Regulations applicable to registering and training personnel in electronic security businesses.
AT&T Digital Life, Inc. (“AT&T”), wholeheartedly agrees with commentors who have noted that there should be a comprehensive review of the regulations applicable to registering and training personnel in electronic security businesses. Although the health, safety and welfare of Virginia citizens must remain a paramount consideration, and AT&T is committed to those goals, the evolving nature of technology, security products and services and the way they are sold must also be considered, in order to create business incentives for new market entrants and for current companies to invest and innovate for the good of the citizens of Virginia.
The current regulations do not recognize important distinctions between the personnel utilized in electronic security businesses. For example, the regulations purport to impose the same licensing and training requirements on all “electronic security sales representatives,” regardless of the functions they perform or their degree of access to sensitive personal information. There are, however, businesses that offer or intend to offer electronic security equipment through retail outlets, utilizing personnel that will not, among other things, go to a prospective customer’s home or have access to sensitive information such as passwords or specific equipment placement. The regulations should be reviewed and revised as appropriate to reduce the burdens when businesses contract with in-store personnel who provide typical retail functions. The statute applicable to electronic security sales appropriately recognizes distinctions between the roles played by different individuals in the sales chain -- for instance, telemarketers and personnel who schedule appointments are not subject to registration or training requirements -- and the regulations should likewise recognize distinctions between retail and premise sales representatives.
AT&T also agrees with commentors who recommend that electronic security businesses be allowed to provide in-house training. In-house training is a valuable tool for retail sales representatives, in particular. A retail sales person may be one of the first contacts a prospective customer has with an electronic security business, and businesses will have the maximum incentive to train their sales personnel to be responsive and knowledgeable, given the competitive marketplace and customer choice, particularly when it is much easier to leave a retail store than to decline an in-home sales pitch.
AT&T looks forward to working with the Division of Criminal Justice Services to review and revise regulations to reflect the current and future state of the electronic security business market.
