NSI new code of practice for security agency providers to improve security guarding service provision
The essential contribution of agency labour providers to the security industry can be undermined by poor practice. Can a new code of practice address the best interests of security buyers and agency workers?
Buyers and providers of guarding services face potential risks in utilising agency labour in the industry. It’s well known that commercial guarding services providers across a variety of security functions, including duties related to the protection and safety of public events, upscale their staffing resources when required.
The use of flexible labour in both the security guarding and events management sectors is common practice, and enhances providers’ operational efficiency and effectiveness. This operational reality, when professionally managed, ensures security standards are maintained and not compromised, whilst fulfilling contractual requirements.
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, by prejudicing the integrity of the supply chain, so offering unwelcome scope for rogue labour and/or worker exploitation.
The wider risk for event organisers and other buyers such as facilities owners and site managers is clear: the consequence of poor labour practice, resulting in a security breach, could lead to a loss of public confidence and damage their future business prospects.
In essence, the labour supply chain flexibility that, whether we realise it or not, we rely on to keep us safe, can have hidden ‘weak links’ which, if breached, can have attendant consequences: 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.
It’s become increasingly clear that there is a lack of ‘end-to-end’ oversight to fully address this risk. So, how can buyers have confidence their main security contractor’s supply chain is all it’s cracked up to be?
Squaring the circle
NSI, a UKAS accredited Certification Body in the Guarding Services market, approves organisations against British standards, ensuring they operate accordingly. Over the last two years, it has seen sufficient risk in the market to justify 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’s integrity.
In the context of feedback received regarding poor practices potentially compromising industry credibility, in 2019 NSI engaged with the Gangmasters and Labour Abuse Authority (GLAA), 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 has been a priority, through the development of a new draft Code of Practice, NCP 119, for the ‘Provision of labour in the security and events sector’. This addresses, and in a sense challenges, labour providers’ processes regarding, for example, the adequacy of screening checks, the monitoring of deployed security guard SIA 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
The new Code of Practice has been developed to enable Guarding Services providers to demand robust and professional employment practices from their labour providers, by requiring them to adopt and seek approval from NSI. In this way organisations providing labour to security companies will be able to demonstrate best practice by holding independent certification in the scope of ‘Provision of labour in the security and events sector’.
By definition, 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 NSI Gold and Silver approved companies operating in the regulated security and events sector.
Importantly, approval to the Code by supply chain partners will demonstrate 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, that professional standards and staff welfare are maintained, whilst ensuring that risks associated with weak supply chains are actively addressed on an ongoing basis, protecting the general public and security officers alike.
Richard Jenkins
Chief Executive,
National Security Inspectorate