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.   


Our compliance checks at the BBC Radio 1 Big Weekend Festival  

by Lisa Shaw, Investigations Officer, SIA Southeast

The BBC Radio 1’s Big Weekend Festival took place this year in Luton from 24-26 May. As a popular event with a great line up, the numbers were expected to reach over 100,000 which meant a large security presence. My team at the SIA covers counties in the Southeast including Sussex, Essex, Surrey, Hertfordshire, Hampshire, Kent, Bedfordshire and Thames Valley. As the event was in my patch, my team and I planned a visit to ensure SIA compliance at the event. 

Our team checked 155 licences and spent time engaging with licence holders and security suppliers at the BBC Radio 1 Big Weekend Festival in Luton.

We spent three days making checks at the event. The first two days involved us attending the site before the event opened to inspect licences of the security operatives on duty.  At the inspection planning stage, all suppliers provided me with a list of documents they had seen to verify identity of the licence holders. We then attended the first day of the event on Friday 24th May to inspect any licence holders we missed on the first two days.  We also observed security procedures and process to ensure that there was no crossover between licensable roles and actions of safety marshals present at the event.   

Sarah Runchman, our Head of Intelligence, joined the inspection to observe how an inspection unfolds, what obstacles we may face when out in the field and what improvements can be made in the process.  I also spent time walking around the site with local licensing officers working jointly to check security at the venue. 

On the day the event opened we were able to observe the security teams carrying out their duties. This included bag searches at the gates and drug detection dogs being used amongst the crowds. We observed how successfully the dogs detected illegal substances with members of the public removed from the queue as a result.  

From left to right: SIA Compliance and Inspections team – Ariarna Moore, Lisa Shaw, Alison Hughes and Elise Winnett 

The inspection was successful with high levels of compliance found from security officers. We inspected 155 licences over the three days. We issued 13 warnings for failure to update address and a further 5 verbal warnings to security officers for failing to display their SIA licences.  

Conducting much of the inspection prior to the opening of the event allowed us to really engage with security officers and marshals and get a feel for how the industry is for them. Our presence at the event was welcomed, with many security officers expressing gladness to see us there. We met a very talented event marshal who is now training to become an SIA licensed security operative. We also witnessed an unprovoked attack by an aggressive member of the public on a door supervisor.  The door supervisor handled the situation with restraint and calmness, preventing any escalation. Watching the incident unfold in front of us highlighted just how difficult a door supervisor’s job can be.  

Overall, it was a rewarding experience to be part of the event and to ensure levels of compliance were met by the security present.  I am grateful for the positive interactions and the opportunity to witness the dedication of everyone involved in ensuring safety of the public and property at the event.  


Jo’s Day in a Life at Reading Festival

One of our Investigations Officers, Jo, takes us through two days on site at the Reading Festival, as part of our SIA team ensuring licence holder compliance.

The famous music event attracts over 105,000 festivalgoers each year, while the security provision numbers around 2,000 operatives.

Walking to the festival

Tuesday 22 August

10.45am I arrive at the festival command centre for the event. It’s home to control teams from the police, ambulance and fire services, as well as event control and security. There’s already an impressive buzz to the place. Communication equipment, monitors and displays are arranged in the centre’s multi use courts.

11.00am I meet the rest of our inspection team who are supporting me today. We meet the Safety Manager for the Reading Festival, and he takes us to the site.

Before we’re allowed in, we must go through a site induction and be given our access wrist bands. This was one of the smoothest processes we’ve encountered to access an event. We were impressed by the improvements to the accreditation process implemented since last year.

The weather was glorious – so no festival mud to traipse through.

When operatives arrive, they must scan in a QR code, which amongst other details includes emergency contact details, then they move to accreditation desk.

11.15am The Safety Manager takes us to the compound for one of the larger of the three security companies looking after public safety at the event. Two others are also supplying security. In the main accreditation tent, we get to grips with checking the process and how security officers coming onto the site are being checked.

Our inspection team splits into groups to do the same with the other two companies supplying security.

Firstly, we are assured of how their accreditation is set up. When operatives arrive, they must scan in a QR code, which amongst other details includes emergency contact details, then they move to the accreditation desk.

Each operative is checked against a staff list, their SIA licence is checked against additional photo identity and against the SIA register of licence holders, as well as a physical check of the card itself using an ultraviolet light to test security features.

It is a good set up and well run. We see people being taken out of the line to undergo further clarification on their accreditation, which shows due diligence on behalf of the security company.

Operatives then move through to pick up their uniforms, any equipment they need and a tabard, different colours for security staff and stewards.

Before they leave, they attend an initial briefing and one final SIA licence check.

It was a good set up and well run.

Next to the main stage

12.00pm Within the accreditation area, we undertake our own further checks on SIA licences and contact our operation control to confirm all is well.

By the time we finish, our team has checked 85 licence holders – all good.

It’s worth a note, that the total security provision numbers around 2,000 individuals across the whole weekend, less today as the event is still setting up. But the number of operatives on duty will increase when the festival opens to the public.

1.30pm We man the gatepost where operatives enter to undertake initial checks before they get to the accreditation gate.

2.00pm We return to the main security compound and meet back up with our team who have been doing similar checks with the other companies.

After a brief break, we go to see the deployed security staff. There’s security staff at three gates to the site and more dotted around arena and stages. We go to the main site gate then walk into the arena, checking staff as we go.

On our way back to the security compound, we hitch a ride on a buggy. We are held at a junction to make way for a convoy of 12 ice cream vans!

5.00pm We meet our team and make our way to the exit performing a few more checks along the way.

6.00pm We’re signed out of the site, and I can make my way back home. I endure the M25 again and when I get home, spend a little time catching up on emails and messages before signing off the day.

Thursday 24 August

Jo, Elsie, Dawn and Michelle on site

11.00am We arrive back at the command centre and meet with our team including our Chief Executive, Michelle Russell who is joining us today.

Despite threats of rain, and taking heavy coats and stout shoes, it was another glorious day.

By now, the festival is functioning rather than being set up. The campsites are filling up fast, there are already tents cheek by jowl. Concessions stands are open and the festival feels like it’s getting into full swing.

There are lots of people walking around, sitting about, enjoying the atmosphere, and getting to know where things are. Metal roadways along the main routes save these from turning into mud baths if it rains.

We can see a constant stream of people arriving, some with some strange luggage solutions; chairs strapped to backs, tents being dragged, sleeping bags hanging from rucksacks, things being dropped.

Security staff are now doing their job rather than being accredited.

Operatives are deployed walking around the camps, keeping an eye on concessions, undertaking access controls and deploying searches for main access areas.

There are eight camps in total; white, brown, orange, purple, blue, yellow, orange and eco.

Our team splits into a separate group.

11:30am We head off for ‘white’ camp, the furthest away, about a 30-minute walk. It was a good day for steps. I clocked up around 15,000 during the day.

White camp is over a temporary bridge built over a river. At each of the camps is a camp manager, store and security manager. We make further checks as the Security Manager radios his team one-by-one to come in for a check.

On the way back we check a further two camps. In addition, we sweep up any security operatives we meet as we walk through and carry out further   licensing checks.

1.45pm We stop for lunch sitting down for a well-deserved break. After which, we walk on a bit further to a site access point and carry out some more checks. We don’t interfere with the search area, as this is very busy.

2.30pm We visit the brown and purple campsites on the way back carrying out more licence checks.

4.15pm As we sweep our areas the other team does the same with theirs. We meet up at the main arena where another security company is providing service for the main arena with the huge stage. We introduce ourselves. The manager is helpful but very busy, so we carry out checks as efficiently as possible and let them get on.

“It was good to have our Chief Executive, Michelle Russell along to share our experiences and talk to her about the little things that can help make our jobs easier.”

4.45pm We decide to call it a day and sit in the command centre for a de-brief.

Overall, the team undertook a total of 85 checks during the day.

It was good to have our Chief Executive, Michelle Russell along to share our experiences and talk to her about the little things that can help make our jobs easier.

5.50pm Michelle thanks the event controller and we leave the site.

8.30pm I get home. A quick check in to catch up on emails and messages before logging off for the day.

Overall, the team completed 170 checks during the two-day operation. In addition, I created 14 watchlists and checked 637 licences prior to the event. So quite an achievement.  

This was the first festival operation that I was leading on, and I was pleased with how it went. Everything was well planned and everyone in the team, both (literally) in the field and at control did a marvellous job.

It was good to see the security provision being deployed to a very high standard. All the checks we undertook were positive, testimony to the work we do with security suppliers long before events take place.

Thank you to the SIA team, the security and events management companies and security operatives who all did a fantastic job in keeping the public safe over the two days.

“Everything was well planned and everyone in the team, both (literally) in the field and at control did a marvellous job.”

Minister of State for Safeguarding out on inspection with our compliance team in the City of London 

On Tuesday 12 September Sarah Dines, Minister of State for Safeguarding, accompanied our compliance team members and City of London Police on an inspection across six locations in the square mile. 

The Minister, Sarah Dines, and our Chair, Heather Baily met and spoke with frontline security operatives, including door supervisors and security guards. The Minister was keen to understand the role and the experiences of licence holders as well as speak with them about public safety. 

Our Investigations Officer, Kirsty Tagg shared with the Minister our ongoing work to tackle violence against women and girls in partnership with local boroughs and the police.  She also highlighted the vital training that operatives receive on recognising indicators of abuse and their duty of care to protect vulnerable people. 

The visits provided an opportunity for the security operatives to speak with the Minister and our Chair, and an opportunity for the Minister to observe our role in enforcing standards within the private security industry. 

The visits allowed us to meet security operatives with a wide range of experience of working in the private security industry. A couple of the operatives had been in role for over ten years, with one holding 18 years of service at the same venue. We also met with an operative who had only just recently received their first licence. 

One of the head door supervisors detailed that they had recently turned away a security operative, with what they thought may have been a fake licence.  

Using ultraviolet light, they had been unable to detect a lack of security features that should have been present on the individual’s licence card.  

We discussed the issue of counterfeited licences with the Minister and explained the ways in which we are tackling this issue by encouraging companies to undertake checks. 

The inspection was completed with a short debrief at the end of the night. 

It was a valuable exercise to introduce the Minister to the work we do out in the field, learn about the experiences of the SIA licence holders, and discuss some of the challenges we can encounter in our work.   

Our thanks go to Sarah Dines, her team, the City of London Police and to all who took part for their continued commitment to working with us. 

Christmas for the SIA Compliance & Investigation teams

John Sandlin leads the Security Industry Authority’s Compliance & Inspections teams. Here he talks about the additional work that Christmas brings as the night time economy gears up for the busiest time for bars, restaurants and entertainment venues.

John Sandlin leads the Security Industry Authority’s Compliance & Inspections teams. Here he talks about the additional work that Christmas brings as the night time economy gears up for the busiest time for bars, restaurants and entertainment venues.

When does planning for Christmas start?
Pretty much as soon as we’ve drawn a breath from the summer events season which finishes around the end of September. Then we start thinking about Christmas. We look at what inspection activity we might want to do and consider requests from partners (such as police, local authorities, and the HMRC) to undertake operations to support their own objectives too. We draw on the huge amount of expertise across the team from colleagues who know the environment well and can help identify issues we need to consider.

London, UK – November 3 2022: Christmas lights in Oxford Street, view at night

So what issues do we need to consider?
In the run up to Christmas there’s more footfall in venues. This creates an increased risk of harm to the public which in turn requires a bigger police presence supported by a larger private security resource. It’s the increased private security deployment that requires our involvement to make sure those working in licensable roles are complying with the necessary regulation.

Although there are variations across the UK, the police tend to focus on ensuring venues are licensed and adhere to the terms and conditions of that licence. This might cover maximum occupancy, fire controls, health and safety considerations and security provision. The police and local authorities are increasingly engaging with venues about protecting the vulnerable alongside checking venue licences. Actually, whenever they are out and about, most agencies talk about protecting the vulnerable as part of protecting the public.

Watch our ‘Helping people in vulnerable situations’ video here

How many of your team are involved in Christmas specific activity?
It’s fair to say all teams are doing some form of activity that directly supports or is impacted by Christmas, so most team members will be involved in that.

As we speak there’s a multi agency operation in Belfast around the ‘ask Angela’ campaign. We’ll be undertaking licence checks, whilst supporting the initiative with messages about the campaign.

Manchester, United Kingdom – November 25, 2011 – Big wheel in the City center of Manchester with beautiful lights during christmas preparation

What additional activities do we deploy for Christmas, is it more of the same or different actions?
We may undertake specific activities, especially if we have solid intelligence that provides a clear aim or benefit. However, Christmas is generally doing more of the same, but with a stronger focus on the night time economy. There’s a huge upshift in volumes and that’s the biggest difference. There’s still a need to continue with other work, for example we’re working in Oxford Street in London during the day, although, to be fair, that’s also connected to the increase in footfall in the run up to Christmas.

What do we do on the front line?
It will depend on the site and any objectives for an operation. However, primarily we’re interested in compliance with the Private Security Industry Act. So, we’re mainly checking individuals are correctly licensed and ascertaining the businesses that operatives work for to build our understanding of the makeup of the local economy. This is especially useful when newly formed companies emerge. We’re also interested in in how labour is deployed and what the labour chain looks like; the more links in a labour chain, the higher the risk of noncompliance. We also check individuals’ employment status which helps identify possible exploitation. Where possible we push other messages and support campaigns to promote awareness and conversations across the industry.

How do security operatives and venues react to your teams’ presence?
Mostly, we get a positive response. Generally, licence holders like to see us out checking licences as they don’t want rogue people in the industry. We occasionally meet one or two unlicensed operatives that may be a little reticent for want of a better word but using our skills we overcome those hurdles.

Do other agencies do similar tasks around Christmas?
The Police and local authorities will be undertaking checks based around venue licensing and will want to assure themselves that venues are complying. Sometimes they may support us on our operations, it depends on specific operations, or sometimes the location. For example, I’d be fairly happy undertaking checks in Westminster without police support but wouldn’t want to do so in other areas without them. That goes not just for London, but anywhere else, you get a good feel for what risks maybe posed in undertaking checks without partners.

How much does the night time economy grow over the festive period?
We always hear that businesses are at their busiest and it’s very true, there are more people in more venues over more nights of the week. There are additional Christmas get togethers with friends, socialising after work, organised office parties – it’s difficult to put a figure on, and it will vary from location to location, but it’s noticeably much busier. Let’s not forget this is the first Christmas without any COVID restrictions.

On top of venues being busier, there are additional entertainment venues and events to consider; pop up fairs, Christmas markets, ice rinks, entertainment offerings, temporary licensed premises.

How stable is resource in the night time economy?
If more door supervisors are needed because a company has a shortfall, then most companies will contract in staff from another to match the demand. However, what sometimes happens is the supplying company will in turn go to another to fulfil the request. This is not a problem as such, but it is a concern. With each company’s loan of resource comes a charge. This can lead to a squeeze on profit margins which is where corners can be cut. When that happens to the risk of improper employment and unlicensed personnel can start to emerge.

How effective are the operations we undertake?
Of course, we have limited resource and we can’t visit every venue. However, what we do has a definite ripple effect. When we’re in a large town or city, just by visiting a few premises, word gets around very quickly that we’re out and about undertaking checks and looking at licences. That has a great deterrent effect within the security community. So, we enlarge the size of our footprint. In addition, we work with colleagues in the Communications team to get the message out and again, this spreads across the community well.

What does it take to deploy an operation?
That’s a good question; lots of work.

Before we set foot on the ground, we undertake pre-inspection activity. This could be meetings with partners, considering intelligence we or our partners have received and undertaking a recce in the locality. We then need to work up aims and objectives before putting an operational order together. Information needs to be created within our database (CRM). Risks also need to be considered and risk assessments completed. We also need to secure resource from across the team and make sure everyone is available for the operation. In addition to staff on the ground, we always have an operational control to assist with licence checks on the STeP database, as well as then inputting the checks onto CRM. This can be quite a laborious task, especially if there are a voluminous amount.

Any last words?
The team are very committed. We have had a fair few new staff so as well as preparing and undertaking activities, experienced team members are also helping to train and guide their new colleagues in this crucial area of work. Everyone in the Compliance & Inspections team plays a part in what we do from the MST to the investigators themselves, supported by colleagues from other teams. The inspection activity being centred on the night time economy requires staff to work evenings and weekends to attend operations, which at this time of year means being out in the cold. I want to thank the teams, I appreciate everyone’s effort and support in keeping the public safe.

About the author

John Sandlin served for 30 years with the Metropolitan Police. He worked as an Investigating and Senior Investigating Officer for over 11 years investigating homicides and other serious crimes. He’s worked at the SIA since early 2015.

How we are tackling identity theft

In the last months, two of our prosecutions cases have highlighted how we have tackled the fraudulent behaviour of some licence holders and the challenges we face.

This month, our Director of Partnerships and Interventions, Dave Humphries, discusses our counter fraud initiatives and the steps we took in these cases.

Our blog aims to discuss developments in the private security industry and to provide further insight and opinion about our work. We look forward to having an on-going discussion with you; please share your comments and opinions.

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Most licensing systems are based on a set of standards and for us at the SIA our system is designed to ensure only appropriate people are given the licence to operate. This involves a number of checks to prove identity that people have the relevant qualifications, checks on criminality and verifying that a person has the right to work in the United Kingdom. Most applicants provide the information we need to make a considered decision.

But what happens when someone knows they will not qualify for a licence, but is determined to get one?  They may test the robustness of our checks and they may submit false documents to do so. We are constantly alert and we do all we can do to address specific threats.

One particular type of fraud that we face is identity theft.  It is not the only category of fraud we have come across, but it was a feature in two recent cases.

These two recent investigations have involved fraudsters stealing the identities of others, but being prosecuted by the SIA for their actions. In both cases, the fraud involved not only an attempt to bypass our online licensing system, but the two individuals also tried to get around the requirement of proving their identity by taking on the full identity of another, to get an SIA licence.

The first fraudster was Moses Oshunkoya who knew the person whose identity he targeted.  He used their personal information to the point that he was able to gain a passport under this new identity.  Using this false identity Oshunkoya got as far as fraudulently gaining an SIA licence.  Nonetheless, our investigation of him resulted in a criminal prosecution.

The second case was Kazeem Oladimeji who was more contrived in his approach. He sought out a former SIA licence holder no longer working within the industry.  He adopted that identity by purchasing a fraudulent passport in the victim’s name. He changed the licence holder’s address, enabling Oladimeji to replace an SIA licence.  Again, the outcome was a successful criminal prosecution.

Both examples show the real threat posed by identity theft.  In both cases, the victims who had their identity stolen contacted us. Once we were aware, we investigated and prosecuted the offenders to ensure their fraudulent activity was brought to an end.

What are we doing to combat such activity?

Thankfully, processing changes in recent years have and will make future cases like this less likely.  For example, we introduced personal online accounts which are password protected. This reduces the ability for fraudsters to engage with us without having access to the online accounts.

We have also made improvements to the way we verify documents. We have improved technology to better identify fraudulent identity documents.  When we do find instances of fraud, we take robust action with our enforcement partners to ensure such documents are taken out of circulation.  Finally, as these two cases highlight, we prosecute the fraudsters.

As the regulator of the private security industry, we play an important role in dealing with identify fraud and together with our partners, we take robust action to tackle such criminality.

Those working in the private security industry can support this by being our eyes and ears and reporting any fraud that they come across.  As with other types of criminality within the security industry; if you suspect fraud please report online or contact Crimestoppers.  Specific information and how the fraud was identified will enable us to take positive action.