International Journal on Criminology Volume 5, Number 2, Winter 2017/2018 | Page 13
International Journal on Criminology
ministers representing the Interior, Justice [ ... ], Labor [ ... ], and Finance
(in order to involve this body in the question of public customers).”
At this stage of the assessment, then, customers have not been neglected in
discussions of private security and regulatory reform. While not all of the recommendations
above have been followed through (for instance, the Security Market
Delegate), others have borne results, and have revealed some practical difficulties.
4. STRATEGIC AND PRACTICAL APPROACHES TO
CONTRACTUAL ISSUES BY PUBLIC AUTHORITIES.
The establishment of CNAPS has brought with it two consequences which
demonstrate the role of the customer. On the one hand, College of the
CNAPS has given them a role by appointing two qualified individuals to
represent them. On the other hand, the tax on private security activities, known
as the “CNAPS tax,” is marked at the bottom of customer invoices. 15 In a more
informal way, the CNAPS quickly established a working group for providers and
contractors. However, the role of the customer within the regulator or related bodies
more closely resembles a partnership than a real acknowledgment of their place
in the administrative and economic regulation of the sector, at least at this stage
(see below).
At the outset of the 2010s, at least, the DISP took over the task of drawing
up and implementing the sector’s economic regulation, and has served to some
extent as “Security Market Delegate,” although with limited success.
After releasing an initial guide to good practices in private security purchasing
in 2012, the DISP launched the Charter of Good Practice for the Procurement
of Private Security Services in September 2013, with the professional associations
for private security firms (ADMS, FEDESFI, GPMSE, SESA, SNES, and USP), the
professional buyers’ associations (the Agora des Directeurs de la Sécurité, ARSEG,
CDSE), and BNP Paribas, SNCF and Société Générale as its first signatories. 16 The
approach was inspired by the principles of soft law and was meant as a tool for
market players similar to others available elsewhere in Europe. 17 The aim was to
encourage providers and buyers “to comply with a set of good practices over the
15 Article 1609 quintricies of the General Tax Code, VII: “The amount of the contribution shall be
added to the price paid by the client. It shall be signaled by a specific notice at the foot of the invoice
for the service in question.”
16 Ministry of the Interior/DISP. September 10, 2013. “Communiqué de presse. Charte de
bonnes pratiques d’achats de prestations de sécurité privée.” http://www.interieur.gouv.fr/
Le-ministere/Organisation/Delegation-aux-cooperations-de-securite/Portail-relatif-a-la-
Charte-de-bonnes-pratiques-d-achats-de-prestations-de-securite-privee/Communique (accessed
April 2, 2017). For the initial guide, see Interministerial Delegation on Private Security.
(2012) L’achat de prestations privées de sécurité: Grands principes et bonnes pratiques, 24pp.
17 CoESS and Uni-Europa. 1999. “Choisir le meilleur rapport qualité-prix—Guide pour l’attribution
des marchés de services dans le domaine de la surveillance et de la sécurité privée,” 28pp.
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