The beginning of the end or……

 
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Friday, 20 October 2017

The beginning of the end or……

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The Beginning of an a new era? 

That is the question being asked by many security professionals after the government’s announcement that the Security Industry Authority is  No Longer an Non Departmental Public Body (NDPB) – Phased transition to new regulatory regime. 

What does this really mean?  I think that the devil will be in the detail shortly, however the notes in the document state “No longer an NDPB (or where appropriate non ministerial department or public corporation) – subject to the spending review and, where appropriate, to impact assessment and consultation these bodies be abolished or change status. Some bodies will be abolished and their functions discontinued. For others, functions may be devolved or transferred, or a new status, such as charity or private firm, will be explored.”

When I read this for some bizarre reason I thought of two Sir Winston Churchill’s quotes “Nothing is more costly, nothing is more sterile, than vengeance.” and “Those who forget history are bound to repeat it”.  Reflecting on the first quote unless my memory is wrong, were the Conservatives not opposed to private security industry regulation? The second quote will be reflected as this piece evolves.

Is it me or should they not have done the impact assessment and consultation before this as it would be seen as good practice to do so never mind best practice, or is it the next step to some form of privatisation for our Regulator?  The latter may prove to be difficult as I am unsure how a private organisation will be able to such enforce regulation.  It beggars my belief that so called educated responsible individuals would even consider such actions without firstly properly consulting with the industry and carry out an impact assessment.  I think that the truth in the matter is that the government do not know what they are doing for reasons only be known to themselves, it is almost like the programme Yes Minister.

Given the alleged criteria that the decisions that were made is the SIA not an organisation that performs a technical function or a function that requires impartiality like others on the list that are being retained.

My interpretation of the announcement at this stage is that regulation will remain in, but our regulator will be restructured or replaced but just because everything may be different doesn’t mean anything’s changed or will it?

The need for a regulator in the private security industry is overwhelming, however we need to ensure that the industry is consulted in full and in a more appropriate manner that it was in the past.  Thinking on the above quote about history by Churchill made me think about the mistakes that the SIA made in its embryonic years, one major concern for me personally is that any new formed organisation by virtue of being newly established will undoubtedly make mistakes that could have been avoided not dissimilar to the SIA in its formative years.

Is it time for a new era, I think that it may well be but I refer back to the project planning and industry consultation needs to be with not only trade associations but also with the wider industry.

I have heard varying rumours or perceptions of how the industry will be regulated going forward, one of these include some kind of business licensing which on the surface again without details seems an interesting and fantastic idea.  Within this I have heard that there may be a “lighter touch” approach to the top 10%, well this also begs an interesting question define top 10%? 

1. Do you base this on the top 10% by turnover?
2. Or by ACS score at this time?
3.  There is a third but I will come to it shortly.

Looking at the first two options, although clearly measurable, how workable or achievable is this?  My first thoughts are it is neither workable or achievable for one simple reason, in using football terminology we would have companies being promoted and relegated on an all too regular basis thus making it complicated to manage and regulate.    The third option for me is to follow the governments lead and engage a bingo caller to call the names out of a hat with no proper planning or apparent reasoning.

On reading the Home Office statement on Infologue (Link to Infologue) has perplexed me even more, particularly the following:

“The private security industry has matured in the six years since SIA regulation began in England and Wales. We believe the time is now right to make a phased transition to a new regulatory regime. “

“Ministers from the Scotland and Northern Ireland Governments have been consulted. They want to ensure that regulation of the private security industry continues in their countries. “
“How this will work is a policy decision for the devolved administrations to make. We will work with them to ensure that transitional arrangements continue to operate until such time that a new regulatory regime is in place”.
I believe that most if not all involved in the private security would agree that the industry has matured, but the big question for me has it matured enough for self regulation?  I think not and there are many, many reasons for me  thinking this way and the first one being the business cost models, I regularly hear from security providers of all sizes not just making comment about margins but largely bemoaning that the margins are or have become unworkable, this is probably a factor in why so many acquisitions and mergers have been taking place over the last year or so with undoubtedly more to follow.  It is only  the industry that can drive margins up not the regulator, another obvious one for me is training and development, although there is little doubt that it has improved it has not improved anywhere near to the levels that they could or indeed some would say should.

Regarding the devolved administrations and the alleged consultation with Ministers from the respective governments intrigues me, I would have  thought that as this is on decision that affects the whole of the United Kingdom they would have consulted with the Members of Parliament in all nations and I understand from my MP Mr. Brian Donohoe has not been consulted  so it makes the facetious part of me appear, did they only consult their coalition ministers of which there is one Conservative and there are eleven Liberal Democrats,  in Scotland collectively they make up some 20% hardly representative especially if they do not understand the need of the industry or the role of the regulator or is this just a 10 second wonder statement? 

At this time without knowing the full information, on the surface I feel that  credit has to be given to both Northern Ireland and Scottish Justice Ministers, David Ford and Kenny MacAskill and their respective governments for standing up and being counted to keep the industry regulated. This in itself although to be applauded raises some serious issues and concerns to say the least.   The first major issue and concern is are we going to have a two or three tier licensing system in what is supposed to be a United Kingdom?  The next issues and concerns revolve around training and the transferability of licenses, could it be that for a security operative to operate trans border that they will require up to six licenses?  One for security operations (Guarding or Door Supervision) and one for CCTV (PSS) for each of the three nations?  We then have to consider the training requirements of what is acceptable and transferrable which could lead to a considerable debate and more importantly confusion.

This government have spoken about fiscal governing, surely it is hardly cost efficient to have multiple tiers of the same?

A lot of what I have written is without doubt conjecture on my part but I fear this is because we are being run by a coalition government that is  determined to manage and facilitate through conjecture.


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