A publication from the International Association of Interviewers

2015 ISSUE 1

Are You Elite? Join Us! Inside this Issue Elite Training Day Preview Cyber Corner CFI Spotlight Interview Video Interviewing Tips Legal Aspects HR 360 © 2015 International Association of Interviewers

CFInsider Q1 - 2015

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IAI AdvisoryCommittee

From the Desk of IAI’s the hairman Executive Director

Letter from the Chairman

Letter from

of the IAI Advisory Board

C

IAI Committee DanAdvisory Doyle, CFI, Beall’s Dept. Stores

[email protected] Dan Doyle, CFI, Beall’s Dept. Stores [email protected] Wayne Hoover, CFI, WZ [email protected] Hoover, CFI, WZ

The International Association of [email protected] Debbie Maples, CFI, Gap, Inc. Interviewers (IAI) celebrates its [email protected] 1st birthday at NRF. Launched at Debbie Maples, CFI, Gap, Inc. [email protected] the last NRF conference last year Kirk Lonbom, CFI, Illinois State Police [email protected] Kirk Lonbom, CFI and now almost 6,000 members Illinois State Police strong, we are experiencing Mike Marquis, CFI, TJX [email protected] growth and a demand for [email protected] education and resources in Mike Marquis, CFI, TJX [email protected] May, CFI, LP Innovations the Loss Prevention sector. [email protected] Please come celebrate with us at booth #1723 Chairman IAI Advisory Board I hope everyone had a successful holiday season and is making the best of what has turned out to be an CFI, LP Innovations where we will be offering special promotional Steven May, RayCotton,CFI,Facebook [email protected] extremely tough winter for many parts of the country. It’s hard to believe that it’s that time of year again! rates on membership with NRF exclusives, [email protected] The National Retail Federation Prevention Ray Cotton, CFI, Lumber Liquidators as well as celebrating our We are rapidly approaching one of theLoss premier conferences relating to interviewing anywhere in the [email protected] conference in San Day Diego is just a few DavidLund, CFI,Dick’sSportingGoods ThankCaryyou world. Elite Training is just around the days corneraway. on April accomplishments. 14-15, 2015 in San Antonio. Jones, [email protected] ICFI, hope we will have an opportunity to see you to graciously our members haveat their Director of Loss Prevention’s for HVHC/Visionworks has offered an who auditorium David Lund, CFI there. For those of you who are CFIs, stop by the made association a success. corporate facility on the River Walk in San Antonio, Texas. This is athis beautiful venue right on the famous Dick’s Goods JohnMillner, CFI,Sporting IllinoisState Senator International Association of aInterviewers booth addition, [email protected] San Antonio River Walk and just short walk to good music,Infood, and drink. GDIT (formerly [email protected] number 1723 to pick up your CFI ribbon for your Vangent), IAI Diamond Sponsor, John Millner, CFISolutions (Ret.) name each of you who are CFIs willwill booth Joiningtag. us atWe the hope HVHC/Visionworks Corporate Office be a number theLP sponsoring organizations Walter Palmer, CFI, PCG #404 of and Software, IAI Illinois State Senator [email protected] wear your ribbon proudly since you have worked and that support the International Association of Interviewers the Certified Forensic Interviewer (CFI). I Gold Sponsor, booth #1426 will [email protected] hard obtain the designation. wouldtolike to personally thank our sponsors for their support. have the following joining us Scott Oser beWegiving away two sponsors iPad minis Shane Sturman, CFI, WZ for the two days: Blue Dot Safes, Checkview, General Dynamics IT, InstaKey, LP Innovations, NAVCO, Walter Palmer, CFI, PCG Solutions during the conference from [email protected] [email protected] While at the booth take a moment and and Securityyou’re Resources, Security Source, Turning Point Justice, Corrective Education Company. our booth. Please stop by our meet the Executive Director of the International booth to see how you can be entered to win one Mark Sullivan, CFI, GT Shane Sturman, CFI, WZ For those CFIs who be attending you will be eligible for 9 hours of continuing education credits for the [email protected] Association of will Interviewers, Bill Pawlucy. of these cool Apple products. You can also submit [email protected] day and program. This will be a powerful program filled with insights for the elite interviewer. Joining Bill hasa half a tremendous amount of experience an entry at either GDIT’s (formerly Vangent) or David Matsumoto us willassociations be Professor Ray Bullhe from United Kingdom. Bull is one of the foremost researchers on MarkDr.Sullivan, CFI, GT with and hasthehelped us makeProfessor LP Software’s booths to increase your chances of Humintell interviewing in the world. He speaks internationally and has written extensively on the state of interviewing [email protected] great strides over the last year to increase our winning. You must be present to win and no more [email protected] and the detection of deception aroundAlso, the world. had a chance to meet Ray in Canada at a conference and membership and sponsorships. you Imight than two entries per person. Dr. David Matsumoto, Humintell was immediately impressed with his knowledge and insight into what we do as interviewers. Melissa Mitchell, CFI want to ask about the plans for next year’s Elite [email protected] Lifeway Christian Stores Training Days on February 11th and 12th, 2014. Asuse webehavior continue to grow, we also continue to On a practical note there will also be a presentation on how to and interviewing in a field [email protected] Melissa Mitchell, CFI We plantoon having some and incredible speakers add keyat staff members that help us with this situation protect businesses malls. This strategy to is being used the Mall of America to will identify Lifeway Christian Stores enhance your interviewing growth. would likePresident to introduce Alan Tague, CFI, Gander Mountain potential threats to the mall, itsskills. customers, and businesses. Mr. MichaelI Rozin is the of Rozin the newest [email protected] [email protected] member of ourpotential team, problems. Scott Oser, Corporate Security at the Mall of America where he actively uses the strategies to interdict Finally, for those of you who are able to attend Relations Director. Scott’s role is to help usAlan Tague, CFI, Gander Mountain Kevin Valentine, CFI, Sterling, Inc. the NRFsession Lossfocuses Prevention Conference hope development. Another on a practical approachwe to career willnew be ancompany in-depth discussion focus on There adding members for the [email protected] [email protected] you will join WZ group at our 31st annual on moving fromthe the trenches as interviewers to key leadership positions in We the cannot C- suite.underestimate If you’ve ever the value IAIKevin Valentine, CFI, Sterling, Inc. association. party from 10to PM toyour 2 AMcareer on Wednesday eveningto the wondered how take as an elite interviewer leveltothis is a presentation you to won’t cannext bring a company seeking gain exposure Craig Cronheim, CarMax [email protected] at theto Whiskey Girl, 702have 5thmoved Avenue, San Diego, want miss. The speakers up the ladder as interviewers to senior corporate leaders. Let [email protected] to the largest concentration of them interview and CA The is promotion. sponsored by: WZ/CFI/IAI/ interrogation decision makers. We have created an Craig Cronheim, CFI, CarMax help 92101. you plan forevent the next Kathleen Smith, CFI, Safeway Inc WZ Technologies plus eBay, The Loss Prevention infrastructure for companies to create meaningful [email protected] [email protected] Doug Wicklander and I, plus many of the staff from WZ, will also be attending and look forward to Foundation, Verisk (Aspect, LERPnet, Enabl-U), and deep relationships with our members through Don Berecz, CPA, CFE, CFI speaking with each of you. If you have a textbook you’d like signed or want to join us in a photo all you and Security Resources. Georgia University many and varied opportunities. DouglasSouthern Wicklander, CFI, WZ have to do is ask. We look forward to every conference where we enjoy reconnecting with old and new [email protected] [email protected] friends. Scott comes to us with over 17 years of marketing

ELITE TRAINING DAY!

Sincerely For your information part three of Adding Forensic Linguistics to your Interviewing and Interrogation David Zulawski, CFE Ph.D. has been delayed because of prior commitments. Part three, Trainingcontinued... ToolkitEby Carole E.CFI, Chaski, in Forensic Linguistics will appear in the next issue of CFInsider. See you in San Antonio! Sincerely, David E. Zulawski, CFI, CFE Chairman, IAI Advisory Board

CFInsider Q1 - 2015

Kathleen Smith, CFI, Safeway Inc. David Zulawski, CFI, WZ [email protected] [email protected] Rick Manning, CFI, FBI (Ret.) [email protected]

Chris McDonald, Compass Group [email protected] Cary Jones, CFI, HVHC INC. [email protected] Douglas Wicklander, CFI, WZ [email protected] David Zulawski, CFI, WZ [email protected]

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Note from ETD Speaker Harvin Moore By Harvin Moore III Stunning news confronted all of us within the last month as Brian Williams, the ABC Evening News Anchor, announced his mea culpa of claiming, for many years, to have been in a U.S. military helicopter in Iraq in 2003 that was hit by enemy fire. Evidently, over time, he even embellished that story. But, as sometimes happens, someone, in this case Military personnel with first-hand knowledge of that event, repudiated Williams’ story and he was forced to recant. However, the language he used to “set the record straight” was that he “misremembered” the event. Is he blaming a “Senior Moment” for his description of an experience 12 years ago? A public figure, once again, chooses words to minimize the impact of what he did. Isn’t the more accurate word “misrepresented”? We read about Celebrity mistakes like his; but the vast majority of improper conduct (which most of us deal with on a daily basis) occurs at a more mundane level of business and society, and by ordinary people. And we do, we wonder how that could have happened? An important question, but as Investigators and Interviewers, the more critical question to ask is Why? Actually, by delving into both questions and searching for answers to both, we enhance the value of our professional services to those we represent. From my experience, I have learned that sometimes the How and Why are deeply intertwined, and there is a fairly common starting point which I call “the fork in the road”. We will discuss the ramifications of getting there, and then, what happens next and why. It may be from a perspective that you will find surprising, informative, moving and memorable. We all look forward to see you at the Elite Training Day in San Antonio, TX over two days, April 14th and 15th, 2015. A group of very qualified and interesting speakers will enlighten and augment your professional skills with presentations you will not find anywhere else. Please Don’t Miss It! We’ll see You along the Riverwalk!

Last Chance to Register for Elite Training Day 2015!

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CORNER

By Rhett Asher

CYBER

Rise in Litigation against Boards of Directors and Executives: Part 1 Lawsuits… coming to a shareholder meeting near you? The news of data breaches normally covers the cost of recovery and the millions of personal records lost. However, there is a new trend emerging following data breaches: the number of lawsuits and the claims against board of directors and officers. The regulatory burden on companies continues to grow, but now individuals employed with or that have substantial equity in a company have also become personal victims to the same cyber-attack that was launched against their company. Officers and directors must be informed of the potential repercussions due to a data breach compromising corporate assets. While the types of lawsuits filed against companies is reserved for a discussion with your company’s General Counsel, this article will present what an executive should be aware of following a breach and the main trends present thus far. *Future articles will delve more deeply into this issue. Many companies have shareholder derivative lawsuits filed against their directors and/or officers following a data breach. This has been the most and most consequential to a company. A shareholder derivative suit is “a lawsuit brought by a shareholder on behalf of a corporation. Generally, a shareholder can only sue on behalf of a corporation when the corporation has a valid cause of action, but has refused to use it. This often happens when the defendant in the suit is someone close to the company, like a director or a corporate officer. If the suit is successful, the proceeds go to the corporation, not to the shareholder who brought the suit”. These lawsuits pertain to the fiduciary duty, abuse or waste of business assets, and/or personal gains. In general, there are two groups of stakeholders that are filing these lawsuits: shareholders and former employees. As directors and officers of a company, in some cases public corporations, you are responsible for the financial wellbeing, corporate assets, employee data, project growth, and much more. Due to the rise of personal information compromised in cyber-attacks, the data breach battle has become personal- with lawsuits directed at individuals. http://www.law.cornell.edu/wex/shareholder_derivative_suit So, what is the best way for directors and officers to protect themselves and their companies? • Designate an executive in charge of IT and data security. • Review and approve all language in SEC 10-k forms. • Perform routine internal and external audits. • Create an incident response team to handle a breach. • Consider the cyber insurance options available to your company. • Update and test an incident response and business continuity plan. For more information and background on this growing trend, below are helpful articles: • http://www.hldataprotection.com • http://www.globallawwatch.com/ For Assistance or questions, feel free to contact: Rhett Asher Vice President, Asset Protection, Data Security & Crisis Management FOOD MARKETING INSTITUTE 2345 Crystal Drive, Suite 800 . Arlington, Virginia 22202 Phone: 202-220-0774 Fax: 202-220-0885 e-mail: [email protected]

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Your Employees Are PRAYING For a Big Verdict: Understanding Religious Accommodation Issues

By Allison West, Esq., SPHR, SHRM-SCP

An employee informs her manager she can no longer work the Saturday shift because of her new found religious beliefs. Or, a new employee notifies HR and her supervisor that her faith requires she wear a head covering at all times even though your dress code prohibits employees from wearing hats in the workplace. How you handle these situations can be the difference between winning and losing a lawsuit. Unfortunately, many employers do not realize they have an affirmative obligation to try and reasonably accommodate their employee’s religious beliefs and practices. Many immediately say “too difficult” or “if we accommodate you, we have to do it for everyone.” These kinds of responses potentially head in one direction: litigation. With religious discrimination lawsuits on the rise, employers must understand the nuances of handling requests for a religious accommodation. So, what is a religion, anyway? Not surprising, countless religions exist in our world. Under Title VII and most state laws, religion is defined to include their Fair Employment and Housing Act (FEHA) define religion to include all aspects of religious observance, practice as well as beliefs. The beliefs must be sincerely held with the strength and conviction of traditional religious views. This means the belief can be formal or informal, theistic or non-theistic and typically include some type of moral or ethical beliefs as to what is right and wrong.Traditional, organized religions such as Christianity, Judaism, Islam and Buddhism are easy to spot; yet religious beliefs that are uncommon, new, followed by a small group or that seem illogical or strange would very likely still qualify as a religion. Practice Pointers: You may have an employee who tells you about a religion unfamiliar to you or you question the sincerity of his or her sincerely held beliefs. The best practice is to assume most beliefs are sincerely held. Statistically speaking, the case is rare where an employee makes up the reason for needing an accommodation. Please do not assume an employee is insincere simply because some of his or her practices may deviate from the commonly followed tenets of his or her religion. For example, you have one employee who is Jewish and wears a yarmulke (head covering.) A different Jewish employee makes a request for religious accommodation but does not wear a yarmulke. The absence of the head piece does not mean the person does not have a sincerely held belief. If some objective doubts exist, consider asking for additional information. You are permitted to ask for details about the religious practice or requirements. If an employee tells you she cannot work Saturdays anymore because she needs to attend a religious service on Saturday mornings, ask if she could attend at different times, days, etc. Further, you could ask the employee to bring in any documentation from her religious entity that could support her need to attend that particular service. Isn’t it supposed to be a REASONABLE Accommodation? An employee has the obligation to put his or her employer on notice for the need for a reasonable accommodation. No magic words are necessary. However, the employee must let you know the request is made due to a conflict between religion and work. The employee should cooperate with any requests for additional information. Unlike the reasonable accommodation requirements under the disability laws that require an “interactive process,” no such requirement exists for religious accommodation. With that said, engaging in an interactive process with your employee is simply good business. The efforts you make – and document – will go a long away with a jury and can help with a defense and possibly avoiding liability. The big question remains - what is reasonable? According to the EEOC, the accommodation must eliminate, not just lessen, the conflict between religion and work, so long as the accommodation does not cause an undue hardship. A reasonable accommodation is any adjustment to the work environment that will allow the employee to comply with his or her religious beliefs. Title VII requires employers to “demonstrate(s) that it has explored any available reasonable alternative means of accommodating the religious belief or observance…” The good news is employCFInsider Q1 - 2015

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Understanding Religious Accommodation Issue ers are not required to provide an employee’s preferred accommodation if a more effective alternative is available. Using the example above, since the employee cannot work the Saturday shift you offer her the same hours on the Sunday shift. The employee tells you she has family obligations every Sunday and cannot work that day. You do not have to try and find another accommodation for the employee because offering the Sunday shift is reasonable. If you offered her the graveyard shift instead of the day shift that would be unreasonable. Practice Pointers: Whenever possible, consider the employee’s proposed method of accommodation. An accommodation is not reasonable if it unnecessarily disadvantages the employee’s terms, conditions, or privileges of employment. What this means is that you cannot penalize an employee simply because they require an accommodation. The most common requests for accommodation are for scheduling, dress, displays of religious symbols or being excused from certain objectionable job duties. Typical methods of accommodation include: use of flex time, voluntary swaps, transfer, use of accrued leave, use of unpaid leave and changing job tasks. To Accommodate or Not to Accommodate? That is the Undue Hardship Question Employers have the defense of undue hardship when determining whether they can provide a reasonable accommodation. Under Title VII the employer must show the proposed accommodation poses a “more than de minimis” cost or burden. Factors considered include not only direct monetary costs but also how the accommodation might burden the employer’s business. Be careful as some states, not surprising that California is one, imposes a much higher standard and requires an employer to show the propose accommodation causes “significant difficulty or expense.” In reality, this showing is very difficult for California employers who must make a real concerted effort to find an accommodation for the employee. Practice Pointers: Potential undue hardship exists when the accommodation diminishes efficiency in other jobs, imposes on co-workers’ job rights or benefits, impacts workplace safety, or causes co-workers to carry a disproportionate share of potentially hazardous or burdensome work. Can customer or employee complaints constitute an undue hardship? Unlikely. Query the customer or co-workers as to the nature of their complaint. Simply because someone makes a complaint that the accommodation is unfair or makes someone feel uncomfortable is not enough to show an undue hardship. Be careful about policies or decisions based on “image” of the company. These types of policies can look like religious bias couched under “customer preference” in violation of state and federal anti-discrimination laws. Additionally, uniformity of appearance is rarely enough for undue hardship. Courts typically respect seniority rights whether pursuant to a collective bargaining agreement or an employer system. A good rule of thumb is to find temporary solutions pending a permanent accommodation such as a bid process, etc. Keep the dialogue going and talk to your employees about voluntary swaps or other options. At the end of the day, employers should train managers and supervisors on how to recognize religious accommodation requests from employees and not just answer “no.” Religious accommodations are made on a case by case. Finally, developing policies, procedures and forms for processing religious accommodation requests will streamline your process and keep your processes consistent. In a future publication Allison will discuss issues when investigating claims of religious discrimination.

Employment Practices Allison West is an employment attorney and uses her legal skills coupled with sound human resources practices to assist companies in managing and reducing their workplace risks. She is a frequent top rated-speaker on employment law and human resources topics and was one of the top 10 rated speakers at the Society for Human Resource Management’s (SHRM) Annual Conference in 2012 and top 10% in 2013. Allison specializes in delivering customized interactive training, coaching executives and managers, human resources consulting and expert witness assistance. Allison specializes in conducting workplace investigations for employers of all sizes and industries, on a variety of topics including harassment, discrimination, theft, violence, disability, whistleblower and other issues. She is a Board Member of the Association of Workplace Investigators and a member of the ASIS Investigation Standards Technical Committee. She is a member of the California Bar and holds a Senior Professional in Human Resources certification. Visit Allison’s web site here: http://www.employmentpractices.net/

Video

Interviewing Tips Make sure to check out all of IAI’s Interviewing Tips! This month, “Why Confess” by Wayne Hoover, CFI Check it out! http://certifiedinterviewer.com/why-confess/ CFInsider Q1 - 2015

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Interviewers, Investigators and Asset Protection Professionals Have Challenges 41% of retail shrink – equaling $18.1 billion to U.S. retailers – attributed to employee theft

Shoplifting & ORC – ”hybrid” forms of retail shrinkage that may involve employee colluders – cost U.S. retailers an additional $14.6 billion

Online/ cyber fraud – which low integrity employees can facilitate – cost North American merchants an estimated $3.5 billion in 2012 011001100

100101010 010101100 2012 National Retail Security Survey (2014)

2012 National Retail Security Survey (2014)

CyberSource’s 2013 Online Fraud Report (2013)

General Dynamics IT Has Solutions Organizations leverage our range of Human Capital Risk Management assessments to identify trustworthy, productive and lower-risk applicants and employees. – – – – – –

The Reid Report® Risk Assessment for integrity, ethics and productivity Information Security Admissions Express for cybersecurity risk exposures Organized Retail Crime Express to deter employee collusion with ORC Employee Safety Inventory for accident prevention Employee Attitude Inventory for efficient investigations and theft audits Express Scales for sales, service, drug avoidance, dependability and more…

Prou our 2 dly in nd ye as an ar IAI Di am Spon ond sor

For inquiries about these or other assessments from our Human Capital Risk Management team, or our consultative solutions that can help improve your bottom line, please contact Eric Hutchison at [email protected] or 312-242-4428.

[email protected] • www.hcrm.gdit.com Copyright © 2014 General Dynamics Information Technology. All Rights Reserved.

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U P DAT E S

CHAPTER

Dr. Saul Kassin of John Jay College of Criminal Justice spoke at our last NE Chapter meeting hosted by Starbucks in NYC. Dr. Kassin reviewed his work on false confessions, showcasing several high profile cases that had been reversed. His talk focused on what elements go into creating an atmosphere where false confessions can occur, warning signs to look out for that a confession may be false and strategies to avoid false confessions. His talk was extremely well received with large amount of participation and questions from the attendees.

CFIs Speak at FMI • Get A Harvard Education For Free – Adam Smith, CFI WANTED: Innovative Leader and Mentors Understanding motivation across gender, age and career objectives • L. Wayne Hoover, CFI • Carmen DuBose, CFI • Towanna Bazile,CFI

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Rationalization of the Quarter Group: Addicted To Stealing Rationalization: Investigations give insight into what happened and who was involved, what is important is to find out why things happen. This leads to the question as to the reason behind the behavior. We all have behaviors that we are addicted to. State It: You know there is a funny little fact about human behavior that perhaps not too many people think about. It’s about those actions, those behaviors that we get addicted to, some of them are good, others perhaps not so much Story It: I remember when Facebook was starting to gain its popularity. My wife and I started our accounts and I soon noticed how my wife was on the computer just about every chance she got. She got addicted to updating her status, checking out what her friends were doing, and finding old friends from days past. It got to the point that we ended up arguing over her addiction, but she just couldn’t see how the behavior was destructive to her and our relationship. This seems pretty innocent, but other types of behavior, can also be dangerous and can lead to potential personal issues. Behaviors such as drinking too much, smoking too much, or perhaps taking things without permission, the act, the simple behavior is what gives us the “high”, the feeling that we like to feel when doing those things. Taking things, or the act of stealing over and over can become addictive, the challenge, the excitement, the thrill - those are the base emotions that cause behaviors to become addictive to us whether it is supposedly innocent behavior like Facebooking all the time, to taking things without permission. Moral It: When a behavior becomes addictive, then it crosses the line from being an ok behavior to one that is not. Addiction to something means people need help, remember the behavior is not ok, it is not acceptable and never will be to take without permission, to steal even if the behavior is something a person is addicted to. Link It: As investigations, again determine what happened and who was involved, it is important to remember that a behavior can be so addictive as to cause the situation under investigation. While it is never “ok” to do some types of behavior, the investigation remains focused on finding out why

Leadership is not about titles, positions or flowcharts. It is about one life influencing another. John C. Maxwell

QUOTE of the Quarter

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CFI Spotlight Interview This CFInsider edition spotlights Jody Huffman, CFI of the Illinois State Police. Jody has been a police officer since 1997 where she started at the University of Illinois Police Department, Urbana, Illinois. In this capacity she worked patrol, investigations and served on a Joint Terrorism Task Force with the Federal Bureau of Investigations. In 2007, Jody joined the Illinois State Police and has served in patrol, investigations involving undercover drugs and health care fraud and currently serves on a Tactical Diversion Squad with the Drug Enforcement Administration. Jody has a Bachelor’s of Science from Illinois State University and a Master’s Degree in Public Administration from Governors State University. Jody is married, and enjoys spending time with her family while traveling and working on her home. Please learn a little more about Jody Huffman below in this spotlight edition. I started as an intern with the Bloomington Police Department when I was in college. This experience led me to the career path of a police officer. The police department allowed me to ride along with patrol officers on numerous occasions which provided an excellent perspective of what the reality of law enforcement was. Once I graduated from college, I joined the University of Illinois Police Department and worked in patrol, investigations and on a Joint Terrorism Task Force with the Federal Bureau of Investigation. I joined the Illinois State Police in 2007, worked in District 5, Joliet on midnight patrol, transferred to District 10, Pesotum on second shift patrol. I interviewed for and received the position of Special Agent with the Medicaid Fraud Control Bureau (MFCB) within the Illinois State Police in 2009. I worked health care fraud from 2009 to 2013 when I was assigned to the Tactical Diversion Squad with the Drug Enforcement Administration. I currently work pharmaceutical diversion investigations at the DEA. For me to take the next step with career development, the CFI designation was a natural extension of learning. Through my years of investigative experience, I was able to conduct countless interviews which led to confessions, admissions, and denials. I wanted to ensure I had the knowledge to handle what the suspect, victim or witness was telling me. Personally, I wanted to “up” my game. My background is general investigations so the idea of working on a more complex type of investigation such as Medicaid Fraud was interesting to me. I believe that all investigators should start out working general investigations then move into more specific investigation assignments as they require additional training and education to be effectively worked. My current assignment with the Drug Enforcement Administration was a natural extension of learning another kind of investigations. The basic principles of investigation are the same; however, each investigation is handled on a much more individualized nature. Interviewing is the life blood of police work and human intelligence is essential to driving a case forward. Each interview I conduct, hopefully, gains intelligence which is used to put the case together. I look at interviews as a series of puzzle pieces when put together can tell the entire story of a case and ultimately lead to prosecution. Over the years, I have worked with numerous private sector retail agencies during investigations. The partnership between the public and private sector is key in terms of making a case. Many times the private sector companies are a victim in the case as well and offer to help law enforcement. Examples of this cooperation include video surveillance, cash register transaction receipts, gaining email address or telephone numbers, or other paperwork which can link the suspect with a particular crime. I have learned no two investigations are ever alike which can be difficult, but ensures I look at each investigation with new eyes. I remember one case where patrol arrested several subjects for an armed robbery. As we began to investigate and conduct interviews regarding the crime, my partner and I learned the subjects who were previously arrested did not commit the crime. For me, merely obtaining a confession is not enough; I have to make sure that it is a proper confession or admission. With the knowledge I gain day to day I know I can confidently advance my career with the Illinois State Police and eventually lead an investigative unit. Ultimately, I want to make policy for the Illinois State Police which can positively impact future law enforcement officers in my agency. CFInsider Q1 - 2015

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Vector Security Congratulates Outstanding Women in Loss Prevention As a top contributor to your profession, you know the importance of staying ahead of the game. Keeping up with industry trends and the latest technology is part of what you do. So it comes as no surprise that LP professionals are working more and more closely with IT to develop cost-effective, business transforming security solutions. Vector Security is poised to help you navigate this shift in the industry. We’ve authored a white paper titled “LP Meets IT for Complete Managed Business Infrastructure, Security and Intelligence.” Download it from our website at www.vectorsecurity.com/lp-meet-it to learn more about the evolving LP landscape and to uncover the customer experience and business intelligence opportunities gained when LP and IT meet.

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For a full list of Vector Security license information, visit www.vectorsecurity.com/licenseinfo

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LEGAL ASPECTS National Labor Relations Board (NLRB) - Triple Play Sports Bar and Grill (2014) There continues to be an evolving set of guidelines for online behavior of employees. This case involved a derogatory online Facebook post by a former employee which was liked by a current associate of the restaurant. Triple Play Sports Bar and Grill terminated a cook and waitress/bartender for supporting a critical post of a former employee. The former employee was apparently angered over an unexpected tax bill because tax paperwork was incorrectly prepared by the organization’s owner. The former employee had posted; “Maybe someone should do the owners of triple Play a favor and buy it from them. They can’t even do the tax paperwork correctly!!! Now I OWE money…Wtf!!!” Many of the former employees and current Triple Play employees commented on the post also complaining they had to pay unexpected tax bills because of the company’s accounting errors. A cook “liked” the original post and the bartender/ waitress wrote;” I owe too. Such an asshole.” This statement may have been aimed at one of the Triple Play owners who was responsible for the tax preparation. After learning about the Facebook posts the owners of Triple Play terminated the cook and bartender/waitress for disloyalty. The two employees filed a complaint with the National Labor Relations Board claiming their communications were protected. The two argued that since the posts were about the terms and conditions of their employment these were a protected activity. Triple Play on the other hand contended the posts were “defamatory and disparaging speech”. This type of speech is not protected by the NLRB. NLRB finds for the employees. The simpler of the two cases for the NLRB to decide was the cook who had merely “liked” the former employee’s post. The NLRB concluded the “like” shared the former employee’s concern and rose to the level of a protected activity. There was nothing defamatory or disloyal about posting the “like”. The bartender/waitress was more problematic since the post alluded to an owner of Triple Play as an “asshole”. In the end the NLRB decided it was not sufficiently disloyal to lose the protection. Ames v. Ohio Department of Rehabilitation and Correction, 2014-Ohio-4774 (2014) The Ohio Department of Rehabilitation & Corrections sent a senior parole officer for a psychological evaluation after he had allegedly said something about shooting parolees. The senior parole officer said that the statement was made as a joke and after a psychological examination he was cleared to return to work. Several months later the parole officer was questioned about using a department computer for nonbusiness purposes. The tipster, a coworker, claimed that afterward he had received a threatening text message from the senior parole officer. Another psychological examination was ordered to evaluate the senior parole agent’s propensity for violence. The second psychological examination was inconclusive and a third examination concluded it was safe to return the senior parole officer to work. In the months following his last examination the senior parole officer supposedly posted a threatening message online. The senior parole officer refused to cooperate with the Department of Rehabilitation & Correction. The department was attempting to investigate whether or not the senior parole officer’s computer had been hacked. Ultimately, the Department of Rehabilitation & Correction terminated the senior parole officer for failure to cooperate in an investigation. The senior parole officer filed a lawsuit against the Department Rehabilitation & Correction claiming the termination was the result of a perceived disability. Results: the Trial court found for the Department of Rehabilitation & Corrections. Later the appeal court followed suit finding that the plaintiff was not able to bring forth evidence supporting the claim. CFInsider: in this case the prompt and thorough investigation of each of the allegations relating to threats of coworkers help support the court’s decision. Since the employee refused to cooperate in the investigation disciplinary action up to and including termination of employment was deemed appropriate. CFInsider Q1 - 2015

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ON THE MOVE December 2014

James Mullaney, CFI was promoted to Regional Investigations Manager for Price Chopper Supermarkets. Ben Lockhart, CFI, CFE was named National Sales Director for Blue Dot Safes. Alan Thompson, CFI was promoted to Regional Manager, Loss Prevention and EHS for the Central Region for FleetPride Inc. Ken Gladney, CFI was named Director of Security at Taco Bueno Restaurants.

January 2015

Ryan Roby, CFI was named District Loss Prevention Manager at King Soopers. Patrick Smith, CFI was named Regional Loss Prevention Manager for Helzberg Diamonds. Tom Ciomcia, CFI is now Loss Prevention Consultant at Deb Shops, Inc. Mike Battles, CFI was named Manager of General Investigations at Texas HHSC Office of Inspector General. John Barbul, CFI was named Regional Loss Prevention Manager at HVHC. Frank Sorrentino, CFI was named Police Sergeant at University of Oregon Police Department. Marc Santiago, CFI was named District Operations Manager at The Home Depot. Joe Dolio, CFI, CFE is now Loss Prevention at Kmart Corporation. Jake Sawyer, CFI was named Asset Protection Manager for Lord & Taylor. Dan Petrousek, CFI, SPHR was named Regional Loss Prevention Manager for ULTA Beauty. Adam Smith, CFE, CFI was named Environmental Health and Safety Supervisor at Southern Wine & Spirits. Aaron Hancart, CFI was named Loss Prevention Manager at Moorehead Communications Josh Bertelson, CFI was named Security Systems Specialist at Park Nicollet Health Services Jake Sawyer, CFI was named Asset Protection Manager for Lord & Taylor. James Ballard, CFI was named Patrol Sergeant at Elkhart Police Department

February 2015

Maurice Edwards, CFI was promoted to SVP, Enterprise Risk Management for Mattress Firm. Daniel Davies, CFI was promoted to Senior Divisional Director of Asset Protection, Division 3 for Rite Aid. Jason Cassidy was named Director of Store Operations for Bevello Sarah McCoin, CFI was promoted to Senior Regional Asset Protection Manager at Hibbett Sporting Goods. Scott Martyka, CFI, CRT was named Corporate Loss Prevention Manager for ALDI, Inc. Rahul Gosain, CFI was named Senior Manager at Alvarez & Marsal. Michael Wittenburg, CFI, CFE, CFCS, CAMS, CCEP-I was named Head of Financial Crime Management at Raiffeisen Zentralbank Osterreich AG. Ryan Bauss, CFI was promoted to Director of Asset Protection for Harris Teeter. Barry Cook, CFI was named Police Officer for Lofs PD. Christopher Dangelo, CFI was named Patrolman for Weymouth Police Department.

We are the International Association of Interviewers 2,500+ IAI members

Committed

1,800+ Number of CFIs

Professional Dedicated Certified Elite

In the past few years… 100+ Promotions of CFIs to Director and Vice Presidents 250+ Executive level CFIs promoted CFInsider Q1 - 2015

15

New CFIs DECEMBER

JANUARY

Robert Buescher Joshua Carroll Marvin Cooper Natalie Gerk-Parra Curtis Hientz Robert Horner Karvis Jerrigan Justina Kissell Matthew Martin Renee McGee Michael Osborne Alexander Snyder Colin Stewart Joseph Toth Bret Van Houten Betsy Vargas Vargas Yvette Weems Diane Williams Matthew Zelno Kimberly Zovishlack

Patrick Daniel Walter Douglas Mimi Foster Richard Gunn John Jacobson Aki Moore William Penn David Rabbiner David Seidler Daniel Sikes Kane Smith John Worsham Casey Wright

FEBRUARY

Pierre Buie Steven Determan Phillip Ijoma Gwendolyn Jacquot Eduardo Mayoral Campos James Morris John Noyes Gary Russell Margaret St. Onge Anthony Wheeler

CISA The objective of this certification program is to create comprehensive, universally accepted professional standards combined with an objective measure of an interviewer’s knowledge of those standards. The ultimate goal is that every person and every organization with a stake in interviewing will benefit from the program, as will the reputation and effectiveness of the entire profession.

CFIs Recertified SEPT. 2014 – NOV. 2014

CFI Code of Ethics

DECEMBER

january

FEBRUARY

The Certified Forensic Interviewer is a

Jason Adams Nicholas Bacon Jeremy Bailey Ernie Beugh Marcelo Bravo Paul Chrisman Kerry Crapia Tina Funk Robert Gibson Kevin Griggs Lawrence Hartment George Hines Carole Hylands Thomas Jones Kevin Kenney Fred Kramer Veronica Maida Chris McCarrick Cliff means Donna Mundis Brandie Patton Marc Santiago Robert Smith Brett Stees Thomas Tauer Victoria To-Dowd James Tyrrel Kimberlee Woo

Kevin Krotenberg Justin Bowers William Dietzen Michael Draper Christopher Gibson Joey Gonzalez John Gregg Robert Hearn William Hill James Hooper Marry Kelly Celia Kettle Danny Lake Harold McIntyre Gary Moncur Joanna Povich Daniel Renauer Eric Rode Timothy Ruggiero Chad Sellers Kim Sharp Stacey Weathers Hongwei Rony Yu

Ryan Bauss Kenneth Boremi Gregory Chesterton Bryan Copas Brian Csorba Pasquale Gallo James Knaak Karl Langhorst Stephen Levine Matt Lincoln Jim Mullaney Floyd Nesbit Jeff Robinson Cecil Rogers Christopher Rosson Patrick Smith Stephen Trefry Samuel Wilkerson

professional with the expertise to conduct a variety of investigative interviews with victims, witnesses, suspects or other sources to determine the facts regarding suspicions, allegations or specific incidents in either public or private sector settings.

The Certified Forensic Interviewer demonstrates understanding of legal aspects of interviewing and proficiency in interview preparation, behavioral analysis, accusatory and non-accusatory interviewing, documentation, and presentation of findings. Click here to link to the complete CFI Code of Ethics. http://certifiedinterviewer.com/about-us/our-values/

CFInsider Q1 - 2015

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Up for re-certification MARCH

APRIL

MAY

Myron Burton Suzanne Castillo Jacinto Davila Kasondra Fehr Brayan Gittings Michael Hooper Robert Mirakaj Sam Reichman Holly Rinaldo Donald Rollings Tamera Schliebe Kerry Shotwell Claude Taybi

Eric Chase Chadd Cranfill Jesse Diaz Mike Forgione John Gammon Paul Leasum Thomas Martinez Andy Montoya Alana Parry Daniel Phillips Lawrence Pike Mark Reaves Charles Rossello William Sanchez Timothy Silvia Eric Smith

Michael Adachi Kevin Baker John Bartlett Chance Bowlin Heather Budenz Adam Cabrera Rod Cabrera Sarah Carr Jeffery Collins Eric Echols Jeremy Ewan Bradley Gardiner Deborah Hesly Michael Ketchmark Marc Lambert Martin Lisitza Bryant McAnnally Eric Means Terrence Murphy Jose Nunez John Prystupa Linda Rorigues Alejandro Shea Joseph Sloan Eric Stone Teresa Townsend Rodrigo Urzua Brittney Vachon Vince Williams Jon Young

IAI New Members DECEMBER

JANUARY Cont.

Michael Fisher Donnell Graham John Harrison Justin Henkenberns Curtis Hientz Henry Karawan John Larson Angie Luti Renee McGee Mark Ochitwa Richard Patrick David Rabbiner, CFI Alan Lott, CFI

Gary Grimes, CFI Emily Hall James Hawkins, CFI Anthony Heavner Level Hedgspeth Ashley Hill Jason Keller, CFI Dave Kendrick Robert Larson Thomas Lau Daniel Lieberman Chad Mackiewicz Matthew Matous AndrewMwangi Osbey Orozco John Partington Giancarlo Pelosi Barry Pruit, CFI Howard Scrivens Justin Spencer David Strom, CFI Ross Tapp jasmin Wlaker George Warren Cera Weaver Misty Williamson Joshua Williford Sean Wright

JANUARY Marc Abramson, CFI Melissa Allgood Alexander Atkinson Caitlin Berkley Jim Bishop Natalie Bonnell Naomi Brown Tom Burke Evelyn Caranci-McErlain Donald Christmas Brian Connelly, CFI Marvin Cooper Amy Cotta Ryan Destler Walter Douglas Monica Fisher Taondria Foster CFInsider Q1 - 2015

Get the Gear only 5 more leather-bound portfolios! In addition to the CFI Coin, we have received requests for numerous CFI items. While several are under development, including a new logo for shirts, we do have 5 commemorative CFI leather bound folders available. The cost is $30.00 plus shipping. Click HERE to order yours today!

Continued on next page

17

IAI New Members FEBRUARY

Missy Andeel, CFI Brandon Bradley, CFI Pierre Buie, CFI Linwood Byrd, CFI Mary Carr Joe Christian Shane Coover, CFI Larry Deal Albert Dinnell Sharnai Fisher Dean Geyser, CFI Shanna Gianchiglia, CFI Jacob Gordon, CFI Tabitha Holmes John Jacobson, CFI Ryan Kinne, Timothy Larson, CFI Chrstine Latour, CFI Kirt Lovett, CFI Matthew Martin Robert McLaughlin, CFI Kellen McWhite, CFI

FEBRUARY Cont.

Richard Nafegar Shekinah Newby Jeffrey Passov Lynn Paul William Penn, CFI Kevin Robinson, CFI Jason Schillinger Gregory Stafford Tony Starrs, CFI Curt Steele, CFI Jasmine Taylor, CFI

Up for IAI Membership Renewal? Click here if you are unsure or want to renew now.

Get your CFI & IAI Shirts for Elite Training Day. Click here to place your order.

CFInsider Q1 - 2015

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Thank You and We Need You! We thank these CFI Committee volunteers and we plea for more! Our volunteers make the CFI designation what it is today! Be active in 2014 by joining a committee. Remember: A committee volunteer receives four (4) Continuing Education Credits toward recertification! Pick one below! Sign up

CONTINUING EDUCATION COMMITTEE Co-Chairman Jack Ternan, G4S Secure Solutions Chance Bowlin, Petco Mike Hannon Shane Jennings, Music & Arts Centers Inc. Andrew Fossler, Johnson Controls Bill Suthard, Barnes & Noble Bill Dietzen, Auto Zone Benjamin Robeano, Big Lots Andrew Barborak, Gander Mountain David Miglin, Big Lots David Dehner, Silver Creek Associates Dan DiMatteo, Portland Police Department Cheryl Floccare, Tractor Supply Company Charles Werner, Nordstrom Brian Kirby, Columbia Sportswear Lewis McFarland, Tilly’s Lansing Williams, Big Lots Kevin Thomas Ken Gladney, Half Price Books Karen Sandoval, Ueltzen & Company LLP Joshua Anderson, Sportsman’s Warehouse Jody Kershaw, Shopko Stores Operating Co., LLC Jodie Murphy, Gap Inc. Jeremy Bailey, Hibbett Sporting Goods Jason Lotts, CVS/Caremark

Jane Woodland , Global Security and Investigations JPM Chase James Carr, Rent-A-Center Garth Gasse, RILA Everett Stein, Tractor Supply Company Elena Hollenbeck, Nike Suzanne Castillo, Ralph Lauren Steve Schwartz, Kohl’s Stephen Munson, Harbor Freight Tools Shauna Vistad, Blue Cross Blue Shield ND Tonya Sjolin, Sur La Table, Inc. Scott Martyka, PetSmart Raymond Cotton, Lumber Liquidators Richard Portmann, Facebook Roderick Cabrera, Tillys Robert Figueroa, Rent-A-Center Robert Sanchez, Carters Richard PortmanWWVes Michael Berry, Walt Disney World Matthew Morgan, Goodwill Industries of Southeast Wisconsin Valerie Marie Knowles, Bloomingdales William Wells, Rite Aid Wayne Hoover, Wicklander-Zulawski, Inc.

NEW ORGANIZATIONS Allie Barton Apple Inc. Bell Manulife Financial Northwest Co. Still Rise Inc.

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membership committee

NE CHAPTER

Christopher Finck, AAFES Melissa Lauricello, Brooks Brothers Jason Lotts, CVS/Caremark Mike Marquis, TJX Companies Melissa Mitchell, Lifeway Christian Stores Joseph Picolla, US House of Representatives Thomas Stein, Ollie’s Bargain Outlet Erik Van Herik, Office Max Douglas Wicklander, Wicklander-Zulawski & Associates, Inc. Kym Willey, Luxottica Retail Jennifer Ziegler , Wicklander-Zulawski & Associates, Inc. Wayne Hoover, Wicklander-Zulawski, Inc.

Advisory Board NE Chapter Mentors Mike Marquis, TJX Companies Steven May, LP Innovations Richard Manning, Federal Bureau of Investigation (Ret.)

Scholarship Committee Katie Ayala, Asset Protection Associates Towanna Bazile, AT&T Joseph Biffar, Chico’s FAS Inc. Chad Borstein, Lowe’s Dustin Brown, SpartanNash Matthew Dawson, CVS Caremark Corporation Robert Gibson, JCPenney Company Inc Chris Girone, Office Depot Michael Hannon, Staples William Hill, AmeriCold Logistics Mark Jackson, Big Lots Tom Kelly, JC Penney Deborah Lanford, CVS Timothy Lapinski, Abercrombie & Fitch Kevin Larson, Kroger Gloria Lopez-Whitman, TJX Marmaxx Group Justin MacIntyre, Von Maur Scott Martyka, PetSmart James Mullaney, Family Dollar Michael Narciso, URBN Daniel Taylor, Panera LLC Victoria To-Dowd, LUSH Fresh Handmade Cosmetics William Turner, Radio Shack Kati Wisniewski, Ratner Company

Chairman Steven Palumbo, Tiffany & Company Immediate Past Chairman Christopher Batson, Gap Andre Stevens, Northampton District Attorney Alfredo Guilfuchi, The Timberland Company Frank Honey, Gap Eric Means, Armani Exchange Elisha Toye, Kohl’s David Lu, Apple Inc. David Kinkeade, Hat World David Dehner, Silver Creek Associates Charles Cherry, Ann Taylor Stephen Dubeck, Petco S. Andrew Awad, AT&T Nathan Prusi, Starbucks Michelle Cabrita, Burberry’s Michael Toledo, American Eagle Outfitters Kourosh Aliha, Sprint Juan Ospina, Michael Kors Joseph Rezendes, Radio Shack Joseph Conte, FedEx Joseph Barbagallo, Citrin Cooperman & Company Jonathan Goodrich, PetSmart John Nicholson, Office Depot John McLean, Macy’s John Fice, LP Innovations Jason Ploof, Armani Exchange Jason Adams, Gap Inc. Timothy Kneidel, CVS Caremark Corporation William Angiolillo, LP Innovations David LoPriore, Elemental Intelligence Systems

NSIDER CFInsider Q1 - 2015

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RATIONALIZATION Committee

WEBSITE Committee

Chairman Randy Tennison, Walt Disney Parks and Resorts

Robert Figueroa, Rent-A-Center Kathryn Fox, Kroger Wayne Hoover, Wicklander-Zulawski, Inc. Valerie Marie Knowles, Bloomingdales Elena Mencos, Ulta Doug Newsome, Goodwill Industries of Upstate/Midlands Mathew Nickoson, North Coast Protective Services Michael Peters, Rite Aid David Ryack Tonya Sjolin, Sur La Table Kevin Thomas Graham Twidale, 7-Eleven Inc.

Michael Ferlotti, Harris Teeter Robert Figueroa, Rent-A-Center Bryan Gittings, Limited Brands Elena Hollenbeck, Nike Wayne Hoover, Wicklander-Zulawski, Inc. Paul Joeckel, Auto Zone Robert LaCommare, Tween Brands, Inc. Thomas McGreal, Wicklander-Zulawski & Associates, Inc. Andie Millaway, Petsmart Eric Rode, Office Depot Robert Sanchez, Carters Shauna Vistad, Blue Cross Blue Shield ND Mindy Solt, Gap

To be an active member of your CFI designation, click here to join a committee.

• The cfinsider journal is distributed in electronic format only. You can view back issues of this newsletter. Click Here. • Opinions and ideas in cfinsider are intended for information only, and not meant to be used as legal advice. Statement sof fact and opinions made are the responsibility of the authors and do not imply an opinion on the part of CISA, its officers, the editors or its members. • Member articles about interview and interrogation published in cfinsider qualify for Continuing Education Credits. • Should you have any questions on obtaining re-certification for your CFI designation, please click here to contact CISA.

Submit an Article CFIs! All CFIs are invited to submit articles, book reviews or other materials for publication. Submission of an article to CFInsider does not guarantee it will be published. CFInsider reserves the right to edit any article for grammar, clarity, and length, but the content or opinions contained therein will be those of the author. Publication of an article, its contents, and opinions do not necessarily reflect the opinion or beliefs of CFInsider or the Advisory Committee.

CFInsider Q1 - 2015

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Letter from the EDITOR

Editors Joseph Nay, CFI, Heinen’s Inc. [email protected] Cary Jones, CFI, VisionWorks, [email protected] Stefanie Hoover, CFI, Verisk Retail [email protected]

Journal Committee Benjamin Robeano, CFI, Big Lots [email protected] Donald Ward, CFI, CFE TJX [email protected]

It seems that conference season is upon us! A quick check of our website lists seven conferences scheduled over the next ninety days. As this issue goes to press, I am just returning from a very impressive FMI Asset Protection conference in Memphis (see page 10 and read the article by Rhett Asher), and our Chairman points out that we are quickly approaching the Elite Training Day event in April. As I review this month’s newsletter, I see many stories that remind me of Elite Training Day. You can read a sample of work from Harvin Moore, scheduled presenter for event and an article by Allison West, former ETD speaker. The most significant tie-in to what Elite Training Day is all about may be our feature on Jody Huffman, CFI, Illinois State Police. Reading Jody’s profile reminds me that what sets the Elite Training Day event apart from other learning experiences is that the event is not just a loss prevention conference, but rather an opportunity for high level interview and interrogation training for everyone. The number of CFI’s “on the move” in the public sector (see page 16) just affirms that observation. So whether you consider yourself public, private, human resources, law enforcement, regulatory, security, asset protection, or loss prevention, we hope you enjoy this issue and we look forward to seeing you in April on the Riverwalk. Sincerely,

Kevin Larson, CFI, Kroger [email protected] Ken Bennett, CFI, PCI Goodwill [email protected] Joe Davis, CFI, Walmart [email protected] Jodie Murphy, CFI, Gap Inc. [email protected] Jim Kelley, CFI, Wal-Mart [email protected] Andy Santiago, CFI, Wal-Mart [email protected] James McLemore, CFI Bealls Department Stores [email protected] Shane Jennings, CFI, CFE Music & Arts Centers Inc. [email protected] Paul Joeckel, CFI, Auto Zone [email protected]

Cary Jones, CFI Director of Loss Prevention

Aaron Denbo, CFI Texas Mutual Insurance [email protected]

HVHC INC.

Steve Welk, CFI Barnes & Noble College [email protected] Allison West, Esq., SPHR Employment Practices Specialists [email protected] Wayne Hoover, CFI Wicklander-Zulawski, Inc. [email protected] David Zulawski, CFI, CFE Wicklander-Zulawski & Associates, Inc. [email protected]

NSIDER

A publication from the International Association of Interviewers CFInsider Q1 - 2015

2014 ISSUE 2 22