As the Court held that “the plain meaning of a security service cannot extend to a security activity that is merely a by-product or once-off incident of the core activity”, there may at times be grey areas as to whether specific employees need to be registered.  Employers should seek advice in doubt – failure to register such employees when required is a criminal offence (indeed in the case in question some of the workers and their managers were arrested by the police). 

Where registration is required, the effect is that: -

1. Your guards must be over 18 years of age,

2. They must be citizens or permanent residents (employers of foreign nationals take note!),

3. All minimum wage and training requirements per the code of conduct for security service providers are applicable.