Statement of Licensing Policy Appendix A - Licensing Best Practice Measures

Best Practice Measures to be included for consideration in the CSA and the SSA

The list below would normally be expected in operating schedules:

• a general knowledge and understanding of the Licensing Act 2003 (The Act)
• the adoption of a policy (such as Challenge 25) with acceptable proof of ID
• a smoking policy which includes an assessment of noise and litter created by premises users
• the use of reusable plastic and polycarbonate drinking vessels and containers, especially in outside areas or after specified hours
• a policy in relation to searching customers for drugs, weapons, seized or lost and found property
• keep and maintain a refusal book for registering attempts to buy alcohol by underage persons or refusals to those intoxicated
• the installation of a digital CCTV system by liaison with, and to a standard approved by, Sussex Police, with access available to individuals working on the premises
• a documented equalities and inclusion policy framework that demonstrates a commitment to creating a fair, diverse, and inclusive environment
• policies for dispersal of customers, which may include signage regarding taxi services, telephone numbers and advice to respect neighbours and minimise noise, also applying to customers using external areas
• licence holders should have clear documented policies and procedures in place which identify all public safety risks associated with their premises for both customers and staff, and measures implemented to prevent, manage and respond to those risks

Items to which positive consideration would be given include:

• membership of the Brighton Crime Reduction Partnership
• use of the ‘NightSafe’ radio system or a similar accredited scheme
• regular training and reminders for staff in respect of licensing legislation, policies and procedures, records of which should be properly recorded and available for inspection
• records of regular checks of all parts of the premises in relation to drug use
• systems in place to ensure details of barred clients are exchanged with other operators
• giving an agreed minimum notice of special events (screening of major sports events, birthday parties, adult entertainment, etc.) to relevant authorities and use of appropriate additional measures at such events
• staff should be aware of their responsibilities regarding smoke-free legislation and for monitoring compliance

Recommend best practice for both on and off premises:

• staff must be aware of the risk of the problem of proxy sales and offer assistance to responsible authorities to deter offences
• signage on premises should set out legal duties
• voluntary restriction of high-strength alcohol, operating schedules may be used to limit high ABV beers, lagers and ciders
• staff training - in addition to personal licence holders' training, staff must be adequately trained for duties
• Challenge 25 would be the norm, particularly in the off-licence trade
• appropriate signage and training for the deterrence of proxy sales

Additional Best Practice Measures to be included for consideration in the CSA

Applications within the CSA will be expected to include in the proposed operating schedule robust additional measures (as appropriate to the nature and location of the venue), which are set out below.

These best practice measures place a special emphasis on safety, including:

• measures to tackle drink spiking
• preventing intoxication
• unwanted sexual behaviour
• the use of ID scanners

Note: The best practice measures are not exhaustive and changes with wording, training providers, and organisations may occur over time.

Objective

An understanding of the Licensing Act 2003 (The Act).

Best Practice Measure/suggested conditions

Well-trained staff will contribute to well-run premises and a responsible approach to the sale of alcohol, provision of entertainment and late-night refreshment.

Formal qualifications for your staff, either to Personal Licence level or to another appropriate standard recognised by bodies such as the British Institute of Innkeepers (BII), would be preferential.

Objective

Preventing Intoxication on Licensed Premises.

Best Practice Measure/suggested conditions

Licence holders must ensure all staff understand their legal responsibilities under the Licensing Act 2003, particularly that serving alcohol to intoxicated persons is an offence.

To prevent intoxication occurring on premises, operators should:

• avoid promotional activities that encourage customers to drink more than intended or consume alcohol rapidly
• refuse admission to individuals who are already intoxicated upon arrival
• train staff to recognise early warning signs of intoxication, utilising all team members, including glass collectors, as additional observers, and consider installing mirrors to improve visibility across the premises
• provide staff training covering alcohol's effects and techniques for managing difficult situations, giving them the knowledge and confidence needed to refuse service to intoxicated customers

Objective

A comprehensive Duty of Care Policy is to be established in relation to preventing intoxication.

Best Practice Measure/suggested conditions

Setting out the steps staff should take to prevent intoxication, and the actions required when customers become intoxicated on the premises. This policy should recognise that intoxicated individuals may become separated from friends who would otherwise care for them, making them vulnerable to harm or exploitation.

Given Brighton and Hove's diverse community, the policy should specifically address:

• LGBTQ+ customer safety: Staff should be aware that intoxicated LGBTQ+ individuals may face additional risks, including targeted harassment, discrimination, or hate crime
• Violence Against Women and Girls prevention: Recognition that intoxicated women and girls are particularly vulnerable to predatory behaviour, with clear procedures for identifying and responding to concerning situations

The policy must ensure that no intoxicated person is left unaccompanied or placed in a taxi without appropriate supervision. All premises staff must be familiar with and trained in implementing this policy.

Objective

The installation of a digital CCTV system by liaison with, and to a standard approved by, Sussex Police. With access available to individuals working on the premises.

Best Practice Measure/suggested conditions

Subject to GDPR guidance and legislation:

• digital CCTV and appropriate recording equipment to be installed in accordance with Home Office Guidelines relating to UK Police Requirements for Digital CCTV System (PSDB Publication Number 09/05), operated and maintained throughout the premises internally and externally to cover all public areas, including the entrance to the premises - the system shall be on and recording at all times when the premises licence is in operation
• the CCTV cameras and recording equipment must be of sufficient quality to work in all lighting levels inside the premises at all times
• CCTV footage will be stored for a minimum of 31 days
• the management will give full and immediate cooperation and technical assistance to the Police in the event that CCTV footage is required for the prevention and detection of suspected or alleged crime
• the CCTV images will record and display dates and times, and these times will be checked regularly to ensure their accuracy
• subject to GDPR guidance and legislation, the management of the premises will ensure that key staff are fully trained in the operation of the CCTV, and will be able to download selected footage onto a disk (or other electronic portable device acceptable to Sussex Police, e.g. USB) for the police without difficulty or delay and without charge to Sussex Police
• any breakdown or system failure will be notified to the police immediately & remedied as soon as practicable, this can be via email to brighton.licensing@sussex.police.uk
• repair records /invoices shall be kept on site for at least 12 months and be readily available to be viewed by all authorised persons upon request
• in the event of the CCTV system's hard drive being seized as evidence as part of a criminal investigation by Sussex Police or for any other reason, the premises will be expected to install a replacement hard drive or a temporary replacement drive as soon as practicable

Objective

Incident reporting.

Best Practice Measure/suggested conditions

An incident log will be maintained by the premises showing a detailed note of incidents that occur in the premises. The log will be inspected and signed off by the DPS (or a person with delegated authority) at least once a week.

The logbook should be kept on the premises and be available for inspection at all times the premises are open by authorised officers of the Licensing Authority or the police.

An incident will be defined as being one which involves an allegation of a criminal offence.

Objective

Security in and around the premises.

Best Practice Measure/suggested conditions

The employment of SIA-registered door supervisors in line with police recommendations and/or a written risk assessment to supervise admissions and customers inside and outside the premises.

SIA badges must be clearly displayed whilst working.

Door staff should sign into a register detailing their full SIA licence number, their name, contact details, and the time and date their duty commenced and concluded

The premises should implement effective security policies to protect staff and customers from conflict, violence and threats in consultation with Sussex Police and ensure staff are adequately trained on these policies. Training records must be accessible for review by police or the Licensing Authority.

At all times that the premises are open to the public, management will contract the backup services of an approved Mobile Support Unit (MSU) that operates at all times the premises are open to the public, with a minimum of 2 SIA-registered Door Supervisors operating from it.

A copy of the MSU contract will be retained at the premises and made available for immediate inspection upon request by Sussex Police or Council Officials.

The MSU will be accredited by the Brighton Brighton Crime Reduction Partnership (BCRP) or another similar organisation approved by Sussex Police, should the BCRP not be in existence.

Objective

Brighton Crime Reduction Partnership (BCRP) membership.

Best Practice Measure/suggested conditions

Premises will become a member of the BCRP or similar scheme approved by the Licensing Authority that operates with radios and uses the Nightsafe and Yellow Card Scheme or similar reporting scheme.

Objective

ID scanners.

Best Practice Measure/suggested conditions

The use of ID scanners where appropriate.

The premises shall install a recognised electronic identification scanning system for customers entering the premises. The system shall be operated at all times when door staff are on duty, and all persons entering the premises will be scanned.

The system should have the ability to identify the hologram of an ID and read both Passports and ID cards, including PASS cards.

The system should be able to conduct tests to determine if a document is genuine or counterfeit.

The system must be compliant with the Information Commissioner's good practice guidance for ID scanning in clubs and bars.

Objective

Equalities and inclusion policy.

Best Practice Measure/suggested conditions

A comprehensive, documented equalities and inclusion policy framework that demonstrates the organisation's commitment to creating and maintaining a fair, diverse, and inclusive environment.

This framework should encompass clear policies, procedures, and measurable objectives that actively promote equality of opportunity, prevent discrimination and harassment, and foster an inclusive culture where individuals from all backgrounds can feel safe.

The policy must be regularly reviewed, updated to reflect best practice and legal requirements, and supported by appropriate training and monitoring mechanisms.

Objective

Safety of staff and customers.

Best Practice Measure/suggested conditions

Licence holders should have comprehensive, clearly documented policies and procedures in place which systematically identify all public safety risks associated with their premises for both customers and staff, and detail the robust measures implemented to prevent, manage, and respond effectively to those risks.

These policies should encompass risk assessment methodologies, hazard identification protocols, emergency response procedures, staff training requirements, and regular review mechanisms to ensure ongoing compliance with health and safety legislation.

The documentation must demonstrate a proactive approach to risk management, including contingency planning for various scenarios, clear allocation of responsibilities amongst staff members, and established communication channels for reporting and addressing safety concerns promptly and effectively.

Licence holders should prepare themselves for the implementation of Martyn's Law.

Objective

Safety of staff and customers: Martyn's Law requirements.

Best Practice Measure/suggested conditions

Preparing for Martyn's Law Requirements

Licence holders should familiarise themselves with the requirements of Martyn's Law (the Terrorism (Protection of Premises) Act 2025), which will require certain premises and events to consider how they would respond to a terrorist attack.

While the Act will not come into force for at least 24 months, early preparation will help ensure compliance and enhance the safety and security of staff and visitors.

The Government will publish guidance during the implementation period to assist in understanding the specific requirements.

Objective

Safety for staff.

Best Practice Measure/suggested conditions

Licensed venues are encouraged to take all reasonable steps to support the safe travel of staff following late-night shifts, including the provision of free or subsidised transport home where appropriate, as part of their duty of care.

Objective

Drinking receptacles.

Best Practice Measure/suggested conditions

The use of reusable plastic and polycarbonate drinking vessels and containers, especially outside areas or after specified hours.

Objective

Vulnerability policies and training.

Best Practice Measure/suggested conditions

All persons working/trading in the night-time economy will be aware of the vulnerability of patrons. Patrons are particularly vulnerable when intoxicated through alcohol and/or drugs, which includes when they are refused entry or ejected from the premises.

There will be a special emphasis on safety, including measures to tackle drink spiking and unwanted sexual behaviour.

Every venue will now need to have a clear and actionable policy in place to prevent and respond to drink spiking. This includes staff training, procedures for reporting incidents, and support for victims.

Training and initiatives should include:

Safety-First Door Policy: Venues will no longer be allowed to eject vulnerable individuals, especially lone adults, without care. Whether someone is intoxicated, separated from their group, or simply in need of help, venues must act responsibly.

Premises to contact the Night Safety Marshalls (NSMs) to assist vulnerable persons to get home safely and get the help they need during the NSM operating hours.

BCRP spiking and vulnerability training.

Home Office Spiking training.

Implementation of the ‘Ask for Angela’ scheme or similar initiatives.

Training in the use of the Back Off Back Up (Bobu) app and displaying the sticker to show venues are part of the safety network, or similar schemes.

Objective

Vulnerability policies and training.

Best Practice Measure/suggested conditions

Awareness of child sexual exploitation, modern slavery and human trafficking indicators.

Objective

Drug use.

Best Practice Measure/suggested conditions

A zero-tolerance policy on the use of drugs on the premises should be adopted.

Posters can be displayed throughout the premises to remind customers of the zero-tolerance policy.

Refusing entry to anyone who appears to be showing signs of drug use and contacting the emergency services in appropriate circumstances. In such cases, an entry should be made in an incident logbook.

A duty of care policy regarding persons suffering adversely from the effects of drugs should be in place at the premises, and staff should be trained on the policy.

Objective

Smoking on the premises.

Best Practice Measure/suggested conditions

Staff should be aware of their responsibilities regarding smoke-free legislation and for monitoring compliance, including in relation to enclosed (or substantially enclosed) smoking shelters.

Objective

Smokers outside the premises.

Best Practice Measure/suggested conditions

Limit the number of smokers permitted outside at any one time after a certain time.

Discourage smokers from loitering outside by not permitting them to take their drinks with them and removing external furniture after a certain time.

Locate smoking areas away from residential premises.

Do not permit customers to congregate on and block the public highway to passers-by.

Objective

Music, singing and speech noise break out from the premises.

Best Practice Measure/suggested conditions

A noise management policy should be in place that sets out sound attenuation measures to prevent or control music, singing and speech noise breakout from the premises.

Objective

Noise and nuisance from customers arriving and leaving the premises.

Best Practice Measure/suggested conditions

Reduce the potential for excessive queue lines with a well-managed and efficient door policy.

A customer dispersal policy can minimise noise disturbance to local residents from customers leaving the premises. A policy should clearly set out measures to avoid a mass exit at the end of the evening.

Display prominent notices close to the exit doors, requesting patrons to leave the premises quickly and quietly.

Display prominent signs in external areas such as beer gardens and forecourts asking customers to keep noise to a minimum.

Restrict the use of external areas after a certain time (e.g. 10pm) if the premises are in a residential area.

Objective

Noise and disturbance caused by deliveries, collections and waste disposal.

Best Practice Measure/suggested conditions

Commercial deliveries, collections and storage/disposal of waste (especially glass), including beer deliveries, refuse collections and storage/disposal of waste and recyclables in external areas, should be restricted to certain times.

Objective

Children accessing licensed premises.

Best Practice Measure/suggested conditions

A documented Safeguarding policy setting out measures to protect children from harm should be in place at the premises.

The policy should consider all activities associated with the premises, including the sale of alcohol and the provision of regulated entertainment and when children should be allowed on or restricted from the premises.

All staff, including door staff and bar staff, should be trained on the policy.

Objective

Underage sales of alcohol.

Best Practice Measure/suggested conditions

The premises will operate a "Challenge 25" policy whereby any person attempting to buy alcohol who appears to be under 25 will be asked for photographic ID to prove their age.

The recommended forms of ID that will be accepted are passports, official Photographic Identity Cards issued by EU states bearing a hologram or ultraviolet feature, driving licences with a photograph, photographic military ID or proof of age cards bearing the ‘PASS’ mark hologram.

The list of recommended forms of ID may be amended or revised with the prior written agreement of Sussex Police, the Licensing Authority and Trading Standards without the need to amend the licence or conditions attaching to it.

Signage advertising the ‘Challenge 25’ policy will be displayed in prominent locations in the premises.

The Premises Licence Holder/Management shall ensure that all staff members engaged or to be engaged in selling, serving or delivering alcohol shall receive induction training. If this training is to be conducted in electronic form, it will, at a minimum, also include a face-to-face discussion session.

This training will take place prior to the selling, serving or delivering of such products and will include:

• a) The lawful selling of age-restricted products – including but not limited to, the requirement of the staff member conducting the transaction to ensure they carry out Challenge 25 checks, regardless of any other staff member checks that may already have taken place
• b) Identifying if a person may be intoxicated and refusal of sale
• c) Vulnerability initiatives and how to respond to potential drink spiking

Further verbal reinforcement/refresher training covering the above will be carried out thereafter at intervals not to exceed 8 weeks, with the date and time of the verbal reinforcement/refresher training documented.

All such training undertaken by staff members shall be fully documented and recorded.

All training records shall be made available to Sussex Police, officers of the local authority and officers from the Trading Standards team upon request.