4.6 The Public Complaint Process

4.6 The Public Complaint Process

Why this matters for the BST exam: "Explain the process for complaints from the public" is a named learning outcome in the Introduction to Security unit. Note carefully that this is not the same topic as handling an unhappy customer at a desk. This outcome is about the statutory complaint route that runs from a member of the public to the Registrar of Security Services, and about what the Registrar can then do to your licence.

Who Can Complain, and About What

Anyone may make a complaint about a security worker or a security business. Two features of the BC process are frequently tested:

• Complaints cannot be anonymous. The complainant must identify themselves.
• Complaints must be made on the Security Programs Division complaint form (an online form, with a paper copy or assistance available on request for anyone who cannot use it).

The complaint must relate to at least one of:

A grievance that falls outside those instruments — a billing dispute with a security company, or rudeness that breaches no conduct rule — is not within the Registrar's jurisdiction, though it may belong somewhere else, such as the BC Human Rights Tribunal or the courts.

The Steps

1. Submission. The complainant completes the SPD complaint form.
2. Screening. The Registrar of Security Services decides whether to accept or deny the complaint and notifies the complainant of the decision.
3. If denied — the complainant may request reconsideration, or complain to the Office of the Ombudsperson.
4. If accepted — the Registrar decides whether the worker or business violated the laws and policies, and tells the complainant when the investigation is complete.
5. Investigation. A security investigator may attend a location, gather evidence, ask questions, speak to people, and copy or seize items. Investigations may also be opened without a complaint, on other credible information.
6. Outcome. Warning, ticket, administrative penalty, licence action — or no finding.

Inspections are a separate stream. Security inspectors routinely check compliance: they may enter a building or property, inspect documents or equipment, ask questions, and copy or seize items. Allowing an inspector to carry out their duties is mandatory — obstructing one is itself a problem, and Code of Conduct s.14(k) requires cooperation with police where required by law.

What the Registrar Can Impose

Before issuing an administrative penalty, SPD must consider whether there is a similar prior contravention, how serious the contravention is, whether anyone was hurt, and whether it was deliberate. These four factors are worth remembering — they explain why a documented, self-reported, non-injurious first mistake is treated very differently from a concealed repeat one.

Suspension and Cancellation: The 14-Day Rule

SPD notifies a worker or business when their licence may be suspended or cancelled, and in most cases gives them the chance to explain in writing first. Where it is necessary to protect the public, SPD may act immediately, providing written reasons; the affected person then has 14 days to respond in writing. SPD considers the response and decides whether to suspend or cancel, place a condition on the licence, or issue a different penalty.

Reconsideration — Not an Appeal Board

This is a common trap. There is no security services appeal board. Under Security Services Act s.51, a person may ask the registrar to reconsider a decision within 30 days of receiving notice of it, and the registrar must confirm, vary or cancel the decision and give written notice. Beyond that, the routes are the Office of the Ombudsperson (for administrative fairness) and judicial review in the courts.

What a Guard Should Do When a Complaint Is Made

• Do not argue with the complainant or try to talk them out of filing. Interference reads as intimidation.
• Write your notes immediately, while memory is fresh, and do not alter earlier entries. Backdating or amending a report after a complaint arrives is itself a Code of Conduct breach and destroys the credibility of everything else you wrote.
• Tell your supervisor and preserve the evidence — CCTV is often overwritten within days, so a preservation request has to go out at once.
• Cooperate with the investigator. Code of Conduct s.14(n) prohibits wilfully or negligently making a false statement, so answer accurately and say plainly when you do not remember.

Key Takeaway

Complaints go to the Registrar of Security Services, cannot be anonymous, must use the SPD form, and must engage one of the four listed statutes or their regulations. The Registrar screens, investigates, and can warn, ticket, penalise up to $5,000 for a worker, or take the licence. The remedy for a decision you disagree with is reconsideration by the registrar within 30 days, not an appeal board — and your best protection throughout is a contemporaneous, unaltered report.