Regal’s Official Statement to the Private Security and Investigative Services Branch

April 27th, 2020
Private Security and Investigative Services Branch
25 Grosvenor Street
12th Floor
Toronto, Ontario M7A 2H3

Attn: Acting Deputy Registrar Navdeep Sidhu-Gil,
Dear Acting Registrar Sidhu-Gill

I would first like to thank you for your response to my enquiries of March 18th, 2020, as it relates to the closing of Serco and licensing of security guards in the Province of Ontario, and I acknowledge receipt of your correspondence on April 24th, 2020.

On March 23rd, 2020, all non-essential businesses in Ontario were forced to close, which included, as we found out, Serco, the testing arm for the Ministry and that closure placed a strain on our ability to service our clients both new and old because it took the access of our industry to create security guards away under the legislation as it reads today. Under Ontario regulation 119/20 brought forth on April 3rd, 2020, under the Emergency Management and Civil Protection Act of Ontario, the Government ordered our industry to continue operating as we knew that they would.

To provide context to our statement above, let me describe to you the challenges that our industry faces on a daily basis as it relates to the employment of security guards even on the best of days. The potential candidate guards must first complete 40 hours of inhouse or on-line training that normally costs the candidate guards anywhere between $100.00 to $600.00 depending on the academy. Then they are then to write the multiple question test at Serco, pay a fee for that service and then another fee for the guard license itself, all of which takes on average about 25 to 45 days, that’s a best-case scenario.

Using the analogy to sum up the points that we are making, if the government declared gas stations an essential service and then closed the refinery that produces the gas that supplies the gas stations, that would make little to no sense. Essentially, exactly what the government did was just that but for the security guard industry.

We had asked the Ministry for emergency provisions on March 18th, 2020, related to licensing not from a renewal perspective but from an onboarding and licensing one. This request was to accommodate the surge that we knew would be coming, not only during the initial shutdown but the eventuality of re-opening of businesses and the new normal that will bring with it a further reliance on guarding operations to support the daily operations of screening and access control that will undoubtedly follow.

You can imagine our frustration after reading an article by Canadian Security Magazine dated April 6th, 2020, where a member of your office suggested that we should look to guards who have been displaced or laid off from as an example, Casinos. Although that may seem to be a legitimate solution, we do know that the majority of guards in Casinos in Ontario are not licensed and have no requirement to be licensed under the AGCO (Alcohol, Gaming Commission of Ontario).

At any rate, we concede that there are 91,000 licensed security guards in the Province of Ontario and if we divide that number equally between the 12 months of the year accounting for birthdays and renewals, you end up with 7500 or so guards per month, which again we concede is a rudimentary calculation and then if we conclude that roughly half of them will require to be renewed that factors into approximately 3300 renewals of licenses a month and there is a 90 day licensing extension. How does the ministry intend to deal with the approximately ten thousand license renewals or more that it will face on mass once the lockdown is lifted, as well as the inevitable onslaught of new guarding applications that may be generated in a timely and effective manner to provide our industry with the horsepower it will require to support the activities of bringing this province back on line? Especially since a member of your office indicated that the department was still working on a backlog of 2000 plus applications and renewals as of the article dated April 6th, 2020.

If we do the math based on the above calculations taking into account just 400 new guarding applications a month during normal business activities across the province, we come to a total of 3700 renewals. That’s in a perfect storm and we know this storm isn’t perfect, if we try and onboard as many new guards as we know we are going to need based on the new normal, the Ministry will become very quickly swamped with applications both old and new and will paralyze the system quickly and will lead to line ups, mistakes and chaos in our industry,

We know that changes to the legislation can be done swiftly as was the case during the G20 back in 2010 where a provision was incorporated into the legislation as it relates to holding out as police, this was done quietly and without much legislative wrangling. Based on the type of changes requested, we don’t believe that this would form any basis of contention from the political parties of the day.

What we are worried about is throughput, we don’t want the ministry to be an encumbrance to working in the industry which was the case during the inception of this program back in early 2000. It provides you the flexibility to throttle up or down your requirements for staffing without impeding our ability to help the province come back on-line.

Patrick Shand unknowing brought about change for the good in our industry; not the least of which was the requirement for all guards to be licensed in First Aid and CPR as you stated in your correspondence. Security is really the “first”, first responders to most critical incidents within Ontario, unless the causation of the injury is immediately known to security, they will be reluctant to provide such assistance for fear of becoming contaminated with COVID-19 and in-fact in a couple of instances with our own guards; they have been cautioned very seriously by first responders to not provide assistance where causation is in question; again during this time of uncertainty because we are not equipped as first responders and do not come with the same level of PPE.

With every problem, we provide a solution, the plan is a simple one, allow us to onboard staff, put them through the same process as before, allow us to conduct criminal records checks on them, credit history’s if you so desire and while you re-tool and catch up, we will continue to operate with cadets that are screened and accredited just as the Ministry would have done, but with stricter conditions on employment.

Our plan again is simple and is provided in a step by step fashion below: Call it the Cadet Program or what have you.

Every person that is interested in joining the security field must first:

Obtain a criminal background check, with zero convictions;
Satisfactory Credit History;
Complete the 40-hour training program;
Have a valid first Aid and CPR certificate;

These requirements are currently the standard with a few notable exceptions, the first exception is that a candidate cannot have a criminal conviction of any kind whatsoever or they are forbidden to work as a security guard. This is actually more stringent than the ministry prescribes as they have 87 convictions for which you can’t qualify to become a security guard.

The second exception is that the cadet cannot be placed in a position whereby they may be called upon to use force of any kind. Cadets would also be excluded from areas where an enhanced reliability check may be required or other clearances that would be predicated on the licensing credential as a start for any process. And the third exception is that they must be under supervision when working. At least until such time as the Ministry returns to normal operations, at that point, all cadets must within a prescribed amount of time by the Ministry undergo their testing requirements and the program returns to normal.

Please provide some serious consideration to our plan. We encourage you to be the solution to this issue. Our whole goal is to work in concert with you systemically not marginally.

Very Respectfully,

Mr. Nick Vetere
CEO, Regal Security Inc.
nick@regalsecurity.ca

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