Please consider the following comments and recommendations on this screen and those that follow:

6VAC20-171-300. Private security services training session

#3 Training Completion forms 

1.     Suggest leaving it as written, “on a form provided by the department, the…”

2.     First concern—increased possibility for error, given all of the numbers required

3.     Second concern—requiring name, identification number, and signature of both training director and primary instructor.  The primary reason to omit some of this information:

4.     Widespread dissemination of ID numbers, names and signatures on training completion forms could invite fraud or identity threat.  We have had first-hand knowledge of unscrupulous individuals working to obtain fraudulent armed security cards. We do not need to create greater opportunity for these individuals.

5.     Administrative staff may not be available at the time the course is being conducted. Preparing training completion forms before a student completes the course invites error, noncompliance, or worse.

6.     Primary instructors often are part-time and leave for prolonged periods immediately after a course ends. Having them return later to sign training completion forms could be a problem and delay getting out the forms to students.

7.     A good administrative staff completes and checks forms carefully, has training director sign, and gets out the forms well before the deadline. However, directors go on vacation, are ill, etc

8.     Suggestion:  Add a provision allowing the training director to designate in writing an assistant training director who would be authorized to sign the forms in his or her absence

9.     Suggestion if the new form must be utilized: 

        * Include primary instructor information on the form but do not require a signature

        * Include the training director’s name and signature but no identification number. 

6VAC20-171-305.  On-line in-service--#7—Same concerns as with 6VAC20-171-3 with regard to training completion form.

6VAC20-171-350. Entry level training.

Regarding the introduction of 10 E Private Security Orientation--

1.         Every class is unique and there are different interpretations of how the Code and Regulations apply to each.

2.         Probability of a lack of attention by students to subject matter not directly related to their course of interest at the time.

3.         The information contained in the proposed 10E

   * Is the foundation of the subject matter for each particular course?

   * Offers cohesion to subject matter of the registration category and

   * Needs to be reinforced, not just offered one time only.

   * Emphasizes DCJS’s role at the center point of policy. 

   * Without presenting this information each time, people will tend to forget that subject

           matter is directly tied to VA Code and Regulations.

4.     Cost impact—requires additional school forms, instructor time, training completion forms, invoicing and bookkeeping, testing, reporting and tracking—and possibility of non compliance.

Suggest that the material covered in 10-E remain as part of each course as in the past.