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 10/24/2012
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10/19/12  3:28 pm
Commenter: Wayne Boggs, Richmond Alarm Company

Self Audit
 

In addition to the concerns over time and energy expended in performing a self audit on a DCJS provided form or format, such audits are a standard part of professional business practice.  A State mandated audit is therefore redundant.  If DCJS wants to provide a guideline for conducting a self audit and chooses to recommend such an audit that's fine.  To require one is not.

There are two additional concerns with requiring a self audit.  To do so requires a Compliance Agent to report corrected or correctable errors in compliance with code or regulations, which may not, in fact probably do not, affect public safety, and in doing so place himself or herself in jeopardy of sanction.  Though DCJS may suggest that serious sanctions would not generally result in identified and corrected violations, such sanctions are called for in the Code, primarily when identified as part of an audit or action conducted by DCJS itself.  I believe it is improper to ask a Compliance Agent to self incriminate.

At the same time, the US Constitution provides protections against such self incrimination, so it is not incumbent upon a Compliance Agent to voluntarily provide such information.

CommentID: 24315