1.5 Public Complaints & Disciplinary Process

How Complaints Are Made

Under section 24 of the SSIA, any person may make a written complaint about an individual licensee (a licensed security worker) to that worker's employer within 90 days after the action or circumstance giving rise to the complaint. Complaints about a business licensee (a licensed security agency) go to the Registrar within 90 days instead (s. 28).

A complaint typically includes:

• The name and licence number of the security worker (if known)
• The date, time, and location of the incident
• A description of what happened
• Any supporting evidence — reports, photos, witness contacts

Under section 25, the employer must investigate and dispose of the complaint. The employer may refuse to investigate, or stop an investigation, if the complaint is frivolous, vexatious, or made in bad faith, or if no investigation is necessary, but it must tell the complainant in writing, with reasons, within 90 days.

Quick Answer: Complaints about an Alberta security guard go in writing to the guard's employer within 90 days (SSIA s. 24). The employer investigates and reports its decision within 90 days; the complainant can then ask the Registrar to review it within 30 days, and the Registrar may vary the licence's conditions, suspend it, or cancel it (s. 26). Licensees must give the Registrar the information the Act requires — refusing is a ground for suspension or cancellation (s. 20).

The Registrar's Powers

The Registrar is the official responsible for licensing under the SSIA. After reviewing an employer's disposition or investigating a complaint, the Registrar may act on the worker's licence or on the employer's business licence:

Separately, section 20 lets the Registrar suspend or cancel a licence if the licensee is convicted of a criminal offence or an offence under the Act, breaks a licence condition or the code of conduct, makes an untrue or misleading statement to the Registrar, fails to provide required information, is not a fit and proper person, or where suspension or cancellation is in the public interest. The Act does not list warnings as a Registrar sanction; offences under the Act are prosecuted separately (ss. 44-46).

What Triggers Discipline?

Common triggers for a disciplinary investigation include:

• Criminal behaviour — a charge or conviction that makes the worker ineligible, or conduct on duty that is criminal (theft, assault, fraud)
• Dishonesty — falsifying reports, claiming unworked hours, lying to the employer or Registrar
• Breaches of confidentiality — disclosing client or security information to unauthorized persons
• Working without a valid licence — letting a licence expire and continuing to work, or working before a licence is issued
• Conduct violations — harassment, discrimination, impairment on duty, failure to follow post orders or Registrar directions
• Failure to co-operate — not responding to the Registrar's inquiries or obstructing an investigation

The Worker's Duty to Provide Information

A licensed security worker must give the Registrar the information the Act and regulations require. In practice this means:

• Responding to the Registrar's requests for information
• Providing accurate and complete information — not misleading the Registrar
• Producing records (reports, logs, licence) as requested
• Not obstructing the process or intimidating witnesses

Failing or refusing to provide required information, or making an untrue or misleading statement to the Registrar, is a ground for suspension or cancellation under section 20 of the SSIA — even if the original incident was minor.

The Complaint Process in Outline

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Mandatory Reports — Brief Note

The SSIA also requires security workers and agencies to make mandatory reports to the Registrar in certain situations — for example, changes to the worker's criminal record status or certain incidents on duty. The detail of mandatory reporting is covered in Module 5; for this module, remember that the duty to report and the duty to co-operate both exist alongside the complaints process.

What Happens After a Complaint Is Filed

Candidates often know that a complaint can be made but not what follows. The SSIA sets out predictable stages, and the ABST may test the sequence.

1. Complaint to the employer (s. 24). The complainant writes to the worker's employer within 90 days of the incident.
2. Employer investigation (s. 25). The employer investigates and disposes of the complaint, or refuses with written reasons if it is frivolous, vexatious, made in bad faith, or needs no investigation. Within 90 days of receiving the complaint, the employer notifies the complainant, the worker, and the Registrar of its disposition and of the complainant's right to a Registrar review.
3. Registrar review (s. 26). Within 30 days of the employer's notice, or if the employer has not completed its investigation, the complainant may ask the Registrar to review the complaint. The Registrar may vary the terms and conditions of, suspend, or cancel the worker's licence or the employer's business licence, and must explain the decision in writing.
4. Director review (s. 27). Within 30 days of the Registrar's decision, the complainant may ask the Director to review it. The Director confirms, reverses, or varies the decision, and the Director's decision is final.
5. Licensee review (s. 23). A licensee whose licence is suspended, cancelled, or varied may also ask the Director to review the Registrar's decision within 30 days.

How a Guard Avoids a Complaint

Most complaints are avoidable through practices the rest of this guide teaches: courtesy even under provocation, accurate and factual reports, confidentiality, staying within your authority, and following post orders. The single best protection is a complete, factual, timely written record — if you document what you did and why, a complainant's version has to compete with your report.

When a member of the public threatens to complain, do not argue or try to talk them out of it. Explain that complaints go in writing to your employer and give your employer's contact information if asked, note the threat in your shift report, and notify your supervisor. Retaliating against a complainant is itself a disciplinary issue.

Worked Scenario

A guard ejects a drunk and aggressive patron from a licensed venue. The patron later files a written complaint with the guard's employer alleging excessive force. The guard's shift report, written the same night, records the patron's behaviour, the warnings given, that no strike was used, that police were called, and the names of two staff witnesses. CCTV confirms the account. The employer investigates, finds the force was reasonable and minimal, and within 90 days reports that disposition to the patron, the guard, and the Registrar. The patron can ask the Registrar to review it, and the same-night report would again be the key evidence. The guard's accurate, same-night report — not the uniform, not the patron's anger — is what carried the decision.