EP 140 Why Labour Exploitation is Security’s Unseen Threat – Paul Fullwood, Former Director of Inspections and Enforcement of the Security Industry Authority, Speaks

Career

Paul joined the SIA in 2001 after a 33-year career first in HM Armed Forces and then in the Police Service.

Paul retired from policing in 2020 as Assistant Chief Constable (Specialist Policing Services) for Bedfordshire Police and the Cambridgeshire and Hertfordshire constabularies, with responsibility for major crime, armed policing, counter-terrorism, and specialist policing services.

Paul was the National Policing Chiefs Council (NPCC) lead for the strategic investigation of complex, sensitive, and serious crime. In this role he advised on policy, mentoring, and developing executive senior law enforcement leaders and senior detectives.

Paul has been a detective at every rank and has served previously with Sussex Police, National Crime Squad, and Cambridgeshire Constabulary, having led several high-profile investigations on a national and international scale.

Paul was the Gold Commander for the tri-force response to the COVID-19 pandemic, with responsibility for all collaborated services across Bedfordshire Police and the Cambridgeshire and Hertfordshire constabularies.

Paul continues to provide support across UK law enforcement as a College of Policing associate and advisor. This includes leading on sensitive national reviews on behalf of the NPCC.

Since joining the SIA as Executive Director in 2001, Paul has sought to transform the Inspection & Enforcement Directorate, putting public protection at the heart of all activity, through effective strategic partnerships, proactive engagement and increased operational impact across the UK Private Security Industry.

Paul led on the SIA response to the Manchester Arena Inquiry Recommendations, working with industry and Home Office to provide an informed SIA position which fully considered views of industry and further enhanced public safety (business licensing/removing the in-house exemption). This is currently subject of a fresh review by the Home Office.

Paul has provided evidence at the Home Affairs Select Committee on ‘Spiking’ alongside other national experts and meeting the safeguarding minister (Jess Phillips) with other key stakeholders to support enhanced public protection activity across this key area. He continues to represent the SIA at national level with key strategic partners.

Since 2024 Paul has led the SIA response to tackling ‘Labour Exploitation’ called Operation Empower working with HMRC and key stakeholders from across the UK private security to raise awareness and tackle this dreadful crime which impacts on some many people.

Paul is also the strategic lead for Operation Benchmark, the SIA response to tackling training malpractice, fraud and criminality, also working with Ofqual and Awarding Organisations to raise awareness and seek to reduce the opportunity to undermine public safety in this critical area

https://www.linkedin.com/in/paul-fullwood/

Security Circle ⭕️ is an IFPOD production for IFPO the International Foundation of Protection Officers

Transcript

0:01

Hi. This episode featuring Paul Fullwood was recorded when he was working with the SIA. He has since left the SIA, but as you can tell when you listen, he was incredibly passionate about all of the big challenges. The SIA face. Paul, we wish you all the best in your new ventures, okay? If you enjoy the security circle podcast, please like share and comment or even better. Leave us a fab review We can be found on all podcast platforms. Be sure to subscribe. The security circle every Thursday. We love Thursdays. Hi, I'm Yolanda And welcome to the Security Circle Podcast, produced in association with ifpo, the International Foundation for Protection Officers. This podcast is all about connection, bringing you closer to the greatest minds, boldest thinkers, trailblazers, and change makers across the security industry. Whether you are here to grow your network, spark new ideas, or simply feel more connected to the world of protection and risk, you are in the right place wherever you are listening from. Thank you for being a part of the Security Circle journey..

Yoyo: 1:37

Well, I have with me today. The long awaited Paul Fullwood, Director of Inspections and Enforcement of the Security Industry Authority, more commonly known as the SIA in the UK. Because there is an SIA in America as well, isn't there, Paul?

Paul: 1:53

I think there is, yeah, but it's probably going to come under lots of different names, but you're right. But the UK, the SIA, Security Industry Authority, so we're very, very grateful for the invitation to speak to you today, Yo Yo.

Yoyo: 2:04

Well, listen, we've been cooking this up for a little while now, haven't we? And we recently appeared on a webinar that I was very privileged to host talking about labor exploitation, where you featured as a panelist, along with some peers from the HMRC, and also,, Paul Evans, Carlisle Security. That went well, didn't it? What do you think that we achieved in that, webinar, Paul?

Paul: 2:27

I'll take a step backwards and labor exploitation just looking at its entirety. And I know that, you know, this is one of the things where I think is the regulator. We're aligned, I think, with the views of the industry on this. It's one of the big, big risks across the UK. And I think the webinar that you hosted and, I think Carlisle were there and HMRC and us as the SIA and other people as well, is that it was a good opportunity to continue that conversation about some of the issues to think about, to recognize some of the threats, risks and harms, the impact on public protection and public safety, the erosion of standards, the exploitation of individuals, buyers, suppliers, and much more. There was loads, there was loads, so I thought it was really good. It was good, good start, let's continue the conversations.

Yoyo: 3:14

I think from my perspective, I've been on that frontline myself personally as a security officer. I had a license for, I think, from 2009 to around about 2018, possibly. Even later, 2019, 2020, so a long, long time. And also, I managed a lot of people on the front line. Even I was surprised at the number of components and different people that need to be involved now in this broader conversation. It isn't just down to the front line providers, is it? And it isn't just down to the SIA to fix this issue.

Paul: 3:51

No, no, it's it's a really, really broad issue really and I think it's probably got worse probably post COVID the pandemic. I think what you find is that, you know, a lot of, you know, the business model in terms of labor supply. And, you know, trying to get resources very, very quickly is very much, being managed through social media. It's much, much quicker. WhatsApp groups, Facebook, and other things as well. Phone calls and people that they know. And there's some really reputable organizations that do do it. I think, you know, as you will know, you know, we regulate individuals in the UK, private security industries, regulate, regulate individuals, don't regulate businesses. So in terms of the checks and balances, the opportunities for exportation are far higher than ever. And I think what we've also seen is we've seen, you know, we're nearly, we're approaching nearly half a million individuals who are licensed as security operatives. Not quite yet there, but we're about 460, 000 and some of those people carry double licenses or licenses across different sectors, but what we are seeing is big increases in rest of the world application. So people coming from overseas, whether that's for student visas or working the UK and we are seeing exploitation. We're seeing people who are being paid way below the national minimum wage, which is illegal. We're seeing people being exploited in terms of their working conditions, their working hours, an erosion of standards, um, and even language issues, which I know is one that we're forever, you know, being asked about and challenged about, rightly so. And so it's a big issue. And I think the conversation that, you know, you hosted and we did with Carl on HMRC is, is an ongoing conversation. This is now core business. But it's not, but it's not, I guess, really the bit to sort of get across. And I know you know this, and I think we've all said this, there will not be one agency or one company that will solve this on its own. Really, it needs a real partnership, collaborative approach. It needs buyers of security to be professional, to make sure that, you know, that they're doing it in a professional way and that, you know, the people that they're employing or they're securing services are, you know, are professional. It needs suppliers of security to make sure that they pay their staff fairly, they treat them fairly and they do what needs to be done. And it needs the agencies like HMRC and the SIA and the Home Office Integration Service to make sure that we deal with those people who fall way below the standards really. So it's an ongoing, it's an ongoing obligation and, um, and it's one that now there's, there is a whole sweep of activity that's taking place. Thank you very much. And that will continue. And certainly from the SIA's perspective, we see this as core business.

Yoyo: 6:30

Well, look, I'm going to try and do this gentleman justice, and this is a little bit off the hip, but I saw a post, it went out last night, so that'll be Sunday night. We're hitting this up, aren't we, Paul, on a Monday morning, apparently the most depressing day of the year. But this gentleman has clearly, I can't find the post, I may not have commented, which is why it's now got lost in the notifications history, but he, he was a reasonably mature man. certainly not at the, very mature end of the scale and neither at the very young end of the scale, but he was right bang in the middle. And he's talking about, the harm. To his career, the harm to his industry, working on the frontline, what does he do? Does he do some more training courses? Does he look for another career? Is he too old to train? Is he too old to learn more? But he doesn't like the way that he feels in his industry sector, on the frontline, in a security role, because it's been devalued so much by those people who aren't taking it so professionally. What would you say to him? And I appreciate I gave you no notice for this question at all.

Paul: 7:36

No, no, it's a fair question, and it's one that we're asked on a regular basis, whether it's, you know, in person at events or even social media, really, I think, in fairness, I think I can see this individual perspective, because I think if you look at it, we've increased the amount of security operatives across the UK. The reality is, is that is that security operatives now are doing far more than they were doing 20 years ago, um, in terms of, you know, we expect far more from individuals in terms of public protection and public safety. And other agencies, for example, like the police service or even local authorities have pulled back. That's not a criticism of them. That's just because they are now focused on other areas and trying to deal with them. So I think for the individual, so in terms of security, there's a lot more security now than there ever used to be. I think also, Whilst we regulate individuals, we don't regulate businesses. Um, and I say this is the sort of like the, you know, the regulator. Um, and so there is that opportunity for exploitation. There's that opportunity for businesses, you know, non reputable businesses not to behave as we would expect them to do now. We know Some really, really great, great businesses. You know that from your own experience. And there's lots of people that's really great businesses, some great CEOs and leaders do a fantastic job. But we also know it's far too easy for businesses to behave in an improper way. Phoenix in setting up, closing down, paying people less than they should be paying, working in a particular way that You know, really, really undermines trust and confidence and going back to this individual that you you flagged up is I can see some of the gaps and some of the weaknesses, really, so I don't think there's any easy answers at the moment in terms of where we are. I think we just need to try and work our way through. In terms of this particular area around how we can try and work together with industry and work together to try and increase awareness and trust and confidence in this particular area.

Yoyo: 9:35

Let's enter the critical thinking space now and I think it's nice to look ahead and look back to now. Let's say that we're sort of five, ten years in the future. We can look back and say, Crikey, you know, it got a bit dirty. It got a bit seedy. People were starting to, feel devaluated in their jobs and they shouldn't, but we cleaned it up. What does good look like, Paul? And I appreciate this doesn't sit wholly on your shoulders.

Paul: 10:01

No, no. Well, it's brilliant. So we're not. As we're not allowed to lobby in terms of, you know, new powers and new legislation, but it's not, you know, it's not a, it's not a state secret that, of course, we follow in the Manchester arena. Inquiry in the recommendations, we were keen to bring in business licensing that wasn't supported by the government, uh, you know, respect their decision in terms of doing it. But, of course, our positions always remain the same that that that should be brought in. And we've made our position clear through our chair and I'll have a baby in our CEO, Michelle Russell, certainly myself and others when asked a question. So I think for me, there's a gap there in terms of where where we are. Um, I think the way that we try and mitigate this now, though, is we've obviously got from a business perspective. We've got the approved contractor scheme, which is currently being reviewed on. We've got the the bass, uh, scheme, which effectively is a business, uh, advisory scheme, which is a sort of refresh and, uh, relook at the approved contractor scheme. And that's been led by one of my colleagues, Tim Archer, a really experienced director with his team, Jane Dubois and other people. And I know that they're working really, really hard to try and fill that gap from a business perspective, and they will work with industry to do that. So for me, that's a real, real positive step forward, I think, in terms of trying to tackle that. I think the other part of it is around continuing to work in collaboration with industry. And you know this, probably just before Christmas, I We invited in the 30 private security companies across the UK, um, and we had an honest and candid and frank conversation. Oh,

Yoyo: 11:42

was it? What can you share? Because I know a lot of people would love to hear some great news from that collaboration.

Paul: 11:49

Yeah, no, In essence, it was it was jointly between us, the SIA and HMRC. We invited the top 30 CEOs in, not all of them attended for one reason or another, but I'm sure that they will attend. But the main things that came out of it is that we had a very candid conversation about the challenges we all face together. We also had a very candid conversation that we need to work in collaboration, and there's much. Reminded people around, you know, some of the challenges, um, and legal obligations on individuals. So, for example, if you are a senior leader of a big private security company, you know, there's legislation that HMRC use called agency legislation, which makes it very, very clear that, the days of you sort of, just turning a blind eye to multiple subcontracting and allowing that to happen. To being used, you know, by others for, for labor exploitation that that's just not acceptable and that will be dealt with by HMRC. So it was very much a candid conversation about we need, we will play our part and we'll do what we need to do. And HMRC will as well. And the Home Office Immigration Service will do. But we need industry to do the same. We need industry to do the same. We need the senior leaders to be part of the solution. it's very easy just to look at the regulator and look at other organizations. But the reason labor exploitation exists, yo yo, just being candid, this is driven by the industry. This is driven by businesses. This is driven by a race to the bottom in terms of where costs are being pushed down, etc, etc. And if we're really If we're really sensible and professional and we want to try and, you know, deal with this with integrity, you know, and honesty and, you know, transparency, then we all need to work together. So it was that sort of conversation and they all come away from it. We all agreed that we were all going to come back again in in the spring. So in March, just to talk through further learning and some lessons about how we can continue working forward together.

Yoyo: 13:54

It's really encouraging to be honest with you to even get that far and to have so many significant key decision makers around the table, Paul. So to your team and to the HMRC, congratulations on even getting that far in getting that I should imagine it was quite cathartic to a lot of individuals knowing some of them, to sit around that room and sort of have that conversation where we're all in this together guys and galls, whether we like it or not. This is something we have a joint collective responsibility take, a position of efficacy on. Did you get that kind of commitment without saying, I appreciate you don't want to reveal anything, you know, we're not here to gossip. but did you get that? Did you get that everybody realized they were all in the same?

Paul: 14:42

Yeah, it's really interesting actually, uh, yeah, yeah. And you'll know this. So they're all competitors. So let's be really candid. They're all competitors. So they're all competitors, but obviously a lot of them know each other. But I think if I'm being honest, I think., there was a realization and there was some really senior people at the summit, which was really, really helpful. But there was a recognition that this is a real issue, that this is not going away, that we need to try and tackle it together, you know, and, you know, legislation, one thing, but actually there's a lot of working practices and collaboration that we can do together. And so I, I got a real sense that, um, Absolutely. And I think we all come away thinking, you know, we should have done this a long time ago. We should be engaging this level a long, long time ago. and it was quite interesting as well, because, of course, people have different, there are some companies there who, Do very little subcontracting. There's some that don't do any at all. There's some that do quite a lot and it's quite interesting listening to their perspective on things and also it's quite interesting watching their reactions to our presentations about what we would expect and what the law is and vice versa. And I think sometimes as well, I think when you're really, really senior leader and I think we're all guilty of this sometimes. I think when you're really, really senior leader, you haven't always really got your feet on the ground. You're always being reassured by lots and lots of other people You've got to actually go and find out for yourself, I think you've got to actually put you, you know, you can talk the talk, but you've got to walk the walk, as I say, now and again, you've actually got to go in there and just find out that if is truth to reality, really. So, yeah, we come away, with a positive vibe that, we're all going to continue working together and I hope that continues as well. You know, I really, really do.

Yoyo: 16:24

Good senior leadership make a point of going out there, don't they? I know that, it would be remiss of me not to mention that Paul Evans, went out to one of the very famous hospitals that had a big, big incident recently. Um, I know of other very senior leadership who make a habit of visiting sites, uh, on Christmas day, uh, because they go out and appreciate, you know, With that personal touch, and I think that that is important to stay in touch, but we know we can't abdicate responsibility in leadership. For example, we not all subcontracting is bad, but if you're subcontracting to a code of ethics, that means that you're not then further allowing that subcontractor to then subcontract on, That can be managed. And I think where companies can go wrong is to abdicate that responsibility. We subcontracted it out. Therefore we subcontracted out the pressure, the burden, the liability, all of those things, you know, that is now down to somebody else to get right. And I think abdicating at that point is very dangerous and it could lead to further exposure in the future.

Paul: 17:31

Yeah, I mean, I think you're right., and you are right. there's some really, really good subcontractors and, you know, and certainly not as the regulator to say that you shouldn't subcontract because that's a business decision. And it's not for us to say that. but I guess really what I would say is that what we can say is when we see multiple layers of subcontracting, we see an erosion of standards. we can say that, you know, we've been, I've been on inspections when I've been out with my team and, you know, and I've asked, you know, men and women on the front line, who you're working for, what you're getting paid and they haven't got a clue, they know what they're getting paid, but the pay levels are so different from, in terms of across the issues. I think you're right. I think probably as well. Yeah, it's probably worth me just sort of flagging really what we find. We launched, several months ago, we launched an operation called Operation Empower. and at the moment, we've got something like 150 investigations on the go, which we work jointly with HMRC. now we you. We have to be very, very clear because we're not the, we're not the, we're not the primary agency for tax evasion. That's HMRC. But if we see any breaches of PSI legislation, of course, we will deal with them. And of course, we've got a wider responsibility for public protection, which we will always follow, but some of the four major themes that we always. C really is, you know, tax evasion, failing to pay national insurance, people being paid below the national minimum wage, which is a criminal offence, and visa abuse, you know, and it, and it's really, really sad. And, you know, we've, you know, we, we've been on numerous operations, you know, big national operations with other agencies, you know, we've been to all sorts of sites, festivals, events, building sites, et cetera, et cetera. Um, and it's a real mixed bag, really, you know, there's some really, really good. Good visits and good inspections and things we do. And I have to say the vast majority of people do a great, great job and do, do well. But some of the things we, we come across are quite sad. And I, and I think we collectively, all of us have got responsibility to try and try and raise awareness and try and tackle that as best as we can do. Now, we don't want to. We don't want to prosecute people. We don't want to take people's licenses away from them unless we have to. We just don't, we don't want to be doing that. But, but the reality is, is that, you know, this is a real issue that we all need to work together collectively across the industry to try and tackle.

Yoyo: 19:52

It becomes like a two tier security situation, doesn't it? With, you know, those looking, those that are supported potentially even in house, uh, always looking down on the lower class. Quality, lower credibility, lower reputational, you know, contracted security. I've never ever been to a site where I felt the contracted security were really valued in the same way as the, in the in house team. So that two, that two tier system does exist. And then I think you've got a three tier with the, you know, that bottom line where, you know, That they don't even know what company they're working for. And they don't even know what their hourly rate is. It's just like, turn up here, get here, we'll sort the rest out later. And, and I, and I can certainly take an appreciation that there is a proportion of, uh, individual who genuinely just wants to work.

Paul: 20:42

Yeah.

Yoyo: 20:43

Um, they, they, and it's quite, um, Emotive when you think about that, because there's a lot of negative press at the moment. I say negative social media around immigration, but who wants to really stop a sincere individual from just earning a good day's pay for a good day's work. And I, and I think we have to, I think we cannot. Again, that these are humans at the end of the day, and I like the way that you showed empathy there in terms of not really wanting to take people's licenses away from them unless you can see that egregious, mistake has been made.

Paul: 21:24

I think you're right. It's quite interesting actually, So festival season last year, and we covered all the major festivals and events and in support of Operation Empowering Labour Exploitation, we created a questionnaire that was more person victim focused. Yeah, so we wanted it to be person victim focused because we wanted to really, really understand about the impact on individuals. And I also want my staff to understand the impact on individuals as well. You know, whilst we're the regulator, you know, we, you know, we need to be doing it responsibly. We need to support people. And protect the public and that includes our security operatives and it was really an eye opener in terms of when we spoke to individuals about the disparity in pay, how they were treated, their working conditions, student visas, where they stayed, how they were managed, who they were working for, et cetera, et cetera. Um, and for me, if I'm being honest, it brought up more worry than, than reassurance really, because I thought to myself, wow, you know, this industry is really. You know, there are, there's some really great people doing a great, great job. And I have to say a lot of people that we met were really professional, wanted to do a great, great, great things. But there were some cases there that we have ended up following up with organizations and managers and companies just to make sure that these individuals are not being exploited and they're being treated and managed fairly and properly, really. And that's what we'll continue to do, you know, and I, And even now, you know, when we we've got a dedicated team focuses on labor exploitation, we can see we can see links across to serious and organized crime and training malpractice, you know, and we've got cases of individuals who've been brought from overseas who have then gone through a a training provider, which is, we've since dealt with, with the organisations and have then gone on to being paid way below the minimum wage. We've got cases of being paid, people being paid, you have six to seven pounds an hour, which is just terrible. so there's a lot this, these are isolated cases but the reality is this stuff goes on. Um, and so we all need to, we all need to play our part to sort of raise awareness and do what needs to be done. there's a couple of ways people can do this. Yeah, yeah. And if I may just, you know, people can, people can report online on our website. It's really easy. Just click on it and you can do it. And literally you just add comes through to us. Every case gets looked at. you can report it. In confidence through, we've got a crime stoppers hotline where people don't have to give their details. We can deal with that way, or you can report it via one of our inspectors, and I often see things on social media and you will do the same. So I know you get copied into them as well. And I look at them and we monitor social media as best we can do, but I often think to myself, if you can see it and you're aware of it, you need to do something about it. Because if you're not doing something about it, you're part of the problem. And I really think that, we need people to take responsibility. And we will always. take action, whether that's advice, guidance, review, we'll always look at them. So we need people to really, really play their part for being honest.

Yoyo: 24:32

And I think broadly, what does exacerbate the whole picture is the fact that since Brexit, it has been harder for the security industry to recruit good quality personnel. as well. And we could see that happening in 2020, 2019, before COVID. It was getting harder. And if anything, when I used to have a CV come across my, hotel chair, because I'd quite often go to a hotel and interview regionally., if I saw that they'd worked for Ultimate, For example, they always had really, or even Wilson James. I'm going back in the day now. there are a number of companies that have this legacy of quality hiring reputation. And you'd take them if you've worked for Wilson James, if you've worked for, this on this site, we know you're good enough to do that job. and so there was an awful lot of recycling, but. Not an awful lot of what I call fresh talent coming through and certainly nobody leaves college these days having worked hard to get a series of A levels or B levels, to then turn around and say, I'm going to go and put myself out in all weathers in the cold and I'm going to go and do this job. Yeah, there are some significant challenges and I think If only there were quicker solutions to not to having resource challenges.

Paul: 25:52

Yeah, I think you're right. I mean, there's some light at the end of the tunnel and we've got this apprenticeship schemes that are on the go, which are going on. We need to continue with those, those have started. There's more work we need to do, right across the industry. But I know that's already happening and there's some people coming through that, which is good, but you're right. I think as well, you know, from a gender perspective, I think it's something like we're still something like 10 percent females within the private security industry, not enough, and you think to yourself, you're thinking, wow, you know, there's just more work we need to be doing. I think in terms of career wise. I think you're right. it's really interesting. Actually, we've got a conversation going on the side at the moment around, you know, Standards and about the, the sectors. And I know that next year or so this year should say 2025 is that we're going to be looking at, our licenses about, are they appropriate now in terms of the sectors and vice versa. And I know Tim Archer's got that, who's the other director, he's got that in hand. But I think there is a real conversation around what more can we do to make this a career for people because it could be a really fulfilling career, a real rewarding career. It's really high level. You know, you think, Martin's law, you know, I do think there's lots of opportunity. It just needs to be coordinated and managed in a particular way.

Yoyo: 27:02

I think it should be sold as a career of opportunity. I mean, look, because in 2009, after I left the police, I went and put myself on the front line, working on a shopping mall for 7 to an hour, which was an average going rate at the time for 2009. 13 hour shifts hurt my feet like hell, but, now look what I'm doing. I'm having a chat with Paul Fullwood with the SIa. It's definitely a land of opportunity out there for one, I'm living proof of that.

Paul: 27:30

Yeah, you know, it's interesting as well really, I say this, so I, similar to you, I came from the police service and I, I retired from policing in 2020 and I had no intention to ever go in, back into full time work. I've done my career in policing and I, it was interesting actually, I thought I'd led as, a gold commander, as chief officer, lots of big operations and events and I thought I knew about private security. This is honestly, I thought I knew about private security. I knew nothing. I knew nothing, honestly. I didn't really appreciate, I mean, my, my Detective and crime, I guess, really, but when I did look after the events and public protection and this and that it's only when I came into the SI as an interim and then obviously stayed there as a full time director, but I really, really learned and spoke and I got so much out speaking to the industry, people like you and other people and, you know, going on inspections and learning stuff and learning and I realized that I didn't really know very much, to be perfectly honest, beforehand, that sounds, I'm being honest, I didn't, I, but now I know quite a bit. I know quite a bit, and I now, and I wish I knew that when I was there, and the more I ask and look, the more questions and things happen in front of me, and I ask questions like, how have we ended up with this? How does that work? How's that linked into there? Um, et cetera, et cetera. so I think it's a really interesting industry. I think there is great opportunity. There's some brilliant people in this industry as well. You know that? And I know some fantastic people, real forward thinkers, entrepreneurs and people who are doing a really, really brilliant job and do lots of good public protection type stuff and provide a brilliant level of service. But unfortunately, there are some charlatans as well. and those are the people, I guess, really, that most of my efforts now in SIA are focused on trying to counter their activities, really, because they undermine The really good work from, the honest, hardworking men and women for the UK private security industry.

Yoyo: 29:26

I'd like to go back to your question. We mentioned business licensing. My understanding was that business was in favor of having the SIA manage the business licensing element, but government wasn't. That's a great shame really, because that meant that at the time the government didn't listen to what's the general consensus. And when an industry in the main turns around and says, you know, we want this, was, it was a shame, that result, wasn't it?

Paul: 29:54

So the Manchester Inner Inquiry. Myself and a guy called Ronnie McGorkin, we led the project for business licensing, and it wasn't just business license. It's about removing the in house exemption, that exists at the moment. And we work with the Home Office, and it's exactly as you said,, there was stakeholder, You know, there was real engagement, lots of different stakeholders, and we listened and we went there for fresh perspective. We didn't have no baggage. we went completely fresh. We weren't involved in any conversations previously around business licensing. So there was stakeholder engagement and there was also independent research undertaken by the Home Office. And our own views, and I think from the stakeholder engagement from the independent research and from our perspective as the regulator, we were left in absolutely no doubt that business licensing should be brought in, we saw it as a, this would really, really benefit public protection, public safety, some of the things that we see around labor exploitation around multiple subcontracting about, you know, stuff going on that we would, we would not like, um, we thought this was the right thing to do that, that went through to the previous, Administration government, um, and they made a decision that they didn't believe that it supported the public protection aims, which, um, you know, we publicly gone out and effectively sort of said, we've got a very different view. Um, and I was very pleased and proud that, you know, I remember. Presenting the facts to our CEO, Misha Russell and Heather Bailey. And to be fair to them, they, you know, scrutinize the plans and the proposals, but we're bought into our position on this and they publicly likewise, you know, make their position clear as the SI board. And I know very recently that, you know, that's, you know, when asked by the new government, that, you know, we've always said this is our position, um, right thing to do. Um, and we, and, and, you know, what's quite interesting, actually, you know, how often do you get a particular subject where you get the industry stakeholders and the regulator all sort of agreeing on the same thing, like completely agree. I mean, it's quite sometimes it's quite, but you do, I mean, it's just, it's quite bizarre, really, but yeah. But we were left in no doubt it was the right thing to do, but we'll see, we'll see what happens.

Yoyo: 32:06

It was unforgettable, to be honest with you, that's why I thought I'd bring it up. Um, look, there are some really, uh, significant agitators, uh, at the moment, and I'm going to use that word in an incredibly positive way, because you've only got to look at what the likes of Lee Turner are doing to highlight the These what we call marigold organizations working at the end where it's so dirty, you've got to put marigolds on. I like learning that term. When I spoke to him about how he's trying to raise awareness, his podcast flew out and off the shelf quicker than any other podcast I've ever done, which demonstrates Paul, there's a huge level of interest in this conversation. Um, and I think, you know, In essence, he's reaching an audience on LinkedIn on social media that we, we haven't collectively been able to reach yet. And I certainly think that's worth exploiting because I, I had no idea about those WhatsApp groups. I had no idea until I started observing one. And if you want to support, uh, by just keeping your eyes on, you know, what's going on, on that, on that bottom end, uh, reach out to Lee Turner because he'll let you have access to certain WhatsApp groups where they're literally trading, uh, hourly shifts and trading jobs, uh, for derogative way of saying it, I know. Um, And you're also, I also saw there, you know, the kind of the delivery driver element, you know, the moped guy who's going to deliver your pizza at 8pm. There's a lot of trading of those tickets going on in the same WhatsApp groups, which again, I would never have known about if I hadn't taken an interest to observe what was going on myself. And I'm thinking again, going back to that human element, who wants to get on a moped at 8pm at night in all weathers and go and deliver pizza to places you don't know. It's pretty scary going out there at certain times of night, certain areas of the country that you wouldn't want to, you know, ride into. And yet there's people out there that they will just trade on those tickets to be able to just go and work and earn some money. we need more agitators, I think, because they are certainly stirring up. the mud from the bottom, and they're causing, the right amount of awareness and attention. What would you say to anybody else who's taking a very ethical position on this and say, look, yeah, I can't let this sit now. Paul, I want to do something. What can I do?

Paul: 34:36

What would you say? Yeah, I wholeheartedly agree with what you just said there, Yo Yo. I think, Lee Turner and others, there's other people that I've spoken with and others that they're ambassadors and champions trying to. Trying to do the right thing really. I think the current times of really, you know, fed the sort of the mode of how people, deal with labor exploitation and resourcing and WhatsApp groups and social media, et cetera, et cetera. I would be saying to, you know, to individuals certainly listening to this podcast is that, look, if we really, really want to professionalize the private security industry across the UK, we really want to professionalize it. Do we want to be, do we want to be working in this particular way? Because I would suggest that reputable companies, no, they wouldn't be. And that's the first thing. The second thing is, I think we've all got a moral obligation and responsibility that if you see this or hear it, then please, please report it, you know, please report it. You can report it to the SI in confidence. As I said before, mentioned earlier on, you can put it on our online portal, or you can Report it via Crimestoppers in Confidence, or you can contact one of your SI people that you know, and we will deal with it as we would see fit, and I can absolutely guarantee and reassure people, every case will be looked at, because what we do, it's the same old, you know, there might be one little bit of information around pull forward or, you know, or yo yo. But actually, it's all those snippets of information that all come together that give you that picture. And that's what happens. And that's why we've got 100, you know, 160 investigations on the go, because that's what's happened. People have stepped forward. But but please, please don't don't be part of the problem. Don't sit there on the sidelines and just watch and comment and moan and groan. You know, if you really want to do something about it, report it. We will do something about it, you know, and we work with HMRC. I have to say HMRC have been really good. You know, they are the primary agency for dealing with things like tax evasion. Um, and I, and I have to say, we've got, you know, we've been working closely with them, uh, all the way through this. And then, you know, we've had a number of spinoff national operations around this. Um, so it's not going to go away, but we need the industry to, to play their part if we could.

Yoyo: 36:43

One of the biggest, and I think most unfair comments I've ever heard about the SIA is that, you know, a lot of people think the SIA doesn't have teeth. It may be. Historically, there has been some justification to say that, but I wouldn't say that now. Uh, when you look at the investigations that you have, what is the most common thing you're seeing across the board that you are currently investigating and what is the most unusual thing you've seen?

Paul: 37:11

Yeah, no, of course, but you know, you're right. I mean, I, I, in the last couple of years, we've really, really tried to focus The S. I. A. It probably wasn't as visible as it could have been, whereas we've been very much more focused on public protection, far more visible, you know, we, you know, our inspection activities, you know, 200 percent more than ever used to be. And, you know, etcetera, etcetera. I, I, I would say the biggest thing that we're seeing at the moment is very much around labor exploitation. Um,, and we see individuals who are being paid below the national minimum the wage. Um, we see individuals. Um, who, uh, are potentially being exploited. And when we, and those are our big, big cases at the moment, that's, that's the biggest, the biggest issue for us, I guess, in terms of volume at the moment, which we work with HMRC very, very closely and the Home Office Immigration Service as well. I think some of the most unusual things, flipping it, we've seen loads, honestly, I mean, like, whether it's, I mean, I, I've even been on inspections, listen to this. I've been on inspections where, where, I've had a security guard say to me, when you gonna give us a pay rise? I say, sorry, what do you mean? and effectively they'll tell me, well, we've been told by our bosses that it's down to the si that we're not getting paid anymore money than we Oh, no, honestly. And I, and I've to like, really, and I've had a conver and I'm, and I've like to go back and like, have this conversation and I, and you know, another things that we've seen where. You know, we've been out on visit, you know, reputable parts of our security operatives and not displaying their badges. And we'll speak to them and say, look, you know, you need to display your badge unless you're, you know, you're working, you know, in a covert role, etc. And there's a reason, part of the guidance, you can do that. And it'll be very much around. Well, our managers have told us that we don't need to do it because we're, you know, we're a specialist team and all this stuff. And so there's all that. Every day is different. Honestly, every day is different, but sometimes as well. And this is going back to, you know, I'll sort of start this really. Most people, the things we see, we deal with through advice and guidance and people just. Make mistakes or just need re educating and that's what we do. You know, we don't go out there as a sledgehammer to crack a nut. We literally, you know, we try and educate and raise awareness. We give feedback in all cases as well, Yo Yo. We never used to do that. So,, before we turn up, we inspect, we go away. Whereas now, in 100 percent of cases, we give feedback. So if we come to you and do an inspection on you. We will, we'll give you feedback around. That's really, really good. Yeah. Yeah. Thank you very much. Really reassured. Thank you. You've explained to us what you're doing and how it's working, et cetera, et cetera. We'll go to your manager as well at the same conversation because we feel that that's a another level of assurance, really. So it's a different mindset to where we've been previously because All right. Republic body, there's more that we can do and there's more we should do and there's more we will do.

Yoyo: 39:56

I had to send one of my guys home once because I was doing a routine site visit myself. Part of that visit is to write down the SIA number of the team that you have on site and on duty at that time. It's a fully auditable process. And, He did the whole, he knew straight away you'd forgotten to bring it in with him. And I said, well, you just need to go home and get it. I'll wait here until you come back. And he looked at me as if to say, are you kidding me? It was like, well, like, are you freaking kidding me? And I went, no, no, no, you need to, you have to have it while you're at work. And it's really important for managers, I think, to understand the SIA. Requirements because there's no point in having a manager that isn't sure and that turns around and says, well, listen, don't do it again. Yeah, I'll get the SIA number from one of the previous site visits I did. Don't worry about it. That's not cool, but I can guarantee you when he did come back, he had a nice little break, a little drive around down the road, like 10, 15 minutes, come back again. I think it was the inconvenience. He came back all chirpy. He was like, no, I appreciate it. So I won't do it again. I'll bet you won't do it again. I remember, but Getting all the way back, to Milton Keynes at about, I don't know, 8. 20pm one night. And I realized I'd left my house keys, uh, on my desk in Canary Wharf.

Paul: 41:07

Oh, no.

Yoyo: 41:08

Yeah, there's only one time you do that. There's only one time you do that. the most soul destroying thing of having to get back on that train, go down into London, go down on the tube, go back into the office, and you're going to be there in another like nine hours. Yeah, there's, there's learn, learn, learn by mistakes. But I think messages to all of those young and, more junior, managers is to know the SIA legislation and laws, pertaining to your people. It's really important, isn't it, Paul?

Paul: 41:39

Yeah, I mean, I do know what I was listening to you and what you've described is what we should all be doing. And I mean this in terms of the we will say to managers and non frontline license holders, you need to do your due diligence, you need to do your checks and balances, you need to check and ensure not just from a not just from a PSI legislation perspective, but also from a human well being welfare perspective, which let's be really honest, that's more important. That's more important. I think what you've described is what anybody would reasonably expect. And I think what we would expect is the regulator, I guess, really, is that, you know, look. If you are responsible for security, whether that's looking after a building site or a nighttime economy or a shopping arcade or, a business center or close protection, it's a really, really responsible job, a really responsible role, you know, and those individuals that do that, we would expect their managers and non frontline license holders just to make sure that they are. They're probably trained, they're probably looked after, they're presented well, they're trained well, they're doing everything we'd expect from them, and I think that's reasonable. And the reason I say that is that, you know, we can only look at the, the tragic events over the last couple of years, terrorist attacks across the UK, you know, and the reality is it's going to be, you know, security operatives are going to be the first people on scene. They're going to be the first people dealing with these sort of things before police service turns up or other emergency workers. And I think that's the time when individuals are really, really tested and challenged around their training, their awareness, their knowledge and managers as well around, you know, have you done the right thing for your staff? Have you checked? Have you done the right due diligence? You know, we can all think of, you know, recent examples from something from the Manchester Rear Inquiry and inquiries where You know, people and organizations are really, really challenged about, you know, what happened. Um, could you have done more? And I think we could probably all do more.

Yoyo: 43:32

Yeah, and I would say in fairness as well, it's not just the, and I'm going to use the term jacket filler again, because I need to be very specific about who we're talking about. It's not just them. That would be the most negligent. I once, was, managing one of the big, Madame Tussauds sites that was a castle. It was hard. It's not hard to figure out what it was. It was a big castle. It was actually built in the same year as, William the Conqueror did his 1066 thing, whatever that was, long time ago. I can't remember it was built the same year, whatever William the Conqueror did conquered a lot. but he built a lot of castles and it was the same year that Windsor caught fire. And, And I had a team using, um, non, uh, regulation, uh, items in with non regulation charges that had not been regulated with the system in a very old office with very old wiring. And I was like, Guys, come on. It was the same year that Windsor caught fire in the most recent one. And I just said, come on, but this is the thing, an organization as valuable and as historic as that is still putting the value of its security in the hourly rate of the individual who's going to be there at that given time. So., we can all work, we can all work out that if they're running two by night, with, I don't know what the rate was, then we'll say it's around about nine pound an hour, because it was a night shift. That's 18 pounds is what they value for, A Castle built in 1066. That's what they value in their securities, 18 pounds. and I can hear a lot of people nodding to this. We all knew the reality situation. And we know that it takes a lot more than two people to do that job really properly. And it takes a lot more than the managers that we have out there. And I, it was easy for me, because every time I checked one of my team's licenses, I hired them. So I knew their SIA license was legitimate.

Paul: 45:34

Yeah.

Yoyo: 45:35

You know I saw it from the get go and I'm like, Oh, new license, John.

Paul: 45:39

I know, but you're right though. I, it's often, you know, buyers and suppliers, when they look at it, it's a bit like, where can we cut the costs and how can we make it cheaper? You know, and I, and security is borderless. Those beings that are right up there. And I would say to buyers and suppliers, you need to stand firm. You really need to stand firm. It's you know, it's not for us to regulate to advise about what you should pay and vice versa. But there's a moral obligation going back to what you said. Yeah, you're just in terms of actually really take a step backwards. These are really important roles, really important. These individuals, men and women, need the right equipment, the right training, the right numbers, the right resources, all the rest of it. Because if they don't, then the bigger thing that they are guarding or securing or looking after is in jeopardy. And I, and I, you know, and I think that's an ongoing conversation that we need to have. You hear this saying, you know, race to the bottom. Yeah. To the bottom. Sure. I, I think industry has got a responsibility to try and change that, if I may. I think, you know, I think if we can get all the big, big companies as we are doing and start having conversations, you know, we can't advise on what people should pay and, and vice versa. The national minimum wage has obviously been upped, which is good. Um, but I think I think I think the viewer security going back to what you've just said about your experience, the perception we need to try and change that we need to try and change it. We need to make it more, more, um, you know, more aspirational, uh, for individuals to be part of and that they are recognized and rewarded for the really important work they do in protecting the public and property and premises.

Yoyo: 47:24

Between 2009, by the way, and around 2019, I can tell you as an Ops Manager, and I think a lot, a lot of Ops Managers, I'll be representing them in saying this, there are a number of clients out there that should know better. Right. They should never be driving the cost down as low as they are. They should provide better facilities for the officer to work in. I remember, and I've talked about this quite openly, I had a client, haul me in. Literally, I had to drive about 60 miles to go into the office. It could have been dealt with over the telephone. Yeah, I want you to remove this security officer from site because he's just, I've just seen him stealing out the skip And to cut a long story short, cause I actually ended up writing an article about it. He was replacing his current chair because the ones they were throwing out from the offices were better quality than the one he'd been given in the security hut to sit on. And I made that client very aware how displeased I was that I was hauled To face a conversation like that, that we kind of could have had over the phone. And, you know, he'd say, it was quite a, it's quite a, a story I'm never going to forget because he said, you know, the black officer and clicked his fingers, you know, what's his name? The black, Samuel, his name is Samuel, but know his name, learn his name. And so there are ops managers out there that I think this is a big part of the conversation that know getting the standard of the basic standards raised. And I'm hoping they're on. But I've been to sites where the security officer was in his car because he didn't even get a seat to sit on. You know, the paperwork was nowhere to be found because every morning the cleaner was thrown away. There was no home for it for the risk assessment that needed to be on site. You know, they weren't warm enough. They weren't given pens. You know, they were abused by warehouse workers because they were there to prevent theft. I just think We've seen that rough end, and I think it's not just the, security providers, it's the clients as well, that relationship. We always know, don't we, if the relationship is good, you know, the big things become little things. But if the relationship is bad, the little things become big things. And I think that that's the time you need to say, as a provider, is this the business we want? Is this the business we want to be associated with? Is this really making us money enough for us to tolerate? This standard because it's it's there as well on the client side

Paul: 49:43

Do you know what, you're spot on, Yo Yo, and I, and I, and you will know this because of your background and career, I always think, I always have this view that if you look after the people, the rest will follow, and honestly, if you invest in people, if you support them, you nurture them, you develop them, you give them trust and confidence, you empower them, they will always, most of the time, most of the time, but most people will do a good job for you, and I think you're spot on, and I think the challenge is for us, is that in our industry, it's because we, because individuals are licensed and, you know, they come from different companies and organizations and all the rest of it. It's too easy for individuals just to be released or moved on and vice versa. And they, you know, they move around. And I think some of this stuff just gets unseen really. So I think you're right. I think there is a big responsibility. Um, on, buyers and suppliers, you know, just to, and managers to make sure that, the people under their charge, that they are being looked after and supported, because they will do you a good job. They will do you a professional job. They will do.

Yoyo: 50:46

And they remember you for it as well. They always remember. They might remember you being a bit strong or a bit firm. But they remember you gave them a good uniform to wear. And that means the world. I remember I had a security officer come in once and I'd just given them this new kit. And he came in the morning and he said, I want to wear this to the wedding. I've got to go to the weekend because this is the smartest suit I've got. And it was just so cute. I'll never forget that. Bless him. Paul Fullwood. Wise words from you. Thank you so, so much for coming onto the security circle and talking to us.

Paul: 51:18

Thank you. Honestly, thank you. I'm very, very humbled for the opportunity and, uh, yo, yo, uh, hopefully interesting conversation and, um, you know, please, please, you know, please convey the messages. We want everybody to work together. We can all make a difference in protecting the public and raising standards, and we all want to do the right thing. So thank you. You smashed it. Thank you, Paul.