Action | Comprehensive Review Private Security Services Regulations |
Stage | Proposed |
Comment Period | Ended on 10/24/2012 |
It appears that if a non-compliance issue is exposed during a self-audit and DCJS is allowed to impose a fine or penalty on self-reporting of that violation, this then becomes self-incrimination and may be a Fifth Amendment issue.
This raises many questions and doesn't solve anything obvious. What if a mistake is made on the self-audit, does it automatically become an assumed fraud, and thereby subject to two violations, the original violation (which could have been human error) and a potentially fraudulent self-audit (again could have been human error)? Does this shift all the audit responsibilities on the back of the company and what/where is the gain? What is the purpose? Without knowing what is included in this "self audit" there is nothing to base a determination of reasonableness. For many companies this new process just creates yet another burden.
I am under the impression we are charged with reducing and streamlining regulations, yet this just moves the paperwork and responsibility onto the back of company.
,