Virginia Regulatory Town Hall
Agency
Department of Criminal Justice Services
 
Board
Department of Criminal Justice Services
 
chapter
Regulations Relating to Private Security Services [6 VAC 20 ‑ 171]
Action Comprehensive Review Private Security Services Regulations
Stage Proposed
Comment Period Ended on 6/10/2010
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3/2/10  7:35 pm
Commenter: Robert Frydrych

D.C.J.S.memo
 
National Service Providers:
The Department has received numerous inquires from locksmiths in regard to sub-contracting with National Service Providers (herein after referred to as NSP) and requesting assurance that the locksmith is in compliance with the following regulatory requirement:
6 VAC 20-171-230. Business standards of conduct.
A licensee shall:
5. Not contract or subcontract any private security services in the Commonwealth of Virginia to a person not licensed by the department. Verification of a contractor’s or subcontractor’s license issued by the department shall be maintained for a period of not less than three (3) years.
The Department has identified numerous NSPs that do not fall under the definition of a private security services business. Taking into consideration the numerous NSPs who have been identified and the fact that many others have not, locksmiths will be considered “in compliance” with the cited regulation by following the following procedures:
When you are contacted by a potential NSP to perform locksmith services within the Commonwealth for their client, you may accept the contract provided:
1.   The NSP provides you with verification that the company does not require licensure in the Commonwealth of Virginia as a private security services business; or
2.   You notify the Compliance Enforcement Unit about the NSP by electronic mail to burton.walker@dcjs.virginia.gov or in writing by fax (804-786-6344) or by regular mail to Burt Walker, P.O. Box 1300, Richmond, Virginia 23218. Include the complete name of the company, address and any contact information for the NSP.
The Compliance Enforcement Unit will investigate the NSP to determine if licensure is required. The Department will continue to update a list of NSPs on the Agency website as a resource.   
Following this procedure will enable a licensed locksmith business to accept contracts with NSPs immediately while the Department determines licensure requirements.  

CommentID: 13345