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Q: On a recent licensing visit, the Council licensing officer said my training records were not up to scratch and that I should seriously consider improving them. Do I have an obligation to maintain extensive records and should I be concerned?
A: Although I would have expected the licensing officer to have commented if you were in breach of any conditions of your premises licence, you should check this, as conditions are often applied which provide such an obligation. Record keeping conditions can be quite prescriptive and often state the details that must be recorded and how long records must be maintained.
If it is not a condition of your licence you are not strictly required to keep training records, although this does evidence good practice. I have seen operators rely on detailed records when under investigation by Responsible Authorities. I have also seen records used to evidence an operator’s due diligence at a premises licence review hearing, which was instigated by the police for a failed test purchase.
You may find it beneficial to maintain appropriate records for several areas including: staff training, providing dates, training provider details (in-house or external) and details of any refresher training; refusals, providing dates, times, details of the individual refused service and the details of the member of staff involved; incidents, including dates, times and a description of the incident and the member of staff involved.
Having considered a refusal/incident log, it may be beneficial for you or the DPS to sign these records off on a weekly basis to evidence that incidents are being actively monitored and potential concerns identified.
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