The following letter was received by Mr Thomas-Symonds' mail system on 12th August 2024. For any members of the security industry who would like a template that you can customise with your own experiences and send to your own MP, please drop an email or LinkedIn message to Paul.

For any members of the public, whether consumers of security services or part of the security supply-chain that would like to add some support to these concerns from within the industry, get in touch and lets see how we can best bring your points in to the discourse.

12 August 2024

The Rt Hon Nick Thomas-Symonds
House of Commons
London
SW1A 0AA

Dear Mr. Thomas-Symonds,

I am writing to you as a constituent in the hope that you can champion a cause that desperately needs government attention. As a company director within the UK security industry, I am continually affected by constant malpractice and unethical business practices within the industry that remain largely un-policed. We have previously discussed these issues when you held the shadow Home Office portfolio, and I regret to inform you that the situation is progressively worsening, affecting both legitimate operators and the staff within the industry.

In the past week alone, I have personally observed seven security guarding tasks being offered on WhatsApp groups to anyone who has joined the group. Immediate action is necessary to address this, and my primary concerns are:

• These roles are often part of the supply chain for large Tier 1 security contractors working with major national brands, including <names given>, for the UK's largest supermarket chains, international ports, and even judicial facilities such as Hastings Magistrates Court. 
• These roles are being offered on a "first come, first served" basis with no form of screening, licence checking, or right to work checks. Often, licences are not verified in person, allowing for the use of fraudulent credentials.
• The roles consistently offer wages below the minimum wage – for example, the role at the magistrates court this week was advertised at £9.50 per hour.
• The exchequer is defrauded of tax as these staff are often paid on a pseudo self-employed basis, allowing employers to circumvent minimum wage laws and avoid responsibilities for pensions, sick pay, holiday pay, and other liabilities.
• The lack of right -to -work checks allows for the exploitation of international students, who are often misled about the legality of exceeding their allowed working hours.
• People's lives are at risk due to untrained and unscreened staff being employed in these roles.

Fellow legitimate operators and I strongly advocate for a business licensing model that mandates anyone operating (or providing labour to) a business offering licensed security personnel to work within a legal framework overseen by the Security Industry Authority (SIA).

The coroner leading the Manchester Arena Inquiry [1] recommended the government implement a business licensing model within the industry (Monitored Recommendation 8):

“Monitored Recommendation 8 (MR8): "Consideration should be given to whether contractors who carried out security services should be required to be licenced." “

This recommendation was taken to the Home Office by the SIA [2] and subsequently denied, as noted in an SIA update [3] document from June 2023:

“On business licensing the Home Office was not persuaded that it would deliver improvements in public safety that would be proportionate to the significant increases in regulatory burdens that this would entail. The Home Office wants the SIA instead to continue with a voluntary approval scheme to drive quality standards in security provision.”

Senior management within the SIA believe that a business licensing model is necessary. From my conversations with individuals within the SIA, the consistent message is that “there is no political hunger [for business licensing].” Furthermore, the current Private Security Industry Act does not provide for business licensing.

I am urging my peers to contact their MPs in the hope that, with your help, we can generate the political momentum needed to secure the future of the industry. Together, we can:

• Amend the Private Security Industry Act 2001 to allow for a business licensing scheme, potentially modelled on the Irish Employment Regulation Order, [4] to implement safeguards, rights, and an industry minimum wage that considers the additional training costs faced by security staff.
• Ensure that no person working within the security industry is employed below the minimum wage, eliminating the practice of self-employed labour provision.
• Mandate that any company providing security personnel must hold a security industry business licence, whether they are a current security provider or a labour-only subcontractor.
• Impose tough penalties on purchasers of security services who use suppliers that circumvent business licensing legislation. Look at the Health & Safety at work act 1974 and the powers held by the Health and Safety Executive as a potential benchmark for enforcement, fines, and statute of limitation exemptions. 
• Implement safeguards to prevent security businesses from closing and reopening under a different legal entity with the same top management to avoid liabilities. Require the regulatory body to be informed of any top-management changes to track directors attempting to evade accountability.
• Empower the SIA to thoroughly investigate the fitness and propriety of top management in security businesses, preventing unsuitable individuals from operating as shadow directors.
• Legislate the level of record keeping surrounding vetting & screening and include this as an area of inspection on business licence holders.
• Integrate the current voluntary "Approved Contractor Scheme" into a new business licensing scheme to avoid confusion among security purchasers. This could be a tiered system (bronze, silver, gold), with bronze for new startup businesses, silver as the standard business licence, and gold replacing the current ACS scheme.

As a real living wage -paying business, I have seen the quality of job applicants in the trade decline to an all-time low. This decline is partly due to the low wages that have become endemic within the industry and customer perceptions of security quality. Moreover, the security industry has fallen well below what most consider a reasonable wage when considering the risks involved and comparing it to other industries that do not require regular up-skill training and re-licensing. As a colleague recently remarked, “I can drive an Iceland van for £14 an hour and be home by 7pm. Why should I pay £300 every 3 years and a couple of hundred quid on a training course to work nights on near minimum wage?”

In the time spent between writing the first draft of this letter on 7^th August and as I prepare to send it to you (12^th August), three Taylor Swift concerts have been cancelled due to a plot being discovered and acted upon by the Austrian security services: Based on early news media it would appear that clandestine operators with a plan had managed to get employed by the venue’s security provider. I have personally worked in venues such as the Principality Stadium, Utilita Arena, and several UK green-field festivals and the only ID check that has been carried out is “which company are you working for mate?”. With business licensing combined with a robust enforcement framework, the fact that only bona-fide contractors would be providing staff would reduce the opportunity for this kind of incursion.

I sincerely hope you can develop these thoughts and those of my peers into a proposition that generates the necessary political will to transform my industry from a cesspool to a profession.

Yours sincerely,

Paul Green

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