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Non-Bank Tenant Security Training

We need to provide periodic training of all employees in their responsibilities under the security program. Does the definition extend to all employees within the physical location of the bank, such as non-employees of financial service subsidiaries who occupy offices with the bank or non-bank tenants?

There's nothing in the Bank Protection Act that requires you to train non-employees about robbery, burglary or larceny. The term non-employee is a little tricky. If your cash-handling facility uses an open platform configuration where representatives of insurance or securities companies are stationed, you should also train those persons regarding your institution's safety measures. Anyone who is, or may logically become, present in an area where a robbery may occur should receive the same training as your platform employees -- with the exception of some confidential information, of course. Anyone who is on your premises by invitation (board members, vendors and third-party service providers) and may become the victim of a bomb threat, hostage event or related offense should also be trained regarding what your institution will do for them or will expect from them. Those persons should also be made part of emergency evacuation drills. I recommend that you don't offer this type of training to customers, however.

First published on 8/18/08

First published on 08/18/2008

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