Protect Duty Legislation
(Martyn’s Law) Solutions

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Guildstone Associates
Protect Duty Legislation (Martyn’s Law) Solutions

Introduction

On Monday 19 December 2022, the Government announced details for the implementation of Protect Duty legislation. The legislation is to be known as ‘Martyn’s Law’ in tribute to Martyn Hett. Martyn was one of the 21 people who lost their lives in the Manchester Arena terrorist attack that took place on 22nd May 2017. A major driver behind the legislation has been the campaigning and lobbying of government in which Martyn’s mother Figen Murray OBE has played a prominent role.

The government is currently proposing to introduce the legislation in early 2023. Its aim will to be enhance the protection of the United Kingdom’s publicly accessible locations (PALs) from terrorist attacks and ensure that organisations and businesses responsible for these locations are better prepared to deal with major incidents.

Rationale behind The Legislation

The governments rationale behind this legislation is as follows:

  • There have been 14 terror attacks in the UK since 2017 which have caused multiple deaths and casualties amongst the general population.
  • The terrorist threat the UK currently faces is multifaceted, diverse, and continually evolving. This makes it difficult to predict which locations could be targeted by terrorists in the future and therefore more difficult to identify and stop future attacks.
  • The need to improve security and ensure that robust, proportionate, and consistent measures are in place at publicly accessible locations.
  • The need to ensure that publicly accessible locations are better prepared to respond to terrorist incidents in light of the possibility of future attacks.
  • An awareness in government gained via engagement with industry that without legal compulsion, counter-terrorism security efforts often fall behind legally required standards.
  • The need to bring a level of consistency to the prioritisation, consideration and application of security processes and measures in publicly accessible locations.

Duty Placed Upon Owners and Operators

The proposed legislation will impose a duty on the owners and operators of publicly accessible locations to increase their preparedness for and protection from a terrorist attack. This will be done by requiring them to take proportionate steps, depending on the size and nature of the activities that take place at the location.

  • The main impact of this legislation will be felt by:
  • Event Organisers
  • Publicly Accessible Location Owners and Operators
  • Owners and Operators of venues staging public events
  • Management and Employees within these organisations

The government has announced that the legislation will apply throughout England, Wales, Scotland and Northern Ireland

Application

As proportionality is a fundamental consideration for the legislation the government has announced that it will have a tiered model, linked to the activity that takes place at a location and its capacity:

  • A Standard Tier will drive good preparedness outcomes. Duty holders will be required to undertake simple yet effective measures to improve protective security and preparedness. This will apply to qualifying locations with a maximum capacity of over 100. This could include larger retail stores, bars, or restaurants.
  • An Enhanced Tier will see additional requirements placed on high-capacity locations in recognition of the potentially catastrophic consequences of a successful attack. This will apply to locations with a capacity of over 800 people at any time. This could include live music venues, theatres, and department stores.

Enforcement
The Government intends to establish an inspection capability to educate, advise, and ensure compliance with the Duty. Where necessary, the inspectorate will use a range of sanctions to ensure that breaches are effectively dealt with.

Guildstone Associates – Profile

Company Overview
Guildstone Associates is a client focused company that specialises in providing an innovative range of bespoke security and risk management solutions to corporate entities and High Net Worth Individuals (HNWI). Since its founding, the company has gained a reputation as the supplier of choice for premier clients in both the public and private spheres.

Experience of Security Provision in Support of Public Events
Guildstone Associates and the wider Black Diamond Group have extensive experience in the management of major public events. This experience has been gained via the security and logistical management of events conducted in support of major national infrastructure projects.

Our Staff – Protective Security Associates
A key component of Guildstone Associates’ success has been its ability to allocate high calibre multiskilled Protective Security Associates to support our clients throughout an event project’s lifecycle. This can be a specialist one off event or a series of major national events. All our Associates have extensive experience of incident and crisis management gained whilst operating in the military, law enforcement and civilian security sectors.

Key Competencies of Guildstone Associates Security Operatives
All Guildstone Protective Security Associates are trained in the following key competencies:

  • Security Risk Assessments, Audits and Surveys
  • Event Management and Operational Control
  • Crisis and Incident Management
  • Integration of Physical Security Systems – CCTV and Audio Surveillance Systems
  • Behavioural Detection and Profiling
  • Access Control and Screening
  • Medical first response

Guildstone Associates Operational Strategy

Our Protective Security Associates work to the Guildstone Associates Operational Security Strategy, as well as the Joint Emergency Services Interoperability Programme (JESIP). Guildstone Associates’ Operational Security Strategy aligns with the UK National Security Framework in the following key areas:

  • Security awareness – The active security awareness and vigilance of all staff is essential. Many staff members and event participants will be extremely familiar with the venue and will notice unusual behaviour or items out of place. They should be given the confidence to report any concerns.
  • Good Governance – Leadership that provides effective security and accountability.
  • Culture and Awareness – A security culture with clear personal accountability and a mature understanding of managing risk, responsibility and reputational protection.
  • Risk Management – Risk management that analyses threats via proven risk management mechanisms and enables clients to make informed, practical and effective business enabling decisions.
  • Information – Information policies that give clients confidence that Guildstone Associates will always maintain the confidentiality, integrity and availability of their information.
  • Technology and Equipment – Use of modern and functional technology and equipment that is resilient to threats and compliant with data protection regulations.
  • Personnel Security – Personnel are a client’s most important asset. Ensuring personnel are suitably protected is key to client confidence.
  • Physical Security – Physical security measures that ensure clients are provided with a safe and secure working environment that protects against a wide range of threats from media intrusion and crime to terrorism.
  • Preparing for and Responding to Security Incidents – Proven security responses managed by experienced staff will greatly reduce a client’s vulnerability to security incidents, disruptive incidents and reputational damage
  • Policy Priorities – Providing security that is truly aligned to client needs and priorities.
  • Vetting – Guildstone Associates only uses personnel who are appropriately licenced and referenced.
  • Accountability – Guildstone Associates always holds itself accountable to clients and key stakeholders, providing confidence that its services will be delivered to meet and exceed their requirements.

JESIP

is used by all UK Emergency Services to deliver an efficient and structured response to emergencies. The Programme observes the following five principles to deliver a jointly agreed working strategy where all parties understand what is going to happen when and by who:

Co-locate

Communicate

Co-ordinate

Jointly understand risk

Shared Situational Awareness

Diversity and Inclusion

Guildstone Associates is an inclusive employer that respects difference and strives to attract talent from all areas of society. It overtly embraces equality of opportunity and seeks to develop and mentor talent from sectors of society that are underrepresented in the security industry.

Legislative Requirements

All Guildstone Protective Security Associates are fully aware of the legislative requirements of licensed security operatives deployed in a protective security role specifically, the following:

  • Their actions must at all times abide by the requirements of the relevant legal, human rights and data protection legislation.
  • Evidence collation carried out by Associates must be done in a manner that ensures the evidence is admissible in a court of law.

Guildstone Associates Protect Duty Solutions

Response to the Implementation of Martyn’s Law

In response to the implementation of Martyn’s Law, Guildstone Associates has put together a range of protective security solutions. These solutions have been compiled with the aim of assisting our clients in the Event and Publicly Accessible Location Sectors to comply with the legislative requirements and spirit of Protect Duty Legislation (Martyn’s Law).

Our solutions are based upon the following key components:

Information and Intelligence

Guildstone’s Protective Security Associates are supported by our Specialist Surveillance and Analytical Associates. These specialists are highly skilled in collating and analysing the threats faced by our clients and their customers when staging events that are high profile, large scale and publicly accessible.

Prior to an event or activity, these specialists will draft a detailed intelligence report and threat picture. This document will be based upon input from multiple sources including Guildstone’s intelligence sources, law enforcement agencies, local authorities, reconnaissance operations, open-source information and historical intelligence gained from previous events. These documents will form the base from which the event risk assessment and security plan will be developed.

Prior to an event taking place all staff and key stakeholders participating in the event will receive a tailored threat picture based on the information contained within these documents.

Philosophy of Information and Intelligence Analysis

Guildstone’s philosophy of information and intelligence analysis is based on the following three key principles:

  • Corroboration – Information and intelligence must be corroborated to determine its veracity and relevance to the operational risk profile.
  • Interpretation – Information and intelligence must be interpreted using analytical methods to arrive at relevant conclusions, prioritise threats and construct risk mitigation measures.
  • Context – Information and intelligence must be analysed in a manner that places it firmly within the current operational risk profile.

Planning

Guildstone’s Protective Security Associates will in conjunction with venue and event organising teams conduct a detailed site reconnaissance and draft comprehensive security and crisis management plans. These plans will cover all components of the event or wider activity.

These plans will be confirmed with local agencies including law enforcement, local government and public transport after which they will be briefed to senior management during the event planning stage.

The plans will pay particular attention to the following:

  • Threats from terrorism both general and venue specific
  • Criminality including the use and supply of illicit substances
  • Identification of key points and vulnerabilities
  • Crisis management and Incident control procedures
  • Emergency procedures including medical, fire and mass evacuation response
  • Actions on unauthorised incursions, ambush marketing, stunt and protest activity
  • Stalking and Fixated fans
  • Unauthorised media
  • Lessons learned and key points from previous events at a venue

Consideration to the management of the key half hour prior to the start of an event will form a vital part of these plans. Studies have shown that it is often within this period that the majority of attendees will look to gain access to an event.

Physical Protection

Our Associates will advise our clients on the cost-effective deployment of a range of physical security solutions that will ensure clients and their customers are protected against a wide range of threats over and above the requirements of the legislation. These will include media intrusion and activities that undermine the integrity of an event such as ambush marketing and types of stunt or protest activity. The aim is to provide a safe and secure environment without detracting from the atmosphere and aesthetics that sets a venue apart and attracts participants and the public to an event.

The main components of the physical protection deployed at an event can include:

  • Security awareness – The active security awareness and vigilance of all staff is essential. Many staff members and event participants will be extremely familiar with the venue and will notice unusual behaviour or items out of place. They should be given the confidence to report any concerns.
  • Training – All event and venue staff should be briefed on how to identify unusual activity such as bags left unattended, unauthorised access attempts and suspicious interest shown by unfamiliar staff, visitors or attendees.
  • Access Control – Access points should be kept to a minimum and boundaries between public and private areas secured. This is especially important in identified vulnerable and restricted access areas such as green rooms. These access points may need to be manned in order to allow egress in the event of emergencies.
  • Passes and accreditation – Staff, delegates, speakers, performers and accredited persons should wear their passes at all times. Visitors to private or restricted areas should be escorted and should wear clearly marked temporary passes.
  • Ticketing – Tickets should be correctly checked and confirmed in a professional and overt manner to discourage attempts at unauthorised access.
  • Screening – As with ticketing the search of individuals and screening of baggage should be carried in out a professional and overt manner in order to act as a deterrent.
  • Vetting and Screening of Staff – To ensure the integrity of security measures and to mitigate internal threat actors it is essential that staff and any agencies providing event support are correctly screened and vetted.
  • Patrolling and searching – Patrolling and searching of key internal and external areas should be carried out prior to, during and upon egress from an event.
  • Traffic and parking – Traffic and Parking controls should be enforced prior to and upon egress from an event. Liaison with local authorities may be required to implement restrictions.
  • Vulnerable access points – Vulnerable Access Points such as external doors, stairways, windows and entry points via adjoining venues should be secured or manned.
  • VIP Arrival and Departure – The management of VIP arrival and departure requires detailed planning especially when these individuals are subject to specific threats due to their profile, campaigning or political activities.
  • Perimeter – The event perimeter should be identified, clearly marked and secured. This may require the use of temporary fencing and barriers supported by patrolling, CCTV and intruder alarm systems. The securing of the perimeter is essential to the integrity of any personal or vehicle searching strategy.
  • Integration of physical security systems – If deployed to or installed at site intruder alarms, CCTV and other technical systems should be integrated so that they work together in an effective and coordinated manner.
  • Vetting and Screening of Staff – To ensure the integrity of security measures and to mitigate internal threat actors it is essential that staff and any agencies providing event support are correctly screened and vetted.

Screening & Detection

Dependent upon the profile of an event and the threats identified our Associates will recommend an appropriate screening and detection strategy. This strategy can consist of the following components:

  • Behavioural Detection Associates – At larger venues and events consideration will be given to the deployment of behavioural detection Associates. All Behavioural Detection Associates deployed by Guildstone are experienced surveillance and counter-surveillance specialists who have an in depth understanding of their role specifically the need to ensure that any evidence they collate is admissible in a court of law.
  • Searching and Screening Teams – Searching and screening teams are often the first staff to engage with event participants and the general public. Whether these staff are checking tickets, searching or directing the public it is essential that they are fully briefed on the threat picture and the need to engage with the public in a professional and welcoming manner.  High professional standards within the search and screening teams are key to safety at venues and reducing tension, especially during the key half hour during which the majority of attendees will seek to gain access to an event.
  • Technical Screening Measures – Detection equipment deployed at a venue should be appropriate to the event being staged. It should both meet the identified security requirements and allow the required throughput of attendees. Participants and customers can become frustrated when queueing at a screening station. Unscreened queues can also present a tempting target to terrorists and criminal elements.

Reassuring and Visible Security

Reassuring and visible security gives customers and attendees the confidence to relax and enjoy an event whilst deterring any threat actors such as terrorists, criminals, stunt marketers and protestors.

For many events, visible security should be highly visible as customers and attendees enter and leave an event but less intrusive while the event is underway. The attendees should however always be confident that they can contact a member of the security team should they need assistance or wish to report a concern.

Security staff should be able to rapidly respond to incidents and in the case of untoward behaviour quickly isolate and remove the individuals concerned before their behaviour escalates and influences the actions of others.

Security staff should also be deployed in a manner that offers reassurance to key attendees such as speakers, performers and VIP guests. This may require the deployment of qualified close protection officers or other security specialists.

Command, Control and Communications

To support major events Guildstone can supply a range of Command, Control and Communications solutions from fully staffed control centres to handheld radio and push-to-talk over cellular solutions. These solutions allow event and security management to manage incidents and rapidly communicate key decisions.

When deployed our control room staff are able to filter and prioritise information and effectively communicate with onsite staff and outside agencies such as the emergency services.

Incident Response and Crisis Management

Guildstone’s Protective Security Associates are highly skilled in advising on and overseeing incident response and crisis management situations. Experienced staff are a vital component of the effective incident and crisis management, especially during the initial stages of an incident where speed of escalation and the potential for rapid deterioration is at its highest. Our Associates are trained to take appropriate action to prevent escalation, mitigate the impact of incidents and ensure the safety of all those attending an event.

At high profile and larger events, designated incident Control and Crisis Management Coordinators will be needed to liaise with the emergency services and work with their control rooms to coordinate any incident response. When liaising with external agencies and control rooms Guildstone’s Control and Crisis Management Coordinators use the M/ETHANE reporting framework. This framework is designed to provide a common structure for responders and their control rooms to share incident information.

The M/ETHENE format is as follows:

  • Major Incident
  • Exact Location
  • Type of Incident
  • Hazards
  • Access
  • Number of Casualties
  • Emergency Services

In less serious cases incident control and crisis management coordinators are able to manage, control and where appropriate de-escalate an incident, allowing the continuation of an event with minimal impact on the experience of those attending and participating in the event.

Next Steps

While Guildstone supports the introduction of Protect Duty Legislation as an appropriate response to current security threats it recognises the challenges that are placed on many of our clients. It, therefore, offers its knowledge and expertise to support these clients in ensuring that their events are fully compliant with the legislative requirements and spirit of Martyn’s Law.

Further Reading

Further information regarding the development of Martyn’s Law and the proposed implementation of the legislation can be found via the following links:

https://www.figenmurray.co.uk/martyn-s-law
https://www.gov.uk/government/news/martyns-law-to-ensure-stronger-protections-against-terrorism-in-public-places

Summary

Guildstone Associates realises that many organisations within the Event and Publicly Accessible Location sectors will find preparing for the implementation of Protect Duty legislation challenging which is why it has designed a range of highly effective solutions based upon proven operating methodologies. As Guildstone understands that the target market of each event and the needs of each client differ, its solutions are designed to be tailored to client needs and the requirements of each individual event. Although the tailoring of a solution may differ, what does not differ is the quality of Guildstone’s service provision, the calibre of its associates and its client first ethos.

Document Download

Guildstone Associates
Protect Duty Legislation (Martyn’s Law) Solutions

To register an interest

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