Our compliance checks this summer- Q&A with Lucia Howland

We spoke with our Regional Investigation Manager & Tactical Events Lead Lucia Howland about our approach to compliance checks this busy summer.  

We seem to be visiting lots of festivals lately, what has our approach been for previous years? 

We’ve always had an interest in festivals and events. Typically, these tend to be high risk events by nature; there’s a demand for lots of security personnel for a limited time. This can lead to pressures on both the quality of staff provision and the due diligence needed to ensure compliance with regulations. Non-compliance might include unlicensed operatives, the presence of cloned or counterfeit licences or the use of stewards in place of security staff for designated roles. This can introduce risks to protecting the public. 

How does the industry cope with demands? 

Generally, the primary security provider that holds a contract with an event organiser will enter into contracts with other providers or use labour from others. Whilst this is acceptable if done correctly, it can dilute due diligence. We accept that this method of working must happen, so our interest is in making sure this is working as it should.  

How do we get intelligence and how does that inform our compliance and inspections activity?  

A lot of the intelligence we get is from the public where someone reports something they’ve seen. This tends to be after an event so the moment has often passed. The challenge is about getting the best intelligence so that it can properly inform our approach. We only have so many investigators so we can’t be present at every event, but we work hard on this and gather as much intelligence as possible. The intelligence team combines this with other information we gather from our own inspections and interactions with those in the industry to form a picture of the threats faced. These are then prioritised and tasked to the Compliance & Inspections teams. 

We need to be mindful that where we have rich intelligence on particular events or providers, we don’t place that on a pedestal; it doesn’t tell us what’s happening at other events we’ve not been to – sometimes we don’t know what we don’t know. 

How do you mitigate lack of organisers’ awareness? 

We start work months before an event happens. We work with organisers and other partners at meetings known as ‘safety advisory groups’. In addition to ensuring security plans are sound, these meetings exist to address any issues in relation to the event for example, health and safety, the environment and logistics and transport issues. At these meetings, a number of partners attend to give opinions and expertise. Sometimes we attend at the request of partners such as the local authority or the event organiser, sometimes we invite ourselves. 

We also work with providers of security beforehand to advise on compliance. We build a good relationship and work with them to make sure their own plans meet the standards required. 

What’s the main difference for us between big and smaller festivals? 

Our processes are the same whether big or small, so it’s a matter of scale really. I think smaller events are easier; there’s less to inspect on the ground and a smaller geography means not trapsing over quite as many fields to inspect security provision and liaise with control stations. 

But the challenge with smaller events is there tends to be less wiggle room to deal with any issues. For example, having fewer security personnel means less flexibility to deploy an alternative operative if an issue relating to a licence is found. 

Venue size and security provision is not a linear relationship. I was at a festival last week with a capacity of 5,000 with 29 security operatives on duty. However, a recent festival with a capacity of 10,000 required 200 operatives. Numbers vary massively and are dictated by the type of event, location, make-up of the venue, geography, entry/control points, demographics, etc. 

What’s the team up to just now? 

The season is now underway, and events are happening so we’re moving to an operational phase. We’re out inspecting festivals regularly now. 

Even though we’ve had pre-meetings with organisers and security providers already, we still inspect. We don’t leave them to it as we need to ensure the assurances, we’re given are accurate. 

What’s the reaction to our presence? 

Generally, we are well received. Good quality security providers which are there to do a good job are pleased to see us and work with us. Some event organisers can see us as presenting ‘yet another hoop to jump through’. But when they see how little we disrupt things and appreciate the value we bring to make their events safer they welcome us being on board.   

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