Much has been achieved in a relatively short space of time by the Security Industry Authority (SIA). Our success stories are plentiful, but there have also been a great many challenges laid before us. Now is the perfect juncture to review the first stage of licensing. How effective has it been? What are the measurable impacts on the industry? How has the SIA performed as the Regulator? More importantly, however, we must be looking forward to the consolidation of licensing and the Approved Contractor Scheme (ACS), and to the future of regulation.
Are there things we at the SIA need to do differently, or perhaps better? Are there lessons to be learned? What sort of strategic relationships do we need to establish – or strengthen – with the security business sector, with those bodies who represent it, with Skills for Security, the various awarding bodies and, in addition, central and local Government?
As the ‘new kid’ on the regulation block – albeit a mature entrant into the world of licensing – I want to look briefly at the first four years of operations at the SIA, review the aforementioned successes and challenges, examine what we have learned as an organisation and then pinpoint what has worked well and what needs to be improved.
I shall then outline our new Stakeholder Engagement Strategy, which we approved at our April Board Meeting.
You may already have accessed our Corporate and Business Plan for 2007-2008 on the Internet (www.the-sia.org.uk). The priorities outlined therein, together with our Stakeholder Engagement Strategy, will point the direction pretty clearly in which we believe we need to travel in the next three or four years. That journey must be a collaborative one – it has to be travelled in step with the private security industry, and alongside all of our key Stakeholders and partners.
Why? Put simply, the SIA needs to become – and to be recognised as – not only a first class Regulator, but also a valued and respected strategic partner to central Government and its various agencies, to the industry and its representative bodies, training organisations, the police service and a plethora of other public sector bodies.
Regulation: why did we need it?
Let me begin by reminding you all why regulation was introduced. The basic premise was that it would contribute to the public protection agenda and crime reduction by acting as a catalyst that would stimulate change and improvement within the private security industry. The aim was to eliminate – as far as possible – criminal elements in the industry, set and maintain higher standards of probity and help to drive forward the standards and Continuing Professional Development (CPD) of all those working in the private security business sector.
Large numbers of people in the industry wanted licensing for all of these reasons and more. They welcomed it, and have played their part in making it a success. Why? They wanted to improve the image of the private security industry, to enhance its reputation, develop the quality of its operations, to promote public confidence and improve the industry’s overall commercial position.
Four years on, there are still challenges that need to be tackled. Cut-throat bidding over contracts persists, as do wafer thin margins. Wages remain very low, the hours long and working conditions are far from ideal. That said, there have been significant changes across the industry, and many success stories (particularly in the door supervision sector).
Since the start of licensing, over 335,000 SIA-approved security qualifications have been attained. That represents a huge body of people actively demonstrating their commitment to security. In addition, 210,000 SIA licences have been granted, 354 security companies have gained ACS status and, most importantly, 7,000 unsuitable people have been prevented from working in positions of trust. An industry commentator recently estimated that nearer 20,000 people had left or been prevented from entering the industry due to their criminal activities. This is a sure sign that regulation is removing criminality from the security sector.
There is evidence to suggest that regulation has engendered trust and fostered a closer working relationship between the police service and the private security sector. This is clearly demonstrated by initiatives such as local authorities and the police using SIA-licensed security staff to patrol late night taxi queues and takeaway outlets.
SIA-licensed door supervisors employed by Torbay and Paignton Councils are currently patrolling the streets in a bid to reduce car crime. Licensed door supervisors are working with the police in Newport, Gwent to ensure that single women going out to pubs and clubs are being responsible about whom they leave with at the end of their evening.
Concrete evidence, then, that today’s private security industry is a completely different animal from its predecessor. It’s now far more successful, healthier and a great deal more confident.
Challenges: Years One to Four
The SIA has faced some headaches in trying to lay the foundations for licensing. The major one was estimating the size of the licensable sectors, and the potential number of licence holders. Information provided by the security industry in those early days was sparse or inaccurate. Not surprising, perhaps, for an industry that was previously unregulated.
Since the start of licensing we’ve been faced with a lower licensable population than initially expected. This led to tremendous financial problems for the SIA and, it has to be said, somewhat difficult relations with the Home Office. I think I can say with some degree of confidence that the figures are now much more accurate, though there are still some disagreements as to how extensive the annual rate of churn actually is in the security sector.
Given the fact that the SIA is required to be self-funding, the result of these early problems has manifested itself in the recently increased licence fee. I regret this. All I can say is that our aim is to run as tight a ship as possible, to be cost-effective and to undertake a review of the licence fee on an annual basis.
One rumour that I have often heard – and would like to quash here and now – is that the SIA moved into expensive, flashy, brand new offices last December, and that this is the reason why the licence fee was increased. Absolutely not true. By moving to Holborn, we’ve reduced our accommodation costs by GB pound 100,000 per annum.
The second big challenge was to try and provide a good customer service, particularly at times of peak demand for licences (as was the case with manned guarding licences in March and April of last year).
We have to acknowledge that, last yearm there were many periods when levels of customer service were well below the performance targets set by the SIA Board, and that we have to do much better than this. Significant changes will be made, particularly in relation to our Call Centre operation. Improving customer service will be a major priority during the current financial year.
Many of you have contributed to our consultation on improving the licensing process, and we have been able to incorporate a number of your ideas. I’d like to thank everyone involved for their valuable input.
Enforcement has been an area which has generated much scrutiny and discussion in the first few years of the SIA’s operations (‘SIA enforcement: too hard or too soft?’, SMT, May 2007, pp36-38). Again, increasing the confidence of the industry and of our partners in our enforcement and compliance activities is another major priority we have identified in the new Corporate and Business Plan 2007-2008.
Communication and engagement
What I’d like to turn to now is the central issue of communication, and of engagement with the industry, leading individuals and representative groups within it, with strategic partners and key Stakeholders in general.
The SIA has engaged successfully and very effectively (at operational level, through personal contacts and with individual sectors) about specific issues, but you have told us pretty clearly that we have been less successful at a strategic level. Earlier efforts to develop a national Stakeholder Advisory Committee failed. Therefore, and as a matter of urgency, we desperately need to address the gap which has opened up as a result.
The basic challenge we face, however, is the great range and diversity of our Stakeholders across the public and private sectors. Just to give you some idea of how many there are, Government partners for us include the Home Office, the Better Regulation Commission, the Information Commissioner’s Office, the Equal Opportunities Commission, the new Commission for Equalities, the Parliamentary Ombudsman, the Office of Government Commerce, the National Audit Office, the Welsh Assembly, the Scottish Executive and many other Government departments besides.
Let’s not forget the 43 territorial police forces in England and Wales, the eight Scottish forces and, of course, the British Transport Police. Then there are the various criminal justice agencies, awarding bodies, a bewildering range of Trade Associations representing the private security industry, wider business and commercial concerns and those individuals who run companies both large and small.
We cannot set up one strategic body which effectively represents such a large and diverse range of private and public sector interests. One reason is that to do so well would be to create a body which would inevitably become too large and unwieldy.
A second – and equally compelling – reason for not going down this road is that on different issues we need to engage with groups and individuals for a variety of reasons and in dissimilar ways. We will want to monitor the views of some organisations and Government departments. In other cases, we may just want to inform groups and Trade Associations of what it is that we are doing.
Engagement will mean different levels of communicating and consulting. It could mean setting up real or virtual networks in some areas to enable diverse interests and individuals to contribute to SIA policy making. Alternatively, it could mean the establishment of Think Tanks. It will certainly entail working with you, and using the vast knowledge and experience within the industry.
Modern, efficient, collaborative
How we consult – and with whom we do so – has to be shaped by our aims and objectives. We aim to be a modern, efficient and collaborative Regulator, working with the private security industry and conscientiously balancing the public purpose of regulation with its commercial implications.
Our wider vision is not just for the SIA to be a model of good regulation, and to be internationally recognised as a major contributor to the quality and effectiveness of the industry, but also to help to reduce crime, disorder and the fear of crime by driving up standards in the industry, enhancing public confidence and promoting a range of opportunities for expanding public-private sector collaboration on security matters.
That vision must shape how we engage and consult. We want to learn even more than we have from Stakeholders and listen to their views, and to improve our policy and planning processes. We want to ensure that we understand the business and commercial environment, market developments and new strategic opportunities, but equally that those who operate in the industry understand the concerns and agendas of the public sector. We want to continue the excellent work carried out to date with our partners, to pool resources in solving problems and achieve joint objectives. We are also keen on collaborating to exploit opportunities and implement change.
Compliance and enforcement activity
First of all, we need to challenge what is perceived to be our lack of engagement with some specific sectors, and the view that our engagement activity is targeted pretty well exclusively at the major players in the manned guarding sector (with little attention paid to small operators and non-BSIA companies).
We want to make the point, loudly and clearly, that this is not the case. It is our priority to encourage smaller businesses and specific sectors to engage with us. We want to work with them and help them to establish and develop networks, both real and virtual, that help canvas their views.
Incidentally, of the current 354 Approved Contractors, 107 of them (in other words 31%) are ‘micro’ or small companies with up to 25 employees. However, only 58 ACS concerns (16%) are listed as large companies.
Second, we recognise the need to overcome perceptions that compliance and enforcement activity is inadequate or unfairly prioritised. There’s now a level playing field on which there is no such thing as respectable offending.
Another priority for us is consultation about the potential for prolonged delay to the licensing of security consultants. We have already written to those who have previously expressed an interest in this subject in order to canvass their views on our proposal.
Subject to that consultation raising no significant issues that have previously been overlooked, we will recommend to the Government minister that consideration of the sector be delayed until 2010.
Similarly, we agree that further consultation concerning the desirability for licensing in-house security officers is necessary. We are planning to host a Think Tank to discuss this issue with various interested parties.
We agree that we should review the possibilities for further licence integration, and that we should try to resolve any remaining confusion about the licensing of Public Space Surveillance (CCTV) operatives. We will undertake a paper-based consultation exercise on licence integration, and seek advice from key Stakeholders on resolving confusion about Public Space Surveillance (CCTV) licensing.
A further issue that has been raised with us relates to reported malpractices in respect of training/qualifications. The majority of allegations were, in fact, unsubstantiated, but where a malpractice was confirmed there was co-operation from the awarding bodies and qualification regulatory authorities in sharing information. There was resolution, particularly where licence decisions were affected.
We accept there is a need to challenge perceptions that training malpractice is rife and not adequately dealt with, and will ensure that we communicate effectively with the relevant awarding bodies. We’ll continue to build on our strong partnership with Skills for Security to ensure that there is much rigour in the management of training subcontracting.
On a positive note, we agree that there is a need to revisit arrangements for providing feedback to information gatherers and ‘whistle blowers’ so that they will feel it worthwhile to continue engaging with us.
We will consult with police partners to learn lessons from them about ways to give updates to our sources of information, and to maintain a good, solid flow of intelligence coming to us.
I hope you will feel that we have been listening very hard to what the industry and you, our partners, have been saying over the past few months. I know that some of you have expressed a wish for the establishment of a national Stakeholder Panel through which to resume a constructive strategic dialogue with the SIA. We want to try a range of alternative strategies for consultation and engagement, and we most certainly don’t want to rule anything out if it could be useful in achieving our common aims.
We are also considering holding a number of consultation events around the country later this year to enable us to meet a wider cross-section of the industry, and to hear what you have to tell us about your experiences of regulation and possible future developments.
In addition, I have asked the Home Office whether it would be possible to expand the Board of the SIA to include a place for an individual who has significant experience in the private security industry (or at the very least has extensive knowledge about it).
Challenges yet to be faced
There is still a lot of work to be done, and many challenges to be faced – but widespread agreement on what we all need to do now. That is to facilitate CPD in the industry, encourage the security sector to expand and to develop more professional services and, most importantly, to continue our joint contribution towards public protection.
We all have a challenging but exciting future ahead of us, and I look forward to leading the SIA over its next three years of development.