Stewart Brown, Senior Security Consultant at the consultancy Surelock, goes over the three things that have to come together to make Martyn’s Law – passed into law in April as the (Protection of Premises) Act 2025 – come into force. First, the inspection and compliance regime by the Security Industry Authority (SIA).
The actual details of the Terrorism (Protection of Premises) Act 2025 wording, out of 46 pages, has 22 pages about the various SIA functions (pages seven to 21 and 33 to 39), 11 pages about Licensing Plans regulations (pages 22 and 39 to 46) and only six pages relating to the owners-operators of premises’ requirements to ‘public protection procedures and measures’.
This scant and inadequate position or importance of protection (in other words security) of premises is, in my mind, disgraceful by the persons who wrote the actual act. They have clearly put the emphasis on regulation, inspection and compliance at the forefront of all actions regarding Martyn’s Law, seemingly or inadvertently not giving due consideration to the owners-operators of premises and events in how to comply with this new legislation.
I know it sounds like I am complaining and against this act, but I am very supportive and greatly in favour of it to “reduce the vulnerability of the premises or event to, and the risk of physical harm to individuals arising from, acts of terrorism….” in the United Kingdom, but as the act stands, sufficient thought has not been given to the persons (owners, operators, persons responsible) on how to comply with Martyn’s Law at present.
The proposed ‘statutory guidance’ to be formulated by a Home Office department, which has been stated to be similar to the Statutory Guidance issued under Section 183 of the Licensing Act 2003, will be very difficult to achieve as it would need to define, explain, clarify, interpret and give examples of the word ‘terrorism’ and a vast number of other words, phrases, sentences and paragraphs identified in the act to enable others to understand what is required for compliance of the Act.
I take it that the statutory guidance will need to identify best security practices in the UK (and abroad), British Standards Institute (BSI) documents already in being, various codes of practice in common use, UK security industry advice documents, Counter Terrorism Policing published information, ProtectUK relevant guidance documents and training advice, National Protective Security Authority (NPSA) issued documents, Centre for the Protection of National Infrastructure (CPNI) guidelines and material, maybe also include the Defence Manual of Security (JPS440/Issue 2 as well as considering all Terrorism Acts, the Private Security Industry Act and other Acts that identify security and safety of persons already in the UK.
2. Register of Competent Advisers (that premises without a security specialist may turn to)
At the present the UK has a small number of independent security consultants, 273 Chartered Security Professionals (CSyP) and about 450 full members of the Association of Security Consultants (ASC), who manages the Register of Independent Security Consultants (RISC). A number of self-employed security consultants and small businesses may be members of other security associations, e.g. the Security Institute, American Society of Industrial Security (ASIS) but the main words in this instance would be ‘competent advisors’ on Terrorism (Protection of Premises) Act 2025 – Martyn’s Law aspects.
Reading through this Act many times would need a security specialist to be very comfortable in advising on the highly sensitive nature of terrorist activity, assessing threats, risks, serious crimes, preventative actions and continuous up to date knowledge on how to protect numbers of people in a range of circumstances at publicly accessible locations (PALs).
The small and limited wording-phrases in the Act need to be fully understood and interpreted into preventative actions and immediate responses and reactions that can keep people safe when the threat or actual attack takes place on or within the vicinity of a premises. Some, not all ex-police/military/security knowledge experts may have the required ability and knowledge to advise correctly on this subject, but the SIA since its inception in 2001 have not been able to understand fully a security consultancy role (similar to private investigators) and therefore define a correct path to appropriate licensing as required by the Private Security Industry Act 2001, to this important part of the UK security sector.
I cannot see how a register of competent advisors could be created in line with Martyn’s Law, as we are all learning this new security legislation which is unique and the first of its kind. Only about 190 Counter Terrorism Security Advisors (CTSA) are in the UK’s 43 police services, and are mainly tasked with national infrastructure, specified industry sectors and advise the public generally on counter terrorism (through ProtectUK online), and local authorities on designing out crime at the planning stages. As there are so few they cannot (and have never been expected to) spend considerable time and effort in reviewing all aspects of a business’ or premises’ or event’s security.
Police used to have specialist Crime Prevention Officers until 2005 when the Home Office Crime Prevention Centre was closed (numbering about 1,750 officers in UK), but crime prevention activity has been incorporated into general police duties mainly by Police Community Support Officers (PCSOs) since and only a few Designing Out Crime Officers (DOCOs) now exist. The Metropolitan Police have only 32, who mainly work with local authorities and Counter Terrorism Policing (CTP).
3. Qualification (for the Consultant, Adviser, Whoever), to Prove Competency
Until Martyn’s Law is embedded into the UK security industry psyche and public consciousness, which will take a few years (after 2027), as following the Private Security Industry Act 2001 and SIA, where licensing and training of the six sectors of security personnel (Security Officers, Door Supervisors, Close Protection Officers, Cash in Transit Officers, CCTV Systems Operators, Key-holding activity) was placed in legislation.
The other parts of UK security industry being Security Consultancy and Private Investigators are self-regulated and despite numerous effective guidelines and competency instructions on general activities there is no specific guidance on separate matters; and Martyn’s Law advisory competency will only come to light after premises and the relevant authorities (SIA-Home Office and HM Courts Service) have identified how this Act is correctly implemented.
Similar to point two above, competent advisors and qualifications will only come to the fore after Martyn’s Law has been running for a number of years as everything to be documented (by the premises, compliance and enforcement by the SIA and police, statutory guidance documentation by the Home Office) has been accepted or challenged in a court of law.
