Security licensing process and licence conditions policies

We've reorganized and simplified content about security industry licensing. Things may look different, but policies and processes haven't changed.

This web page presents the security licensing process and licence conditions policies in their entirety. You can find what you need using the table of contents below, or use CTRL+F to search for keywords.

Table of contents

Policy Updates

This section shows a list of all updates made to the document.

Section 1

• 1.1 How to use the Policies
• 1.2 How the Policies are Organized
• 1.3 Role of the Registrar
• 1.4 Function of Policy

Section 2

• 2.1 Introduction
• 2.2 Licensing Exceptions—Individuals
  • 2.2.1 Determining whether security work is incidental to primary work
  • 2.2.2 Determining whether an individual is a private investigator
  • 2.2.3 Out-of-province private investigations
  • 2.2.4 Services to prevent the loss of property—Determining whether an individual is performing the services of a security guard
  • 2.2.5 Door security—Determining whether an individual is performing the services of a security guard
  • 2.2.6 Housesitters—Determining whether an individual is performing the services of a security guard
  • 2.2.7 Pre-installation wiring—Determining the need for a security alarm installer licence
  • 2.3.1 Determining employment status
  • 2.3.2 Branch offices
  • 2.4.1 Requirements for photographs
  • 2.4.2 Individuals who can control a business entity applicant
  • 2.4.3 Licence Type Table
  • 2.5.1 Definition of ordinarily resident
  • 2.5.2 Eligibility to work in Canada
  • 2.5.3 Information checks for applicants
  • 2.5.4 Issuing licences to peace officers / police officers
  • 2.6.1 English fluency requirements
  • 2.6.2 Training and experience requirements for private investigators
  • 2.6.3 Training and experience requirements for locksmiths
  • 2.6.4 Training and experience requirements for alarm service installers
  • 2.6.5 Training and experience requirements for security consultants
  • 2.6.6 Training requirements for Security Guards
  • 2.7.1 Security worker licence changes
  • 2.7.2 Security business licence changes that involve no change in ownership or management of the security business or the licensee
  • 2.7.3 Security business licence changes that involve a change in ownership of the security business
  • 2.7.4 Security business licence changes that involve a change in management of the security business
  • 2.7.5 Security business licence changes that involve a change in ownership or management of the business entity holding the licence
  • 2.8.1 Hearing formats
  • 2.8.2 Notice of Administrative Hearing
  • 2.8.3 Representatives
  • 2.8.4 Recordings
  • 2.8.5 Decisions

  Section 3

  • 3.1 Introduction
  • 3.2 Code of Conduct
    • 3.2.1 Code of Conduct for Security Workers
    • 3.2.2 Code of Conduct for Security Businesses
    • 3.3.1 Types of security workers who can obtain an authorization
    • 3.3.2 Qualifications
    • 3.3.3 Approved restraining devices
    • 3.3.4 Re-qualification requirements
    • 3.4.1 Security worker application requirements
    • 3.4.2 Security worker licence conditions
    • 3.4.3 Security business application requirements
    • 3.4.4 Security business licence conditions
    • 3.5.1 Security business qualifications
    • 3.5.2 Security worker qualifications
    • 3.5.3 Re-qualification
    • 3.6.1 Supervision requirements for locksmiths
    • 3.6.2 Supervision requirements for private investigators
    • 3.6.3 Supervision requirements for security alarm installers
    • 3.6.4 Supervision requirements for security guards
    • 3.7.1 Working as a peace officer
    • 3.7.2 Recording use-of-force events
    • 3.7.3 Branch office records
    • 3.7.4 Conditions for individuals with medical conditions
    • 3.7.5 Flashing lights
    • 3.7.6 Requirement, while on duty, to produce a Security Worker Licence when requested by a member of the general public with respect to armoured car guards or doorpersons at licensed liquor establishments
    • 3.7.7 Markings and accessories of security guard vehicles

    Policy updates

    Policy updates

    Section	Topic	Date
    2.5.4.1 and 2.5.4.2	Issuing licences to peace officers	No date
    2.6.2	Training and experience requirements for private investigators and private investigators under supervision	No date
    2.6.6	Training requirements for Security Guards	No date
    3.3.2.4 and 3.3.2.5	Restraining Devices	No date
    3.7.5	Flashing Lights	No date
    3.7.7	Markings and accessories of security guard vehicles	No date
    2.7.2 and 2.3.2	"Doing business as" Names	June 27, 2018

    Section 1

    Section 1.1: How to use the policies

    The document holds the licensing-related policies of the Registrar of Security Services (the registrar). These policies were developed to coincide with the Security Services Act (enacted September 1, 2008) and replace all previous policies issued by the registrar under the Private Investigators and Security Agencies Act.

    The polices are complied in this document for use by Security Programs Division (SPD) staff but may also be used as a reference document by licensees and other agencies.

    The policies refer throughout to the Security Services Act (the Act) and Security Services Regulation (the regulations), but it does not duplicate the provisions from those documents. This means that anyone who wishes to refer to these policies should also review the provisions of the Act and the regulations for a comprehensive understanding of licensing requirements and responsibilities.

    Section 1.2: How the policies are organized

    The policies are divided in 3 sections:

    • Section 1: Background information on the role of the registrar and the function of policy in regards to the work of a regulatory body
    • Section 2: The policies relating to the licensing process—whether a licence is required and documents required as part of the licence application
    • Section 3: The policies relating to licence conditions that have been, or may be, imposed by the registrar. This section also holds policies relating to qualifications and applications for authorizations that allow the use of restraining devices, firearms and dogs (note: policies for restraining devices, firearms and dogs are still under development)

    Each policy is presented in the same way, in the following order:

    1. Section and major subsection number and title (for example, Section 2.2: Licensing Exemptions)
    2. Introduction—describes the nature of the policies found under that major subsection
    3. Policies—presents a series of numbered policy statements, organized by topic
    4. Rationale—is the explanation of the policy statement being presented
    5. The reference to the section of the Act and/or regulations that provides the authority for the policy statements is also included under each topic heading

    Section 1.3: Role of the registrar

    The Registrar of Security Services (the registrar) is appointed by the Minister under section 49 of the Act. A number of powers and responsibilities are imposed on the registrar under the Act, including:

    • The power to issue licences
    • The power to impose conditions on licences
    • The power to set the form and manner of applications
    • The responsibility for dealing with complaints, and
    • The power to take enforcement action against a licensee

    The registrar has developed the policies outlined in this document to assist the registrar in exercising these powers and responsibilities.

    Section 1.4: Function of policy

    Policy plays an important role in the work of a regulatory body. To understand this role, SPD staff need to be familiar with the relationship between the Security Services Act, Security Services Regulations and SPD policy.

    The primary statement of law is written in legislation. Legislation provides “hard rules” that must be followed without exception or the exercise of discretion. Because legislation sets out hard rules, it is broadly written. The finer points of law are set out in regulation and policy. This allows for greater flexibility and, in the case of policy, the exercise of some discretion.

    The Security Services Act is a broad statement or expression of laws regulating the security industry. The Security Services Regulation fills in some of the details of the legislation. Like legislation, regulations are law. However, they are subordinate legislation made under the authority of the statute. This means there must be authority in the legislation for a regulation. An advantage of regulations over legislation is that they are easier to change or repeal. By amending regulations, the government can adapt quickly to changing program needs and operational issues.

    Policy is the next step in filling in the details of legislation. It is an important aspect of the work of all regulatory bodies. Policy, unlike legislation and regulations, is not passed by the government but developed and approved by the registrar. As the needs of stakeholders and government shift, the registrar can respond quickly by reviewing policy with major stakeholders and amending it when necessary.

    Policy provides guidelines that direct the actions of SPD staff in applying legislation and regulations. Without policy, a regulatory body could not make consistent and equitable decisions regarding the groups it regulates. Regulatory bodies need standards and principles to provide a framework for the exercise of their discretionary powers. If there are no criteria to guide decisions, the decisions will be arbitrary and, over time, inconsistent. The development of criteria through policy structures decisions and the exercise of discretion.

    Policy does not set out “hard rules." When making a licensing decision, the registrar will consider the legislation, regulations, policy and the circumstances of the situation. Some situations require that the registrar exercise discretion and act in a manner different than that expressed in policy. This is one of the advantages of policy. It can be flexible in a situation when warranted. Unlike legislation that may require one course of action, the registrar can exercise discretion and move outside of policy to ensure that the law is upheld and all parties are treated fairly. Policy is generally binding on program operations and will generally be upheld by a judicial or quasi-judicial body.

    Section 2

    Section 2.1: Introduction

    The Act authorizes the registrar to issue:

    • Security worker licences to individuals who wish to engage in security work, and
    • Security business licences to individuals or business entities who wish to carry on a security business

    Section 15 of the regulations prescribe 15 different types of security worker licence and 11 different types of security business licence, along with the nature and extent of security work that can be provided under each. The registrar may also issue licences that combine different worker or business licence types.

    The licensing process allows the registrar to determine whether an individual or business entity meets all the conditions, qualifications and requirements for the particular licence type applied for. For some individuals or business entities, the licensing process also will include a preliminary step that includes a review of whether licensing is, in fact, required.

    This part of the manual outlines policies relating to the licensing process, organized in sections that reflect the various steps or decision points in the process. This part also contains policies relating to various licence or licensee changes that may occur after licensing. The final section in this part details policies relating to licensing hearings.

    Section 2.2: Licensing Exceptions—Individuals

    There are six kinds of security work defined in the Act. If an individual performs security work, that individual will need a licence unless they are exempt under the regulations or the security work they are performing is incidental to the individual’s primary work. Section 2 of the regulations sets out a list of individuals who are exempt and do not require a security licence.

    Section 1 of the Act defines the six kinds of security work. In some situations, it may be difficult to determine whether the services an individual provides fall within one of the six defined kinds of security work. The policies outlined in this section assist the registrar to determine whether an individual requires a security worker licence in order to work.

    2.2.1: Determining whether security work is incidental to primary work

    Rationale

    Individuals may have some job duties that fall within the defined kinds of security work, even though security work is not their primary job responsibility. For example, a change room attendant who monitors the number of garments taken into a fitting room is likely performing services to prevent the loss of property. However, it is not necessary for change room attendants to be licensed as security guards, because their primary function is not security. In recognition of this, section 2(c) of the Act provides that an individual does not need to hold a security licence if the registrar determines that the security work in which the individual is engaged is incidental to the individual’s primary work. The factors the registrar will consider when deciding whether the security work is incidental are set out in this policy.

    Policy

    2.2.1.1 An individual may engage in security work without a licence if the registrar determines that the security work in question is incidental to the individual’s primary work

    2.2.1.2 In order to be incidental to an individual's primary work, the security work in question:

    1. Cannot be the primary work
    2. Must be meaningfully connected to the primary work
    3. Must be subordinate to the primary work, and
    4. Must relate to carrying out the function of the primary work

    2.2.1.3 The registrar will consider a variety of factors relating to the work of the individual when determining whether the work is incidental, including:

    1. The individual’s job title
    2. The individual’s job description
    3. The nature of the primary work of the individual
    4. The nature of the security work of the individual
    5. Knowledge base required for the primary work
    6. Whether and how the primary work and security work are related or connected
    7. The percentage of time the individual spends on the security work
    8. The frequency of the security work, e.g. every day or on occasion
    9. Whether other individuals engaged in the same type of primary work are engaged in similar security work to the same extent, and
    10. Whether it is reasonable to expect the individual would engage in that type of security work when carrying out his or her primary work

    Reference