Full Regulatory Impact Assessment for Manned Guards & Keyholders

Steps to mitigate these risks are set out in paragraph 2.3.2. OPTIONS2.1 The Initial Regulatory Impact Assessment considered the option of doingnothing about the employment of unsuitable individuals in the private security industry.It did not explicitly examine the option of encouraging self-regulation, but since this wasalready a feature of the status quo, it fell within the option of doing nothing. Responsesto the White Paper were strongly supportive of legislation to provide national, consistentregulation of the industry. Extensive discussion during the passage of the legislationthrough Parliament dismissed the options of doing nothing or relying on self-regulation.The Act expressly charges the Secretary of State with establishing the Security IndustryAuthority and making regulations for the licensing of individuals in the private securityindustry. This RIA does not, therefore, re-examine the options of doing nothing or selfregulation.2.2 This Partial RIA looks, therefore, at the options for the content of regulations andthe sub-regulatory framework of SIA licensing for manned guards and keyholders, andinvites recipients to offer their views and comments on the options discussed. Theprincipal variables in preparing for regulation are the criteria for the granting of licences.Section 7 of the Act provides for the SIA to set criteria under three headings:• to determine whether applicants are fit and proper persons to undertake theroles of manned guarding and keyholding ;• to determine whether applicants have the training and skills necessary to engagein those roles; and• any other criteria which the Authority thinks fit2.3 The SIA has set the core competency requirements for training intended formanned guards and Appendix 3 provides further information about this. As forkeyholders, the SIA propose at this stage to set criteria in relation to the test for fit andproper persons and to necessary competencies and to set a minimum licensing age of18.2.4 The aim is to design a set of criteria which successfully addresses the risksidentified above; i.e. that are sufficiently rigorous to make a real difference to levels ofcrime and fear of crime and also to establish appropriate standards of probity, but thatare not so onerous that the industry cannot function. This RIA looks in broad termsat the effect of a range of options in order to establish whether they areproportional to the risks faced and place no unnecessary burdens on the impacton the public and on businesses.• Option 1: Apply a very low criminality threshold and make no competencyrequirementsThe criminality threshold could be achieved by refusing licences only to thoseapplicants whose criminal record includes serious offences. “Serious” would bedefined as (1) serious arrestable offences appearing on the face of the Policeand Criminal Evidence Act 1984 (e.g. murder, rape, possessing a firearm withcriminal intent); and (2) other offences which the SIA considered to beparticularly serious in relation to manned guarding and keyholding activities.7