On the 11th of January 2016, the Home Office announced a Periodic Substantive Review (PSR) of the Security Industry Authority (SIA) titled simply: Review of the Security Industry Authority. Many will have the view, as a result of constant inaction on the part of the Government, that the current PSR is merely a box-ticking exercise and not worth participation. Infologue.com believes that it is important to treat this review with the same importance as the security services industry treated review when the Con-Lib Government threatened to abolish the SIA as part of the so-called “Bonfire of the Quangos”. There is a lot that requires mending in the “Regulated Security Sector”, some requiring structural reform and others fine-tuning. Regardless of our views, it is important for every stakeholder, including licence holders, ACS contractors, End Users, Trade Bodies, Trade Unions & Security Associations to complete the Review of the Security Industry Authority.
Our initial thoughts on what a future Regulator should look like are as follows:
Legal Duties of the SIA
It is important at this stage to set out the legal duties of the SIA. The key responsibilities of the SIA are set out in the Private Security Industry Act 2001. There are two responsibilities:
1. The compulsory licensing of individuals undertaking designated activities within the private security industry; and
2. To manage the voluntary Approved Contractor Scheme, which measures private security suppliers against independently assessed criteria.
Shifting the Responsibility from Individual Licensing to Business Licensing
Since 2010, the industry has called for a lighter touch regulation involving business licensing, under the auspices of the Security Industry Regulation Alliance which proposed a blueprint on how the industry could be reformed. The perception of the industry was that the proposed blueprint was used as a political football between the Department for Business, Innovation & Skills and the Home Office. Bizarrely, it appeared as if the Government stalled the proposals, arguing that it would mean more red tape for business, which the vast majority of the security industry had requested. Furthermore, the light touch regulation would free up a significant proportion of individual licence holders (370,283 – Jan 2016), who would have their applications or renewals processed through their employers. A large proportion of the Door Supervision licence holders are self-employed, working for more than one employer. This is a large amount of voters that would be freed from regulation.
The Approved Contractors Scheme (ACS)
There has been great debate over the ACS scoring system which confuses procurers. The current ACS has scores on 9 categories of business activity. Scores range from 0 to 174.
Our opinion is there should be two levels of quality, an ACS standard and then a higher standard for high-performing companies. This could create real differentiation between companies working towards a fixed standard.
Many operators believe that the entry level ACS score of 0 should be should be regarded as the minimum standard for the security industry. Sadly, the ACS has only managed to recruit 808 (Nov 2015) security companies out of an estimated 4200 companies, less than a quarter. Many approved contractors will herald the ACS as a success; our belief however is that the scheme is fundamentally flawed. On the SIA website; The Act provides for a voluntary scheme but also provides power to convert it into a compulsory one.
Progression and development of regulated frontline operatives
Whilst the Regulator has responsibility for the training requirement of regulated frontline operatives, Infologue.com is of the opinion that the Regulator should work with the Security Industry in developing a progression path specifically designed for the Regulated Sectors. There is evidence in some companies that a progression pathway exists but it is our belief that progression pathways should become more formalised throughout the regulated security sector. We are aware of the work that Skills for Security have undertaken in this regard, but it is our belief that this could be more focused towards the security services industry.
One of the SIA licence requirements is the successful completion of a mandatory course. Different SIA licences have different requirements, with practical and theoretical training required. Thereafter, the candidates are required to sit examinations. The security training sector has been fraught with malpractice, including exposés on TV. Our thinking is that the SIA should introduce independent examination centres, in the mould of driving licence examination centres for the theoretical elements, and then allow training centres to focus on the practical requirements. The problem is that there is a large proportion of security “guarding” licence holders who have not had any mandatory training since the inception of this requirement. It is our belief that theoretical refresher training would be prohibitive both in terms of logistics and cost. This could easily be solved through online training, which could encompass theoretical requirements of new entrants to the regulated security sector. Infologue.com believes that emergency first aid and practical fire training should form part of a modern security operative’s arsenal. Finally, the introduction of new training requirements, such as counter-terrorism training could also form part of such an online infrastructure. We also believe that emergency first aid and practical fire training.
One of the most significant issues facing the regulated sector is the consistent reduction of margins annually. The provision of security services is regarded as a commodity leaving no margin for the development of frontline personnel. It is our opinion that the Regulator could fund the proposed infrastructure, as well as development work on the progression path as proposed above, through the recovery of funds seized in terms of the Proceeds of Crime Act.
Finally, there is a perception that the term, Security Guard, which is used by the SIA for a frontline security operative is derogatory. We believe this title is not befitting of a modern security officer. It is possible for the Regulator to make this change without legislation. We are sure the industry stakeholders could find a more suitable name.
Deadline for Responses
The deadline for responses is midnight on the 18th of February 2016