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SIA Stakeholder Conference 2009: State of the Nation

22 May 09

Following vice-chairman Robin Dahlberg’s welcome, the SIA’s chairman Baroness Ruth Henig began yesterday’s 2009 SIA Stakeholder Conference with a forceful and detailed Keynote Address.

By Baroness Ruth Henig

In beginning today’s proceedings, let me first of all say that I’m delighted so many of our Stakeholders, partners, security suppliers and buyers are present here in Manchester for our annual Stakeholder Conference entitled ‘The SIA Journey: Have We Gone Far Enough?’

We’re approaching the halfway mark of what has thus far been both a busy and extremely eventful year. It’s our intention that this conference should track the Security Industry Authority’s (SIA) journey to date, reviewing both the obstacles and successes and then look towards the future. We need to consider the challenges and goals that lie ahead for us all.

The SIA isn’t a lone traveller on the road to higher standards. At this time, there doesn’t seem to be a commonly shared view as to the relative roles of the Regulator and the industry when it comes to raising standards. I very much hope we can arrive at a common agreement in due course.

While of course it’s no secret that we’ve had our fair share of problems in the past, I firmly believe that in the first five months of this year we’ve made huge leaps forward. We’ve seen our organisation stabilise and strengthen on a significant scale. The processing times for licensing have improved, and we’re now running smoothly as an effective, proportionate Regulator.

We’re not complacent, and although much has already been done, we’ll continue to work hard on improving services for our Stakeholders.

Improvements to customer services

There have been considerable improvements made to customer services in recent times by dint of us enhancing our licence application process. Last month, 90% of all properly completed licence applications were processed within 40 working days. 93% of those applications received from UK and European Economic Area (EEA) nationals were processed within 33 working days.

Our database management system and our Call Centre response times have also been improved. We receive around 42,000 calls each month. During April, for example, 93% of those calls were answered within 30 seconds.

In addition, as many of you will know, last year we were subject to several reviews – a delivery review, the Hampton review, a National Audit Office report and an organisational structure review. The end result was clear objectives for the year ahead, and an organisational restructure that has promoted efficiency and effectiveness in equal measure.

In the primary area of our work, in other words licensing, we have already responded to a 35% increase in applications. We continue to fine-tune the licensing process. Having duly met our target of dealing with 80% of applications within 33 days, we’ve now increased that target figure to 85%.

We’ve been working closely with our Contact Centre to improve waiting times and the quality of service, and we shall be increasing our telephone response time target to 95% of all calls answered within that 30-second window.

We plan to achieve this by focusing on efficiencies and their improvement, while at the same time keeping fee levels static for this coming financial year. On top of that, we’re currently looking at ways in which we might improve our online facilities, and implement the online licence application procedure.

To better address customer service improvements, we’ve set up a dedicated Customer Experience Forum. This will help us to understand Stakeholder needs, and to improve the level and quality of contact between the two parties. The first meeting has already taken place, and now we can focus on working together to improve the SIA customer experience.

The Approved Contractor Scheme

In terms of the Approved Contractor Scheme (ACS), we have exceeded our forecast for the number of approved companies. There are now more than 600 companies approved, covering all licensable sectors. There are firms of all sizes in the scheme, from sole contractors through to large, multinational companies.

More than 95% of ACS companies re-registered during 2008 – with the annual registration fee remaining unchanged – and over 150 companies applied for approval for the first time. These high levels of registration show just how much the scheme is valued by security contractors and their customers alike.

I know the ACS is a much-debated issue, and we need to look at ways in which we can all contribute towards further developing the scheme.

In everything that we do, we need to know and understand two things – what’s important to Stakeholders, and what is the impact regulation has on the industry. We need to hear peoples’ views about us so that we can respond to Stakeholders’ concerns or expectations, and encourage open channels of communication.

Last year, we undertook a review of our Stakeholder Engagement Strategy, affording the opportunity for those who wished to make an input to be involved with the decision-making processes. Our approach is very much one of working with the industry and Stakeholders in the wider environment.

We welcome external input in order to push improvements in the development of our policy, planning and process. Our successful, self-perpetuating network meetings and the ACS Forums also provide opportunities for you to engage with us on a face-to-face basis.

Benefits to be derived from collaboration

There are many benefits to be derived from working collaboratively with the industry. By listening to those who have vast experience in the security sector, we can take advantage of this knowledge and harness it to help us better assess and manage risks and, in turn, develop regulation. We can also better understand the business environment and developments in the market.

In essence, working closely with Stakeholders allows us to collectively pool resources, solve problems, implement necessary change and reach our objectives.

We actively engage with the industry in a number of ways. I hold regular strategic level meetings with key Stakeholders in order to communicate our messages and gain feedback. We consult widely, calling for views on major decisions and policy making.

In addition, we measure and assess the impact of SIA activities on various sectors of the private security industry. At an operational level, there are also many meetings with industry representatives, Government bodies, industry and trade associations, so too our enforcement partners such as the police and local authorities.

Mention of our enforcement partners leads me to another crucial element of our work. The SIA regulates the private security industry to ensure that only fit and proper people are employed in positions of trust within our communities. For SIA licensing to be trusted by members of the public, and for it to work well, it’s vital that we have an effective compliance and enforcement strategy in place.

Let me be clear. We understand that you in the industry, who take pride in your businesses, ensure high standards and meet the Terms and Conditions of regulation need to know – and see – that we’re taking action against those who don’t comply with the law.

We expect compliance with licensing requirements at all times. Our starting point is to try and help organisations and individuals meet their legal obligations. We take an intelligence-led approach to compliance, working with partners to enforce and, where necessary, prosecute offenders. Our approach strives to balance the needs of the industry and business with public protection.

Ultimately, we need to know that the use of our enforcement powers is appropriate – making sure our actions are risk-based, proportionate and targeted.

Intelligence is a vital factor

In all of this, we are intelligence-led. Any information we might receive is carefully analysed, such that we can monitor trends and maximise the impact of our enforcement activity by targeting those areas at greatest risk of non-compliance, and where the public is put at risk.

Next year, we plan to make preparations to ensure that we benefit from having the power to impose further sanctions – such as fines and penalties – which fall short of prosecution. Our ability to do so is provided by the Regulatory Enforcement Sanctions Act 2008.

As I’m sure you will be aware, we provide monthly online updates on the actions we have taken and on key regulatory activity. By way of an example, in March we received 970 pieces of intelligence sent to us by members of the public and the industry. The information was filtered through our partner Crimestoppers, the police and other law enforcement agencies.

In that month alone, this information allowed us to revoke 26 licences, suspend 55 and risk assess 58 security companies – 29 of which were judged to be of high or medium risk, and were duly highlighted to members of our compliance and investigation team.

We also shared 78 key pieces of information and intelligence with our law enforcement partners in order to reduce crime, disorder and the fear of crime on a wider scale. Last year, we issued 331 written warnings and 19 improvement notices, at the same time revoking 3,618 licences.

Compliance and enforcement issues

At the SIA, we’ve developed strong relationships with the Home Office and other Government departments, local authorities and police forces – as well as those bodies that represent them, the UK Border Agency and the Serious Organised Crime Agency. We’ve continually worked with these types of bodies to ensure that the success of our investigations is maximised.

Together with the police and local Government licensing officers, SIA investigators visit towns throughout Britain each and every week to carry out targeted or random checks measuring compliance with the law. We determine whether or not security operatives – door supervisors, officers and vehicle immobilisers – are working within the licensing rules.

Less visibly, last year we dealt directly with 300 security businesses that we’d assessed as being high risk in terms of compliance. This included 160 security guarding businesses and 86 door supervisor companies.

While we will help businesses where appropriate, we’ll also prosecute if necessary. We have 26 prosecution cases involving over 200 offences either completed or going through the Courts. Some of those cases, of course, have been afforded a high profile. Our right to prosecute was challenged in the High Court last year, but the Court came down firmly in our favour.

As has been widely reported on SMT Online and by info4security, we were recently involved in the largest operation ever mounted in Scotland to tackle rogue security companies. SIA investigators joined officers from the Strathclyde and Lothian and Borders police services, the UK Border Agency and the Department of Work and Pensions to target rogue security firms working at construction sites across mid-Scotland.

We pooled intelligence to tackle companies that were believed to have links with serious and organised crime, targeting 120 security staff at more than 200 construction sites operated by 37 different security companies.

The operation was a huge success, with 23 individuals reported for working without an SIA licence, one manager reported for deploying unlicensed operatives, four operatives reported for failing to display their SIA licence and others reported due to benefit irregularities, immigration issues, fraud and drug-related offences.

To my mind, the scale of this operation shows the commitment of the SIA and our partners to target those who disregard the law.

The future of private sector regulation

The past two years have witnessed considerable change for the SIA. We’ve seen a significant increase in licence applications. We’ve stabilised the processing of Right To Work checks for applicants from outside the European Economic Area. The ACS now covers around 60% of all those employed by the private security industry.

There have been major convictions which, in turn, have sent a strong and positive message that we will take decisive action against those that flout the law.

We have also reviewed the ways in which extending our remit could further contribute to public protection. Indeed, we are in the process of introducing regulation to Northern Ireland, thereby ensuring that standards of training and professionalism are the same across the whole of the United Kingdom. Applications are now being accepted from individuals working in the private security industry in Northern Ireland to gain their licences, and from security providers wishing to apply for the ACS.

In addition, we’ve also begun the planning process to regulate enforcement agents – or bailiffs, as they’re more commonly known – and licence private investigators. Subject to Government go-ahead, we anticipate that the licensing of both parties will be in place come 2012.

We are currently revamping the core competency framework for qualifications, and will be making a formal announcement on this during the summer.

Introducing compulsory business licensing

Subject to the current Home Office consultation, we’ll develop plans to introduce compulsory business licensing. We’ll start with the vehicle immobilisers. I believe this will enhance our regulatory impact.

We are also considering how best to improve and develop the ACS, and will carry out work this year to consider whether there’s scope for recognising differing levels of excellence within the scheme – a matter on which I know many of our Stakeholders hold strong views.

Most recently, we’ve announced that after a solid review of the arguments and evidence put forward to us in relation to the licensing of in-house personnel, further regulation will not be introduced in this area. While I know that there are some in the industry who have called strongly for the introduction of regulation across the security industry as a whole, we were not presented with substantiated evidence of any risk to the public that would justify its introduction.

We have published the full findings of the report so that we are open and transparent. We’ve clearly shown the rationale for the decision that has been taken, and have requested that anyone wishing to comment should contact us. We’ll revisit the matter in three years’ time, and evaluate whether or not the arguments and evidence remain unchanged.

If you feel strongly about this issue, please make sure that you pass on to us concrete evidence about risks and problems that you’ve seen arising from the current situation which we can then feed into the review.

Service cost versus service level

Another area in which there is great interest is, of course, the matter of the licence fee. The main issue here is the competing priorities of service cost against customer service levels. This is certainly a debate that will need to be had with members of the security industry so that views can be gauged.

Over the coming year we plan to consider this matter in some depth. The bottom line is whether customers wish to pay more for an exemplary level of service from the licensing system, and also whether or not the fee should fund higher levels of enforcement activity?

Operationally, there are several priorities for the year that will allow us to perform more efficiently. We have started the planning for re-tendering the outsourced Contact Centre service and, if we do change to a new provider, we’ll need to ensure this is done without negatively affecting service levels. We’re building capacity to deliver a more consistent level of service, and to improve performance across the licensing process.

We’re fully committed to developing staff members’ skills such that they attain higher levels of customer service abilities and professionalism.

On another note, we’ll manage the change programme to extend to new regions and sectors subject to impact assessments and Parliamentary approval (such as business licensing, enforcement agents, private investigations/pre-cognition agents and Northern Ireland).

Importantly, we will also maintain and develop our network of compliance and enforcement partnerships in order to build further on recent successes.

Towards reading the future

Looking to the future, it’s imperative that we’re able to respond to a changing security industry, and try to predict challenges such as the implications of the present economic situation or key events like the 2012 Olympic Games or the 2014 Commonwealth Games in Glasgow.

We’re currently developing our Corporate and Business Plan for the next three years. That will be published along with the Annual Report later on this year. The Corporate Plan will set out how we intend to deliver our mission to be an effective, fair and efficient Regulator. This acknowledges various challenges and operational risks to which we may be exposed in that time.

It’s evident to us that most of the regulated private security industry now complies with the Private Security Industry Act 2001. A key challenge for us is how to develop communications channels such that we reach all of our Stakeholders – because, as I’ve already outlined, an open debate with the Stakeholders is essential to enable us to perform strongly.

Another big challenge for the near future will be the aforementioned Olympic Games. Over the past year, we have been raising awareness of our role with key Olympic Stakeholders in order to minimise the risk of non-compliance with regulation both before and during the Games. We’re also considering initiatives to support heightened demand for security industry services prior to and during the Games.

Going forward, we will most certainly be making a contribution to the Home Office’s Olympic Security Programme, at the same time working with the London Organising Committee.

Backdrop of the downturn

Any challenges or changes in the industry are set against the backdrop of the current economic downturn. There’s a possible causal link between the financial climate and an increased risk of criminality. We recognise the potential for increased demand for private security industry services, and the potential subsequent increase in licence applications.

To prepare for this eventuality, we have implemented a more robust process for forecasting demand, and have expanded flexible staffing to deal with potential surges in licence application demand while also striving to keep additional costs to a minimum.

We shall continue to work and share information with agencies like the UK Border Agency to improve the quality and timeliness of criminal record checks and Right To Work information. We are also keeping track of work by such agencies to implement new technologies.

On that note, there are developing technologies – for example biometrics – that could help us to fulfil our public protection agenda, in addition to improving efficiencies and customer service.

Our efforts to improve our service to customers and deliver value for money have largely focused on improving the service from our outsourced Contact Centre. We have recently made a range of changes and implemented increased capacity to accommodate rising levels of information, upgraded our IT systems to improve performance and made enhancements to the way in which we monitor capacity and, therefore, deal with the increased volume of licensing applications.

Our contract with the current service provider is due to expire next year, so we have necessarily begun the process of procuring a new supplier so that we can continue to provide value for money and offer services that meet the needs of the industry.

Committed to reducing red tape

Might I also say that we are completely committed to the Government’s target of reducing red tape by 25% come 2010. As part of our ongoing improvement in this area, we plan to introduce an online licence application process.

We welcome the ongoing challenges to ensure that we keep the impact of regulation on the industry proportionate as we extend regulation to new sectors. In our approach, we’ll continue to be targeted, risk-based and proportionate and, going forward, will further enhance work with compliance and law enforcement partners to multiply our capabilities.

Our enforcement activity will continue to be focused on those areas where there’s the greatest potential for non-compliance and risk to the public. In doing this, we shall continue to remain open and transparent, consulting with you as our Stakeholders to seek your input, support and knowledge of the industry.

We achieve the most when we work together, and truly understand each other’s aims and objectives. We also need to fully understand each other’s roles in raising standards.

During the coming year, given the uncertainty in the economy it’s now more important than ever to maintain close relationships and harbour effective and open channels of communication.

We cannot always agree, and we at the SIA cannot promise to achieve all of our goals all of the time, but having met so many of you across the industry I’m confident that you’ll continue to make sure we work effectively with you to deliver public protection and improve the quality of private security provision.