Consultation outcome

Business approval scheme consultation: feedback executive summary

Updated 11 July 2024

Introduction

About the SIA

The SIA was established under the Private Security Industry Act 2001 (the Act) to contribute to public protection by setting and improving standards for the regulated private security industry in England, Wales, Scotland, and Northern Ireland.

To achieve this the Act stipulates that we have two primary statutory responsibilities: to license individual security operatives and to provide a register for private security businesses.

SIA approval of businesses

We have a duty to ensure that there are arrangements in place for approving businesses that provide security industry services in the UK. We have a register of approved businesses. We set the conditions that must be met to join the register and we approve businesses under those conditions.

The SIA currently approves around 750 security businesses. 85 of the largest of these businesses by turnover account for around 40% of the total UK private security market, employing around 30% of individual SIA licence holders.

Strategic context

The business approval scheme is the main way for the SIA to influence improvements in business standards. It is a voluntary, quality-based scheme through which the SIA promotes good practice and cultivates improvements in industry standards.

In 2023, we considered what changes we could make to our existing Approved Contractor Scheme (ACS) to ensure better public protection outcomes. We refreshed our strategy for approving private security businesses and set out our plan for improving business standards in our SIA Strategic Plan 2023-26.

The consultation

In February we launched a public consultation on the key principles that we propose should underpin our business approval scheme going forward. The consultation document can be found here. The proposed changes would place public protection at the heart of the scheme. This would signal a marked shift in how we approve businesses and how standards are defined for the private security sector.

The consultation sought views on:

• the case for change in principle
• our emerging thinking on changes that we propose to develop further
• whether there are other changes we should consider as we develop the scheme

The consultation closed in April 2024. In accordance with government pre-election rules, publication of the findings was put on hold until after the General Election on 4 July.

We received over 400 responses to the consultation from across the UK. Overall, respondents broadly supported our proposed approach. The responses also provided a great deal of helpful feedback on issues we raised in the consultation. Skills, professional development, training and industry experience were reoccurring themes.

We extend our thanks to everyone who participated. We are now planning to develop detailed designs for the new scheme and will take the feedback we received into account in that work. We will hold another public consultation on the final proposed design of the new scheme. We intend to launch the new scheme during the business year 2026 to 2027.

Summary profiling the responses received

We received responses from across the UK. The highest volume of responses came from Greater London and Southeastern England. The lowest volume of responses came from Northeastern England and Northern Ireland.

A total of 405 people responded to the consultation, 86% of whom are in the private security industry. The majority were ACS approved contractors, with the next largest number being non-ACS private security businesses and then individual licence holders.

The breakdown for the rest of the respondents is:

• 4% - ‘partners or public bodies’
• 3% - ‘members of the public’
• 1% - ‘industry consultants’
• 1% - ‘SIA licence-linked qualification trainers’
• 1% - ‘standards-setting organisations’
• 1% - ‘ACS assessor’
• 3% - ‘any other individuals and groups’

Summary of results

Case for change

We asked whether the new scheme should be focused on public protection outcomes, and what issues and challenges the scheme should prioritise.

The responses we received

78% of respondents agreed that the future scheme should focus on public protection outcomes.

The top themes respondents felt the scheme should prioritise were:

• compliance - with SIA and HMRC rules, rules on working conditions, including welfare and pay (16%)
• skills - in particular more training for frontline employees to increase capability (13%)
• labour and subcontracting - with the emphasis on adherence to HMRC guidelines (11%)

22% wanted a focus on reassuring the public about safety: the capability of frontline employees, including their knowledge and skills, and working conditions.

Eligibility criteria and pathway to approval

We invited views on the eligibility criteria for the new scheme and the pathway to approval.

The responses we received

Analysis of the responses we received shows that:

• 84% agreed that the core eligibility requirements should continue to include evidence of a good track record
• 47% said that those seeking approval should provide evidence of having supplied private security under contract for at least 12 months
• 56% agreed with a move to more flexible weighted requirements that consider a range of factors
• Most said that skills and experience (84%) and time supplying private security under contract (72%) are the most important to evidence and test
• 79% agreed we should continue to require and test evidence from all businesses that they can identify and mitigate public protection risks
• 83% agreed with a pathway to approval; a majority of 36% said businesses should achieve full approval within 12 months while 14% said the time allowed should be given on a case-by-case basis

Approval criteria

We asked for views on the criteria we should use to approve businesses under the new scheme

The responses we received

Analysis of the responses we received shows that:

• 73% agreed with a ‘must’, ‘should’, and ‘could’ approach to approval criteria
• 58% agreed businesses should be encouraged to go beyond the minimum and achieve good practice
• In response to the question on what other commitments businesses should be expected to achieve, 36% said ‘skills and professional development’, 15% said ‘employee pay and benefits’, and 7% said ‘working conditions’
• 56% agreed we should expect those supplying specialist services to demonstrate capability by meeting additional requirements

Assessment methods

We invited views on the methods we might use to assess businesses who have applied to join the scheme and what the assessments should focus on.

The responses we received

Analysis of the responses we received shows that:

• 56% agreed assessments would give sufficient assurance that requirements are met
• 69% agreed with prioritising how standards are achieved by focussing on service delivery
• 48% of those supporting a focus on service delivery agreed with upwards of 80% being spent on it
• 64% agreed with an approach that allows us to tailor assessments to prioritise and support higher risk businesses
• 71% who did not agree with tailored assessments said ‘consistency is needed’ or ‘at least an annual assessment is necessary’
• 26% said they expected to see something else in our approach to assessments, with most expecting to see ‘random visits and checks’

Approval types

We asked for views on how a new scheme might take account of the specialised, regulated services that businesses supply. We also asked whether we should consider certifications, accreditations, and approvals from other bodies that businesses hold. In addition, we invited views on whether we should provide a voluntary register for third parties supplying labour to private security businesses.

The responses we received

Analysis of the responses we received shows that:

• 76% agreed that businesses should disclose all regulated services and demonstrate requirements are met throughout their operations
• 80% agreed that recognising those supplying specialist services on the business register would give buyers greater clarity on which businesses best meet their needs
• 76% agreed that business approvals should recognise other certifications achieved, with 27% saying we should consider ‘International Standardisation Organisation’, 16% ‘The Contractors Health and Safety Assessment Scheme’, and 11% the ‘Safe Contractor’
• 69% agreed with a voluntary register for relevant third parties, 59% of whom agreed with an approval condition for businesses to only use registered third parties
• 81% agreed with a more meaningful and transparent public register of approved businesses

Other proposed changes

In our consultation, we asked these additional questions about other proposed changes, and received the following responses.

Question 1: Should we define and ask about certain roles for people involved in the supply and management of services that mitigate public protection risks?

74% agreed with defining and asking about certain roles.

Question 2: Should we expect private security businesses to report significant or material incidents or issues to us?

72% agreed that we should expect businesses to do this.

Question 2a: If so, what type of incidents or issues do you think businesses should report?

Some of the incidents they think businesses should report include ‘violence and assaults’ (28%), ‘accidents’ (10%), and ‘health and safety’ (10%).

Question 3: Would you find it helpful for us to communicate or publish themes in reported incidents and emerging threats?

86% agreed that this would be helpful.

Question 4: Should the future scheme focus on businesses having their own capacity to meet their customers’ needs and therefore have stricter rules on sub-contracting?

68% agreed with stricter sub-contracting rules.

Question 4a: If not, please tell us why and if this is about impact on your business?

A key concern was the adverse effect on smaller businesses who do not have the bandwidth of larger organisations.

Question 4b: If yes, which of these rules are you supportive of?

84% agreed that businesses should demonstrate an understanding of the risks associated with sub-contracting.

Question 5: Should the future business approval scheme include stricter rules on the use of labour providers by SIA approved businesses?

76% agree with stricter rules on the use of labour providers.

Question 5a: If so, which changes should we make?

81% said businesses must be required to demonstrate an understanding of the risks associated with sub-contracting and evidence mitigation of these risks.

76% said businesses should only use labour sourced from a recognised supplier or who is registered with the SIA as a third-party supplier.

Question 5b: If you disagree, please tell us why and if this is about impact on your business?

Most of those that disagreed with stricter rules on labour providers said that ‘effective due diligence’ is needed instead. Some also recognised ‘difficulties with labour supply across the industry’ and some said that ‘stricter rules around labour providers could result in a negative impact’.

Next steps

Read a more detailed breakdown of the responses to this consultation.

We expect the next phase of designing the business approval scheme to start in Autumn 2024.

Once we have drafted the design for the scheme we will hold a second public consultation. Our intention is to launch the new scheme during the business year 2026 to 2027.

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