The Impact of Unlicensed Security and How to Prevent It

The UK events sector is a £42 billion industry, preyed on by fraudsters in the private security industry who are not Security Industry Authority (SIA) licensed leading to improperly trained individuals cover all types of events, customers and clients being none the wiser. The SIA has prosecuted over 30 people or businesses in the past 12 months, with one of the SIA’s most significant prosecutions the LS Armour case affecting the security of many high-profile events nationwide.

All ARK’s responding officers hold a valid SIA licence and we are an Approved Contractor Scheme (ACS) company.

Who is the Security Industry Authority (SIA)?

The SIA is an independent body that regulates the UK’s private security industry, reporting directly to the Home Secretary under the Private Security Industry Act 2001 “the Act”. The organisation’s two main duties are compulsory licensing of individuals undertaking designated activities in the private security industry and managing the Approved Contractor Scheme, assessing private security suppliers against specific criteria.

What is the LS Armour Case?

The director of LS Armour, Lee Szuchnik, alongside his fellow director Erica Lloyd, supplied unlicensed staff with fake SIA licences to the Download Festival, Glastonbury Festival, two Adele Wembley Stadium concerts, 2000Trees Festival and Cornbury Festival in the summer of 2017. Unlicensed door supervisors were also supplied to two pubs.

Szuchnik was himself refused an SIA licence in June 2017 due to prior offences. The security staff supplied by LS Armour were using the identities of genuine SIA licence holders, which had been dishonestly obtained by the two directors by inviting legitimate licenced individuals for interview.

The SIA, working with South Wales Police, also found the directors were planning to send unlicensed staff to more events. Lee Szuchnik was consequently jailed for two years and three months and Erica Lloyd was given a suspended sentence.

Four of LS Armour’s staff found to be using false SIA badges were summonsed under section 1 of the Fraud Act 2006.

Nathan Salmon, Criminal Investigations Manager at the SIA, said:

“This fraud put untrained and un-vetted security staff in a position of responsibility at numerous festivals. This put event organisers, suppliers, and members of the public at an increased security risk.  People going to events and festivals must be able to have confidence in the fact that the security personnel put there to protect them are legitimately licensed.”

Is Unlicensed Staff’s Lack of Training the Sole Issue? 

In a word, no. Unlicensed staff are not just entirely untrained for the events, some have been found smuggling drugs for extra money. A BBC Three documentary Festival Drugs: Meet the Dealers exposed the use of unlicensed security at festivals and showed how easy it is for security personnel to get drugs on-site with a fake licence.

A whistle-blower in the documentary explained:

“There is so many big festivals at the same time up and down the country, the big [security] companies, they don’t have the manpower, they’ll subcontract big chunks to different people. They’ll put an advert on the internet and they’ll take anybody.”

What Do You Need to Know About Event Security?

When planning and implementing security at an event, it’s important to do you research and be informed about what exactly you want. Keep in mind, you pay for quality and by paying less for security you’re more likely to increase the risk to your attendees and damage your reputation. Always consider the Act and seek independent legal advice when buying security, this ensures better customer service and an overall safer event.

Carry Out a Risk Assessment

A risk assessment will help you to determine where security staff are required, what level of security is needed and for what activities, as defined by the Act. It can support your application for a Premises Licence or Temporary Event Notice if you require either, you can find this information out from your local licensing authority. In the risk assessment, the guidance developed by the National Counter Terrorism Security Office (NaCTO) must also be taken into consideration for any event and applied appropriately to prevent terrorist attacks. You can contact your Safety Advisory Group for further assistance.

SIA Licensing and Licensable Activities at Events

Security personnel require an SIA licence when they are contracted by a consumer for their services.

Any manned guarding activity at events must be undertaken only by SIA licensed staff. The Act defines manned guarding as providing a physical presence to guard premises, property and one or more individuals.

There are two types of licences that are applicable to events, front line or non-front line. A front line licence is a plastic card, compulsory for any licensable activity and non-front line activity, except key holding. Whereas a non-front line licence is a letter required for anyone managing, supervising and/or employing staff who undertake any licensable activity.

Manned guarding is split into five types of activity with their own SIA licences:

  • Security Guard: This involves guarding premises against theft, unauthorised access or damage.
  • Door Supervision: This includes guarding licensed premises such as pubs, bars and clubs. In-house door supervision is licensable.
  • Close Protection: This is the guarding of individuals against assault or injury.
  • Cash and Valuables in Transit: The use of specially manufactured vehicles to provide secure transportation and protect against property damage and theft.
  • Public Space Surveillance (CCTV): The use of CCTV equipment to monitor and guard premises, property and people.
  • Key Holding – A key holding licence is necessary when keeping or controlling access to keys for security.
  • Vehicle Immobilisers – It’s illegal to immobilise vehicles in England, Wales and Scotland but legal in Northern Ireland. A licence is required for restricting or remove vehicles, where a charge will be incurred for the release of said vehicle. In-house vehicle immobilisation is licensable.

If licensable activities are undertaken in relation to licensed premises, an SIA door supervision licence is obligatory. Licensed premises are typically open to the public, supply alcohol for consumption or provide regulated entertainment. The areas covered by the premises licences is for the local licensing authority to decide. However, it is the decision of the premise licence holder to decide when the premises are open to the public.

What Are Licensable and Non-licensable Activities for Events?

This list is not exhaustive, but it will give you an indication of the activities where an SIA licence would be needed in an event.

Licensable Activities That Require an SIA Licence

  • Checking the suitability of people entering the event, searching bags and people to stop unauthorised items getting into the premises like drugs.
  • Dealing with antisocial behaviour including anything likely to cause harm.
  • Patrols of the perimeter to avoid unauthorised people gaining access by other means than the main entry point.
  • Contracted to protect performers, VIPs or important clients.

Non-Licensable Activities That Don’t Require an SIA Licence

  • Customer care responsibilities such as directing customers to where to purchase refreshments and checking their tickets.
  • Dealing with pedestrian and traffic flow at the entry and exit points.
  • Reporting of any health and safety risks to the appropriate, responsible person.
  • Volunteers

Establish Clear and Definitive Job Descriptions

 All staff should know their job description, what activities they’re carrying out and why it’s important. The job description should include the licence status and location of the activities. Staff can be allocated to different activities when they’re no longer required at their post, for instance, once all the patrons have entered, you won’t need anyone searching bags, but this should be included in the job description. A licence may be used for more than one licensable activity should the SIA specify they’re satisfied to do so.

The Use of Volunteers

Many events rely on volunteers to run smoothly and safely, there must be a clear distinction between volunteers and staff contracted for security purposes. Volunteers do not require a licence, when providing security, they must work for free and receive no financial benefit or reward.

Make the SIA’s Approved Contractor Scheme a Precondition

Businesses that provide security services can apply to join the SIA’s voluntary Approved Contractor Scheme. They are independently assessed every year and all ACS companies can be found on the SIA’s Register of Approved Contractors. Consider making it a requirement that your security provider for your event be an ACS company.

Finding Your Security Provider

When identifying the best security provider for your event, it’s important to be due diligent and don’t make a hasty decision. These are just some of the questions that you may ask and should be based on the findings of your risk assessment:

  • Has the business provided security to any events like yours? If so, ask them to supply references.
  • Is the company comprehensively insured for the security services that you need?
  • Do you need an SIA Approved Contractor for your event?
  • Will the company need to subcontract or use labour providers for your event?
  • What are you going to be charged and what are the security staff going to be paid for working at your event?
  • Can the company provide evidence of their procedures e.g. VAT and PAYE compliance, national minimum wage and right to work checks?
  • Should you carry out a business credit check to help you make an informed decision on suppliers?

Employing Subcontractors and Labour Provision

For large scale events, finding a security provider big enough to supply operatives entirely from its own pool of employees is difficult. Subcontracting and labour providers is often used to fulfil their obligations for big events. Suitable checks must be in place to make sure all individuals are correctly licensed for the role.

Subcontracting puts the responsibility of delivering the customer contract on another company fulfilling it on behalf of the business that originally won the contract. Whereas labour provision means the responsibility always stays with the company that won the contract but rely on third parties to help with delivery.

 When buying security services, you must be clear in your expectations for subcontracting and labour provision. If you’re not comfortable with your security provider doing either, they need to be told. All terms and conditions should be in writing and make clear where responsibilities and liabilities lie between you, your security provider, subcontractors and any labour providers.

What to Do Prior to the Event

Contact your security suppliers to get a list of all the individuals that will be working your event, this list should have full names, date of birth, SIA licence number, job role and their employer. You can use SIA’s Licence Status Checker to make sure they all have valid licences.

Your security supplier should tell you if they are supplying any staff that they don’t know and provide you with a list of any subcontractors or labour providers they’re using; full company name, address, contact telephone number and company number. You can also check social media to see if they have been recruiting for your event that way. Any unknown staff should be asked for an additional form of photo identification like a driving licence or passport

Make sure to have a main point of contact for everyone working at the event. All your job descriptions, instructions and briefings must be pre-agreed with your security supplier, any subcontractors and labour providers. They must also all be aware of your premises licence, notice or other permission to ensure you maintain compliance.

Staff must be on site before the event begins so they are familiar with everything including contingency plans, so they know exactly how to act in all emergency situations whether it’s crime, terrorism, a natural disaster or loss of communication. SIA Approved Contractors are required to ensure their staff are appropriately trained in Counterterrorism awareness. If the event is for children or vulnerable adults, staff must know the signs of any probable non-visible conditions and work with any support workers.

What to Do During the Event

 On opening day, refer to your watchlist on the SIA’s Licence Status Checker so you know if anything has changed. Any unlicensed staff must be reported to your security provider, police and the SIA.

This is also the time when you should carry out your secondary identification checks on unknown licensed security staff. Anyone that’s not licensed, like volunteers, must be aware of the parameters of their role, what they can and cannot do.

Staff should complete signing-in sheets and attend a briefing before the event opens to the public. You must make sure the staff contracted to you is equivalent to the number on site and note down who was and wasn’t present at the briefing.

What to Do After the Event

Following on from your event, debrief with your security provider on what went well and any areas for improvement. If you’ve been working with the local authority or police, you may want to do the same with them.

Keep the signing in sheets for your records, if you find there’s any individuals you weren’t made aware of, check their details with the SIA’s database. You can contact the SIA if you have any issues regarding licensing or the legitimacy of your security provider.

Enforcement of SIA’s Licensing Conditions

SIA licences come with conditions which licence holders must abide by. The SIA can issue a written warning, revoke or suspend a licence and prosecute you. It’s an offence to engage in licensable activity without a licence. There’s a maximum penalty of six months imprisonment and/or a fine up to the statutory amount.

It’s also an offence for a business to claim it’s an approved contractor when it isn’t, including displaying the ACS accreditation mark with a penalty fine up to £5,000. You can also be prosecuted for supplying unlicensed security operatives.

SIA regional teams engage with event owners, police and Safety Advisory Groups before an event and at large events, attend in-person to work with organisers to check security staff are correctly licensed.

Reporting a Crime or Breach of Licensing Terms

If you have any information about someone in the private security industry committing a crime, it can be reported through SIA’s website. It can be anything which might affect their SIA licence status.

The SIA can also offer fully comprehensive advice on all licensing, the Act to help you understand how it might affect your security requirements.

About ARK

Alarm Response and Keyholding is part of the Asset Protection Group and we specialise in providing professional keyholding and alarm response services across the UK. Securing your home or business to ensure the safety of your family and staff. We have been providing keyholding and guarding services since 1982. Because we take the responsibility for responding to out of hours of alarm activations.  As well as securing sites on behalf of owners with fully licensed SIA security officers.