FOI release

Training given in relation to assistance dogs or guide dogs

Published 6 January 2022

1. Request

• What training is given in relation to assistance dogs or guide dogs to security staff?
  • If applicable, when did this training get rolled out?
  • If applicable, who is responsible for training these modules?
  • If applicable, is this training provided as a refresher?
• Please provide copies of training modules relevant to assistance dogs/guide dogs
• How many complaints have been recorded relating to assistance dog/guide dog refusals to the SIA
  • If records of complaints exist, what were the outcomes (i.e enforcement action, warnings etc)?
• Please provide a copy of the SIA policy on assistance dogs/guide dogs.
  • If no policy exists, please provide an explanation on this.
• Please provide any other relevant information the SIA hold, produce, publish, present, relating to assistance dogs/guide dogs.

2. Response

The SIA holds the information that you have requested and a response to each of your questions can be found below.

2.1 What training is given in relation to assistance dogs or guide dogs to security staff?

Applicants for an SIA licence will need to achieve the relevant units for the regulated activity in which they want to work and which they need to get a licence for. This response will make specific reference to units required to obtain the Door Supervisor licence. The SIA does not and has never been expected to deliver training to the private security industry itself. The SIA is required to set or approve standards of training and this is done by creating and publishing specifications for learning and qualifications.

The ‘Knowledge and Skills Specification: Common Security Industry Knowledge’ sets out that learners must have an awareness of legislation as it applies to the individual in carrying out a licensable activity which includes but is not limited to being able to demonstrate an understanding of equality and diversity.

The indicative content sets out as an assessment criteria, identify key legislation relating to promoting equality and diversity in the workplace. The following topics must be covered:

• key legislation: Equalities Act 2010; Human Rights Act 1998
• protection from discrimination in the workplace:
  • protected characteristics: race/ethnicity/nationality, gender, religion or belief, disability, sexual orientation, gender reassignment, marriage/civil partnership, age, pregnancy and maternity
  • direct and indirect discrimination
• areas where equal opportunities legislation applies: recruitment; access to training; pay and benefits; promotion opportunities; terms and conditions; redundancy; dismissal
• employer’s duty to make reasonable adjustments

Learners must understand the importance of effective communication skills and good customer care which includes explaining the importance of understanding diverse customer needs and expectations.

The indicative content sets out as an assessment criteria, understanding how to communicate effectively as a security operative that involves recognising diverse customer needs and expectations. The following must be covered:

• types of customer: internal and external, direct and indirect
• customer needs/expectations: e.g. information, assistance, directions
• customers with particular needs: e.g. physical difficulties, learning difficulties, sensory impairment, English as second language, under influence of drugs and/or alcohol

Learners must know and understand how to keep vulnerable people safe by recognising their duty of care with regards to vulnerable people and identifying factors that could make somebody vulnerable.

The indicative content sets out as an assessment criteria, recognising the duty of care with regards to vulnerable people. The following must be covered:

• duty of care is: “a moral or legal obligation to ensure the safety or well-being of others”
• people may not always appear to be vulnerable so best practice would be to have a duty of care for everyone

It also sets out as an assessment criteria, identifying factors that could make someone vulnerable. The following must be covered:

• vulnerable: being under the influence of alcohol or drugs; alone or receiving unwanted attention; separated from friends; appearing lost or isolated; being followed or threatened; victims of domestic violence; young people under the age of 18, mental ill-health, learning disabilities, physical disabilities, being elderly, being acutely ill, Key behaviours associated with a range of invisible disabilities (physical, mental or neurological condition that limits a person’s movements, senses or activities that is invisible to the onlooker).

In the ‘Knowledge and Skills Specification: Door Supervision’, learners must know how to conduct effective search procedures.

The indicative content sets out as an assessment criteria, demonstrating how to search people and their personal possessions. The following must be covered:

• use of signage to indicate that searching could take place
• explain the search policy
• obtain permission of person being searched prior to the search
• follow venue policy / assignment instructions
• same-sex searching
  • follow same sex searching policy (inc. searches of transgender individuals should be performed according to the SIA’s ‘Trans customers: A guide for door supervisors’ guidance, available from this page on GOV.UK)
• use appropriate PPE
• use self-searching techniques (where appropriate)
• search with a witness or in view of CCTV
• consideration must be given to protected characteristics
  • age
  • disability
  • gender reassignment
  • marriage and civil partnership
  • pregnancy and maternity
  • race
  • religion or belief
  • sex/gender

The SIA does not know where or how individual operatives are deployed and are therefore clear that the training that forms part of the initial barrier to getting a licence may not be sufficient for all deployments. The SIA is clear that the mandatory training that applies to all operatives does not exclude the industry from legal obligations or good practice to provide the training that is required for a security operative to safely perform his or her role. The SIA is a licensing body and does not hold the details of where security operatives are deployed, and is therefore unaware of the site specific situations that security operatives may face. It is for this reason that the SIA make clear that the training requirement set for the purposes of licensing individuals are a minimum standard and may not equip security operatives for all situations at events or venues that a security operative may be deployed to. An event or venue assessment may identify additional training that security operatives would benefit from. I believe that this is commonly understood within the industry.

2.2 If applicable, when did this training get rolled out?

The content referred to above was published in February 2021 for implementation in April 2021. Content on equality and diversity and customers with specific needs has been in place for at least the last 10 years.

2.3 If applicable, who is responsible for training these modules?

The training is delivered by training providers who are in turn approved and audited by one or more awarding organisations e.g. BIIAB, Highfield Qualifications, NOCN, Pearson BTEC, Qualifications Network, SFJ Awards and Trident Awards.

2.4 If applicable, is this training provided as a refresher?

No.

2.5 Please provide copies of training modules relevant to assistance dogs/guide dogs

I have attached to this email:

• Knowledge and Skills Specification: Common Security Industry Knowledge
• Knowledge and Skills Specification: Door Supervision

The SIA does not hold the training materials used by the training providers.

2.6 How many complaints have been recorded relating to assistance dog/guide dog refusals to the SIA?

The SIA does not run a formal complaints scheme in relation to the conduct of businesses or individuals operating in the private security industry. Nor does it operate a complaints scheme in relation to licensed premises.

When the SIA receives information from a member of the public regarding the conduct of a private security business or its operatives it is treated as intelligence. This is because any information received can only be utilised by the SIA in so far as it informs any investigation into breaches of the PSIA or the licence / ACS criteria and conditions.

The SIA does not typically release intelligence or provide an update regarding any action taken in relation to intelligence. This policy was developed in line with the FOIA; which provides public authorities with an exemption from disclosing information relating to investigations and proceedings an authority conducts (section 30) and from disclosing any information that would prejudice the authorities ability to exercise its statutory functions (section 31). Subsection (3) of both of these sections provides the SIA with an exemption from confirming or denying whether any intelligence is held.

The SIA acknowledges there is a public interest in the public being made aware of whether and what action is taken by the SIA in relation to intelligence it holds because it allows for public scrutiny of its effectiveness as a regulator and contributes to public confidence regarding standards within the security industry. However, the SIA considers there is a more significant public interest in ensuring that the disclosure of intelligence should not prejudice its ability to conduct is investigations and exercise its regulatory functions, for example by protecting the integrity of ongoing and/or future investigations.

2.7 If records of complaints exist, what were the outcomes (i.e enforcement action, warnings etc)?

Not applicable.

2.8 Please provide a copy of the SIA policy on assistance dogs/guide dogs

The SIA does not have a specific policy relating to assistance dogs/guide dogs as the SIA equality, diversity and inclusion policy incorporates the approach that would be taken in respect of individuals with assistance dogs/guide dogs.

2.9 If no policy exists, please provide an explanation on this

Not applicable.

2.10 Please provide any other relevant information the SIA hold, produce, publish, present, relating to assistance dogs/guide dogs.

Section 15 of the Private Security Industry Act 2001 requires the SIA to run an Approved Contractor Scheme (“ACS”) which is a recognised hallmark of quality within the private security industry as ACS businesses have been independently checked against performance indicators and are the top suppliers of security industry services. Businesses that are not members of the Scheme should strive to meet these standards.

The ACS Self-assessment Workbook sets out at Criterion 6 relating to people that a defined policy relating to equality and diversity must exist which is implemented and communicated and the induction pack must include the organisation’s guidelines on equality and diversity.

[Reference: FOI 0303]