Christian Strike                                                                     January 15th 2025

Founder / CEO

Vigilant Security Services Inc. 

31 McBrine Dr. Unit 12

Kitchener, Ontario, N2R 1J1

strike@vigilantsecurityservices.org

(519) 783-1371

Re: Feedback on Proposed Changes to the Private Security and Investigative Services Act (PSISA)

Dear Minister Kerzner,

This letter provides feedback on the proposed changes to the Private Security and Investigative Services Act (PSISA), highlighting potential issues and proposing constructive recommendations to ensure the updated regulations are practical, effective, and aligned with the operational realities of security professionals.

The private security industry in Ontario is a cornerstone of public safety, complementing the work of law enforcement and ensuring the security of diverse environments, including residential communities, commercial establishments, healthcare facilities, and educational institutions. Your government’s ongoing focus on enhancing public safety and fostering a secure environment for all Ontarians is truly commendable. We greatly appreciate the strong support you have shown for police and first responders, which has helped build safer communities across the province.

Private security professionals are indispensable partners in this shared mission of public safety, providing an essential and often irreplaceable layer of protection to communities and businesses alike. With over 160,000 licensed professionals, the sector has experienced significant growth in recent years, reflecting an increasing demand for its essential services. Security guards play an indispensable role in protecting property and individuals, managing emergencies, and deterring criminal activity. Their responsibilities often extend to interacting with vulnerable populations and providing investigative expertise. This multifaceted engagement significantly impacts the daily lives of Ontarians, contributing to safer communities and enhancing the overall quality of life in the province.

Given their integral role in public safety, private security professionals are often the first line of response in many scenarios, bridging gaps where public policing resources may be stretched. While your government’s focus on supporting law enforcement is evident and effective, we believe that the private security sector deserves similar recognition and support to fully realize its potential in complementing these efforts. Recognizing these contributions, it is imperative that any legislative changes to the Private Security and Investigative Services Act (PSISA) support the continued growth and professionalization of this sector.

Feedback on Proposed Amendments

1. Uniform and Equipment Standards

Proposed Regulations:
Prohibit certain t-shirt colours (e.g., black, navy blue, grey).
Mandate additional patches for uniforms and titles on hats.
Restrict the use of rank indicators (e.g., epaulets).
Concerns:
These changes create unnecessary costs for security agencies without clear evidence of benefit. The average small to medium sized security agency in Ontario has 200 Security Guards, with an average cost of $40.00 per collared shirt, in addition to the costs of tailoring to add the required legislated patches will exceed $20,000 on average for each affected agency.
Rank indicators are a source of pride and professionalism for guards and have no proven negative impact on public perception.
Recommendation: Simplify uniform regulations to focus only on changes with a demonstrable impact on safety or professionalism. For example, allow existing patches to remain compliant if they meet visibility standards.

2. Vehicle Use on Private Property

Proposed Regulations:
Prohibit the use of sirens and push bars.
Outlaw prisoner cages in vehicles.
Concerns:
Sirens and push bars are often critical for security operations on large private properties, such as mines or campuses, where security acts as first responders
Prisoner cages provide a safe way to detain individuals awaiting police transfer, especially in remote areas where wait times can exceed 6 hours.
Recommendation: Allow use of sirens, push bars, and prisoner cages on private property under specific guidelines to address operational needs while avoiding public confusion.

3. Inspection Authority

Concern: The current PSISA does not empower inspectors to assess "in-house" security programs (e.g., those in bars, hospitals, or shopping centres).
Frequently observed issues exist within in-house security programs of non-compliance with the current uniform, vehicle and record keeping regulations under the PSISA.
Recommendation: Grant SolGen the authority to inspect in-house security operations to ensure compliance with licensing and training standards across the sector.
 

Additional Recommendations for Industry Improvement

1. Training and Licensing

Proposal: Introduce a tiered licensing system to differentiate levels of training and responsibility, especially for guards authorized to use force.
Rationale: Tiered licensing ensures that only adequately trained professionals are entrusted with advanced responsibilities, such as the use of less-lethal tools. This concept was initially proposed in 2008 but has not been implemented.
Proposal: Mandate in-person delivery of the 40-hour training program, with exceptions for remote areas where virtual, instructor-led sessions can be allowed.
Rationale: Standardized in-person training minimizes fraudulent practices and ensures guards are adequately prepared for their roles.
Proposal: Require annual in-service training for security guards, with a minimum of 8 hours per year.
Rationale: Ongoing training maintains professional standards and aligns with practices in policing and other public safety roles.

2. Background Checks

Concern: Outsourcing background investigations for security guards to private companies raises risks of fraudulent approvals.
Recommendation: Return background investigation responsibilities to SolGen to maintain oversight and ensure integrity in the licensing process.

3. Addressing Training Gaps for Armed Guards

Concern: The Authorization to Carry (ATC) course has not updated its curriculum to reflect changes in the Criminal Code (Sections 34/35). Some sections of the Criminal code which have been repealed and replaced for more than a decade are still part of the current curriculum. 
Recommendation: Revise the ATC curriculum to include accurate legal instruction, ensuring armed guards understand the lawful use of force. 

4. Custody Transfer Delays

Concern: Security guards often face excessive delays (6–12 hours) in transferring arrested individuals to police custody, creating operational and humanitarian challenges.
Recommendation: Introduce policies that allow custody transfers via telephone authorization from police in specific circumstances, reducing wait times and enhancing efficiency.
 

5. Additional Suggestions for Industry Professionalization

Proposal: Require agency owners to pass proficiency tests before obtaining a license to operate security services.
Rationale: This measure would elevate industry standards and ensure only qualified operators manage security agencies.
Proposal: Permit security guards to carry less-lethal tools, such as pepper spray, under strict training and licensing requirements.
Rationale: With rising assaults on security guards, access to less-lethal tools would enhance personal safety and their ability to manage threats.
To conclude, the private security industry is a vital pillar of Ontario’s public safety framework, forming an essential part of the resources your government relies on to keep Ontarians safe. Security guards are indispensable in their contributions, providing critical support to law enforcement and ensuring the safety of individuals, businesses, and communities across the province.

As you consider updates to the Private Security and Investigative Services Act, we urge you to recognize the importance of this sector and its role in achieving your government’s public safety objectives. Supporting the growth, professionalization, and operational capacity of private security professionals will only strengthen Ontario’s overall safety and security.

We would welcome the opportunity to discuss these issues further and would greatly appreciate the chance to meet with you and your office to share insights and collaborate on solutions. Thank you for your continued commitment to public safety and for considering these perspectives.

Sincerely,

The Undersigned

Christian Strike
Founder / CEO
Vigilant Security Services Inc.