Private security industry Regulator the Security Industry Authority (SIA) and its delivery partner Pye Tait Consulting have now published the findings realised from the extensive consultation that took place during Phase One of the project designed to review the Approved Contractor Scheme (ACS) in detail.
Overall feedback from the consultation – for which over 650 individuals submitted responses – shows that the existing ACS is “functioning well”. Nevertheless, a number of improvements to be made are duly identified. The SIA will now work with Pye Tait Consulting to deliver on those improvements during the subsequent phases of the review.
Some of the amendments required are deemed to include simplifying and improving the language around the standards, less focus on processes and documentation and a greater concentration on measurable outcomes.
With Phase One of the project highlighting a number of emerging themes for strengthening and enhancing the ACS, the Regulator has taken some strategic decisions in relation to the scheme’s future. Discussions during the consultation centred on whether the standard should be raised, possibly setting membership numbers at risk. There were also discussions focused on whether the ACS should be a more accessible standard, enabling greater numbers of companies to attain it. The SIA’s experience indicates that this isn’t an ‘either’/’or’ question. The Regulator has found that standards can be raised and that businesses will respond accordingly.
The SIA is clear that it doesn’t want standards to be lowered as this would be contrary to the organisation’s core statutory purpose of raising standards in the private security industry. The Regulator will now continue to focus on the level of the standards in Phase Two of the review.
Strategic purpose of the ACS
The question of whether the ACS is a differentiation scheme that allows businesses to market themselves and gain greater market share was discussed. The issue of differentiation through higher and lower standards, such as Gold, Silver and Bronze, prompted mixed opinions. The SIA has decided not to introduce a system of differentiation.
On this issue, the Regulator commented: “We believe the primary purpose of the scheme should be to facilitate improvement to security businesses. This will help create a market and a better security product which will, in turn, help to protect the public. A secondary purpose of the scheme is that it may be used to help drive behaviours in the industry in response to particular Government priorities, such as counter-terrorism, violence reduction and safeguarding of the vulnerable.”
When it comes to eligibility criteria, the Phase One review findings show that there’s an appetite for strengthening the eligibility and ‘fit and proper’ criteria. An SIA staff sub-group has been established to consider how these can be made more robust and make recommendations. This work will continue in parallel with Pye Tait Consulting’s development of the new standard. The Regulator will consult on this matter in the coming months.
Raising the standard
In terms of raising the standard, the Regulator observed: “We believe that we should concentrate on establishing that the quality standard describes good practice for a well-managed security business delivering a consistent service. This will be a focus for Phase Two. Current work to review the eligibility criteria and Terms and Conditions will also continue with a view to producing a reasonable and proportionate ‘fit and proper’ criteria. We will support businesses aspiring to higher standards and make the scheme accessible through such support.”
Focusing on the appropriateness of the pass/fail scoring methodology, the ACS scoring system itself is believed by some to be too complicated and at odds with the intent of the general scheme. With that in mind, this and alternative scoring methodologies will be explored in Phase Two and Phase Three of the ACS review. The SIA is clear that any standard facilitating continuous improvement must include a mechanism to track performance over time.
With one eye turned towards future ownership of the scheme, the consultation revealed little appetite for anyone other than a Government body, such as the SIA, owning and administering the ACS. These findings will be shared with the Home Office in due course.
The SIA will also seek to raise awareness of the differing routes to assessment, including the opportunities that are currently offered for recognition of standards such as the Community Safety Accreditation Scheme.
Business licensing or mandatory ACS?
Business licensing or a mandatory ACS? This was cited as being important as a means to drive down criminality and ensure that businesses are working across the same level playing field. The desire for a mandatory ACS among some parties was fundamental. They believe that any changes to the ACS other than this are secondary. There’s unlikely to be legislative opportunity for business licensing in the short-term. The Regulator will now share these findings with the Home Office and consider what may be done to raise standards among non-ACS security businesses.
In Scotland, there has been a Public Procurement Directive in place which mandates the use of ACS security providers if the security relates to a public sector contract. During the consultation, some support was given to the idea of seeking an extension of this approach beyond Scotland. The SIA will now discuss with the Home Office the benefits of mandatory ACS for public sector security contracts based upon the existing Scottish model.
The Regulator has considered the potential for security businesses specialising in certain sectors or having certain specialist expertise being given overt credit for this such that potential buyers can be informed as such. Due to little support and the difficulties of how such a move could be incorporated, though, the SIA has decided to discount pursuing a modular approach for the time being.
Interestingly, Pye Tait Consulting’s research has pointed towards the need to help reinforce understanding of the ACS among security solution buyers. SIA Approved Contractors strongly believe that the SIA should be doing this. Irrespective of any changes to the ACS, the Regulator proposes to augment its efforts to raise awareness of the value and benefits of the scheme, in addition to the risks involved around not using SIA Approved Contractors.
Last November, the Regulator published a guidance leaflet for buyers and, this year, will conduct research into the behaviour patterns and influencers of the buyers of security such that the SIA’s communications to raise awareness and secure engagement are both focused and effective.
The SIA also wishes to see awareness raised among other stakeholders, with police forces being a good example. Currently, police forces are invited to comment on ACS applicant businesses ahead of any approval decision being made. The Regulator will explore opportunities for the development of police forces’ role in order to keep those companies with serious criminality associations away from ACS accreditation.
Improving the training of assessors
Additional themes for consideration during Phase Three of the review include improvements to the training of ACS assessors. The consultation highlighted a perception that the assessment process is typified by varying standards which should be addressed through some form of standardisation methods. These findings are at odds with the SIA’s existing metrics and the changes made since April last year to improve the quality of the assessment.
Pye Tait Consulting is clear that the views expressed during the consultation reveal this to be an issue. The Regulator will consider these views and their implications for the consistent application of the standard.
One significant set of criteria which was prominent during the consultation was that focused on compliance with HMRC’s regime, notably that ACS staff should be on PAYE. The case for doing so was made strongly by the influential Strategy and Standards Group, which comprises trade bodies and representatives from the security industry. “However,” stated the SIA, “introducing blanket rules such as this will require care, consideration and
further consultation. There are concerns that such an approach has the potential to exclude legitimate employment models.” The Regulator is now in dialogue with HMRC about how its initiative on ‘conditionality’ may help to address these concerns, including through setting these matters on to the statute.
During January and February, the SIA is working with Pye Tait Consulting on Phase Two of the ACS review, in turn asking stakeholders for their views on the proposed changes to the scheme, including the ACS standard and the Self-Assessment Workbook.
There are a number of ways in which Approved Contractors, non-ACS security contractors, the buyers of security, assessing bodies and other stakeholders can be involved. There’s going to be an online survey on a draft revised standard and Self-Assessment Workbook (SAW), telephone interviews and Workshops.
Proposals for a revised standard and SAW will be available shortly via Pye Tait Consulting’s ACS Review Portal which is going to play host to an online survey for people to share feedback.
The SIA is planning three discussion Workshops to gather in-depth feedback on the way forward and proposed changes. They will take place as follows: London (1 February 2018), Leeds (14 February 2018) and Edinburgh (15 February 2018). Further information is available online at: www.pyetait.com/ACSReview
The revised ACS standard will be implemented this coming summer, with the transition managed to enable security businesses to prepare for change. It’s likely that security businesses will not be assessed against the new standard until some time in late 2018/early 2019.