In a recently-published White Paper, Industry Qualifications’ CEO Raymond Clarke has stimulated discussion and thinking around improvements that can be made to training and assessment practices for licensed qualifications in the UK’s security industry.
The White Paper has been produced following reports of alleged malpractice in several security training centres understood to be working with a number of awarding organisations.
In making its proposals, Industry Qualifications recognises that most of the training and assessment in the sector is conducted to a good or high standard, but it’s widely acknowledged that assessment in the security sector is high risk and that malpractice is perhaps more widespread than has been publicly recognised to date.
Here’s what Raymond Clarke and Industry Qualifications has to say on the matter…
Training and assessment is undertaken by training departments of security companies and through private sector training providers. In relation to the training provider market in particular, there are a number of issues as follows:
As a regulated sector, there’s an attraction for training providers to enter the market due to the perception of regular and ongoing business. Entry barriers for training companies are, at present, extremely low.
The sector suffers from the over-supply of training provision, leading to aggressive cost-cutting and pressures on centres to demonstrate high achievement rates.
Security education is used as a vehicle for return to work and employment schemes, attracting students ranging from those interested in working in the industry to those who are not. When combined with payment by results, the risks increase.
Cost pressures on centres impact upon awarding organisations wishing to go beyond the established norms in pursuit of effective quality assurance.
These and other factors combine to make the security sector a high risk one for awarding organisations.
Industry Qualifications has been engaged in an internal review since the autumn of 2014, considering how it might effectively manage the risk of malpractice in the security sector in terms of both training and assessment. Much of our early focus has been on the development of the IQ External Verification team as auditors for the risk assessment standard (ISO 31000) to broaden their understanding of risk outside of the narrow context of external verification as defined by the Joint Awarding Body (JAB) Guidance.
The nature of some malpractice is such that it’s doubtful whether the common approach of awarding organisations – and the regulatory framework within which it is discharged – is sufficiently robust. Industry Qualifications is confident that it applies and usually exceeds the JAB Guidance, but recognises that there are limitations in the effectiveness of quality assurance where a centre is minded to commit systemic fraud.
The purpose of this White Paper is to encourage a wider review and identify those adjustments and enhancements that can be made in order to reduce the risk of malpractice and fraud.
Proposals fit into three categories
The proposals that Industry Qualifications believes should be adopted broadly fit within three categories: the licensing of those involved in training and assessment, the collection and sharing of data across awarding organisations and a review to ensure that external verification is responsive to social, economic and cultural diversity. Let’s examine each in turn.
Training and assessment tends to be undertaken within security companies, or is provided by educational providers, some of whom have strong links with the industry and others not.
At present, under the provisions of the Private Security Industry Act 2001, there’s no requirement for trainers, invigilators or directors of training companies to hold Security Industry Authority (SIA) licence. Where the training centre is a security company, it’s more usual for training staff to have an industry licenses. No provision exists for the licensing of trainers.
The Industry Qualifications position is that:
(1) A new category of license should be developed by the SIA for trainers. Trainers would continue to require to be qualified in training delivery and have appropriate sector competence, but in addition they will be required to apply for a licence. This process would enable a Disclosure and Barring Service (formerly Criminal Records Bureau) check to be undertaken (which is currently not the case across all training providers). Most importantly, it would allow for a licence to be revoked should malpractice or fraud be uncovered.
(2) Owners and directors of training companies should also be required to hold a non-front line licence which will enable suitable checks to be undertaken on whether they are fit and proper persons. Again, revocation of a license on the grounds of malpractice or fraud would remove offenders from the industry.
(3) Industry Qualifications believes that there’s a strong argument in general – and not specific to the security industry – for trainers to be registered and for them to be removed from that central register in the case of proven malpractice or criminal/inappropriate activity.
The licensing of trainers and directors/owners of training companies will significantly reduce the potential for fraud by increasing the cost of entry and the risk to the individuals and organisations concerned if they behave in a fraudulent manner.
Sharing of data
The Office of Qualifications and Examinations Regulation (Ofqual) currently requires awarding organisations to inform other awarding organisations operating in a sector when a centre has had its recognition withdrawn. The reasons for withdrawal of recognition range from malpractice through to non-payment of bills and more minor issues. Other awarding organisations then make a judgement on whether they wish to recognise the centre concerned, and should take into account the evidence provided by the reporting awarding organisation.
The system provides reasonable real-time intelligence, but it’s not possible to review whether a centre (or the directors involved in the operation of a centre) have historically been reported by another awarding organisation. This means that a rich source of risk-based data isn’t available to awarding organisations when they’re making decisions about the approval of a centre.
The proposal from Industry Qualifications is that Qualification Regulators consider maintaining an historical record of centres and directors that have been the subject of malpractice investigations that have indeed uncovered malpractice.
Quality assurance within centres is largely monitored through centre approval, external verification, assessment monitoring (checking examination scripts statistically and in terms of how they have been completed) and whistleblowing. It’s the considered view of Industry Qualifications that the following actions need to be taken across all awarding organisations, irrespective of what those awarding organisations choose to add to the quality assurance process:
(1) All centres should be subject to a centre approval visit prior to approval. While this is the case for Industry Qualifications centres, there is some evidence to suggest such a policy is not uniformly observed across all awarding organisations
(2) Awarding organisations should maintain statistical data on attendance rates at examinations. The backgrounds of (and motivations for) those attending licensed security programmes is varied, and lifestyles can be chaotic. This results in large numbers of candidates not showing up for training/assessment. We believe that this provides an opportunity to hide fraudulent activity.
By maintaining average attendance rates for centres, if there are significant swings in attendance, particularly during an unannounced centre approval visit, it could be highlighted as a risk factor worthy of additional investigation.
A further part of the proposal relates to the need for an evidence-based study to understand whether activities such as whistleblowing are as effective in certain communities or economic and social strata. There’s some empirical evidence to suggest that malpractice tends to be geographically concentrated.
Research is required to understand the reason for this. In particular:
*Whistleblowing, which is probably the most useful tool in the uncovering of deliberate fraud, might not be a norm within all parts of society?
*Do awarding organisations need to look at social, cultural, economic or ethnic diversity within the composition of deployment of external verification teams?
We fully recognise and appreciate that these issues will need to be considered with respect, sensitivity and honesty. The view of Industry Qualifications is that it’s a consideration worthy of review.
In addition to these proposals, Industry Qualifications will continue to work with centres and key partners to enhance our own approach to quality assurance, building upon the capability and reputation that we’ve already developed to date.