The National Security Inspectorate: The Benefits Of Our New Code of Practice
Richard Jenkins, Chief Executive of the National Security Inspectorate (NSI), explains the benefits of a new Code of Practice covering labour provision of front line guarding and event staff. The standards are designed to address the risks that buyers face in the supply chain for security services. They will also ensure professional security officers do not suffer potential worker exploitation.
The scale of the Covid-19 pandemic has had major economic ramifications and, as a result, a substantial impact on security. Following the March 2020 national lockdown, the NSI joined a number of other organisations calling for specialist employees – including security officers – in approved companies to be classified as key workers. As the leading certification body in the guarding services market, we felt that the recognition of regulated (licence-holding) security professionals under this category was essential to our country’s national infrastructure. This is because of their vital work in, amongst other areas, the security of empty or closed stadiums, arenas and a variety of other events venues.
Buyers and providers of guarding and events staff services face potential risks in the unwitting use of unqualified agency labour in the industry. It’s well known that commercial guarding service providers across a variety of security functions, including duties related to the protection and safety of public events, upscale their staffing resources as and when required.
The use of flexible labour in both the security guarding and events management sectors is common practice, enhancing providers’ operational efficiency and effectiveness. This operational reality, when professionally managed, ensures security standards are maintained and not compromised, whilst fulfilling contractual requirements.
The Covid-19 crisis has imposed new and further demands upon organisations that manage and monitor access to a wide variety of premises, with additional security officers now being deployed to maintain social distancing at venues as well as traditional duties. This has made the flexing of resource in deployment of outsourced security staff more – not less – likely.
Upscaling – The Dangers
Yet too often, inadequate management procedures linked to the scoping of additional security officers pose a risk to the safety and security of the public, therefore offering unwelcome scope for rogue labour and/or worker exploitation.
The wider risk for event organisers and other buyers such as facilities owners and venue managers is clear: the consequence of poor ‘management-of-labour’ practice resulting in a security breach, could compromise public safety or worse.
In essence, the labour supply chain flexibility we rely on to keep us safe is susceptible to weak links which, if broken, risk attendant consequences. This could be fallout for buyers, for service providers, for those employed through such working arrangements and the general public. In the worst-case scenarios, rogue labour could have devastating results.
What has become increasingly clear is the lack of ‘end-to-end’ oversight to fully address this risk, which in turn ensures buyer confidence that their main security contractor’s supply chain is not misplaced – i.e. it actually is all it’s cracked up to be.
Squaring The Circle
The NSI approves organisations against British Standards, checking their compliance and ensuring their capability to operate accordingly. In recent years it has seen sufficient risk in the market to justify the development of a Code of Practice and an approval scheme that both protects buyers and allows guarding providers to independently demonstrate their labour supply chain integrity.
In 2019 following feedback received regarding poor practices potentially compromising industry credibility, the NSI engaged with the Gangmasters and Labour Abuse Authority (GLAA). This 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. The GLAA has highlighted sectors vulnerable to labour exploitation as including those with sub-contracting arrangements since they are harder to monitor.
A workable and practical means of addressing this risk was seen as a priority. The result? A new Code of Practice – NCP 119 – for the ‘Provision of labour in the security and events sector’. This addresses and challenges labour providers’ processes regarding, for example, the adequacy of screening checks, the monitoring of deployed security guard SIA (Security Industry Authority) licences, adherence to Working Time Regulations, compliance with minimum wage regulations and checks on right to work and employment status. In short, it addresses rogue labour.
Best Practice Procedures
This new Code of Practice has been developed to enable Guarding Services providers to demand robust and professional employment practices from their labour suppliers by requiring them to adopt and seek approval from the NSI. In this way organisations providing labour to security companies will be able to demonstrate best practice by holding independent certification.
By definition, the use of the term “labour provision” applies to activities which are described as bought-in-labour, licensed or unlicensed, as well as labour employed and/or supplied by a third party to temporarily supplement the contracting company’s own workforce. Its scope covers all labour provision to the NSI’s Gold and Silver approved companies operating in the regulated security and events sector.
Importantly, approval to the Code by supply chain partners demonstrates to buyers of services an end-to-end supply chain commitment to meeting statutory and legislative requirements, as well as meeting certain relevant environmental, social and governance criteria in the provision of services delivered.
These requirements include measures related to best practice in terms of organisational structure, finances, payroll, insurance and premises. They also include personnel, sale of services, operations and documentation, training and record-keeping. Companies procuring additional labour to support service delivery on their contracts will shortly be able to require labour providers to obtain a Certificate of Approval to NCP 119.
The intent is to ensure, and demonstrate to buyers including events venue operators that professional standards and staff welfare are maintained, whilst ensuring risks associated with weak supply chains are actively addressed on an on-going basis, protecting the general public and security officers alike.
Richard Jenkins became CEO of the National Security Inspectorate in 2014. With its roots stemming from the early 1970s, the NSI is now the UK’s leading security and fire sector specialist Certification Body across the UK. Richard’s experience in the private sector, within the UK and EMEA, spans sales, retail and wholesale distribution, manufacturing, international logistics and quality systems in blue chip organisations such as IKEA, Chubb, Steelcase and Caterpillar.
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