Full Regulatory Impact Assessment for Manned Guards & Keyholders

Option 25.17 Option 2 sets the criminality criteria very high and also requires evidence of highlevels of competency. Businesses or individuals would have to pay for training in orderto provide the required evidence. It must be assumed that a high proportion of thosecurrently working in these business sectors would fail to meet the criminality standardsas would be the case on professional competences, and potentially a reduced ability totransfer existing qualifications. This would therefore result in a higher number ofindividuals being excluded from employment under Option 2, resulting in significantrecruitment costs for companies both supplying and using the services.5.18 For Option 2, the social costs are complex. On one hand, setting licencestandards very high might lead to an increase in public and police confidence and areduction in crime around these sectors of employment. However, setting standardstoo high would be likely to have three negative effects:• high levels of evasion• continuing unlicensed activity• severe shortage of licensed operators, running the risk that places of work wouldbe under-supervised.This option could also encourage those who have been refused a licence, but haveremained crime free, to return to a life of crime.5.19 The total industry costs of Option 2 would include licence fees, application times,training costs and ongoing recruitment costs. Inflated wage levels resulting fromscarcity of licensed operators are difficult to estimate but would be an additional cost.Option 35.20 The criminality criteria proposed under Option 3 would exclude some currentlyworking in the industry, and this would result in recruitment costs. There would also betraining costs in order to reach the required levels of competency. However, thesecosts would be offset by the benefits of lower staff turnover, as employees recognisedthe benefits of a higher status career, and greater marketability, as higher standardswere recognised by customers.5.21 There would be few social costs under Option 3 and a number of benefits asoutlined in paragraphs 4.6 and 4.7.5.22 The total industry costs of Option 3 would include licence fees, application times,training costs, and ongoing recruitment costs. Inflated wage levels resulting from somescarcity of licensed operators are difficult to estimate but would be an additional cost.Other Costs5.23 The public sector costs include those to the Home Office of setting up the SIA.These set-up costs of £21.2 million will not be recouped by the collection of licencefees.5.24 There will be a cost to the Department for Constitutional Affairs in respect ofappeals to Magistrates’ Courts and Crown Courts, which will be refunded by the SIA.16