One of the more controversial aspects of our task as aviation/cargo security professionals is the question of background checks, commonly (and incorrectly) interpreted as being a criminal record check.
So what is a background check?
A background check as defined in the Civil Aviation Regulations of 2011 means:
“background check” means the checking of a person’s identity and previous experience, including any criminal history as part of the assessment of an individual’s suitability to implement a security control and/or for unescorted access to a security restricted area;
You will note from the above definition that the criminal record check is a very small part of the background check but we have elevated it in importance to being just about the only thing that we check when carrying out the background check required by Regulation.
And even when we do find a person with a criminal record the decision on the person’s suitability for employment in a security sensitive position is not straight forward or clear cut, there is no reason whatsoever that a person with a criminal record could not be a very valuable team member who would present no threat to aviation security.
Not so other aspects covered by a proper background check; things like:
- employment record,
- possible radical affiliations, pending investigations,
- criminal affiliations,
- serious financial difficulties,
all these aspects that could present a much bigger threat and which become clear on a thorough background check.
We make extensive use of pre-employment forensic interviews and polygraph tests combined with very thorough vetting of employment records before we employ people in security sensitive positions, perhaps not perfect but a process that has proven effective.
This is an international problem, this article is from the Sydney Morning Herald:
What happened at TNT in Melbourne?
The personnel were subjected to a standard criminal record check which did not cause any alarm because the people concerned had never been convicted of a crime!
How could this have been prevented?
A forensic interview and polygraph pre-employment would have helped.
We need to go beyond the standard “crim check” into the realm of proper, professional background checks especially for persons in security sensitive positions like screeners and persons applying security controls in respect of cargo and persons including all access control personnel.
Remember that the one of the most difficult to detect and combat threats to aviation security (and the general security of your company and its operations) is the “insider threat”, it is critical that you implement proper background check procedures to protect yourself and your company.
Changes to Part 110 of the Civil Aviation regulations currently awaiting signature by the Minister of Transport call for much more stringent recruiting policies and processes including much more intensive background checks for screeners.
This is a very positive development that we should all support.
How can we help?
Please feel free to call us should you require advice on the background check process.
The 14th Amendment to the Civil Aviation Regulations was published on the 28th October to be effective 30 days from date of publication, download the amendment here:
The revisions to the Part 108, Part 109 and Part 110 Regulations and Technical Standards that have been in the works since 2012 passed the final benchmark on the 12th June 2015.
The Regulations will now go to the Minister for signature before becoming law and the Technical Standards will go to the Director of Civil Aviation for signature.
Here are some of the things that you need to know:
1. High Risk Cargo and the security measures relating to High Risk Cargo are clearly set out;
2. All Regulated Agents and Known Consignors to apply cyber security measures
3. Procedures for Transfer and Transit cargo set out;
4. Changes to Exempted Cargo, in particular that human remains are no longer exempt;
5. Regulated Agents no longer have to screen 10% of cargo from Known Consignors;
6. Known Consignors no longer function on the basis of a relationship with a Regulated Agent only, each Known Consignor now requires a Security Manual and is free to deal with any Regulated Agent;
7. Training for the personnel of Regulated Agents and Screeners is no longer under Part 108 all security training is now under Part 109;
8. Air Cargo Security Familiarisation Training as we knew it under Part 108 has been replaced by Aviation Security Awareness Training under Part 109 and the scope of people requiring training has been dramatically increased;
9. Screeners now require 10 days training plus 1 day X-Ray machine familiarisation training plus 10 days On The Job Training per screening method that they will use;
10. Screener Supervisors must be qualified Screeners before undergoing an additional 5 days of Supervisor training;
11. Security Managers, Designated Officials and Deputy Designated Officials require 5 days training.
These are some highlights, we are available if you need further details on any of the above and on the possible implications for your business.
The changes to Part 108 and security measures have long since been introduced into most security programs these should not cause any problems at all and should be welcomed as they are very good for cargo security.
Probably the most contentious issue from these Regulations will no doubt be the length of training for Screeners and Supervisors of Screeners. In the cargo world training required goes up dramatically.
We fully support these changes, remember that Screeners ensure your safety and the safety of all who fly, do you really want a poorly trained individual who has been given the minimum possible training screening the cargo under your seat?
We need to have world class training and certification, period. No debate, no if or buts, no excuses or debates about time and expense, this is a security issue not an economic debate.
Even the much vaunted TSA has challenges, they recently failed 97% of routine security tests.
We can do better.