Below is an exchange of letters with Secured By Design, following an original letter from GK Strategy, a lobbying and PR firm, seeking support for references to SbD in new building regulations.
My initial concern was the conflict of interest between SbD as a company essentially selling a quality assurance mark also being involved in setting the regulations that create the need for that assurance.
The exchange reads chronologically from bottom to top. The responses explain the situation and Mr. McInnes has been commendably transparent. My concerns about the conflicted position of SbD, and indeed other quasi official police-related companies such as RSS Ltd., remain.
I am publishing the exchange in the interests of transparency and fairness, following my initial open letter to SbD (at the bottom) and subsequent discussions with Mr. McInnes.
From: alan mcinnes
Sent: 11 November 2014 20:43
To: Salmon Christopher Police & Crime Commissioner
Subject: Re: ACPO Secured by Design & Housing Standards Review
Dear Christopher,
Thank your reply. I fully understand your views on our being referenced and respect that. We, however find ourselves in this situation by circumstances not entirely of our choosing having been referenced by government departments and their official publications for many years.
Secured by Design is a crime reduction initiative supported and operated by all forces to demonstrate the significant benefit of blending environmental design with physical security standards. Alternative models from other well meaning agencies have failed through lack of resources. Our income generation is separate and is the only means of the project existing without public funding. We use the corporate title across most of our work streams for recognition and impact as any organisation would. Police forces use it for elements of their crime reduction work.
Hitherto the SBD home security project has been supported in local and central government policy and guidance as a means of getting a realistic and research proven level of security into the housing sector. Government Circular 5/94, various PPG planning guidance, the Home Office / DCLG guide ‘Safer Places –Crime Prevention and the Planning System’ all promoted SBD as an effective model. These documents have all been removed as part of the ‘red tape challenge’ to streamline planning to encourage the construction sector to build more homes. However, in future local authorities may only utilise projects and guidance such as ours if they are signposted by a relevant government department. That is the effect and reason for our inclusion in the HSR proposal. Otherwise the route to apply SBD, the only recognised security standard, is eroded.
The HSR proposals are the product of contributions by many organisations and the emerging consensus is that door and window security should be made compulsory and supported by standards… The DCLG may only reference British and European Standards, but recognises that there are equivalent standards under LPS and ST standards which the SBD model accepts when accompanied by ongoing test certification which ensures production lines maintain standards year on year. TheDCLG/HSR does not require certification and the British Standards do not cater for some types of door configuration, such as communal entrance doors, which the other standards do. Secured by Design therefore broadens availability whilst meeting or exceeding the DCLG standard. SBD is not compulsory but many builders are seeing security and SBD as customer added value. Therefore to acknowledge that SBD is compliant with the proposed regulation leaves it open for those organisations, particularly the police service, who wish to negotiate a wider security benefit with the builder.
You asked for an outline of our expenditure. I am now able to give the 2013/14 figures, hence the short delay in my reply, for which I apologise.
Income from all sources £1,304,376. With expenditure as follows:
Salaries £719K (56% of expenditure) 13 staff Includes 2 seconded police officers and 3 administrative office staff seconded from ACPO all on full cost recovery.
Office rent and services from ACPO: £67.6K
Marketing, publicity material, exhibitions: £155.7K (12%)
Conferences / meetings / exhibitions to support police interaction with commercial security sectors £34K
National Training Event for 130 police crime prevention specialists £63K (free places for each police force, including Scotland,)
SBD Awards and grants £17.1K (grants to Neighbourhood Watch, Capel Manor Secure Garden exhibition, Safer Parking Scheme)
Research: £10K p.a. (50% joint funding with Home Office – 4 year EngD crime & environment.)
Specialist support to police forces : £34K (fees to external experts to cover for staff absence/workload peaks)
External Audit: £5K
IT: £10.9K
Bad debt: £25K (loss of contracted membership fees due to insolvencies.)
New web site & new company administrative database, design & development £70.5K (capitalised as asset)
Remainder covers company general operating expenses, travel & subsistence, telecoms, replace company cars, servicing, repairs & renewals, business insurances ( professional indemnity/public liability/ vehicle/staff).
Corporation Tax of £9.1K was paid on a surplus of £23K.
Reserves are based on full contingency for staff redundancies and all creditors to include return of any remaining balance of current year membership fees in the event that we ceased to trade, thereby removing risk or financial embarrassment to the police service or any associated official organisation.
I trust this assists and have no problem with you sharing our discussion on your website..
Yours sincerely,
Alan.
Alan McInnes,
Director & General Manager
ACPO Crime Prevention Initiatives Limited (t/a ACPO Secured by Design)
Registered in England & Wales No:3816000. VAT Reg. No. 740 3703 61
Registered office: First Floor, 10 Victoria Street, London SW1H 0NN
From: Salmon Christopher Police & Crime Commissioner
To: alan mcinnes
Sent: Thursday, 30 October 2014, 10:54
Subject: RE: ACPO Secured by Design & Housing Standards Review
Dear Mr. McInnes,
Thank you for your prompt reply. I understand that these issues go beyond the Housing Standards Review, and that many relate to the legacy of former police governance arrangements. I am grateful for your explanation.
The use of an external agency did not particularly concern me, except that it highlighted the interests involved. What does concern me is that SbD is seeking specific reference to itself in legislation which protects its status, despite having no statutory basis. It creates a privileged position in which SbD both creates the rules as a quasi-official body, and generates income off the back of them as a company. I am aware that the review does not apply to Wales but these habits tend to cross the border.
I am not clear from the information you sent me how much income is generated each year, how and what it is spent on. I would be grateful if you could share that.
Would you object to sharing this exchange on my website by way of explanation to my earlier concerns?
Yours sincerely,
Christopher
Christopher Salmon
Comisiynydd, Swyddfa Comisiynydd Heddlu a Throseddu
Commissioner, Police & Crime Commissioner’s Office
Rhif ffôn/Phone: 01267 226440
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From: alan mcinnes
Sent: 28 October 2014 14:17
To: Salmon Christopher Police & Crime Commissioner
Subject: ACPO Secured by Design & Housing Standards Review
Dear Mr Salmon,
Thank you for your response to my email and the opportunity to set out the position of Secured by Design. You raise issues far wider than the Housing Standards Review, which I should point out at the outset does not apply in Dyfed-Powys or the rest of Wales. To put this all into context I felt it might be helpful if I gave some of the background to our work and why we operate as registered (not for profit) company.
Secured by Design dates from 1989 when all police forces agreed to support this burglary initiative to promote designing out crime and physical security to encourage the construction industry to improve security in the built environment. It has had the support of the Home Office and the predecessors of the DCLG since that time through both policy and planning guidance.
Whilst proven to reduce crime by considerable independent research, the financing of project development and publicity material was problematic and in 1999 with support of all chief police officers and the Home Office, ACPO Crime Prevention Initiatives was established to manage the project, raise funds and invest any surplus in crime prevention activity, primarily within forces. It obviously cannot not pay dividends and has never paid any chief officer for their time (or expenses) as a director. A key issue is that as a company we are able to hold trademark, copyright and contracts and are able to defend them without recourse to public funds. I note that the College of Policing is also a registered company and there are parallels in other public sector areas.
ACPO has been the sole shareholder, our accounts are externally audited and published; we are subject to the Freedom of Information Act and registered with the FCA and Data Protection Commissioner. Our governance is through Directors drawn from chief police officers, including Policing Scotland. A briefing on our activities was sent to all PCC’s shortly after their inauguration.
We do not receive any public money and repay the police service and ACPO for any facilities used including office space. Currently we have two seconded police officers working with us and we repay full costs to the forces from which they come. Since 1999 we have raised income by recognising security products which pass tests to show they have significant crime prevention benefit. The security products from around 450 companies are not just for burglary prevention or building security but a benefit to the consumer in the widest sense. Importantly there is no obligation to use these products through our guidance documents. It is the standards we support.
The income finances our operation and is only used to support crime prevention projects, research and publicity in police forces around the country. For example, we are currently proving financial assistance to over a dozen forces with the provision of staff to undertake SbD work as funding within those forces is not available. I am not aware that your force has taken advantage of that funding stream which is disappointing as through this medium alone we have been putting over £50k a year back into police crime prevention across the country. In addition, we are 50% financing a PhD placement at the Home Office to investigate the part crime impacts the environment through carbon emissions and we hold the only annual training events for police crime prevention specialists and provide two free places to each force, including your own. Were we not to do this, in the present difficult financial environment there would be no crime prevention CPD training for officers at all.
It is unfair to suggest that we have carved out a preferential role as you claim for commercial reasons. We with other organisations were contributors to the Housing Standards Review (HSR) representing the police service interests in security and burglary prevention, particularly regarding emerging forms of attack. Whilst Secured by Design covers design features which can influence crime and a range of security issues covering just about every security risk in buildings, the HSR has identified just one of our many dozens of standards to feature in draft Building Regulations for doors and windows. A significant number of homes are built using local police Secured by Design advice and the HSR has therefore noted our compliance with the proposed Regulation. From what you say in your letter, I am sure that you will support the need for ongoing local activity to reduce and prevent burglary in homes and that all the practical application of Secured by Design is undertaken by local police officers. We are just a focal point to develop and promote the project without the need for taxpayers money (which frankly has not been and is not available to support the project)
To reassure you, the project is in effect owned by each police force and with the impending departure of ACPO the practical ownership and direction from chief police officers will continue through the College of Policing, the National Policing Leads and Chief Constables Council.
Secured by Design also has a significant reputation in itself in that our small team is regularly consulted by public bodies to assist in matters of security, technical standards and advice to the public. You may recall that the 2012 Olympic legacy sites were required to be accredited by us. We are currently contributing to discussions with National Assembly for Wales as to how our standards might influence the private rented housing sector and enhance its long standing support for Secured by Design in social housing in Wales. We are also copied and referenced internationally by government and academic institutions.
Again from what you say in your letter, you clearly appreciate the benefits and rationale of SbDbut it maybe that you were unsighted on the way we operate and how we support the initiative. I hope this letter has helped explain that.
I am sorry if the use of an external agency to seek to enshrine SbD in the planning system caused you concern. It was simply an issue of our limited resources and the need to use our income to the best effect. I am happy to acknowledge that we are worried about the potential impact of a weakening of the need for effective crime prevention in the planning regime and we could not sit back and risk SbD being overlooked. As I said earlier, SbD is about standards and about standards which have been shown to reduce crime. The only vehicle we have to help do that is ACPO CPI and that is a corporate convenience in terms of how the initiative can be supported without public money and little more.
I think that it is fair to say that in the light of the changes within ACPO, once the dust has settled the service will need to look at how it wants to support SbD in the new environment. It may well be that in trying to emphasise the police service based nature of what we do the structure of the business may better suit a community interest company but given we generate income from the private sector to reinvest in policing any changes will need to be considered carefully.
I attach a copy of our last audited accounts and would be happy to meet to discuss any of the matters you have raised, but rest assured we are a police project for the reduction of crime.
Yours sincerely,
Alan McInnes.
Director & General Manager
ACPO Crime Prevention Initiatives Limited (t/a ACPO Secured by Design)
Registered in England & Wales No:3816000. VAT Reg. No. 740 3703 61
Registered office: First Floor, 10 Victoria Street, London SW1H 0NN
Dear Mr. McInnes,
Thank you for your email. I am afraid to say it strikes me as highly questionable that Secured by Design should be seeking to carve out a preferential role for itself in legislation, using its police association and an implied threat to crime rates as leverage.
Secured by Design is a commercial entity and a subsidiary of ACPO, itself a private limited company. Both stand to benefit directly from lobbying efforts conducted under the banner of crime prevention. Nowhere is that conflict of interest made clear. I have no intention of endorsing what appears as little more than an attempt to secure privileged commercial position in planning policy. My submission to DCLG will make clear the importance of those conflicts.
I would also be grateful for a full copy of your accounts, an explanation of your business model and your governance arrangements, membership and structure. ACPO, after all, has been publicly funded. Presumably all its subsidiaries have benefited from some form of public support, in kind or otherwise. ACPO has been scrapped but Secured by Design may continue, in which case its exact provenance should be made transparent.
I have no objection to the principle of designing things with crime prevention in mind. I have a very great objection to private enterprises trading on public service reputations to secure themselves preferential markets.
Since you have not emailed me in person, I have no means of replying to you directly. I am publishing this response and your letter instead.
Yours sincerely,
Christopher Salmon
Christopher Salmon
Comisiynydd, Swyddfa Comisiynydd Heddlu a Throseddu
Commissioner, Police & Crime Commissioner’s Office
Rhif ffôn/Phone: 01267 226440
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From: Jonathan Greenberg
Sent: 20 October 2014 15:37
To: opcc
Subject: Secured by Design – Housing Standards Review Consultation
Message on behalf of Alan McInnes, General Manager of Secured by Design:
Dear Mr Salmon,
I wanted to get in touch following my previous letter to you regarding the Housing Standards Review to update you on the Department for Communities and Local Government’s (DCLG) latest consultation which was launched on 12th September, and the impact these proposals will have for crime rates in your area.
Throughout the review we have been engaged in discussions with DCLG to ensure that crime prevention remains a core feature of housing standards. I am delighted to inform you that the DCLG’s latest proposals for security standards in new homes reflect the views expressed by Secured by Design and many other stakeholders; this positive step will ensure that all local authorities can protect residents from crime in the future.
The DCLG’s revised costings rightly show that implementing security standards is relatively inexpensive and does not place much burden on developers. The department’s approach will make the process even simpler for developers, which will support a boost in house building without compromising the security of residents. Furthermore, this approach will help to mainstream crime prevention and foster a competitive market for security which, in turn, will boost innovation and drive down costs even further.
I would add that whilst DCLG should be commended on these proposals, it is important that as part of any plans, an independent and transparent group is set up to keep security standards under review in order to adapt to the ever changing modus operandi of offenders. We believe that Secured by Design, in partnership with the academic community and others, would be best able to lead this agenda. We will be making this point to the department.
The DCLG’s latest consultation can be found (here) and details of the revised approach are set out in a new requirement for security, Part Q (here). I have included a few points on the proposals below for your information.
However, these proposals are not final and there is still work to do ahead of the consultation deadline. With this in mind, we would be extremely grateful if you would be kind enough to submit a response to the DCLG firmly supporting the latest proposals ahead of the deadline on 7th November. I attach a template consultation response which you might wish to use for ease, but please do let me know if you require any further information or assistance.
Responses can be submitted to DCLG via an online form (here), by email at HousingStandardsReview@communities.gsi.gov.uk or by post at Housing Standards Review Team, Department for Communities and Local Government, 2 Marsham Street, London SW1P 4DF.
Once again, thank you for your support.
Kind regards,
Alan McInnes
DCLG’s current approach proposes the following:
- Security should be based on the provisions of British Standard PAS 24 and applied as a national mandatory requirement to all new homes
- A new requirement, Part Q , would be introduced into Schedule 1 of the Building Regulations
- The DCLG notes that alternative approaches that can be shown to achieve an equivalent or better performance would also be acceptable
- Within the consultation draft of ‘Approved Document Q: Security’, DCLG cite Secured by Design as also meeting the provisions
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