The procurement of additional labour to support service delivery in the security guarding and event management sectors is common practice and gives companies the flexibility to scale operations effectively. When professionally managed, this extension of the labour force ensures security isn’t compromised. However, when not adequately managed there’s a risk to the safety and security of the public and the integrity of the supply chain, not to mention the potential for worker exploitation. Richard Jenkins elaborates on the fine detail.
If the procurement of additional labour isn’t well managed this can manifest itself in an absence of adequate checks and monitoring when it comes to deployed Security Industry Authority (SIA) licences, security screening to BS 7858, adherence to the Working Time Regulations, the paying of minimum wage rates and checks on right to work and employment status.
With growing industry awareness of the Gangmasters and Labour Abuse Authority’s (GLAA) activities, as well as feedback received by the National Security Inspectorate (NSI) relating to poor practices potentially compromising industry credibility, we took the decision to develop a new Code of Practice, NCP 119, for the ‘provision of labour in the security and events sector’.
The NSI invited Darryl Dixon, director of strategy for the GLAA, to speak to approved companies about the challenges for the security sector in relation to exploitation and criminal activity. The GLAA is a Government body that works in partnership to protect vulnerable and exploited workers. Its teams investigate labour exploitation across all sectors in England and Wales, covering offences against the Gangmasters (Licensing) Act 2004, the Employment Agency Act 1973, the National Minimum Wage Act 1998 and the Modern Slavery Act 2015.
Sectors the GLAA has highlighted as being vulnerable to labour exploitation include those with sub-contracting arrangements being, as they are, harder to monitor. Knowledge of suppliers and those across the supply chain to whom your organisation does not directly contract is therefore paramount.
An insightful publication on this subject can be found on the GLAA website www.gla.gov.uk/media/1573/human-trafficking-spotting-the-signs-v5-all-amends.pdf
New Code of Practice
The new NSI Code of Practice has been welcomed by NSI Gold approved companies and is due to be published imminently. There will likely be a grace period of 12 months before adoption of the Code becomes mandatory for NSI Guarding Gold and Silver approved companies.
In practice, the Code requires security companies to work only with labour providers who adopt the Code and gain NSI approval. The intent is to ensure (and demonstrate to buyers) that professional standards and staff welfare are maintained, as demonstrated through regular independent audit and the holding of a Certificate of Approval.
The requirements of the Code include those related to organisational Best Practice, personnel, sale of services, operations and documentation and record-keeping. The personnel requirements relate to recruitment, training, employee Terms and Conditions and uniform.
The sale of service requirements includes the transparency of contractual documentation as well as the contract terms themselves, while operations covers the deployment and management of staff, suppliers and confidentiality.
The personnel requirements include governance, record keeping and competence in recruitment and selection, Terms and Conditions for employees, the right to work and security screening.
Keen focus on training
The Code requires organisations to have clearly defined and documented training policies, providing induction training to all staff in matters related to employment and the organisations procedures, with training demonstrably completed before each employee is deployed to an assignment.
Maintaining records of all training undertaken by staff is necessary. Those records shall be retained in either soft or hard copy format (or both). The records shall include details of training undertaken such as: date of training, the subject matter of the training and details of the individual(s) delivering the training (with the signature of both the trainer and trainee). Records should also be kept as to whether the training was delivered externally or on line.
Non-compliance with the Code would manifest as the absence of adequate checks and monitoring of deployed security officer SIA licences, security screening to BS 7858, adherence to the Working Time Regulations, the paying of the minimum wage and checks on right to work and employment status.
Supply chain partners’ approval to this Code of Practice will help ensure security is not compromised and that integrity is maintained in meeting statutory and legislative requirements, staff well-being and relevant environmental, social and governance criteria, thereby reinforcing Best Practice.
Trusting approved companies
Every company awarded NSI approval meets the relevant industry standards for the security and fire safety services they provide. Every one of these companies also operates a quality management system or business operating system and its Board of Directors has been assessed.
There are several checks and balances that, for a buyer, can afford confidence when it comes to choosing an NSI approved company with which to work:
*NSI approval is a strong endorsement of competence. To maintain approval, an organisation is subject to ongoing annual audits. NSI auditors check competence (as described in British Standards or similar) for the service(s) provided by a given business. These services must be evidenced and/or practically demonstrated. Improvement Notices are issued when processes, training or customer service procedures are identified as being non-compliant. They require root cause analysis and effective corrective action to be taken and evidenced to the NSI as part of a cycle of continuous improvement. This degree of scrutiny is the added value of independent audit
*It’s vital for anyone choosing a guarding service supplier to ensure the organisation they select holds a valid Certificate of Approval relevant to the services they seek to buy. The expiry date and scope(s) of approval are clearly shown on all Certificates of Approval issued by the NSI. Scope is important since it defines the competencies for which approval is held. Competency in alarm system installation is of no relevance to security guarding or door supervision services. Any doubt as to the validity of approval can easily be checked directly with NSI
*In regard to the ‘people’-related services such as key holding or security guarding, for example, the SIA licence checks for criminal records, evidence of training and competence. The SIA licence is one part of the requirement for approval
*As an independent body, the NSI holds UKAS accreditation for the services it delivers, while its schemes are recognised in UKAS schedules. These underline its competence, impartiality and capability. UKAS routinely ‘checks the checkers’ with a rigorous audit
Ultimately, this new NSI Code of Practice will further enhance confidence in NSI approval as an indication that the guarding services provided will be professional and technically secure.
Richard Jenkins is Chief Executive of the National Security Inspectorate
*Keep up to date with the latest developments on the publication of the new NSI Code of Practice NCP 119 by visiting LinkedIn: https://www.linkedin.com/company/nsi–national-security-inspectorate/, Twitter: @nsi_approved or the NSI’s website: www.nsi.org.uk
**The NSI is the UK’s leading independent third party certification body in the guarding services, security systems and fire safety sectors, helping to protect businesses, public organisations, homeowners and the general public through the rigorous audit of more than 1,800 security and fire safety solution providers nationwide
***UKAS is the UK’s sole national accreditation body, responsible for determining, in the public interest, the technical competence and integrity of organisations offering third party certification in accordance with international standards for the accredited certification of management systems such as ISO 9001 (ISO 17021) and product standards pertinent to security and fire safety, such as BS 7958 for CCTV (ISO 17065)