Submission to the Ministerial Advisory Group for Victims of Retail Crime

Strengthening the Security Industry – Targeted Consultation

Sent via email, January 2026.

Heart of the City (HOTC) represents the interests of businesses and property owners in Auckland's city centre. We advocate for a vibrant, accessible, safe, and welcoming city centre that is a great place to do business.

Our Business Association represents a diverse mix of small, medium and large retailers, hospitality operators, service providers, and commercial tenants operating in New Zealand’s largest and most complex urban retail environment.

Retail crime in the Auckland city centre has become more frequent, more organised, and more brazen, directly aligning with the trends identified in the consultation paper. We are particularly concerned that the current environment of low consequence and limited intervention has normalised offending behaviour and undermined confidence among business owners, workers, customers, and the wider public.

We therefore strongly support reform that enables a more proactive, professional, and empowered security industry, alongside appropriate safeguards and Police integration.

Responses to Consolidated Questions:

1. Are security officers currently carrying out functions that meet market and retailer expectations?

No. While most security officers act professionally within their current remit, the current model does not meet retailer expectations in a high-risk, repeat-offending environment.
While services are provided on a regular basis that retailers do appreciate, the inability of guards to intervene within current law in many situations reinforces an offender perception of impunity and lack of consequences. For many businesses, especially small retailers, this results in security being perceived as a cost rather than an effective deterrent and leads to significant frustration.

2. Are you happy with the current role of retail security officers, or would you prefer to see the role expanded?
We strongly support expansion of the role.
The current role is misaligned with:
•the scale and persistence of offending,
•the often calculated and organised nature of retail theft, and
•the expectations of impacted businesses

An expanded role which is underpinned by consistent and fit-for-purpose training, regulation, and integration with Police would significantly improve deterrence and confidence.

3. Are you confident that security officers could take a more proactive role under the “Enhanced Status Quo”?

No. While forthcoming citizen’s arrest reforms may reduce some legal uncertainty, the Enhanced Status Quo still relies on guards acting under a defensive legal doctrine rather than clear authority, and uneven, market-driven training standards.
This approach does not provide sufficient certainty for:
•security officers undertaking frontline risk,
•retailers purchasing proactive services, or
•the public observing interventions.

Without explicit statutory authority, we do not believe this option will materially change behaviour on the ground

Option 2 - Improved Training Requirements

5. Should training requirements for retail security officers be improved?
Yes. Current minimum training (1.5–2 days, often without refreshers) is not fit-for-purpose for either current challenges or any expanded role.

6. Have you had experiences with guards who lack sufficient training?
Yes. Our members report frequent issues across a variety of providers including:
•inability to de-escalate escalating situations,
•poor situational judgement,
•lack of confidence engaging repeat offenders,
•inconsistent professionalism across providers.

These issues mirror the findings referenced in the paper and in coronial and academic reviews.

7. What should a higher standard of training focus on?
Training must prioritise:
•de-escalation and conflict management
•lawful detention and use-of-force thresholds and execution
•recognition of repeat and organised offenders
•mental health, youth, and neurodiversity awareness
•Recognizing "stalking-like" behaviour or persistent unwanted attention and all forms of harassment both subtle and overt and intervention methods around this.
•clear decision-making under pressure
•coordination with Police and incident handover

This training should be:
•mandatory,
•refreshed regularly, and
•directly linked to licensing.

8. If training was improved, would this give you more confidence to seek a proactive property guard?
Yes we believe it would give businesses more confidence in seeking guards for retail and other purposes. But only if matched with clear legal authority. Training alone does not overcome the legal precarity faced by guards or the reputational risk borne by retailers and others procuring security services.

Option 3 – Bespoke Legal Powers for Retail Security Officers
10. Is introducing specific legislative powers a good way to reach the desired end state?

Yes. This is our strongly preferred option. Option 3 directly addresses:
•the lack of consequences emboldening offenders,
•the legal risk placed on frontline guards,
•retailer reluctance to invest without certainty
•inconsistent professionalism across the industry

Without bespoke powers, proactive security will remain limited and fragmented.

11. Should powers be based on the Parliamentary security model?
Yes, with appropriate retail-specific safeguards. The Parliamentary model demonstrates that:
•enhanced powers can coexist with accountability,
•professionalism improves when authority is clear, and
•public confidence increases when actions are visibly lawful (Full Paper, Annex).

12. Do retailers have space to detain offenders until Police arrive?
In many cases, no. And especially small businesses. This reinforces the need for:
•Police-led escalation protocols, and
•Realistic detention expectations (short duration, safety-focused).

Small inner-city businesses cannot bear this responsibility alone.

13. Should licensing be limited to reputable security companies rather than individuals?
Yes. We support:
•licensing at the company level
•board-level accountability, with clear expectations set for guards
•audited training and compliance standards.

This is critical to avoid:
•inconsistent application,
•misuse of powers, and

•erosion of public trust

14. Are DIA and PSPLA suitable oversight bodies?
Yes, provided they are adequately resourced and given strengthened monitoring roles. Robust reporting, auditing, and consequence management are essential if expanded powers are granted.

Concluding Position
From a city centre business perspective:
•The current system fails to deter repeat offenders.
•Small businesses are disproportionally harmed and cannot self-fund security solutions to meet their needs.
•A “no consequences” environment has normalised offending behaviour.

We strongly support Option 3:

Bespoke legal powers, tied to significantly higher training standards, professionalised licensing, and strong Police linkage.

Without this, investment in security will continue to grow without producing safer outcomes, which benefits neither businesses nor the general public.