SMT Online Editor's View: Raising the ACS bar

27 May 09

Last Thursday’s Security Industry Authority (SIA) Stakeholder Conference in Manchester was an interesting, lively and timely affair.

I’ve already edited and reproduced some of the speeches on SMT Online, and there’ll be more to follow (including excellent presentations courtesy of Peter D’Arcy, who compared regulation in Abu Dhabi with that in our own nation, and Graeme McCabe speaking on behalf of the Home Office’s Better Regulation Team).

In what is now becoming a tried-and-tested format for this type of occasion, the Regulator chose to mix keynote presentations with break-out sessions on numerous topics – one of them being the Approved Contractor Scheme (ACS) for guarding companies.

Not surprisingly, the ACS session beginning at 11.20 am was the most popular of those organised on the day (the others concentrating on the Regulator’s strategy and approach to communication and customer services, and an overarching threat and opportunity assessment in relation to the future of the private security industry).

Before each group of Stakeholders on respective tables was tasked with debating certain issues relating to the ACS (more of which anon), there was a necessary – and pretty detailed – dose of scene-setting courtesy of the ACS’ assistant director Andrew Shephard.

Are guarding standards improving?

Are standards really improving in the security guarding sector – and specifically in terms of service delivery – as a result of the ACS?

We were shown a graph by Shephard detailing the responses of 172 buyers of security services. 52% of them had said: “Yes, the SIA Approved Contractors do exhibit higher standards.”

It’s always nice to support figures with anecdotes. Client references, if you like. The SIA duly did so. Some of the comments from buyers included: “Approved companies have quality systems in place, and show a willingness to improve”... “Service delivery standards are way in advance of those demonstrated by non-Approved Contractors”... “The staff are better trained and vetted”. You get the picture.

For their part, 125 ACS companies surveyed this year suggested that standards within their organisations are now higher than was the case pre-scheme.

The National Audit Office report of 2008 states in no uncertain terms: “The Approved Contractor Scheme is a success”, while the Office of Government Commerce report in that same year outlined: “...there is emerging evidence that the ACS is improving standards across the industry...”

As of today, there are 615 companies listed on the Regulator’s official Register of Approved Contractors. “Every time we approve another company, it represents one more that has had to meet the standards we’ve set,” said Andrew Shephard in Manchester. “That must mean standards are gradually being raised across the industry.” 150 companies have joined the Register in the past 12 months alone.

Shephard embellished his theory by reminding us all of the fact that 35 of the 89 indicators marked against in order for companies to join the fold have been enhanced over the past 12 months. In other words, requirements have been raised across one third of all basic indicators.

No more changes planned for 2010

“We’ll need time for these adjustments to settle down,” opined Shephard. “On that basis there are no more changes scheduled for 2010, but we do want to show you all that the ACS is a fluid proposition. It hasn’t simply stood still since its inception.”

Continuing the statistical nature of his presentation, the SIA’s ACS guru unveiled a chart showing that 750-plus complaints against Approved Contractors have thus far been examined, and 25 SIA-enforced company withdrawals have taken place (three of them during this financial year).

That’s the back story, then. Not a great deal there you didn’t already know or suspect, I would suggest, but some of the detail is well worth bearing in mind for the latter part of my discourse.

Taking to the lectern, Robert Dye – the ACS’ development manager seconded to High Holborn from Conformity Solutions – outlined some of the things that have been/are now being done to enhance the ACS.

These include a new assessor strategy (to boost the consistency of assessment) and an ongoing study to determine whether or not further differentiation within the ACS would be appropriate and/or necessary.

According to Dye, there wasn’t – and still isn’t – an issue when it comes to the consistency of company assessments, nor the quality and competency of the assessors. “However, we did need to know,” he stressed, “if the current strategy is delivering Best Practice on behalf of – and for – the Regulator.”

12 recommendations before the Board

Following the assessor/assessment strategy review, no less than 12 recommendations were made to the SIA Board. Among them a stated desire to reduce the number of assessment bodies to four and the overall number of assessors involved with the scheme.

There’s also a requirement for those assessors remaining to undertake a pre-determined number of assessments on a quarterly basis.

“A number of assessors were not having frequent enough contact with the SIA,” explained Dye, “so this last decision was designed to address that particular issue.”

Without wishing to pre-empt any of the findings realised by the differentiation study, I would suggest Dye is right to state that this work has raised a number of interesting questions for the industry to consider.

For example, how can differentiation be achieved in the real world? Is it appropriate for the ACS at all, given its purpose and positioning as a regulatory tool subject to the Hampton principles?

What options are there for differentiation anyway, and which of them would best support not just the ACS itself but also the overall mission and vision of the Regulator?

The results of the study are due to be laid before the SIA’s Board at its next meeting, which just happens to be taking place tomorrow. It’s the Board members who shall decide which – if any – of the differentiation options are to be taken forward.

Inevitably, there’ll need to be further consultation on the implementation of recommended options before anything happens.

Eight options for ACS differentiation

In a nutshell, there are eight options. For informed choice differentiation, the SIA would publish advice on the relationship between the ACS and other approvals/means of certification.

Criteria-based differentiation, meanwhile, would see the Regulator introduce additional levels of approval based on assessment against new criteria.

For performance-based differentiation, the SIA would again bring in additional levels of approval, this time based on the measurement of contractor performance. For the record, that would be my favoured option.

The assessment score method has been debated umpteen times now. The use of existing assessment scores, though, strikes me as being a massive headache for security companies.

End users – particularly the bean counter types in procurement who know little or nothing about security purchasing – will just use those tallies as a brick with which to beat up tendering contractors on price.

Benchmarking differentiation would entail the refinement of the existing assessment scoring approach in order to recognise performance in several different areas, while Beacon Status refers to the SIA recognising “exceptional achievement” by contractors in specific areas.

Assessment-type differentiation could see the Regulator promote the use of alternative assessment processes and, last but not least, company-wide approval would engender the SIA identifying contractors approved for all types of security services provided to the client.

With Shephard and Dye’s joint presentation at an end, Stakeholders at each table in the room formed a sub-discussion group.

Earlier in the day, Andrew had asked me to take on the task of presenting overall findings to the main conference during the afternoon session. I was only too glad to accept, as this sharpened my appetite still further to discover just what’s going on with the ACS.

What can be done to raise standards?

We were asked to consider what actions the SIA might take in relation to the scheme that would do most to raise industry standards over the next five years or so. Also, what ought to be the long-term vision for the ACS?

We were told that, during our deliberations, consideration could be given to new requirements – the financial probity of companies, their employment Terms and Conditions and different training regimes among them.

We also had to look at the differentiation options, the compulsory licensing of companies, those aforementioned changes to the assessment process, public awareness of the ACS – does it need to be raised? – and whether or not there’s an ideal number of companies that ought to underpin the Register?

There were ten tables in the room, each hosting around ten people. A pretty decent sample size, then, with big hitters (Wilson James’ director Stuart Lowden, the SSAIB’s leader Geoff Tate and Tony Imossi, president of the Association of British Investigators) included in the mix.

What, then, were our collective findings? Just about everyone in the room was in favour of some kind of financial probity check being made on companies to confirm their suitability for ACS registration. Participants described this as being “relevant and desirable”.

Too much reliance on process, perhaps?

Initially via his table’s spokesperson Linda Sharpe, and then pretty forcefully on his own, Stuart Lowden made the point that he believes there’s too much reliance on process within the ACS (before suggesting that adherence to process doesn’t necessarily raise standards).

“I have a deep concern that the policing of the ACS is not as rigorous as it could be and ought to be,” said Lowden. “If two companies pitch up at an end user’s premises and they’re both ACS, then as things stand the client may as well buy on price. They will do, particularly given the present financial climate.

“The inspection regime for companies is far too process-driven. That being the case, the situation as things stand can only worsen. In my opinion, we need to make whomever is doing the inspecting a little more streetwise.”

Again, consensus opinion is that public awareness of the ACS is still way below where it needs to be. How to address that? Well, the ACS Forums for contractors run two or three times each year, and a very good suggestion was made to cajole the Regulator into running a similar series of events focused on clients.

Alternatively, the ACS Forums could be organised on the basis that each contractor is allowed to bring a client along as their guest.

Andrew Shephard’s response? “That idea has been broached before, and we’re not against it.” Possibly time for some swift action on that front then, Andrew.

Truthfully, the ACS is but one area for clients to peruse just now. For the most part, end users don’t know what the ACS is all about – despite the fact the SIA has promoted heavily to them by way of its regular Corporate Updates and various other initiatives.

In addition, are the enlightened security clients’ expectations of the scheme realistic?

Aspiring towards The Aspire 100

Talking of other things to occupy the mind, permit me for digressing slightly but one individual in my group – Philip Steele from Cash-in-Transit specialist Brinks – mentioned The Security Watchdog’s latest project.

The Aspire 100 is a brand new initiative designed to offer representation to national, regional and local contract guarding companies who, currently, are not ranked within the Infologue Top 20 (annual turnovers here range from £23 million to £380 million).

With the Top 20 guarding companies controlling in excess of 88% of the total revenues generated in the UK security guarding sector, The Watchdog’s theory is that this leaves the remaining 590 ACS members (and those operating outside the scheme) with only 12% of the UK contract guarding market to pick over.

“The objective in establishing The Aspire 100 alliance is to provide a nurturing platform for calibre organisations outside the Top 20 such that they might collaborate with and support each other in offering the UK’s client base an alternative, quality service option,” explains The Security Watchdog’s chairman Terry O’Neil in an official statement issued on 6 May.

“We also see a role for members to work in harmony with the Top 20 in supporting regional workforces wherever and whenever required.”

Companies qualifying for entry into The Aspire 100 must be ACS members, and also meet at least one of the following criteria: they must be in the upper quartile (top 25%, currently a pass exceeded by at least 39 points) of the ACS benchmarking and achievement levels or have obtained the Gold Standard of the National Security Inspectorate (NSI).

Alternatively, a given company must have committed to a minimum of 36 annual independent on-site audits through the Silver Fox Scheme – also run (and for some time now) by The Security Watchdog.

Members will “significantly benefit from an ongoing publicity campaign” and participation in a number of shared User Forums where they can voice any concerns they might be feeling about the industry – and “provide the collective action needed to effect change”.

The official Watchdog statement ends: “As an alliance, these concerns can be raised directly with the SIA so that the voice of The Aspire 100’s members cannot in the future be ignored.” Food for thought, isn’t it?

From my own perspective, I feel that we need one scheme – the ACS – and one scheme only that’s all-inclusive and acceptable to all. Acceptable in terms of its remit, the way in which it’s administered and enforced and, most important of all, acceptable in terms of its outcomes.

Judging by the comments made last Thursday we’re not quite there yet but, at this crucial juncture, should we start muddying the waters with potential alternatives?

Compulsory licensing of security companies

Anyway, back on track. The compulsory licensing of companies – and, by extension, their directors – is another area upon which everyone in the room concurred. Stakeholders want to see this happen, and fast.

As to whether or not there’s an ideal number of companies that should be within the ACS, well… You’ve read Andrew Shephard’s view of the world. Personally, I think 615 companies and counting is most definitely NOT the way forward.

I hark back to (then) BSIA chief executive David Dickinson’s comments made around the time when the ACS went live. Dickinson was predicting 200 or so companies of better quality would be left after the ‘shakedown’, all of them operating on a level playing field and winning work on the basis of their ACS credentials in tandem with added-value propositions.

What do we have at the moment? With 600-plus companies on board and rising, how on Earth is the client base going to identify the right contractor with which to do business?

That situation can only be made worse by the aforementioned procurement mandarins solely reliant on a ‘tick box’ approach to buying based on – at best – scant security knowledge.

In turn, much security guarding provision continues to be bought on the cheap. This begets the continuation of low pay for the rank and file, lower grade Terms and Conditions of employment, excessive working hours and just about everything else that any right-minded security practitioner wishes to see eradicated.

Like it or not, the Regulator must recognise that the ACS standard is perceived by many as being far too weak. It still doesn’t include any of the recognised British Standards.

Aside from the opportunity to deploy staff under the Licence Dispensation Notice – how well that little variable is being policed was another area that cropped up in discussions last Thursday – there appears to be scant reward for becoming an Approved Contractor.

Greater clarity demanded for assessment

All of us agreed that there needs to be greater clarity within the ACS assessment procedure.

One group of participants suggested that it should change and develop as a security company develops, in much the same way that a tracker mortgage ‘morphs’ in line with the Bank of England base rate. Not a bad idea at all.

When the subject of new requirements for training was mentioned – and bespoke recognition for training carried out by companies for themselves and individuals could certainly be set within the ACS framework – I immediately began to dwell on the Scandinavian model.

That’s what we should be aiming for, but there are luddites in this country still moaning about the extra day being added to Basic Job Training. With thinking like that we’re never going to make any progress.

Four days is the absolute bare minimum. We need to be reaching much, much further than that. You cannot possibly teach conflict resolution properly in one day in any case. NVQs and Continuing Professional Development could and should become part of the overall mix.

Interestingly, there was a stated desire for the ACS to interact more with the insurance community. I’ve always suggested that said community could do far more to raise standards among security clients, but perhaps it’s not all their fault.

Speaking during the late afternoon wash-up session, Dan Hooton – group head of security with the Prudential – ventured that he’d not received any communication on the ACS in the three-and-a-half years he has been with the company.

The differentiation options – and this issue as a whole – undoubtedly caused the biggest stir. The scoring system is perceived not to engender a level playing field.

Geoff Tate opined: “The ACS covers both small and big companies. Is it really possible to have a one-size-fits-all solution here?” A good point succinctly made.

Taking the bull by the horns

What I would say – and have said on numerous occasions – is that it’s up to the industry to drive standards here. The SIA is beholden to provide a framework and plot a course, but the industry – in the form of companies and their clients – must take the bull by the horns.

For it is they who need to assume responsibility for the guarding sector’s growth and prosperity. They who must commit themselves to raising standards within their own company infrastructures, improving staff welfare and constantly reviewing service delivery such that it’s at the very best level it can possibly be.

On that note, why do we still have guarding company leaders carping on about what the SIA is (or isn’t) doing to raise levels of service?

Let me gently remind them that the SIA’s key role in all of this is to ensure minimum compliance in line with Home Office decisions and expectations. It’s not the Regulator’s task to do the contractors’ job for them, nor has it ever been.

It’s high time the guarding sector and its client base assumed overall and clear responsibility for the future of guarding. That’s what the Regulator wants to see. It’s what we all want to see. So how about it?

Until next time.

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