Secured by Design – the only choice

Invited to open proceedings at the Association of Security Consultants’ (ASC) Consec 2005 Conference (held once again at the Metropolitan Police Sports and Social Club in Bushey, Hertfordshire) by chair Patrick Somerville QPM, former Lincolnshire Police chief constable Richard Childs – now chief executive of the Confederation of the British Security Industry – provided delegates with a typically challenging and controversial prelude to one of the event’s two major themes, namely the regulation of security consultants.

Speaking in his capacity as managing director of ACPO CPI’s Secured by Design initiative, Childs split his Keynote Address between this topic and the conference’s other agenda item, that of crime prevention and security measures in the design of new developments. However, it was Childs’ comments on the proposed licensing of both consultants and other sectors that drew most attention.

‘Not on message’ subjects

In his typically forthright style, Childs warned the Consec 2005 audience from the outset that he might upset the apple cart with his comments, before moving on to call for a thorough and independent review of licensing progress to date.

“My view is that the world, and the industry, do not look the same as they did four years ago [when the Private Security Industry Act was published], and to assume that regulatory methods designed for the industry then are still fit for purpose now is to also assume that my dinner jacket currently fits me in the same way it did at that time.”

Childs continued: “However, such a view is regarded as heresy. Nobody seems willing to stand up and ask this type of question about the scale and direction of future licensing. My feeling is that the ‘cabal’ responsible for running the strategic direction of the security industry prevents anyone from mentioning these kinds of ‘not on message’ subjects.”

Having raised the polemical temperature of the conference considerably, Childs was then quick to add that he is not against the scope of licensing enacted to date. Indeed, he stated that he had favoured its introduction for door supervisors, wheel clampers and security officers. That said, in the light of experience gained so far, in terms of the cost and volume of work involved Childs called for an examination of the potential net gain from both future regulation of further sectors and the extension of existing licensing.

Explaining the motives for raising his head above the parapet, Childs duly lamented a general lack of debate or discussion about where regulation will be applied next. He cited the role of the Better Regulation Task Force (which will become the Better Regulation Commission from 1 January, an independent advisory body sponsored by the Cabinet Office) and its aim of reducing unnecessary regulatory and administrative burdens on business while ensuring that regulation and its enforcement are proportionate, accountable, consistent, transparent and targeted.

“These are not words I suggest the Security Industry Authority (SIA) would understand. In a sense it’s about putting a brake on initiatives and bureaucracy dreamed up by civil servants looking for work that, while it may once have seemed a good idea, has perhaps been overtaken by time and events.”

Proportionate regulators, Childs added, should only intervene when necessary. Accountable regulators must be able to justify their decisions, he argued, and be subject to public scrutiny.

“These aren’t my words, but those of the Better Regulation Commission. That being the case, before the SIA commences any further work on extending regulation in the security industry, it should compare and contrast what it intends to do to see if that’s in accord with these principles. If not, well then further regulation is nothing if not illegitimate.”

As an observer, one has to say that, in the way the SIA operates in those parts of the security industry it has already licensed, it does appear to be introducing arrangements which will lead to it almost running the very minutiae of the industry rather than regulating it. That would be a fundamental error. In short, it’s not what regulation is about

Ricahrd Childs, Chief Executive, Confederation of the British Security Industry and MD of ACPO CPI Secured by Design

The best way forward?

Turning to the upcoming extension of licensing to the work of security consultants and private investigators, Childs recalled his own police career. “When representing ACPO, I don’t remember there being a serious concern over criminals infiltrating the ranks of security consultants or investigators,” he remarked. “And neither was there a worry that most individuals within both groups were unprofessional or criminal.

“Whether investigators or consultants give good value for money is most definitely not what regulation should be about,” said Childs. “As an observer, one has to say that, in the way the SIA operates in those parts of the security industry it has already licensed, it does appear to be introducing arrangements which will lead to it almost running the very minutiae of the industry rather than regulating it. That would be a fundamental error. In short, it’s not what regulation is about.”

Continuing his discourse, Childs added: “I’m not suggesting there shouldn’t be a proper, professional underpinning of what consultants or investigators do, but licensing is not the only way to ensure they behave impeccably. Should regulation of these sectors proceed along the same lines as that for wheel clampers, door supervisors and contract security officers? Is this the best way forward?”

Childs then moved on to further explain his call for a review of actions to date, urging an independent examination of what he described as ‘the need and the process’. “Just because the Private Security Industry Act 2001 allows it doesn’t mean it must happen. I have yet to hear the fundamental question that should be top of the list – that is to say: Why? It’s time the industry itself became more assertive and stopped trying to just comply with whatever the SIA proposes. It should think more deeply over whether regulation is still relevant before spending more of its money trying to do something that’s potentially unnecessary.”

Concluding his remarks on this issue, Childs attempted to rally united support to demand that this type of review is undertaken. The timing of Peter Hermitage’s resignation as SIA chairman (see News Update, p6), he added, presents an opportunity to seize the bull by the horns. “I don’t believe there should be a Regulatory Impact Assessment in relation to security consultants. That’s something carried out by the Regulator to justify what it wants to do. Rather, we need a review genuinely looking at the issues. Without it, I fear the industry will be sacrificed at the altar of mindless, mechanistic and unchecked regulation over an expensive and unnecessary bureaucracy. The industry is at risk of being forced to dance to the tune of a few vested interests which currently wield the power.”

Professionalism is key

Richard Childs’ provocative comments were later met with a calm but strong riposte from outgoing SIA chairman Peter Hermitage. At first, Hermitage sought to quell potential rumours surrounding his decision to stand down from the Authority.

“My decision to leave the SIA is a very simple one. I want to do some other things in life. It does not signify a massive about-turn in the SIA’s processes or strategy.”

Having laid that topic to rest, Hermitage moved on to explain some aspects of the Approved Contractor Scheme’s methodology.

In truth, there are 1,001 ways for security consultants to gain the knowledge and develop the necessary skills and experience they need to fulfil their roles, ranging from on-the-job training to CPD

Kevern Oliver, competancy consultantant, SIA

The SIA decided to tackle particular sectors first – rather than companies – and did so in consultation with the industry, he said. The SIA produced profiles of the activities involved in these sectors and the competencies required, and then set the licensing criteria around these competencies. Regulatory Impact Assessments were then produced.

A good deal of work remains to be done in terms of how such a scheme would apply to security consultants, Hermitage added. In turn, consultants’ comments on this are now warmly welcomed.

Latest news on licensing

Following Peter Hermitage onto the stage were two of his newer colleagues, starting with Alison Wellens, the recently-appointed development manager for special projects. Providing the Consec audience with a review of progress to date on the timetabled regulation of security consultants, Wellens explained that a Regulatory Impact Assessment would be published in mid-February 2006 and managed by the Home Office. This process will provide a framework of options for licensing, with stakeholder responses then invited over a three-month consultation period.

Following this, the Home Office will act on the preferred approach, which in theory could include taking no action to regulate this sector of the industry.

Wellens was followed by the SIA’s dedicated competency consultant, Kevern Oliver. Oliver offered some salient feedback on the experience of 45 delegates who attended a one-day workshop in Glasgow and two two-day workshops in London last July.

These delegates were drawn from a representative sample of practitioners, including sole traders, small and large companies and agencies in addition to education and training providers.

“We wanted to know the issues, ideas and concerns of consultants over the introduction of licensing, and the sector’s view of what a competent security consultant is. So far, this is the first report back to the SIA on what the problems might be and, as such, it provides a fascinating insight,” revealed Oliver.

The Security Industry Authority workshops’ agenda looked at what makes a good security consultant, and how they obtain formal recognition of their professionalism. Apprehensions were raised on topics ranging from the subject of ‘scope’ (who’s in and who’s out?), the policing of the sector once licensing is in place, what benefits licensing of the sector would bring to the industry, the impact on international operations and the need to take into account practitioners’ wide range of already acquired knowledge, understanding and expertise.

Value and meaning

What we are talking about is putting a brake on initiatives and bureaucracy dreamed up by civil servants looking for some kind of project work that, while it may once have seemed a good idea, has perhaps been overtaken by time and events

Richard Cilds, chief executive, Confederation Of The British Security Industry and managing director of ACPO CPI’S Secured by Design Initiave

As consultants work in a wide range of areas, there is also a concern that a ‘one size fits all’ approach could lead to a ‘lowest common denominator’ result with little value or meaning. Indeed, this is one of the topics that Ian Johnson of Ian Johnson Associates [recently elected as the first chairman of the BSIA’s new Security Consultancies Section] raised earlier in the year. Writing in the 2005-2006 edition of the BSIA’s Security Direct directory, Johnson asks: “Our skills cross so many subject areas. How will competencies be benchmarked for work such as corporate investigation services?”

Responding to some of these questions at Consec, Kevern Oliver remarked that the SIA is aware of differences between this sector and those already being licensed. For example, consultancy is a highly professionalised occupation and practitioners usually bring a range of expertise and backgrounds with them from previous roles.

“However,” added Oliver, “one question I’ve been asked concerns the potential conundrum where, if we have licensing and set standards, we are in a loop wherein one cannot gain the experience without a licence, but you cannot obtain the licence without experience. There was also a recognition among those attending the workshops that there are only limited learning and development opportunities for newcomers.”

Competency requirements

The SIA’s current working definition of competence is defined as ‘performance over time – to an agreed standard – in the workplace, consisting of: knowledge and understanding, specific skills, generic skills and experience.’ Feedback from the workshops suggests that a variety of sector-specific expertise is a ‘must have’ for competent security consultants.

While the SIA will define the competency requirements for licensing, it is only seeking to identify what Oliver called the ‘core’ of competence (ie the fundamentals appropriate for licensing). The specification of all aspects of an operative’s competence is the role of those developing the National Occupational Standards for this sector – a task currently being overseen by Alan Martin, head of standards development at SITO.

In terms of specific skills, the present working template involves risk assessment, management and control along with knowledge, understanding and the application of civil and criminal law, regulations and standards. Relevant technical and operational skills are also fundamental pieces in the jigsaw.

Moving on to generic skills, the draft list comprises communication and interpersonal skills, ethical business management techniques and high level problem solving.

Questionnaires were sent out late last month to representative associations, institutions, trade and public bodies, education and training providers with a view to inviting feedback.

Copies are available as downloads direct from the SIA’s website at www.the-sia.org.uk