common Investigations Management System (CIMS); when the investigation escalates into an incident, the case information shall be moved to the CIRS system.
A case file shall also be completed for each incident and copies of the case file shall be retained in the store/DC for a period of seven (7) years and a copy of all Internal casesshall be given to the ETL-HR.
B. CIRS/CIMS Documentation
1. CIRS and CIMS files are considered part of the investigative process and may be subject to subpoena and disclosure if a case goes to trial. Cases shall be documented in a complete and professional manner.
2. Narrative - The case narrative shall be written in a clear concise format and shall include at minimum the following:
a. Five steps of apprehension - Provide a detailed, chronological order of each of the five steps, and where and when they took place. If a step is missed, and a Productive Merchandise Recovery (PMR) takes place, identify the missing step(s) and reason in the narrative. (Example - PMR conducted because APS lost sight of subject on sales floor and was unable to maintain surveillance.)
b. Detailed description of why subject was observed. (Example: "Subject entered building wearing a large winter coat and the temperature outside was 89oF," not "Suspicious suspect entered the building".)
c. Names of team member(s) involved - List the names of all team members and their roles within the apprehension.
d. Law Enforcement - If law enforcement is involved in an apprehension or if the subject is referred to law enforcement detail the role law enforcement played in the stop. Also, note this information in the law enforcement section of the CIRS report.
NOTE: Narrative shall be noted if law enforcement decides to make the apprehension, such as when AP has not observed all five steps of apprehension. In these cases AP team members may assist law enforcement.
e. Weapons - Indicate if a weapon is present at any time during any incident. Also indicate if the weapon was used during the incident (i.e. Razor blade used to cut open DVD package).
f. Handcuffs - If a subject is handcuffed, indicate who handcuffed the subject and why the handcuffs were applied (reference Handcuff Directive).
g. Detailed description of apprehension location - Specifically identify the location where the apprehension took place, (E.g. "Green Main Exit" not "Exit").
h. Surveillance of the incident - Note whether CCTV, physical surveillance or both were used to observe the incident.
i. Other cases/information - Reference other CIRS/CIMS cases that led to initial observation of the subject or supporting evidence to the apprehension. Also, if AP team member was tipped by another team member or guest, and witness statements gathered after apprehension.
3. Narratives are to be treated as evidence and shall NOT contain the following::
a. Subject description (race, gender, sex, age, etc.) - The CIRS report has a section that asks for subject description and any information shall be documented here. The narrative shall NOT contain this information; it shall contain only the facts leading up to the apprehension/incident.
b. Slang terms, jargon or acronyms - Narratives may be used as evidence during criminal/civil cases. Therefore, all jargon and slang terms shall be avoided and all acronyms spelled out (i.e. Assets Protection Booking Room instead of AP Booking Room).
c. Generalizations- The narrative is a factual description of what took place, and shall not contain any opinions of the team members, generalizations about the subject or assumptions of what they may have done or intended to do.
d. Multiple cases/incidents - An individual CIRS case must be completed for each incident; cases occurring on the same shift are not to be grouped together into a single incident.
C. Case File -
A case file must be created for all apprehensions/incidents within a store/DC. The AP team member involved shall be responsible for ensuring all evidence is collected and filed properly. At a minimum the case file must contain the following:
1. A copy of the CIRS narrative and any other related CIRS/CIMS cases.
2. Photos - Any photos taken of the subject/evidence shall be kept with the case file. Photos must be labeled with the case number and date.
3. Video - Copies of video relating to AP cases/apprehension shall be retained for a period of 7 years.
a. Video shall include observation of the five apprehension steps.
NOTE: If a step is not captured on video, the CIRS report must be updated indicating why the particular step was missed. (Example: Limited camera coverage in automotive section did not allow for constant video surveillance.)
b. Video shall be transferred to a VHS or DVD/CD and properly labeled with the date and case number.
c. All other video shall be retained for a minimum of 30 days.
NOTE: Video must be retained for all AP incidents/apprehensions and kept with the case files for a period of seven (7) years. All other video shall be retained for a minimum of 30 days unless otherwise noted.
NOTE: If video is copied to a VCR tape, ensure the tab has been removed to prevent over-taping.
NOTE: If law enforcement requests a copy of the videotape, make a copy and retain the original. Original recordings shall be provided to law enforcement upon the receipt of a subpoena; in such cases ensure the store/DC retains a copy prior to turning over the original. If law enforcement insists on taking custody of the original without a subpoena, provide the original but ensure a copy is retained. Ensure your DAPTL/Distribution GAPTL is notified any time law enforcement requires a copy of evidence.
4. Witness statements - All team members involved shall be required to give a witness statement of the incident and these statements shall be retained in the case file. Any other statements gathered by AP team members shall be properly labeled (case number and date) and filed in the case file.
5. A copy of the Trespass Notice (if applicable).
NOTE: In the event of a serious incident (assaults with serious injury, death, sexual assaults, armed robbery) or any other incident receiving media attention, the ETL-AP/APGL shall partner with the DAPTL/Distribution GAPTL for further guidance regarding the scope of additional evidence to be retained in the case file.
AUTHORITY TO APPROVE CIRS CASES Revision: 01-2006 Effective: 02-22-2006
A. Purpose
This section outlines the authority and requirements for CIRS case approval.
B. Approval
1. AP team members are not permitted to approve cases they have initiated and entered into the CIRS reporting system.
2. All cases shall be approved by the next level AP supervisor (or higher).
3. Prior to CIRS case approval, the approver shall review the case for:
a. Complete and accurate narrative, including details of the case outlining the five apprehension steps, a chronological sequence of events from subject entering store/DC to apprehension/exit, proper spelling and limited use of acronyms.
b. Proper documentation of the case, including team members involved, law enforcement involvement, any weapons used/found, whether a subject was handcuffed, location where the incident took place, date and time of incident, etc.
c. Directive compliance.
d. Complete case file including any photos, witness statements, accompanying video, etc.
e. Ensure the case is properly coded.
NOTE: Cases not meeting above minimum standards shall be sent back for re-work. The supervisor shall work with AP team member initiating the case to ensure complete and accurate details and coach team member on deficient case details.
4. Supervisors shall review cases for approval on a daily basis.
5. Cases shall be approved or returned for re-work within 48 hours of submission.
NOTE: Details used in CIRS are considered evidence and may be called upon if a case is brought to trial. It is vital that team members complete the narrative in a timely fashion with the facts of the case. The report is designed to capture the sequence of events and must be a factual list of events. Team members must refrain from adding opinions or assumptions when documenting the case.
TICKET FRAUDRevision: 01-2006 Effective: 02-22-2006
A. Purpose
Ticket Fraud is defined as "Changing the price on merchandise with the intent of purchasing the merchandise at a reduced price."
B. Ticket Fraud Apprehension
1. An Apprehension shall only be permitted when ALL of the following criteria have been met:
a. Written confirmation has been received that your local jurisdiction will prosecute Ticket Fraud referrals and this confirmation is on file in the store and with the DAPTL.
b. The person or group involved has known theft or Ticket Fraud activity and the known activity is documented in a CIRS narrative.
c. The AP team member has pre-approval to make the Ticket Fraud apprehension from their GAPTL, DAPTL or Investigations Team Leader.
d. All elements of the Ticket Fraud have been observed:
1. Selection of the item. 2. Placement of the new ticket on the item.
3. Purchase of the item at the incorrect price.
e. If selection, removal and placement have been observed, but an apprehension cannot be made due to other criteria not being met:
1. Handle the incident by asking the cashier to request that the price be
checked. The cashier can then inform the guest of the correct price. 2. Partner with your DAPTL or Investigations Team Leader.
3. Gather all evidence and document the incident in CIRS using the "Ticket
Fraud" classification.
FOOD CONSUMPTION / FOOD PASSING INVESTIGATIONS Revision: 01-2006 Effective: 02-22-2006
A. Purpose
This Directive applies to all areas of food sales (Food Avenue, Starbucks, etc.) as well as any other food items available for sale in Target stores. It also applies to single or multiple incidents of food consumption or passing.
B. Handling
1. Incidents of team member food consumption and food passing shall be treated as a policy violation and referred to Human Resources for further handling. AP will NOT conduct an interview or refer for prosecution these types of incidents, however they may assist HR by providing information and supporting documentation.
2. Investigations that reveal cash theft or theft in bulk (example: a case of pop) shall be handled by AP as a theft (internal or external). AP must observe the five steps prior to apprehension.
TEAM MEMBER DISCOUNT VIOLATION INVESTIGATIONSRevision: 01-2006 Effective: 02-22-2006
A. Purpose
This Directive outlines the procedures for an investigation of a team member suspected of a violating Target’s Team Member Discount policy.
B. Investigation/Apprehension Steps
1. AP shall notify HR as soon as they become aware of a discount policy violation.
2. AP shall conduct an investigation to establish the scope of the team member’s violation.
3. If the investigation reveals other possible dishonest activity, AP shall open a team member investigation and document the investigation in CIMS.
4. If no additional information of other possible dishonest activity exists, the case shall be immediately forwarded to HR or higher level of management for handling.
TEAM MEMBER INTERVIEWS Revision: 01-2006 Effective: 02-22-2006
A. Purpose
Team member interviews shall be conducted as a part of an internal investigation. Only AP team members who have successfully completed Target’s Assets Protection Internal Interview Certification are authorized to conduct team member interviews.
NOTE: An AP team member who has successfully completed Internal Interviewing Training and is in the process of becoming certified, may conduct a team member interview in the presence of another trained/certified AP team member.
B. Conducting a Team Member Interview
1. Prior to conducting any team member interview, supervisor approval is required.
2. Prior to conducting a team member interview, the AP team member shall partner with:
a. The appropriate HR Partner or STL.
b. The next level AP team member.
NOTE: If the HR or STL/DC Team Leader disagrees with the decision to interview the team member for dishonesty, the AP team member shall meet with the HR and/or STL/DC Team Leader to discuss their concerns. If a mutual agreement cannot be reached, the AP and H. R. team members shall contact the DAPTL/Distribution GAPTL and Human Resources Representative (HRR). Together the DAPTL/Distribution GAPTL and HRR shall make the final decision as to whether or not the team member will be interviewed.
c. The AP team member shall present a written summary of the investigation findings (HR Cover Letter) to the HR or STL/DC Team Leader.
3. Team member interviews are to be conducted in accordance with all Target internal interviewing procedures.
4. Before conducting an interview of a team member there must be evidence that the team member has participated in a dishonest activity. Team member interviews shall NOT be made solely on the basis of an implication by another team member. There must be corroborating evidence in addition to any implication and the evidence shall be presented in the written summary of the investigations findings (HR Cover Letter). Some examples of "Other" evidence:
a. Digital or standard CCTV video
b. Merchandise/hand tags
c. Product wrapping
d. System reports
TIME AND ATTENDANCE VIOLATION INVESTIGATIONS Revision: 01-2006 Effective: 02-22-2006
A. Purpose
If an AP team member becomes aware of any time card/attendance policy violations they shall handle as follows:
1. Immediately forward all information regarding the violation the ETL-HR/Distribution HRM/HRR.
2. Do not conduct an independent investigation into the suspected time card/attendance violation.
3. If an AP team member is requested to support a time card/attendance investigation, contact the DAPTL/Distribution GAPTL or next level AP supervisor for approval.
4. If the time card/attendance violation involves an AP team member, inform the ETL-HR/Distribution HRM/HRR and contact your DATPL/Distribution GAPTL for guidance.
EXECUTIVE INVESTIGATIONS / INTERVIEWS Revision: 01-2006 Effective: 02-22-2006
A. Investigations
1. AP team members who have knowledge or suspicion of a Target executive violating a company policy shall notify their next level AP supervisor.
2. The supervisor shall make the determination whether to investigate the executive and who shall be responsible for the investigation.
B. Interviews
1. Once the supervisor makes the decision to interview an executive, the interview shall be conducted by one of the following:
a. DAPTL, ITL or Distribution GAPTL
b. GAPTL,
c. Director of Assets Protection, or
d. Vice President of Assets Protection.
2. Prior to engaging in an interview, the interviewer must have prior approval from the GAPTL or Director/Vice President of Assets Protection and the ETL-HR/Distribution HRM/HRR.
UNDERCOVER INVESTIGATIONS Revision: 01-2006 Effective: 02-22-2006
A. Definition
An undercover investigation is defined as "Placing a contract individual, law enforcement officer or team member into a non-AP store/DC position on multiple occasions for the purpose of uncovering serious security or policy violations."
B. Approval
The Director/Vice President of Assets Protection must approve any investigation where Assets Protection proposes using an undercover investigator. This applies to any store/DC-based undercover investigation.
NOTE: Utilizing AP team member from another Target location to assist store AP related surveillance is not considered to be an undercover investigation. (Example: An ETL-AP/APGL covering vacation at an alternate location for another ETL-AP/APGL.)
PHARMACY INVESTIGATIONS Revision: 01-2006 Effective: 02-22-2006
A. Purpose
This Directive outlines AP policies for handling Pharmacy Investigations.
B. Investigations
1. Any proposed investigation of a Pharmacist or Pharmacy team member shall be immediately communicate to the DAPTL.
2. The DAPTL shall then discuss the investigation with the Pharmacy Supervisor, GAPTL and ETL-HR prior to any action.
C. Fraudulent Prescriptions
1. AP team members shall not make any apprehensions on fraudulent prescription cases.
2. If requested, AP team members shall support fraudulent prescription cases by gathering evidence for law enforcement (such as video footage, subject or vehicle descriptions, etc.).
3. AP team members shall become involved in fraudulent prescription cases if physical danger is imminent to team members or guests.
4. Pharmacists shall notify local law enforcement and professional boards as required.
D. Pharmacy Keys
1. Pharmacies are operated under a separate keying system. The Pharmacy shall not be opened by anyone other than a registered Pharmacist under any circumstances.
GUEST SERVICE ISSUES / GUEST INCIDENT Revision: 01-2006 Effective: 02-22-2006
A. Purpose
This section addresses the proper handling of Guest Service Issues and Guest Incident filed at the store level.
B. Guest Issues Involving AP Team Members
1. The ETL-AP shall contact the DAPTL and STL upon notification of any guest issues involving another AP team member.
2. The DAPTL and STL shall determine whether the situation is a Guest Service Issue or a Guest Incident.
C. Guest Service Issues
1. A matter shall be treated as a Guest Service Issue if all of the following apply:
a. The guest complaint relates to the manner in which the guest was treated in the store, such as a NPI or receipt check, and does not involve any claim of bodily injury of property damage,
b. The guest is not represented by an attorney and
c. The matter can be resolved with a guest service payment of $200.00 or less in gift certificates, gift cards or a check.
2. If the matter does not meet all three (3) of the criteria listed above, it must be referred to the Guest Reporting Center to be handled as a Guest Incident.
NOTE: If there is any doubt about the matter meeting any of the Guest Service criteria, contact the Guest Service Reporting Center.
D. Handling a Guest Service Issue
1. The DAPTL shall handle a Guest Service Issue as follows:
a. Partner with the Guest Reporting Center and the STL.
b. Once contacted by the guest, investigate by reviewing any CIRS reports, case files, video, witness statements, etc. regarding the particular incident.
c. Contact the guest and attempt to resolve the issue.
d. Document all actions taken and communications with all parties.
e. Determine the best method to resolve the guest service issue: written apology, guest service payment ($200.00 or less) or an understanding that Target is not at fault.
f. If the matter can be resolved as a guest service issue, contact the GAPTL and present the case.
g. When a resolution has been reached, notify the Store Team Leader (STL) and District Team Leader (DTL) of the situation and resolution type and amount (if applicable).
NOTE: Guest Service payments must be charged to the store or district account, as directed by the DAPTL.
h. If the matter is resolved on a guest service basis, no written release from the guest is necessary.
i. Document all details of the case in CIRS including any type of settlement.
2. If after discussion with the guest it does not appear the matter can be resolved as a Guest Service Issue, report the matter as a Guest Incident and contact the Guest Reporting Center.
E. Guest Incidents
1. Any matter that does not meet the three (3) criteria for a Guest Service Issue (listed in C. 1. above) must be reported to the Guest Reporting Center as a Guest Incident.
NOTE: A claim is reported using the same procedures for reporting a Guest Accident.
2. The DAPTL shall discuss all Claims with their GAPTL and the STL.
