Round Table on the Oversight of Non-State Policing in South Africa

Round Table on the Oversight of Non-State Policing held 10th March 2005

1. OSF SA Mission

The Open Society Foundation for South Africa (OSF-SA) seeks to promote the values, institutions and practices of an open, civil and democratic society. It works for a vigorous and autonomous civil society, not dominated by the state, in which minorities and divergent opinions are respected.

Within the context of these objectives, the Criminal Justice Initiative (CJI), a programme at the OSF-SA, seeks to build and strengthen the structure, systems and practices of accountability within criminal justice institutions with a view to strengthening democratic processes, and operationalising the principles embodied in the Constitution.

2.Introduction

The nature of policing in South Africa is changing dramatically and with it the demands and challenges for the oversight and the accountability of those policing services.

The services and functions associated with the role of traditional state police are being increasingly taken on by private concerns.

While the architecture in South Africa, for oversight of the South African Police Service is developed, the situation with regard to those policing functions undertaken by private concerns is not that clear.

It is further complicated by the fact that these services are provided in exchange for profit.

South Africa has seen significant growth in non-state policing over the last decade. The private security industry has expanded rapidly and now stands at almost four private security members to every SAPS member.

City Improvement Districts are now common place in the major cities. Here, rate top ups, paid by property owners, buy additional services of which security often forms the bulk. The trend is not limited to the wealthy and business who can afford to pay for the service.

Neighbourhood watches are common in many communities where civilians volunteer to undertake police - like patrolling duties.

This growth in private security is not a feature unique to South Africa. However it does represent one of the more significant manifestations of this trend and carries with serious implications for the policing reform agenda in the country.

While extensive mechanisms exist to oversee the state police, the question is whether there is sufficient oversight over non-state policing. To explore this under researched issue, the OSF-SA hosted a round table discussion on 10 March 2005. It forms part of a larger conversation on policing oversight which has unfolded over the past two years under the banner of another OSF-SA project, on strengthening police oversight in South Africa.


3 Format of the Roundtable

The roundtable drew on the expertise of specialists in the criminal justice sector with the view of identifying pertinent issues confronting the accountability and oversight of non-state policing.  The format consisted of presentations on

 Plural Policing - Tensions between the business of security and our Constitutional entitlement.  Where does oversight lie?
 Oversight of the private security industry. The Security Industry Regulatory Authority
 Oversight of policing partnerships. The City Improvement Districts 
 Oversight of  community based initiatives such as the Neighbourhood Watch
 Oversight of Non State/ Plural Policing -  Challenges and lessons from other countries

4. Presentations

A summarized version of the presentations follows. The PowerPoint slides and text of the presentations are included at the end of the report.

4.1 Plural Policing and Democratic Accountability Re-Evaluating Oversight

Ms Julie Berg, researcher at the Institute of Criminology at the University of Cape Town opened the discussion on plural policing and democratic accountability.  The central challenge posed by developments in policing was

“… to harness the diverse efforts of plural policing providers and auspices in the furtherance of public safety, without allowing the vagaries of unequal access and differentiated provision – fuelled by security as a commodity – in a weakly regulated market to segregate populations further along lines demarcated by their capacity to purchase additional security or retreat from the public sphere.” (Crawford et al, 2005)

She began by outlining a number of post-modern developments affecting South African policing. These included
 Fragmentation of social power
 Increased police emphasis on managerialism , consumerism  / commodification  and promotionalism
 State employing a ‘responsibilisation’  strategy (NCPS and White Paper on Safety and Security) – partnership approach
 Changes in property relations – policing of public and quasi-public space / ‘communal space’
 Policing as risk management – policing of ‘risky’ populations
 Fear of crime
 Rise in commercial security

She then went on to describe the notion of plural policing and its impact on how policing was perceived and approached. In her opinion it meant:
 A Shift in focus from ‘police’ to ‘policing’
 The development of new security arrangements or a ‘mixed economy’ of policing entities
 Policing as plural: policing and security provided by bodies other than the ‘state’ police

Concluding, she noted that plural policing poses a number of challenges to effective oversight. There is little state input into the nature of plural / networked policing. Although this is being taken up on a provincial and local level, many policing networks remain unevenly co-ordinated, ad hoc and weakly organised. Rules of engagement tend to develop over time and through personal relations. Players in the networks operate with different resources, knowledge, powers and goals. This exacerbates a blurring of duties and conflicts of interests. This confusion is carried into the public arena among communities and citizens often ignorant of the operation of the criminal justice system let alone the role and responsibilities of many non - state policing agents. The situation is critical as the type of policing provided by non - state police is often heavily focused on visible security / policing. It provides front-line interaction and a first encounter by the public with policing.
Meanwhile the commercial nature inherent in many of the plural policing partnerships often means that certain areas tend to become over policed while others become increasingly under policed. The social exclusion of groups of people poses an increasing risk as safety and security becomes commodified. This poses a number of challenges regarding accountability to the broader safety mandate of policing embodied in the constitution.

In this competitive, consumer-orientated environment the issue is how to hold evolving policing networks accountable. There is a need to align actions of security providers with the public good.  A central question is whether current oversight mechanisms for each policing entity need strengthening along with the co-operation and co-ordination of various mechanisms and agencies or whether the development of an overarching regional and independent oversight body to co-ordinate networked policing activity is required.

Alternatively, is state involvement necessary to accommodate new accountability arrangements or should the status quo be maintained allowing plural policing networks to ‘naturally’ develop and evolve over time and that these grass roots developments determine the type of local oversight needed?

4.2 Oversight of Private Security - The Private Security Industry Regulatory Authority

Mr Eddie Booyens, acting head of the Western Cape branch of the Private Security Industry Regulatory Authority presented on the oversight role of that body.

Currently the security industry comprises of 4500 companies and some 900 000 registered security personnel of whom 283 000 are active.

The Private Security Industry Regulation Act 56 of 2001 established a Private Industry Regulatory Authority (PSIRA). Chapter 2 of the Act provides the objectives of this body. These include the promotion of accountability. Oversight is provided through the active monitoring of compliance.  The authority comprises of five members who have no vested interest in the industry and are appointed by the Minister for Safety and Security.  The Authority employs staff to carry out its mandate and has an oversight mandate over these staff as set out in Section 9.  In turn they account to Parliament by means of annual reporting. The authority has offices in the Western Cape, KwaZulu Natal and the Eastern Cape along with a head office in Pretoria.

The first interaction between the PSIRA and the security company happens at registration. All security service providers are expected to register with the Authority. An application form assesses whether a prospective company complies with the basic company obligations such as tax and conditions of employment as well as having the infrastructure to provide the service being offered.

All registered security companies also agree to abide by a Code of Conduct which represents a second level of monitoring. Violations of the Code of Conduct are investigated and if found valid are subject to sanction. Fines are usually imposed for more common and less serious transgressions but in serious cases a company could lose its operating license.

Industry training represents another level of monitoring. All training needs to be accredited by the Authority.

The industry is regulated through an inspectorate who monitors the industry and reacts to complaints. These inspectors are governed by their own code of conduct set out in Section 32 of the Act. On receipt of complaints or after having witnessed an alleged violation, a charge sheet is opened to which the accused is given opportunity to respond or may be summoned to give answer.  In the case of a guilty verdict the Director of the Authority has the power to impose a penalty. Prosecutions are usually done within the Authority and resident prosecutors are employed for this purpose.  The powers of the Authority include, under Section 27, the application for an interdict against the guilty party. In addition the contractor of any service provider in contravention of the Act can also be held liable.  If an accused is not satisfied with the outcome the company has 60 days in which to appeal. In the case of investigation the charge is normally handed over to the SAPS to undertake the necessary background checks.

4.3 Oversight of Policing Partnerships – The City Improvement Districts

Mr Derek Bock, Chief Operations Officer Cape Town City Improvement District, presented on the oversight of policing partnerships of the Cape Town Central City Improvement District (CID)

He began by outlining the difference between two entities, the Cape Town Partnership and the Central City Improvement District. Currently there are Improvement Districts in many parts of Cape Town including adjacent city areas such as Sea Point, Oranje Kloof and, Green Point. The Central City Improvement District was established four years ago and funded by the rate top up paid by the 1200 local property owners.

 The Partnership is the managing agent for the Central CID.
 The Partnership focuses on strategic issues, i.e. attracting and facilitating investment opportunities.
 The Central CID focuses on operational issues, e.g. cleansing, safety, security and marketing
 Responsibility for managing security rests with Central CID.
o Central CID enters into an agreement with security service providers. In this instance. Securicor, who recently became part of Group 4 making them the biggest private security provider in the world.
o Manages the contract by means of a dedicated security manager.

Speaking to the security complement in the central city he said

 A security manager reports to the Central CID Chief Operations Officer to ensure that the contract is properly managed.
 Likewise, a contract manager is appointed by the security service provider.
 Together the security and contract managers need to ensure the following;
o That force levels are maintained.
o That security officers behave in the appropriate manner.
o That security officers are properly trained.
o That visibility of security officers is maintained throughout the Central City.
 Penalties were imposed for transgression and security  officers accused or guilty of any crimes were not allowed to work on the project.

Currently the contract is worth R 1 million a month and supports six patrol vehicles, horses and a personnel compliment of 60 day shift and 40 night shift officers. This contract regularly comes up for review and renewal.

Formal agreements in place include:

 The Central CID and security service provider have a service level agreement with Securicor to ensure compliance and performance.
 The SAPS and City Police work in close co-operation with Central CID security, but always take the lead. In joint operations the Central CID security maintains the perimeters while the SAPS undertake the operations. A city police officer is usually present in Central CID vehicles to provide for policing powers if this is necessary. The Central CID also supports the SAPS’s Sector Policing project aligning operational areas to sectors. City Police can call on additional Central CID support paying for any overtime incurred.
 Central CID security forms part SAPS safety and security forums
 Central CID security manager is currently the Chairperson of the Community Police Forum.
 Central CID Chief Operations Officer serves on the Civilian Oversight Committee of City Police.

Issues and challenges facing the Central CID include;

 Achieving a ‘mind shift’ from being a normal security officer to an actual “bobby-on-the-beat”.
 Dealing with social challenges such as the homeless and street children.
 Powers of arrest for security officers.

Concluding he said that the Central CID is seeking to play as constructive and development role as possible and in this regard is supporting adjacent city areas which did not have the funds to establish a CID in and attempt to address possible displacement of crime. Likewise they have recently employed a social services officer to deal with the more social issues encountered. Support is also provided to a local NGO, the City Mission. 

4.4 Oversight Of Civilian Safety And Security Structures

 Mr Zahir Amien of the Western Cape Department of Community Safety presented on the oversight of civilian safety and security structures.

The intention of his input was to  provide a broad overview of the current status of oversight of civilian law enforcement structures such as neighborhood watches and other community based structures involved in policing and law enforcement such as the street committees, community patrols etc. 

In his opinion, the growth of community based volunteer policing and law enforcement organisations has been an organic process in South Africa. Organisations such as neighborhood watches and street committees are cultural realities in coloured and african townships respectively. They were a direct response to the historical legacies of Apartheid-based policing which was intentionally not geared to protecting communities but rather to protect and serve the Apartheid regime. 
Since the advent of democracy these organisations as well as other community based anti crime organisations have evolved and grown. ISS research shows that more than 61% of South Africans participate in neighborhood watch organisations.

 The Western Cape government has embarked on a mass mobilisation campaign (Bambanani) to encourage communities to participate in community-based safety and security structures and in particular neighborhood watches as part of its philosophy of partnership policing.    

Currently there is no statutory legislation which provides for the specific oversight, regulation and accountability of community-based policing initiatives such as the neighborhood watches and street committees etc. Hence these structures operate only within normal common law and statutes applicable to all people, entities etc. SAPS reservists however are an exception and operate within the ambits of the SAPS Act.

The current modus operandi is that these structures are self regulatory. Currently neighborhood watches are guided and regulated by a uniform constitution and code of conduct.  It is however not compulsory for a neighborhood watch to subscribe to any broader associations.

However neighborhood watches which form part of the Bambanani campaign (approximately 3000) are trained, equipped, paid and managed by the Department of Community Safety. In order to qualify for offered resources, the neighborhood watches needed to comply with departmental regulations, policies and procedures which include being part of the Community Police Forums (CPF’s), being subject to their constitution and code of conduct and being lead operationally by the SAPS. The intention is to provide an incentive to regulation and hence oversight.

An institutional arrangement thus exists where the Bambanani neighbourhood watch volunteers are accountable in varying degrees i.e financially, operationally and intuitionally to:
 The National Government-SAPS;
 The Provincial Government –DCS;and
 The Community -CPF’s. 

Several mechanisms exist to promote accountability and oversight. These include
 Co-operative agreements with the SAPS-operationally;
 Service level agreements and financial accountability with the Department of Community Safety;
 Accountability via the CPF’s.

Non compliance impacts directly on resources and cooperation

Several challenges still present themselves. These include

 No specific legislation to regulate and hold Neighborhood watches accountable;
 Vigilantism

4.5 Oversight Of Non-State/Private Policing: Challenges And Lessons From Other Countries

Prof Anthony  Minnaar  of the Department  of Security Risk management, School of Criminal Justice, College of Law at UNISA presented on oversight of non-state/private policing: challenges and lessons from other countries.
When considering the debate on oversight of non state policing, one of the foremost problems encountered is a definitional one: what is private policing, private investigations, and crime control and crime prevention and are they part of community policing? Where do they fit into public policing?

The term private policing is used interchangeably and synonymously with that of private security even though the majority of the security industry is involved in purely guarding functions. There is a great distinction between private policing and guarding operations whereas the term policing implies an overall role of guarding, reaction and investigations. Private security does not generally have all these under one umbrella but they do exist in separate forms.

Modern security requirements however  dictate that ‘policing’ activities, very similar to those of the public or state policing agencies do occur, namely managing security risks (potential crime), risk (crime) profiling, risk (crime) analysis (identifying vulnerabilities), risk reduction, investigating any breaches of security and collecting information/intelligence as well as evidence of breaches in the provision of security (which might well be the perpetration of a crime against the organization/company) and the protection of assets, property and people.

Moreover, some of the functions such as securing premises, patrols, responding to alarm calls or crime reports and crowd management are very similar for both forms of policing. Furthermore, private policing involves more than just patrol and guard duties. Many of the allied activities to these two functions involve asset or people protection – establishing perimeter security and other protective barriers and security measures – and are essentially also designed to prevent insiders and outsiders from committing crimes, in other words pure and simple crime prevention. Furthermore, many security companies have developed investigative capacities and collect information, evidence, interview suspects and develop a criminal case (which is usually handed over to the authorities for prosecution) in the process of investigating ‘incidents’.

The crux of the oversight issue is that of accountability. The main function of public police agencies is to protect the public at large. In comparison the private security Industry operates on a profit motive and is accountable directly to the individual citizen only as a client and certainly not to the public at large. They are in fact accountable only to the client insofar as providing a security service and to their shareholders in terms of making money for them. But when public monies, taxes and business levies are used by local government or not-for-profit organisations to contract (as in CIDs) private security companies to provide some sort of policing of CBDs (CCTVs, foot patrols, investigation and arrests etc) then questions of public accountability and monitoring of those (private) police activities are inevitably in the public’s interest

One ‘grey’ area is the role of private investigators and the ancillary issues in their work regarding ethical questions around
 access to information by private investigators for legitimate purposes (e.g. governments using licensed agents to test fraudulent insurance claims);
 protection of privacy, accessing of confidential information, trespass and harassment (intimidation) in the course of private investigations or interrogations (interviewing of suspects).

Alison Wakefield has stated:

“….the growing role of a regulated private security industry in the policing of areas of mass private property, residential areas and even town centres should, therefore, not be seen as unpalatable so long as attention is paid to the powers and tools they are given for controlling their territories, the training they receive and the accountability structures that provide a check on their practices. [Furthermore] in relation to the exchange of information, standards must be set and safeguards must be laid down to ensure that such information remains confidential …. (Wakefield. 2003: 234).

The above recognises, not only the presence of private police in certain urban contexts and situations, but also a number of other issues in oversight, i.e. the need for professional training not only in security but also in policing (quality of service provided); but also to formulate a formal framework of accountability so that such private police officers can know and understand their responsibilities as well as limitations on actions when providing such private policing services. These are all crucial aspects to the monitoring and oversight of their activities.

Generally private sector operatives are subject to a much less stringent system of scrutiny than public police. In addition, when looking at oversight of private policing and the Private Security Industry the question that always comes up is: The ‘public’ interest versus the client’s (paid for) needs?

In Australia one of the problems regarding controls and monitoring of misconduct of private security operatives is the lack of understanding about the laws regulating their activities. This is linked to a lack of compliance as well as no knowledge of the penalties for breaches of the law.

The questions then that are posed in terms of oversight are:
 Firstly, what portion of private policing activities should be monitored in accordance standards and accountabilities of public police?
 Secondly, how should that monitoring occur, or in other words what body should be doing the monitoring?
 Thirdly, is consumer satisfaction not enough ‘oversight’ for the provision of private police i.e. the setting of service delivery as the standard or should monitoring include any misconduct and the imposition of sanctions through a court of law?
Regarding International control/monitoring responses, one of the main responses in developed countries has been the increased regulating of the private security industry and the establishment of private security regulatory authorities – full regulation is a recent phenomena in many developed countries (e.g. the UK legislation was only formulated in 2001 and regulations and licensing only implemented in 2004)
Stricter regulation is usually accompanied by the licensing as  in the UK. Fees are charged and the licence is renewable every three years for all service providers. In some countries this is linked to background checks on all registered security personnel for the existence of any criminal record.
In certain US states private security operators and agencies are bonded (which is forfeited if found guilty of misconduct). In the US this has been coupled with use of more effective civil remedies (i.e. civil litigation) for harms in both public and private sectors of policing.
In the implementation of a more regulated private security industry there has been the concomitant improvement of procedures for screening, training and managing civilian specialists.

Overall, in dealing with the entry into the public policing domain, a number of developed countries rely on the establishment of effective Public/Private Partnerships (PPPs) i.e. Partnership Policing.

Partnership policing has been most successful where it is:

 an extension of a national initiative and part of government policy.
 there is regional and local oversight.
 strategic co-ordination .
 operational and frontline co-operation (at grassroots level).

The PPPs are often underpinned by the formulation of so-called information sharing protocols. In other words the exchange of crime information in effective partnerships is governed by predetermined protocols applicable where disclosure is strictly justified. These protocols can improve data exchange between the parties and also enhance trust and confidence between the co-operating parties. They also lay down the ‘rules’ for the co-ordination of information collection activities and can lead to the establishment of formal databases i.e. an information node where all information can be collected, collated and analysed.
In addition, PPP operations, activities and deliverables also need to be underscored and supported by means of Service Level Agreements (SLAs). These are in essence specific service contracts outlining exact functions, responsibilities, limitations on authority, reporting lines, pooling and sharing of crime information, etc.
PPPs functions are often made more successful by means of instituting regular partnership meetings and structured briefings, since these can lead to a better understanding of the limitations and constraints on actions of the different partner organisations.

In all these partnership activities there is the obvious need for clear guidelines and accountability structures to be developed for each activity especially where they are strictly ‘policing’ activities.
One of the main sticking points of the formation of local level partnerships between the police and private security has been the issue of accountability (and not so much funding or resources). This in turn links to the issue of sanctions and disciplinary procedures for any misbehaviour, use of excessive force or abuse of powers that might be perpetrated by the private sector members of such formally established partnerships.

Worldwide the monitoring of private police per se (as opposed to the mere regulating of the Private Security Industry) is a relatively new demand. Given the uneven co-ordination, weak accountability and segmented regulation of policing all over the world, obvious formal oversight arrangements are a prerequisite to protect the public interest. One aspect of this is to institute a closely regulated private industry as a counter to existing public policing oversight. A UK report on Plural Policing Report found “there is an urgent need to consolidate and clarify relations” [between private security industry role players and public police]. Furthermore, that “suitably robust forms of governance and regulation [be implemented] to ensure [private] policing is delivered in accordance with democratic values of justice, equity, accountability and effectiveness” (‘Plural Policing’: The mixed economy of visible security patrols. Report by the Centre for Criminal Justice Studies, Leeds University, Oct 2004:1).

5 Discussion

The presentations were followed by questions and discussion. The questions asked in the discussion were

 Non State Policing - Public Expectations - where does accountability lie?
 Current Oversight mechanisms – are they sufficient?
 Possible areas/strategies for intervention

Emerging from the discussion the following points were noted:

Definitions

The diversity of the sector as well as the existence of mixed arrangements increases the complexity of the debate on oversight arrangements. Any debate on oversight and accountability in the private security arena  needs to be structured on the foundation of a clear definition of the industry or component being considered. As such, definitions need to articulate whether the focus is on private security in its totality or parts thereof such as community based options or partnership models. Furthermore the type service offered be it guarding, an investigative, policing function or a crime prevention service needs to be considered.

Capacity for Monitoring

Generally participants were of the opinion that capacity for monitoring and oversight is limited. The Authority is entirely funded out of registration fees and the small budget unable to bolster monitoring capacity. The effectiveness of the Private Security Industry Regulatory Authority is compromised by the limited number of monitors. In the Western Cape there are only five Inspectors. The work of the body is therefore largely dependent on complaints and less on investigative work.  Most complaints, some 60% tend to be labour-related with the balance being Code of Conduct issues.  In the province there are some 20 to 30 Code of Conduct violations a month. There is no system for public reporting. Neither are statistics kept on use of force or deaths in custody or as a result of security officer actions. 

Compliance with the Firearm Control Act

The compliance of the security industry with the provisions of the Firearm Control Act, including the safe guarding of weapons, the registration of individual weapons to individual security officers and competency training is a critical issue.

Foreign Military Assistance

Both the Foreign Military Assistance Act and the Private Security Industry Regulation Act cover the issue of mercenaries but loopholes occur as contracting usually happened outside of the country.

Municipal Police Oversight Committees

Cooperation between CID and Police is governed by partnership agreements.  Municipal Oversight Committees which could play an important oversight role are largely unable to fulfill this function. This is largely due to capacity issues.

Events management

Events companies providing short term security are often the most problematic. Many of these companies employed persons with little or no formal training and the short term nature of the contracts mean that they often fall outside of any action that could be taken by the Private Security  Industry Regulatory Authority  A New Bill on use of non registered security personal for event security management is being considered.

Legislation and Policy

The participants were generally of the opinion that current legislation and policy is sufficient to ensure monitoring and oversight of the private security industry. However while legislation provides for monitoring and oversight of the private security industry, little is available for community based initiatives.

Anthony Minnaar in his presentation notes that one of the outcomes internationally of Private Security Industry infiltration of public policing spheres of operation is the  implementation of  systems and structures like the neighbourhood wardens (UK) and blockwatch system. These supplement public policing with affordable private security which is community based. A state-funded option here was the implementation of Community Support Officers (CSOs) in UK during 2002/3. This facilitated community participation but also deflected private security usurpation of policing functions and the challenges this brings with it. CSOs are dedicated patrol officers in uniform with limited powers.

City Improvement Districts

Interaction between City Improvement Districts is being proposed to look at inter alia  standardisation across the Improvement Districts. As such it can address issues around partnerships between private security and the SAPS and standardisation in service level and partnership agreements.

Alternative Dispute Resolution

Related to non - state policing was the use of community based dispute resolution.  The South African Law Commission is considering options for an enabling legislation to encourage and provide a framework for this practice.

6 Issues for consideration in a way forward

1. Anthony Minnaar mooted the need to establish a more formal National Forum where representatives from public police and private security can discuss and formulate solutions to issues of cooperation and oversight . This Forum should to be other than the PSIRA board which is not a forum and which concentrates on professionalising the industry by setting training standards, sending out inspectors to check on registrations and working conditions, and implementing the Code of Conduct etc.
The proposed Forum can provide the opportunity for the setting up of a national ‘Think Tank” to research, test and recommend policy which can lead to the development of a formal framework where partnership policing can operate in practical terms to the benefit of the community at large. The Forum can also assist the government in formulating the requisite legislation, in order not only to formalise the various ad hoc and informal co-operation that is occurring in some areas but also to establish appropriate structures for partnership policing to occur on a sustainable and effective level.
2. Additional research on oversight and accountability of both the private security industry and community based policing initiative is required. This could feed into legislation development such as the proposed Safety and Security Act. Such research needs to include more conceptual work on definitions.
3. The capacity and funding of the Private Security Industry Regulatory Authority should be considered to enable more investigative oversight of the industry.
4. Monitoring capacity needs to be strengthened. The development of Standards and Qualifications in the field of law enforcement oversight to be undertaken by the National Standards Body in terms of the National Qualifications Framework needs to be expedited.
5. The training profile of the security industry is lacking in critical areas. An example was made that all that was offered to many security industry personnel in sensitivity training was a week-long course.
6. Discussion on oversight on  non-state security  should   be proposed  to the Portfolio Committee on Safety and Security as an agenda item on their  proposed Oversight Summit.

7 Conclusion

The oversight of non state and plural policing requires considered attention. The size of the industry is significant. It out numbers the SAPS by four to one undertaking many of the tasks traditionally associated with the police.  Yet by comparison oversight and accountability mechanisms are weak. The Regulatory Authority is under staffed and under resourced. Often the only oversight is in the form of private service level agreements between service providers and clients. Composite statistics on issues such as use of force or deaths and injury at the hands of the private security industry are not available and dedicated investigative capacity is absent.
The SA Human Rights Commission has raised a further challenge to the industry. They conducted an enquiry into boom gated communities in September 2004. In their findings the Commission stated that it did not support boom gate communities finding this type of security measure supported dysfunctional cities and social division while not being able to demonstrate a meaningful impact on crime. While the boom gate represent one facet of private security, the social exclusion of groups of people is an ever more likely occurrence as safety and security becomes commodified.

The issues raised in this discussion including the need for additional research inform policy, improving capacity at  the Private Security Industry Regulatory Authority including the development of standards and qualifications in the field of law enforcement oversight,  addressing the  training profile of the security industry and  establishing a national forum where representatives from public police and private security can discuss and formulate solutions to issues of cooperation and oversight, represent a number of initial  steps that  can be taken to addressing some of the concerns raised.