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DesignTechnicalIssues2014 PDF
DesignTechnicalIssues2014 PDF
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Protecting Crowded Places: Design and Technical Issues
Produced by the Home Office in partnership with the Centre for the Protection of
National Infrastructure and the National Counter-Terrorism Security Office.
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Contents
Chapter 4 Public and private space: design, management and maintenance – page 14
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Introduction
1.01 The UK faces a significant threat maintenance of public spaces and
from international terrorism. The current streetscapes and to conservation officers
assessed threat level to the UK can be in the context of development in
found on the MI5 website1 where more Conservation Areas.
information can also be found on what
1.04 The guide gives practical advice on
threat levels mean, who decides the level
how best to incorporate counter-terrorism
of threat and how the threat level system
protective security measures into
is used. Whilst there have been attacks
proposed new development schemes
against well protected targets around the
whilst ensuring that they are of high
world, experience shows that crowded
design quality. The advice that is set out is
places remain an attractive target for
generic and cannot address the plethora
terrorists who have demonstrated that
of varying circumstances and degrees of
they are likely to target places which are
risk which apply to different facilities.
easily accessible, regularly available and
Consideration should first be given to the
which offer the prospect for an impact
relevance of such measures and whether
beyond the loss of life alone (for example,
or not they can be appropriately achieved
serious disruption or a particular
through the planning system in any
economic/political impact).
particular case. If so, the measures should
be appropriate, proportionate and
Purpose of the guide balanced with other relevant material
considerations.
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terrorism measures as part of new emergency planning work rather than as a
proposals in sensitive historic areas and discrete issue in schools. It is important
sites which, for example, may not be able that schools keep pupils safe from threats
to utilise the typical solutions offered. See to their well-being, and schools do this
section entitled „Historic Environments‟ very well, keeping their premises secure.
(paragraphs 4.07 - 4.14) for specific They are generally controlled
retrofitting design advice when considering environments, unlike universities and
counter-terrorism measures within historic colleges, where any member of the public
environments. can gain access to the campus.
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Terrorist methodology
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An explosion and motorcycles through to large goods
vehicles (LGVs).
2.04 An explosion is normally the sudden
and violent release of energy caused by Explosive effects
an extremely rapid chemical reaction
which turns a substance (usually a solid or 2.07 The six basic effects of an explosion
liquid) into a large quantity of gas are:
(generally at high pressure and • blast wave: the blast wave is a very fast
temperature). This reaction is typically moving high pressure wave created by the
measured in microseconds. The
rapidly expanding gas of the explosion.
expanding gas is produced rapidly and The pressure gradually diminishes with
pushes the surrounding air out in front of it distance but can reflect and diffract around
creating a blast wave.
structures;
2.05 When an explosion occurs at ground • fire ball: the fire ball is created as part of
level there are several effects created that the explosion process and is local to the
cause damage and injury. The effects will seat of the explosion. It is generally
be dependant on the power, quality, associated with high explosives;
quantity and location of the explosive
material deployed and are outlined in • brisance: this is the shattering effect, is
paragraph 2.07. very local to the seat of the explosion and
is generally associated with high
Improvised explosive devices
explosives;
2.06 Improvised explosive devices (IEDs) • primary fragments: these are parts of the
range in size from person-borne small device or its container (including the
containers, rucksacks and suitcases to vehicle if vehicle-borne) which have been
larger devices, such as those that are shattered by the brisance effect and are
vehicle-borne. The latter may be borne by propelled at high velocity over great
a variety of vehicles, ranging from bicycles distances;
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• secondary fragments: these are 2.10 Whilst attacks using firearms will be
fragments that have been created by the countered by armed police or the military,
blast wave. Typical secondary fragments protective security measures such as
include glass, roof slates, loose gravel, those detailed in Annex A may help
timber and metal. These can travel mitigate the impact of an attack, and
considerable distances; and should be considered at the design stage
of a development. Although this guidance
• ground shock: this is produced by the is focused specifically on building designs,
brisance effect of the explosion shattering tight access control involving an effective
the ground local to the seat of the staff pass system and the regular training
explosion, i.e. creating a crater. The shock of staff using well-developed
wave resulting from the crater‟s creation response/emergency plans is important in
then continues through the ground. supporting technical solutions in mitigating
Causes of fatalities, injuries and the impact of a terrorist firearms attack.
damage from blasts Further information on these proposed
2.08 The main causes of fatalities, injuries measures are provided in Annex A.
and damage as a result of an IED are: • Project Argus and Project Griffin (see
• direct weapon effects including primary Annex F), as well as protective security
fragments, lung blast damage, thermal advice published by NaCTSO, help raise
burns and ear drum rupture; secondary awareness of the business community to
the terrorist threat and the value of
fragments such as glass, spall (flakes of
material that are broken off a larger solid recognising those involved in hostile
body) and other objects thrown by the reconnaissance. This helps to disrupt
blast; potential attacks and to produce important
intelligence leads.
• collapse causing crush injuries; and
2.11 Project Argus also provides guidance
• post-event falling debris (including to the business community to help plan
glazing, façade, internal walls etc) their response to a terrorist attack using
damaged equipment and damaged firearms6. This includes;
infrastructure which can hinder the speedy
evacuation of buildings. • how you would communicate with police,
staff, visitors, neighbouring premises.
Chemical, biological, radiological (including using, for example, public
materials and firearms attack address systems);
2.09 The issues arising from chemical, • the key messages you would give them
biological and radiological (CBR) materials in order to keep them safe;
are various and complex. However, in
essence, the potential problem will be less • how you would secure key parts of the
onerous the more the threat can be building to hinder free movement of the
excluded from a facility. Key mitigation terrorists (including use of enhanced doors
involves good access control into critical and locks to withstand entry from armed
facilities and the protection of air intakes intruders and provide cover for those
within buildings and its distribution caught up in an attack);
thereafter.
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• incorporating a firearms attack scenario More detailed advice about actions people
into your emergency planning and caught up in a firearms attack can take
briefings; and can be found on the NaCTSO website.
Businesses can also obtain further
• testing the plan annually. information from their local police Counter-
Terrorism Security Advisers.
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The challenge of blending counter-terrorism protective
security measures with urban design principles
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3.02 Each site is different and there is no Counter-terrorism protective security
“one size fits all” solution. Different sites measures should not impose upon the
present unique challenges and overall style and intention of a place;
considerations that will result in bespoke
solutions, including those that meet the • considering counter-terrorism protective
needs of the disabled. security measures at the design stage
helps ensure measures work together and
3.03 Typical measures that help to deter, do not displace vulnerabilities elsewhere
detect and delay a terrorist attack are set in a new build;
out in the table below. They are grouped
into five key counter-terrorism design • strengthening a building or place by
principles: better blast resistance; better designing in counter-terrorism protective
building management facilities; search and security measures offers wider business
screening, better traffic management and continuity benefits in the event of a
hostile vehicle mitigation measures; and terrorist incident; and
better oversight. “Designing-in” counter-
terrorism protective security measures • incorporating good counter-terrorism
from the outset will benefit those involved protective security measures is also good
throughout the development process, from crime prevention.
concept design through to planning
approval, as well as those who will use Generally, good counter-terrorism
and visit the places and buildings. These protective security measures will support
benefits will best be achieved through other measures intended to reduce other
collaborative working and broad types of crime.
engagement with all parts of the
community. The benefits include: 3.04 In seeking to deliver these benefits it
is important:
• it is more cost effective to “design-in”
protective security measures from the
• that appropriate counter-terrorism
outset of a scheme;
protective security measures should be
proportionate to the risk of terrorist attack
• there are aesthetic and functional
to which the building/place is exposed;
benefits to designing-in counterterrorism
and
measures at the concept stage rather than
later on. The building or place should be
• that costs for new protective security
attractive, accessible (see „Urban design
measures should fall where the
principles‟ in paragraph 3.05 below) and
responsibility for those measures lies.
work for those that will use and visit it.
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Table 1: typical counter-terrorism protective security measures
Install doors and locks which are better able to withstand entry from armed
intruders and provide robust ground floor facade material, which together
will help to provide cover for people caught up in a firearms attack.
Air intakes that are in a secure area and above the first floor level;
Hazardous material stores that are at a safe distance from the building and;
Better traffic Structural measures that prevent access to, or close proximity of,
management and unscreened vehicles to the building or space; and
hostile vehicle
mitigation measures Measures that reduce the speed of vehicles approaching the site or its
defences, like bends or chicanes
Well maintained and managed litter-free building surrounds that reduce the
opportunity for suspicious hidden items and suspect activity to go unnoticed;
Well managed access points and reception facilities that offer less
opportunity for intruders to go undetected and may deter them from taking
further action
Better search and Provision of sufficient space at vehicle entrances to allow proportionate
screening measures screening of vehicles (and their occupants / loads) as and when the threat
dictates;
For higher risk sites, consider off-site screening of deliveries and mail.
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Urban design principles • quality of the public realm - a place with
attractive and successful areas accessible
3.05 Good urban design creates places to the public;
which maintain sustainable and attractive • ease of movement - a place that is easy
environments which people want to use. to get through but where routes do not
The principles of well-designed places and compromise security;
spaces can be recognised as those with:
• legibility - a place that has clear image
• character - a place with its own identity; and is easy to understand;
• continuity and enclosure - a place where • adaptability - a place that can change
access for the public is clearly identified; easily; and • diversity - a place with variety
and choice. Urban design principles are
described more fully on the government
planning portal’7.
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Public and private space: design, management
and maintenance
Integrating counter-terrorism protective described in Part M of the Building
security measures into public realm Regulations) such as vehicle setting down
design points, will be necessary.
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counter-terrorism protective security and buildings and large developments in
crime prevention can be found at Annexes conservation areas.
D and E.
4.11 When seeking advice from English
Historic environments Heritage, contact the relevant regional
office. However, if more specialist advice
4.07 The advice in this section concerns is required on security issues in the
incorporating counter-terrorism protective historic environment, this can be provided
security measures into existing historic by English Heritage.
environments where there are special
considerations. This means the advice is
concerned with retrospective fitting of
measures rather than designing measures
into new developments from the outset,
although common principles apply.
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reversible. Applications for planning 4.15 In considering integration of security
permission and/or listed building consent measures into streets and spaces, the
will need to be accompanied by more long-term management and maintenance
detailed plans than usual. For example, by issues could usefully be taken into
specifying methods of fixing where works account at the earliest stages. The long-
would affect the historic fabric. term financial and administrative
commitment required to keep the
4.14 Where it is necessary to prevent measures effective and attractive need to
vehicles from getting close to a facility, it be allowed for in appropriate planning,
may be possible to introduce a physical highway and management agreements.
barrier into the landscape design. If there Other key issues are:
is valuable underground archaeology,
shallow excavation or surface
mounted/pinned barrier solutions will often
be favourable. In especially sensitive
locations, it may be better to prevent
uncontrolled vehicular access to the
surrounding streets completely, displacing
the traffic management works to a less
sensitive location.
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access will need to be restricted. Having covered by those benefiting from the
specific management and maintenance implemented measures;
plans ensures continuity, even after initial
commissions or staff appointments are • high quality and well maintained space is
replaced. Changes may also occur to the a key strategic requirement and objective
legislative frameworks of, for example, of nearby interested parties (e.g. property
traffic orders or regulations that may owners, prominent tenants, land owners);
require agreements to be updated;
• site staff roles. There is a strong case for
• consult widely - local consultation has putting trained staff into spaces as they
always been the key to ensure that the can provide a range of services within the
priorities of key interested parties and space e.g. interaction with the community
local populations (including the disabled using the space and carrying out of
community) as well as other user groups specific tasks such as locking up or
(e.g. tourists/nearby workers, and visitors) checking for damage/maintenance tasks.
are taken into account. Broader Where this presence is onstreet, it is best
engagement and collaborative working will if trained personnel are clearly identifiable
result in better design solutions and can as working for the appropriate highway
have significant management and authority. Where this function is being
maintenance of public space benefits, carried out by non-highway authority
minimising conflict with those who use the personnel, an appropriate contract and
space; service level agreement needs to be
agreed with the highway authority;
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Planning Authority (LPA) may wish to
secure a particular level of access or
security provision that is appropriate for
the proposed use of the land by an
applicant. Such measures can be made
the subject of conditions on a planning
permission, or be the subject of
appropriate obligations in a related
Section 106 Agreement.
4.17 In the case of crowded places, it may possessions, for non regulated
be appropriate to ensure, through applications19. It will also be appropriate in
appropriate conditions on a planning other circumstances to ensure that
permission, that the proposed layouts unencumbered pedestrian public access is
allow for secure entrance areas where maintained and that the security measures
security screening (people, vehicles and proposed are proportionate to the use (i.e.
mail/deliveries) and control can be best the right of access by the public to areas
carried out with minimal risk to the least of public realm accessible from the
number of people. Information on the highway). This is particularly relevant
specification and implementation of search where security measures restrict vehicular
and screening measures is available on access and there are managed security
the CPNI website. A public available measures requiring trained personnel.
standard has been developed by the Appropriate obligations in a Section 106
Home Office Centre for Applied Science Agreement can be used to ensure that the
and Technology which gives guidance and level of restriction is commensurate with
recommendations for checkpoint security need and that the public are not unduly
screening of people and their bags and
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restricted in accessing important amenities example where an „Access Only‟ Traffic
such as shopping. Order restricting vehicular access to a
shopping area is managed by security
Personnel security personnel employed by local businesses.
This is most appropriately done through
4.18 Where access control measures are the use of a Section 278 Agreement
incorporated into a building, or installed to setting out the level of training, service
control access to a wider area of and monitoring required by the service
streetscape, the personnel controlling provider and the financial arrangements,
those measures must be trained and in order to ensure that those that benefit
trusted. from the service pay the full costs.
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4.29 CCTV is not an alternative to getting
the design right in the first place, for
example, avoiding recesses in building
elevations/facades that can offer hiding
places for devices or individuals and may
require monitoring /oversight. If poles for
mounting CCTV cameras are being
considered, careful thought will be needed
to minimise the impact on the streetscape.
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parliament. The Code of Practice20 came camera systems so that there is
into force on 12th August 2013 setting out proportionality and transparency in their
guiding principles that should apply to all use of surveillance, and systems are
surveillance camera systems in public capable of providing good quality images
places. These guiding principles are and other information which are fit for
designed to provide a framework for purpose.
operators and users of surveillance
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Annex A: Typical counter-terrorism design attributes -
design of structures
When considering the incorporation of practicable for buildings that are modest in
counter-terrorism measures into general scale and/or have only modest levels of
design advice to site owners and occupancy.
operators is available from theNaCTSO
website. Counter-Terrorism Security External areas
Advisers (CTSAs) also offer detailed
security advice on a bespoke basis and Measures that should be considered
will provide proportionate consideration to include:
new build sites and redevelopments,
focusing effort commensurate with the • physical measures such as external
assessed attractiveness of the site and barriers and/or a strengthened perimeter
where the likelihood of return - in the form to prevent access to the facility for the
of protective security improvements - is placement of Improvised Explosive
higher. Advice is also available from the Devices (IEDs) either by forceful (i.e.
private sector on a commercial basis. If suicide car bomb) or overt means (i.e.
appropriate, the Centre for the Protection pedestrian suicide bomb). See also Annex
of National Infrastructure (CPNI), via the B, (Design of hostile vehicle mitigation
CTSA, may also offer bespoke advice. measures) for further information;
The CPNI website contains general
security advice across a range of spheres • measures to limit secondary
including cyber, personnel, and physical fragmentation;
security; as well as guidance on security
planning. Further advice for designers and • avoidance of hiding places around
architects can be found using the Resilient buildings and within façade arrangements
Design Toolkit on the police Secured by that might be used to conceal a hostile
Design website21. Engagement with the person and/or an IED;
Counter Terrorism Security Advisor should
be sought at the earliest opportunity in the • the value of CCTV coverage as a
design process to ensure the best potential deterrent; and
consistent and proportionate advice,
preferably at RIBA Stage 1. • any pedestrian and vehicle gates to be
compatible with the robustness of the
The measures described below are not remainder of the perimeter.
mandatory and the desirability of their
inclusion in a development depends on a Building structure
range of factors. Where the measures are
appropriate, they will help to mitigate the Measures that should be considered
vulnerability of buildings to terrorist attack include:
and limit the extent to which the building
might exacerbate the effects of such an • as a minimum the measures for
attack. They are particularly relevant to robustness against disproportionate
buildings with significant occupancy and collapse for Class 2B buildings described
size and may be less realistically in current Building Regulation A3;
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• the use of either framed reinforced • using non-glazed cladding materials that
concrete or framed structural steel; will provide protection from fragmentation
and will not readily fragment or fail under
• if framed reinforced concrete, use in-situ blast loads and fixed to the structural
connections. Ensure beams, columns and frame with connections that can resist
floor are all tied continuously together inward and outward loading;
using robust vertical and horizontal
reinforcement details. In addition to normal • avoiding blast traps/containment in
gravity and environmental loads allow for building elevations/façades (such as
load reversal (e.g. slabs being forced overhangs and deep recesses) or
upwards by explosion pressure (see surroundings;
robustness clauses in current code of
practice BS EN 199214 and consider the • protected spaces (previously known as
use of these clauses irrespective of bomb shelter areas) and the evacuation
building height); routes to them should provide effective
resistance to blast and fragments. The exit
• if framed structural steel, ensure that routes should be duplicated. They should
connection details will take reverse be in a core part of a robust building,
loadings. Floor slabs to be tied to beams remote from threat areas and away from a
with in-situ topping BS EN 199315 perimeter, preferably at levels above
robustness clauses to be considered ground floor or in a basement. They
irrespective of building height); should also provide good fire resistance.
Overall space should be provided on a
basis of at least 0.66m² per person,
• if unscreened vehicles are permitted to related to the building occupation level.
enter underground parking facilities then Provision in protected spaces should
ensure that the structural design considers include a means of communicating with
the floor/roof slabs, columns and the facility‟s control room and the outside
connection details within this facility. In world, lighting and water and, ideally,
addition, this vulnerability needs to be seating, toilet facilities and a back-up
clearly considered in any contingency means of communications. Specialist
plans, for example building evacuation advice should be sought;
plans which involve the movement of
people around the building; • avoiding masonry buildings over two
storeys, unless special masonry
• the spreading of structural sway/ shear reinforcement is employed;
stability throughout the building, especially
where expansion joints split up the • using pre-cast framed structures where
structure. Concrete walls and shafts that connections between components provide
provide stability may also provide useful a comparable level of robustness to that
protected internal spaces where achievable with an in-situ reinforced
occupants can take shelter from external concrete frame;
threats;
• roof structure (and components of) over
• attaching glazed and non-glazed occupied spaces constructed of reinforced
cladding panels directly to floor slabs concrete (not less than 150mm thick)
rather than to perimeter columns; particularly if there is a mortar threat; and
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• as small as practicable structural spans
with regular column grid spacing and the
avoidance of large spans, particularly at
lower levels. Check removal of key
elements if exposed to or at risk of impact
explosive attack to ensure that their
removal does not lead to a progressive
collapse.
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• provision of public address (PA)/
communications for emergency • locating air intakes for the HVAC system
announcements; in a secure location and ideally at level 2
or above;
• separation of the main public/visitor
entrance from the main stair/service/ lift • ability for the HVAC system to be
shaft riser; capable of rapid shut-off and the location
of make-up air intakes in a secure area;
• separation of the main public/visitor/
reception area from any central internal • locating essential/critical services away
atria; from vulnerable façades of the facility; and
• split floor areas up with robust internal • locating the security control centre within
partitions to limit penetration of possible a protected area of the facility.
fragmentation;
Parking of vehicles beneath buildings
• the incorporation of at least two
staircases in the layout, spaced apart but The parking of vehicles and the delivery of
preferably with no more than 50m goods beneath buildings may in some
between them, and orientated to provide circumstances offer particular design
diverse, well separated escape routes; advantages (such as preserving street
frontages and using land more efficiently)
• entrance arrangements appropriate to which may outweigh other considerations.
the likely attempted hostile entry risk (e.g. However such underground or
vehicle and pedestrian barriers). For subbasement parking and delivery areas
example, the provision of a lockdown can present significant challenges from
capability for the entrance area in an the point of view of counter-terrorism
emergency, where initiation of lock-down protective security as they increase
is by local alarm and release is remote (for vulnerabilities to terrorist attack by vehicle-
example from an inner security control borne improvised explosive devices
position); (VBIEDs) – and hence pose a risk which
needs to be assessed. Where such
• entry control and associated barriers facilities are planned and they involve
giving access to a building should be access by unscreened vehicles, then it is
located at the outermost practical position important that those proposing the
possible. The further a hostile event is development consider the extent of the
allowed into the main body of a structure, risk posed and any appropriate options for
the greater the damage that will generally mitigating it by reducing the development‟s
occur; vulnerabilities. Where appropriate in the
light of police CTSA advice about the
• if an entry access control system is to be assessment of risk, this includes
provided, it is preferable that it includes considering introducing design mitigation
PIN verification at the outer boundary; measures such as a strengthened
structural building design (taking account
• separation of the general heating, of advice from police CTSAs - see bullet
ventilation and air conditioning (HVAC) points under „Building structure‟ above)
system from the provision for the entrance and improved traffic management,
areas/foyers;
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including screening of vehicles (see
„Traffic Management‟ in Annex B). General considerations
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Annex B: Typical counter-terrorism design attributes -
design of hostile vehicle mitigation measures
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registration is familiar to the site) or by Part M – access to and use of buildings. In
hostile occupants negotiating their way particular, requirements for disabled
through on a pretence or by using stolen parking and setting down points should be
or cloned access control or ID passes. reviewed.
Alternative scenarios include an unwitting
mule/delivery driver delivering an IED
surreptitiously planted by an attacker or an
insider threat bringing a device into their
own work site; and
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Site design can accommodate approach that for certain threat vehicle
countermeasures to layered vehicle attack types would exceed the capability of the
scenarios where one or more of the above original vehicle security barriers. Equally,
threat scenarios is used – for instance one monitor neighbouring site activity, security
hostile vehicle to create a gap by way of measures and ownership, in case any of
penetrative attack or blast and then these affect the vulnerability of the assets
another to exploit the subsequent gap and and security systems. Once a site‟s
get closer to the asset. vulnerabilities have been assessed it is
possible to assess risk and to devise
Site assessment for vehicle-borne mitigating counter-measures.
threats
Traffic management
Each site will require a specific
assessment before counter-measures can For retro-fitting a site, avoid starting from a
be recommended. Those doing the point which tries to accommodate the
assessment will need purely to assess existing traffic patterns of staff, deliveries
whether the adjoining land is traversable and visitors as this will usually result in
and if so by what vehicles, ignoring solutions that are less effective and more
congestion, signage, road markings and expensive than otherwise might be
“rules of the road. possible. Instead, start from a point where
the aim is to manage traffic in such a way
Part of the assessment will be to assess that natural blast stand-off is created and
maximum speeds and angles of attack less traffic has to negotiate vehicle access
achievable by a hostile vehicle control points. If pass check personnel are
undertaking a penetrative attack. This in-situ at an access control point then
process is called a vehicle dynamics design the area so that they are not put
assessment and profiles all the approach under undue pressure or distracted by
routes. This allows the counter-measures traffic management requirements.
to be designed to an appropriate level,
preferably not over or under-engineered. Options
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screening facilities can offer multiple • if vehicular and/or pedestrian traffic into,
security benefits by reducing the number or along, a road needs to be temporarily or
of vehicles that need to access either a permanently restricted for counterterrorism
secure site or underground delivery and purposes, the Chief Officer of Police can
parking facilities within a development. recommend to the Traffic Authority that
Such off-site screening increases the they introduce an Anti- Terrorism Traffic
confidence of any vehicle that does arrive Regulation Order (ATTRO). This is made
at a site and can release valuable space with reference to Sections 22(c) and (d) of
inside the development for alternative the Road Traffic Regulation Act 1984 (as
uses. Other environmental, safety and amended by the Civil Contingencies Act
cost benefits may also ensue from off-site 2004). Further information on their
screening facilities; applicability and selective use is available
from CPNI or CTSAs. Discussion is
• traffic inclusion for any vehicles within recommended with disability user groups
and around a large perimeter site is an regarding alternative setting down or
option but typically would need to be parking arrangements which may need to
coupled with individual protection be considered if hostile vehicle mitigation
schemes around critical and/or vulnerable measures to a site restrict vehicular
assets thus providing reduced blast stand- access to certain areas.
off;
Traffic calming measures
• although temporary vehicle security
barriers at times of heightened threat are Slowing traffic in advance of vehicle
an option for some sites, they have a security barriers has a number of benefits.
number of drawbacks. These are that their It gives drivers the ability to better
deployment is intelligence based; they comprehend what is expected of them at a
require specialist equipment and time to barrier system. It provides the guard force
deploy; unless stored locally, they would with more time to assess approaching
normally need to be transported to site; vehicles and their occupants and affords
they may be deployed too late if in more scope to react appropriately. In
response to other attacks; temporary addition the vehicle approach speed will
barrier systems are usually less effective be reduced accordingly. This reduced
against penetrative impact than speed can then be used to design an
permanent alternatives; they are often not appropriately „matched‟ barrier system to
suitable on natural or soft ground resist the hostile vehicle impact, thereby
surfaces; their modular and wall-like potentially reducing costs and
nature does not always lend their effective infrastructural/engineering impacts as well
use to undulating or unmade ground; their as potentially allowing for more visually
mass may preclude their use at certain acceptable barrier solutions to be
sites; few temporary barrier designs deployed.
incorporate integral vehicle gate systems;
and effective temporary barriers tend not Traffic calming can be achieved by way of
to lend themselves to use at sites which horizontal deflections (typically bends or
have less defined pedestrian lines and chicanes). Horizontal deflections can
which need to be pedestrian permeable preclude poorer turning circle vehicles –
such as at transport interchanges or although parts of the chicane can be
shopping centres; and designed as retractable or removable for
occasional access by such vehicles.
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that evergreen or seasonal foliage does
not obscure sight lines for guard force
surveillance. It is rare to be able to rely
solely on trees as a vehicle security barrier
due to the inability to grow sufficient
strength trees close enough to each other
to deny vehicle access between them.
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(active) barrier systems are considered to
be „machinery‟ and with that the system • PAS 68 entitled ‘Specification for Vehicle
owners and designers have a duty of care Security Barriers’ which covers the
to design a safe environment in which manufacture and testing of vehicle
people can work and/or transit through on security barriers. It is strongly
foot or vehicle. Operable barriers will recommended that all vehicle security
require maintenance and servicing during barriers be specified to comply with PAS
their lifetime and there is therefore a need 68 at an appropriate performance level;
to implement a robust service level and
agreement to reduce or eliminate barrier
downtime. Despite best efforts, there is • PAS 69 entitled ‘Guidance for the
always the possibility that an accident or Selection, Installation and Use of Vehicle
collision occurs between the operable Security Barriers’ provides guidance on
barrier and a legitimate or hostile vehicle. the selection and installation of vehicle
It is therefore very important to a have a security barriers. CPNI also provide
contingency plan that allows that location awareness and training on the subject of
to be either brought up to full operational designing-out vehicle-borne terrorism to
capability very quickly or secured and an architects, engineers, planners and
alternative location used. personnel with security, site ownership or
operational responsibilities. CPNI can also
Specifications and advice provide specific advice commensurate to
the attractiveness of the site, and maintain
The Centre for the Protection of National a list of appropriate, tested counter-
Infrastructure (CPNI) has published impact measures derived from their extensive
testing and installation guidance research and development programme.
documents, in the form of British Advice is also available from the private
Standards Institution Publicly Available sector on a commercial basis.
Specifications (PAS)10. The two
documents are:
32
Annex C: Case studies
Effective protective security regimes draw financial impact and business disruption
upon the „Deter, Detect, Delay‟ principles. caused by installation and implementation.
The appearance of a site to any potential
attacker, whatever the motive, can play a Consideration of security features is most
significant role in how they assess the effective for new build sites at the
vulnerability of that site. design/concept stage, so effective
consultation with the relevant interested
A clear area, well maintained, with parties, planners, designers, police and
managed access points and reception security experts is of paramount
facilities set in tidy grounds, presents an importance. This will identify the level of
image of professionalism and offers less security required and the most appropriate
opportunity for an intruder to go unnoticed. measures and systems available to meet
This may well be enough to deter them that requirement. The procurement and
from further action. installation can then be incorporated into
the design and build budget, whilst the site
Once an attacker has decided to continue and building design can accommodate the
with an intrusion then robust, security measures and still achieve a
proportionate, well maintained and well welcoming, attractive, comfortable and
managed protective security systems, safer environment.
including structured policies and
procedures, that are adhered to, make it
more difficult for critical assets to be The following examples show how recent
accessed. As a consequence, an attacker projects have included good counter-
has to evade or circumvent these terrorism design principles.
measures to effect an entry. An integrated
security regime will detect an intruder at Better blast resistance
an early stage and, most importantly,
before any critical assets have been Resistance to blast can be achieved in a
reached. number of ways. A Government
Department‟s headquarters building in
The attacker must then breach the central London is a good example of how
physical security measures before gaining measures can be combined to reduce the
access to any assets. The right measures vulnerability to blast.
will provide a sufficient delay to allow time
for the security response to reach the A series of bollards (impact tested to
point of attack and apprehend the intruder. appropriate BSI PAS 68 criteria) has been
installed around the building perimeter to
Existing sites looking to improve their keep potentially hostile vehicles further
overall security arrangements will have to away. This system provides distance
install new systems and physical between the bollards and the building,
measures retrospectively. It is important referred to as „stand-off‟, reducing the
therefore to select the most appropriate effects of a blast on the building.
measures applicable to that site and its
security requirements to minimise the In addition, the building incorporates
laminated glass in strengthened frames to
33
reduce fragmentation and so reduce the access. These bollards are controlled by
number of casualties in the event of a the on-site security guard force.
blast.
Better building management facilities
The construction of raised beds and a
water feature at the main entrance softens All buildings require services and
the appearance of the building, making it management facilities such as delivery
more attractive to visitors and personnel areas, post rooms and storage areas.
alike. Heating, ventilation and air-conditioning
systems (HVACs) and utilities all have to
Another good example can be found in a be located within, around or upon the
sports stadium. The overarching building structure. These systems may
requirement at stadia, which is mandated carry vital data or provide energy for
by legislation, is to ensure the safety of the essential processes and critical assets.
many thousands of people accessing a Ducting, pipework, cable management
venue for an event and departing systems and other building services
afterwards. Hostile vehicle mitigation installations can be vulnerable to attack if
measures were constructed at pedestrian inappropriately placed; and appropriate
access points in such a way that they arrangements need to be in place to
would be clearly visible to crowds and ensure that maintenance work is carried
therefore ensure easy egress whilst out by trusted personnel.
reducing any potential trip hazard. In
addition, these measures were designed
and constructed so that, if an attack took
place, as well as preventing a hostile
vehicle entering the pedestrian walkways,
they would be more resistant to blast, thus
reducing injury to people nearby from
secondary fragmentation.
34
hatches. Access to these systems is stage and, due to the importance of the
regulated by the existing access control route and the need to maintain service
regime applied across these sites, with no access, a permanent road closure was not
requirement for additional fencing, policies an option. Through consultation with the
or procedures. Physical circumvention of local authority a series of measures have
the protective regimes, although not been introduced. These include a robustly
impossible, is extremely difficult, enforced parking and loading restriction
especially if it is to be achieved and, more significantly, an Anti-Terrorism
undetected. Traffic Regulation Order (ATTRO).
35
not confirmed then the vehicle is rejected levels of cost or disruption whilst still
and can easily be returned to the roads maintaining the required level of
network or, if necessary, intercepted by protection.
the appropriate enforcement agency.
Better traffic management and hostile
vehicle mitigation measures
36
pioneered and tested by CPNI with the reclaim areas of the public realm for the
help of industry and predominantly reflect benefit of pedestrians. One piazza is a
the architecture of the adjoining listed notable example of this. Formerly a two-
buildings. They utilise shallow foundations way vehicular route, the area has been
that are designed to accommodate subject to a high quality design approach
existing underground obstacles such as that integrates security measures
utilities and roots of mature trees. The alongside improvements to the public
structural core is made of a unique realm. The carriageway was raised to
proprietary blast resistant system which footway level and repaved using granite
consists of steel plates and friction welded setts, while the footway itself was
spacers which is then filled on site with resurfaced with York stone. Stone seating
concrete. In the case of walls and and planters are used to subdivide the
balustrades on Whitehall, Portland stone space, allowing adjacent restaurants to
cladding is then applied to the core. spill-out onto the footway.
Better oversight
Initially, concrete blocks and bollards were One major shopping centre in the UK has
utilised to enforce TEZ measures. Over a large number of CCTV cameras within
time, these have been replaced by more the site and these are monitored and
permanent solutions which sought to controlled from a dedicated security
37
control room. The system also responsibility for management and
incorporates an Automatic Number Plate accountability issues.
Reader (ANPR) that has a number of
software filter measures to reduce excess
data capture and keep the system more
manageable. For example, during day-to-
day operation it uses an internal database
of vehicles known to the security
management.
38
A major sports stadium is an example of a A major project to develop a station
private sector building with overt protective commenced in 2000. Major interested
security measures designed to mitigate parties were involved in the planning and
against a hostile vehicle attack. design from the outset. These included,
from a security point of view, British
It was a major project involving Transport Police (BTP) Counter-Terrorism
partnership working between the site Security Advisers, Crime Prevention
owners, architects, Government security Design Advisor, Crime Reduction Officers,
advisers, police CTSAs, local authorities experts from the Centre for the Protection
and others. of National Infrastructure (CPNI) and,
because the original building was a Grade
The need for a partnership approach was 1 listed building, representatives from
identified at an early stage in the project English Heritage and railway heritage
(RIBA stage 1). A police „Major Projects‟ organisations.
team became involved and this team
arranged for the local CTSA to advise on
counterterrorism protective security
measures.
39
staff. Each vehicle is logged at the Control
Room upon arrival and details relating to
the retail unit expecting the delivery, plus a
driver contact number, recorded.
40
Access control and searching regimes
The major station example used above
A national stadium illustrates good
also represents a good example of how
practice in ensuring there is an efficient
underground service areas can be
searching regime for spectators entering
protected. The underground coach drop-
the site. Sufficient numbers of well trained
off area, where substantial numbers of
searchers are present to reduce as far as
people arrive and depart from the station,
possible any queuing outside access
has had vehicle blockers installed at the
gates. Those spectators who do not have
entrance and exit points and is covered by
bags with them can be fast tracked to
an extensive CCTV system. These areas
further optimise access procedures.
are constantly manned by a uniformed
security guard who validates the
The stadium encourages people not to
authenticity of a vehicle arriving at the
arrive with bags through ticketing and
entry point. If the vehicle is allowed to
website communication and will randomly
enter then the blockers are lowered
search identified spectators who arrive
remotely by the security control room
with bags/rucksacks.
personnel. Operating the blockers in this
manner further reduces the possibility of
A Government Department headquarters
the security guard being coerced or
building operates an access control
overcome in order to afford access to a
regime where all personnel are subject to
hostile vehicle.
a security pass system and government
vetting protocols to achieve a minimum
level of security clearance.
41
At a major city station the whole station Within the night-time economy sector, one
facility has been separated into security city centre based nightclub venue has
zones. The Restricted Zone (RZ) encloses employed a series of policies and
the departure and arrival lounges, procedures to reduce its vulnerability. This
platforms and trains and access is limited site has a maximum capacity of
to ticketed passengers and authorised approximately 3000 people and, at peak
personnel. Passengers must pass through times on Friday and Saturday nights, this
a security area operating airport standard capacity is often achieved. The club
screening systems. management has engaged with the local
authority and business sector to address
several issues.
42
through a fully auditable record of events. or other security related anomalies, which
It also establishes an invaluable database are resolved before the club is opened for
for the investigation of instances of business. This activity deals with the
suspicious activity such as hostile possibility that devices may have been
reconnaissance and is an obvious planted, or preparations made for some
deterrent to potential intruders/attackers other activity, by paying customers, out of
who would be wary of their appearance hours contractors/visitors, or persons who
and activity being recorded, even in may have managed to circumvent existing
background scenes. access control measures.
This venue operates during daytime hours Radio links to security personnel at other
as a bar and restaurant and there are venues in the city, and the local police
several different access points. Prior to the force, allow information about suspicious
nightclub opening times, these additional activity to be spread quickly and this
access points are closed down and affords valuable extra time for reaction to
secured, leaving just the main club potential hazards and, if necessary,
entrance available. Security measures are implementation of emergency plans.
concentrated here, with security personnel
patrolling in high visibility jackets. Within Many sites, regardless of which sector
the foyer are various signs displaying they are operating in, face restrictions and
information about partnership working with limitations on the physical security
the local authority, police and nearby measures they can deploy. This may be
venues, searching regimes and tolerance due to a number of issues including
levels. Disruptive individuals are ejected in planning constraints, heritage
full view of those waiting to enter. All considerations, building construction, local
clientele are required to pass through an infrastructure and services, environmental
archway metal detector before entry and impact, or a combination of effects from
any suspicious items identified are some or all of these. In these instances
removed. No bags are permitted inside the options for site operators are constrained,
club. so security has to be addressed through
policies and procedures designed to
This is a good example of rule setting reduce vulnerability.
immediately outside a single entry point. It
very effectively advertises that there is a However, it is important to remember that
well-managed and stringent security sites that do not install physical barriers
regime in place and is a potential deterrent will remain vulnerable to a determined
to a large amount of criminal activity, attack, such as that from a vehicle-borne
including hostile reconnaissance and improvised explosive device. Any physical
attempts to deliver improvised explosive measure installed, temporarily or
devices. permanently, must be managed by an
appropriate policy and procedure to
Club management has introduced a policy ensure that it is operated correctly,
of planned searches. These are maintained according to manufacturer‟s
implemented across the entire site by specifications and addresses the relevant
sector teams just prior to nightclub security issues to the required level.
opening times and soon after nightclub Where the hostile vehicle mitigation
closing times. Each defined area is measure installed is active rather than
searched for suspicious items, insecurities passive (e.g. retractable barriers or swing
43
gates) it will be most effective where site open them when they are content that the
security personnel are trained to keep the vehicle, load and occupants seeking entry
barriers in the secure position and only have been satisfactorily screened.
44
Annex D: Sources of counter-terrorism protective
security advice
Advice on how best to integrate
proportionate counter-terrorism protective NaCTSO trains, tasks and coordinates a
security measures as part of good urban nationwide network of specialist police
design is available to site owners and advisers known as Counter-Terrorism
operators from: Security Advisers (CTSAs).
45
countermeasures to evolving threats.
As well as undertaking initial training Additionally CPNI provide awareness
covering physical and personnel security, briefings and training courses on the
site surveying and counter-terrorism, subject of designing-out vehicle-borne
CTSAs undertake additional mandatory terrorism to architects, engineers,
training over two years covering hostile planners and personnel with security, site
vehicle mitigation, specialised physical ownership or operational responsibilities.
security and operational requirement
training, leading to the successful CPNI provides integrated security advice
submission of a Licentiateship in Counter- (combining information, personnel, cyber
Terrorism Security Management. To and physical) to organisations which make
ensure the high standard of training is up the national infrastructure. This advice
maintained, refresher training is delivered helps to reduce the vulnerability of the
on the various disciplines relevant to national infrastructure (primarily the critical
counter-terrorism. In addition, quality national infrastructure) to terrorism and
assurance inspections are carried out by other threats to national security.
NaCTSO on an annual basis of all police
forces throughout the UK. This includes CPNI is an interdepartmental organisation,
the inspection of CTSA surveys to ensure with resources from industry, academia
that the advice follows a nationally and a number of government departments
consistent standard. and agencies (including the Security
Service, CESG and departments
A CTSA can be contacted in the first responsible for national infrastructure
instance via the local police website or sectors). CPNI draws on expertise,
switchboard. In case of difficulty, CTSA knowledge and information from the range
contact details can be found on the of organisations that contribute to its work.
NaCTSO website or through contact with It sponsors research and work in
NaCTSO via email: partnership with academia, government
nactso@cpni.gsi.gov.uk partners, research institutions and the
private sector to develop applications that
Centre for the Protection of National can reduce vulnerability to terrorist and
Infrastructure other attacks and lessen the impact if an
attack does take place.
CPNI10 is the Government‟s national
technical authority which provides Private Sector Advice:
protective security advice to businesses
and organisations across the national The Register of Security Engineers and
infrastructure. CPNI advice aims to reduce Specialists (RSES)
the vulnerability of the national
infrastructure to terrorism and other Specialist counter-terrorism design advice
threats, keeping the UK‟s essential can also be obtained from members of the
services (delivered by the Register of Security Engineers and
communications, emergency services, Specialists. This Register is maintained by
energy, finance, food, government, health, the Institution of Civil Engineers and is
transport and water sectors) safer. sponsored by CPNI.
CPNI runs a research and development The RSES17 is managed and organised by
programme devising effective the Institution of Civil Engineers and
46
provides a professional competence
standard for potential clients and insurers Secured By Design – Design Guides
through its code of ethics, demanding peer
review and strict continuing professional All the information on making a
development requirements. development Secured by Design is in the
design guides. Each type of development
Suitably qualified and independent has its own document which can be
security engineers and specialists can be downloaded for free. Developments which
engaged by sites, local authorities or third meet all the criteria are applicable for a
parties to provide costed protective Secured by Design award. For advice,
security advice or to develop or comment information or to apply for a Secured by
on other advice received from CTSAs. Design Developer award please contact
the local CPDA to the development.
47
Annex E: Role of Crime Prevention Design Advisers
(CPDAs)
CPDAs exist in almost all police areas. promote „Secured by Design‟, „Safer
Where they do not exist, their counter Parking‟ and other relevant security
terrorism “filtering” function is managed by award schemes;
CTSAs (see below). • promote effective community safety
Designing-out crime (including terrorism) practice and encourage the
at the earliest stages in the planning development of safer environments
process can be extremely effective in that reduce risk and mitigate the
developing safer and more secure impact of crime;
environments in which people can live and • establish effective local and
work. CPDA‟s monitor the Local Authority national partnerships in order to
Planning Registers, and develop a develop the built environment in
relationship with local planners to discuss ways that reduce opportunities for
relevant projects. They will offer security crime and disorder;
advice to applicants (developer and the
design team) on appropriate applications, • establish strong and effective lines
and will be asked for their opinion as part of communication with the local
of the planner‟s official consultation. planning authority and develop links
CPDAs refer relevant applications into the planning process to ensure
onwards for Counter Terrorist (CT) advice that where security advice is sought
from CTSAs. The CPDA and CTSA then on new or existing planning projects,
work together to deliver appropriate police advice is able to be offered as
conventional security and CT advice on early as possible;
these filtered projects, although the level • influence and encourage planners,
of CTSA engagement will depend on the designers and developers to
assessed attractiveness of the site. incorporate crime reduction,
Some projects elect to work to Secured by including counter-terrorism protective
Design standards (SBD) and the CPDA security measures into their
will support this process. They: development projects.
CPDAs can be contacted through the
police force in the relevant area by ringing
• offer risk-commensurate crime 101. Further information can be found on
reduction advice and actively the Secured by Design website21.
48
Annex F: Police led initiatives raising awareness of
counter-terrorism protective security
Project Argus event can be obtained from the NaCTSO
6
website .
Project Argus is a counter-terrorism
tabletop exercise produced by the Argus Professional and Argus Planners
National Counter-Terrorism Security Office
(NaCTSO) and delivered by the national Architects, designers and planners can
network of police CTSAs. play a significant role in delivering
improved counter-terrorism protective
The exercise scenario comprises a security. Argus Professional was launched
coordinated terrorist attack targeting a in 2008 to target built environment
„crowded place‟. It specifically aims to professionals including architects and
provide valuable counter-terrorism advice designers, with a modified version (Argus
on protective security, (including how to Planners) for an audience consisting of
deal with a firearms attack), resilience and planners from both the private and public
hostile reconnaissance in light of the sectors. They both aim to demonstrate
current terrorist threat. It does this by that counter-terrorism protective security
taking businesses through a simulated measures can be designed into structures
terrorist attack. The simulation provides a and spaces to create safer crowded
realistic scenario prompting open places.
discussion to identify the measures for
preventing, handling and recovering from Project Griffin
a terrorist attack and explores their
expectations against reality. Project Griffin is a police-private industry
initiative to accredit security personnel in
Delegates are split into small syndicate identified locations by their attendance at
groups and asked to work through a a one day course in order to improve their
number of questions and scenarios skills and knowledge in relation to
prompted by the simulated sequence of counterterrorism activity.
events and the CTSA facilitators are
supported by a panel of experts. Project Griffin aims to encourage
members of the community to work in
These events have been successfully run partnership with the police to deter and
since January 2007 and have been detect terrorist activity and crime. This will
developed to target different business be achieved by working with the
sectors. Examples include retail, night- community to:
time economy, hotels, health and major
events, for example, those related to the • raise awareness of current terrorist and
Olympics but separate from Olympic crime issues;
venues. Project Argus will continue to be
developed as required. Events are • share and gather intelligence and
facilitated by CTSAs free of charge - information;
details of how to access a Project Argus
49
• build and maintain effective working
relationships; The Project Griffin Awareness Day also
serves to help people think about their
• maintain trust and confidence in the own local procedures and processes for
police and other authorities; and dealing with certain types of incident
during times of emergency.
• empower people to report suspicious
activity and behaviour. Operation Lightning
50
Annex G: Useful publications
NaCTSO guidance
NHS Estates Health Building Notes
NaCTSO counter-terrorism protective (HBNs)
security advice publications are available
at the NaCTSO website5. ‘Streets for All: Guidance for Practitioners’
was produced in 2005 by English
CPNI guidance „Protecting Against Heritage, in conjunction with the
Terrorism‟ - available at the CPNI Department for Transport. These regional
website10. manuals are aimed at all those involved in
the design and management of streets. A
Cabinet Office guidance on ‘Public Safety summary Streets for All (2004) document
in Complex and Built Environments’ is also available.
(Capstone guidance on integrated safety
management) published in 2007. British Council for Offices Security Guide
published in 2009 (available to members
Department for Transport and Department only).
for Communities and Local Government
document: ‘Manual for Streets’ and the Contact
associated ‘Inclusive Mobility’ guidance.
The National Counter-Terrorism Security
British Standard BS8300 Design of Office can be contacted via its website5 or
Buildings and their Approaches to Meet by email: nactso@cpni.gsi.gov.uk
the Needs of Disabled People – Code of
Practice.
51
Glossary and definitions
Accessibility – The ability of people to behavioural effects that will reduce crime
move round an area and to reach places and anti social behaviour and reduce fear
and facilities, including elderly and of crime, thereby improving the quality of
disabled people, those with young children life. These behavioural effects can be
and those encumbered with luggage or accomplished by using design to reduce
shopping. those features that support criminal
behaviour.
CONTEST - the Government‟s
overarching counter-terrorism strategy. It Crowded place - The working definition of
was most recently published in July 2011, “crowded places” is widely drawn:
with the aim of reducing the risk to the UK crowded places are regarded as locations
from international terrorism. or environments to which members of the
public have access that, on the basis of
Context – The setting of a site or area, intelligence, credible threat or terrorist
including factors such as traffic, activities methodology, may be considered
and land use as well as landscape and potentially liable to terrorist attack by virtue
built form. of their crowd density. Examples include:
52
Public space/realm/domain – The parts Stand-off – The minimum distance
of a village, town or city (whether publicly between an IED/VBIED and its target.
or privately owned) that are available,
without charge, for everyone to use or Urban design – The art of making places.
see, including streets, squares and parks. Urban design involves the design of
buildings, groups of buildings, spaces and
Retro-fitting – Enhancing existing sites landscapes, in villages, towns and cities,
retrospectively with the recommended and the establishment of framework and
approach to, and required specification of, processes which facilitate successful
counter-terrorism protective security development.
measures.
VBIED – see IED.
Streetscape – The street patterns,
furnishings and landscaping that form the
built environment.
53
End notes
1) https://www.mi5.gov.uk/home/the-threats/terrorism/threat-levels.html
2) https://www.gov.uk/government/organisations/department-for-transport
3) https://www.gov.uk/government/publications/the-strategic-defence-and-
security-review-securing-britain-in-an-age-of-uncertainty
5) http://www.nactso.gov.uk
6) http://www.nactso.gov.uk/our-services
7) http://planningguidance.planningportal.gov.uk/blog/guidance/design/
8) https://www.gov.uk/government/publications/manual-for-streets
9) https://www.gov.uk/government/publications/inclusive-mobility
10) http://www.cpni.gov.uk/
11) https://www.cpni.gov.uk/advice/Personnel-security1/
12) http://www.ico.gov.uk/for_organisations/data_protection/topic_guides/cctv.aspx
13) 12) Further advice on CCTV is available from the CPNI website www.cpni.gov.uk;
from the Centre for Applied Science and Technology website
https://www.gov.uk/government/publications/cctv-supporting-small-businesses
; and in NaCTSO guidance booklets available on the NaCTSO website
www.nactso.gov.uk
14) BS EN 1992 has replaced BSI8110 although it is currently still in practical use.
15) BS EN 1993 has replaced BSI5950 although it is currently still in practical use.
16) More information about glazing can be found on the CPNI website
http://www.cpni.gov.uk/advice/Physical-security/ebp/
17) Further advice on RSES are also available from the Institute for Civil Engineers (see
website: www.ice.org.uk) and ICE details can also be found on www.cpni.gov.uk and
www.nactso.gov.uk
18) http://www.cpni.gov.uk/Security-Planning/Staff-training-and-
communications/workplace-security/
54
20) https://www.gov.uk/government/publications/surveillance-camera-code-of-
practice
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Published by the Home Office
© Crown Copyright 2014
ISBN: 978-1-78246-387-0
56