Guidance

Events guidance for buyers of security (web version)

Published 13 July 2022

1. Introduction

Are you planning an event and thinking of buying in security?

You need to be sure that any security services you buy are compliant with the law. This means ensuring that individuals are properly licensed where necessary.

The events sector in the UK is worth £42.3 billion pounds. Most, although not all, events will require some professional security. Some or all of these security staff may require a licence issued by the Security Industry Authority (SIA).

The purpose of this guidance is to help you to identify the roles at your event that may require a security licence under the terms of the Private Security Industry Act 2001. It also includes a checklist you can use to help you choose a security provider. It’s important to understand what makes someone licensable. This will help you make sure you have the right person in the right role at the right time.

This is only intended as general guidance. It is not a substitute for the complete definition of licensable activity within the Private Security Industry Act 2001. You should read it in conjunction with the Act. It is also not possible to give definitive guidance as to who is licensable in all circumstances as it will always depend on the specific circumstances of the case. You should consider the implications of the Act for particular events or premises, and seek appropriate independent legal advice.

2. The Security Industry Authority

Who are we?

The Security Industry Authority (SIA) is the organisation responsible for regulating the private security industry. We are an independent body reporting to the Home Secretary, under the terms of the Private Security Industry Act 2001. Our remit covers the United Kingdom. The Private Security Industry Act 2001 outlines a system for the statutory regulation of the private security industry.

The SIA has two main duties. One is the compulsory licensing of individuals undertaking designated activities within the private security industry; the other is to manage the voluntary Approved Contractor Scheme, which measures private security suppliers against independently assessed criteria. You can find out more about the scheme at the SIA’s website.

3. Examples of licensable and non-licensable activity

The lists below are not exhaustive. You should always remember that it is not the job title that matters; it is the work, or activity, that an individual does that determines whether they need a licence.

3.1 Licensable activity

You need an SIA licence if you do any of the following:

• screening a person’s suitability to enter the event or venue: for example looking out for individuals under the influence of alcohol or drugs, or behaving in an anti-social way. This includes those who are searching bags to ensure that there is no unauthorised access or any damage to property or injury to others
• searching people and/or property for the purpose of preventing unauthorised or illegal items from entering the premises, for example cameras, alcohol, drugs, or weapons
• responding to incidents within crowds, queues, or the audience to control behaviour which is anti-social, undesirable or likely to result in harm to others
• protecting a pitch, track or other identifiable area from spectators or others with the intention of preventing unauthorised access or damage
• providing a security presence to prevent and detect crime within a designated area
• guarding property and/or equipment in situ during the set up and breaking down of an event, exhibition or similar
• patrolling the perimeter of an event to prevent unauthorised entry by individuals, whether by climbing or breaching any fences or barriers, or by being let in via an access point
• working as a bodyguard protecting performers, corporate guests, clients VIPs, etc. under a contract for services
• observations and reporting roles as part of, or in support of, guarding. Licensable activity includes providing a physical presence or any form of surveillance to deter or otherwise discourage something from happening, or to provide information if it does happen about what has happened. Examples of such roles include (but are not limited to) patrolling the venue, observing from fixed positions, or monitoring CCTV footage

3.2 Non-licensable activity

You do not need a licence to do any of the following:

• customer care duties including directing patrons to refreshments, toilets and first aid facilities
• directing spectators to seating areas by checking tickets.
• providing safety advice and assistance to patrons
• ensuring gangways and exit/ evacuation routes are kept clear for health and safety purposes
• helping with evacuation procedures in the event of danger to patrons, including liaising with representatives of the emergency services
• having responsibility for the health, safety and comfort of spectators within a designated area
• monitoring and maintaining the pedestrian flow at key locations, for example entry and exit points
• providing guidance and direction to visitors arriving by car or on foot, including the management of roadway crossings to ensure the safe passage of visitors over the roads
• reporting to a supervisor or safety officer any damage or defect which is likely to pose a threat to spectator ‘health and safety’, for example a damaged seat or barrier
• work as a volunteer

4. Volunteers

Many events across the UK rely on volunteers to help deliver an event safely and provide a positive customer experience. We recognise the value of volunteers, but for the purposes of the Private Security Industry Act 2001 there needs to be clear dividing line between volunteers and contracted-in security, and clarity regarding the criteria for both.

Only individuals employed, or contracted in, to carry out licensable activities are covered by the legislation. Volunteers, by virtue of not being employed or contracted in are not considered to be employees. Therefore they are not licensable under the Private Security Industry Act 2001 (unless in relation to vehicle immobilising – refer to the Private Security Industry Act 2001).

However, volunteers working as manned guards at events must provide their services for free. They must receive no financial benefit, payment in kind or reward for their services to be defined as a volunteer. The principles on what constitutes a payment in kind or reward are defined by HM Revenue & Customs. They identify a payment in kind or benefit as one that is subject to either PAYE (tax) or National Insurance contributions.

The list provided on the HMRC website is comprehensive, but not exhaustive. If in doubt, individuals or organisations should seek independent legal advice.

The following examples show how some common occurrences are likely to be treated:

• the payment of out of pocket expenses (e.g. travelling to and from the event) would not be considered a payment in kind
• the payment of a donation made direct to a charitable organisation would not be considered as a payment in kind as long as no part of this payment is then passed on to the individual
• the provision of a meal or meal vouchers during the working day is acceptable. However, provision of vouchers to be exchanged for, ‘lunch at the Ritz’ for example could be considered a reward
• the ability to view the event while working (directly before, during or after a shift) would not be considered a reward, however preferential treatment, or discounted rates for premium tickets (e.g. Men’s Final on the Centre Court at Wimbledon, or a Cup Final match) could
• tickets provided to an individual for use by themselves (whilst not working), their family or any associate could be viewed as a reward
• the provision of uniform or appropriate equipment for the job would not be considered payment in kind or a reward, nor would certain other items of clothing such as a motif tie. However, the provision of official merchandise, for example CDs or DVDs could be

5. Vulnerable groups

If the event is aimed at children or the vulnerable you should consider whether you need any enhanced screening and vetting checks. If vulnerable groups with a specific non-visible condition (e.g. Tourette’s, Asperger’s, or autism) will be attending the event, brief your security staff in good time. They will need to be able to recognise the broad signs of the condition in question. You should also advise them to work with any accompanying support workers.

6. Contingency planning

Event organisers should use risk assessments and tabletop exercises to run through the event from initial preparation of the site through to its conclusion. This helps to clarify how you will use the different security operatives on site both in a business-as-usual capacity or in an emergency situation

Contingency planning, or stress-testing, hypothetical scenarios will help illustrate how to use security operatives in an emergency situation. It’s usual to plan responses to incidents such as terrorism, serious crime, natural disaster, medical emergency, missing persons, equipment failure or loss of communications.

For most events it is unlikely there will be the opportunity to have a “live” contingency exercise to train security staff. However, this pre-planning will ensure there are sufficient numbers, clearly defined roles and responsibilities, and procedures in place.

We recommend that anyone buying security for events should give every member of their staff a clear job description. This should detail the activities they should do as part of their role, and the purpose of those activities. We also suggest that you include the licensable status of the individual and the location(s) where they will be working.

7. Counter-terrorism

The UK has seen a number of terrorist attacks in crowded public places. The National Counter Terrorism Security Office (NaCTSO) have produced a number of publications to offer guidance to event organisers and security staff regarding protective security to prevent future attacks. You can find the most recent publications on the NaCTSO website.

NaCTSO’s Action Counters Terrorism (ACT) programme of training aims to increase public safety by raising security industry awareness of how best to reduce and respond to the most likely types of terrorist activities. The aim of ACT is to:

• help understand the threat of terrorism to the UK
• guide individuals on what to do if they find themselves involved in a terrorist incident or event that leads up to a planned attack
• enable people to recognise and report suspicious activity

We require SIA approved contractors to ensure that their staff are appropriately trained in counter-terrorism awareness. We recommend that anyone supplying security operatives to events similarly ensures that their security staff have undertaken counter-terrorism awareness training.

8. Choosing a security provider

Your choice of security provider can have a significant impact on the success of your event. We recommend that you carry out some general due diligence enquiries before you choose a security provider. This will help safeguard your business or event from financial and reputational risks.

We list our recommended enquiries below. This list is not exhaustive. Some points will not be relevant to all events.

• Does the company have experience of providing security to events similar to yours?

• Can the company provide references that you can verify from other events?

• Is the company insured to undertake the security services it is offering to provide to you?

• Does the company have public liability insurance?

• Does the company have business premises and can you visit the company at this address?

• Do you require an SIA approved contractor for your event? If so, is the company claiming to be an SIA approved contractor for the security services you require at your event?

• Check the SIA’s register of approved contractors on our website to ensure their accreditation is up to date.

• Can the company provide assignment instructions, health and safety policies for staff, contingency plans, staff training, equipment, and continuity of service plans for your event?

• Can the company provide a staff list for all roles they are supplying at your event?

• Can the company provide evidence of their due diligence procedures in relation to the Private Security Industry Act 2001, VAT and PAYE compliance, the national minimum wage, and right to work checks?

• Can the company supply a VAT number? You can verify this number by contacting HMRC on 03000 538254 before you enter into any agreements and by making regular checks of all VAT registration numbers afterwards.

• Can the company supply a PAYE number?

• Will the company be subcontracting any parts of the contract or using labour providers? If so, consider HMRC guidance on the use of labour provision which can be found at gov.uk/government/publications/use-of-labour-providers

• Add a clause in the contract requiring labour suppliers to show evidence of their VAT and PAYE returns, and payments they have made to HMRC, as well as their screening and vetting checks on the staff they are supplying to your event.

• Add a clause in the contract requiring your authorisation for further subcontracting to a third party

• Adding a clause in the contract preventing the use of offshore intermediaries

• Check the details of any potential subcontractors or labour providers against the register of approved contractors. Do subcontractors or labour providers hold appropriate insurance policies?

• Check with potential security providers and their preferred subcontractors/labour providers who is responsible for the screening and vetting of staff and ensuring they have the correct SIA licence for their role.

• What additional training (beyond that required to obtain an SIA licence) have your potential security supplier and subcontractors/labour providers given to the personnel they are deploying to your event? Specifically, what counter-terrorism awareness training have they had?

• What are you being charged for the staff being supplied to your event? The Association of Labour Providers advises that charging less than their suggested hourly cost of supply may indicate unsustainable practices within the business. The suggested rate as of April 2021 was £12.08 for those over the age of 25. This takes into account statutory wage payments only. You can find the latest rates on the Association of Labour Providers’ website here: labourproviders.org.uk

• Similarly, what are the staff for your event going to be paid? Consider checking workers are actually paid their contractual rate, and that it complies with the current National Living Wage/National Minimum Wage. As of April 2022, this is £9.50 for those over the age of 25. You can find the latest rates here: gov.uk/national-minimum-wage-rates

• Is a Business Credit Check appropriate to mitigate the risk to your event? For example, have potential suppliers been associated with companies in the past that have gone into bankruptcy? Are the decision makers for the company who they say they are? How long does it take the company to pay its invoices and how does this compare to industry average? A credit check may assist you in making an informed choice about suppliers.

9. Enforcement

The Private Security Industry Act 2001 established a number of criminal offences. These include supplying unlicensed security staff, and working in a licensable security role without a licence. You can find further details regarding the offences and their associated penalties on the SIA website.

10. Report a crime or concern

If you see or hear about someone in the private security industry committing a crime, we want to know about it. That is not just someone working without a licence or in breach of our licensing conditions; it can be any crime they have committed which might have an effect on their licensable status. You can report information via our website at GOV.UK/SIA.

You can also report illegal activity anonymously by calling Crimestoppers on 0800 555 111.

11. Resources

• Security Industry Authority (SIA)
• National Counter Terrorism Security Office (NaCTSO)
• HM Revenue and Customs (HMRC)
• Association of Labour Providers
• Home Office Immigration Enforcement (HOIE)
• Institute of Licensing (loL)
• Health and Safety Executive (HSE)
• The Purple Guide (to Health, Safety and Welfare at Music and Other Events)

Please be aware that you will need an annual subscription to access the Purple Guide, which is produced by the Events Industry Forum.