What this means
Start with the exact decision in front of you.
The SIA may consider reliable information beyond convictions when assessing whether someone is fit and proper, including material from police or other bodies. The holder may not receive every underlying detail, so the response should identify inaccuracies and address public risk without speculation.
Immediate priorities
Organise the position before responding.
Record exactly what the notice discloses and what remains unclear
Gather independent evidence relevant to reliability and present risk
Avoid contacting witnesses or investigators in a way that could prejudice another process
Detailed guidance
The procedure, evidence and possible route from here.
01
Understand information beyond convictions
The SIA's fit-and-proper assessment may consider non-conviction information indicating public risk or unsuitability, including material from police, employers, regulators or other sources. The absence of a charge or conviction does not prevent a licensing review, but the SIA should still assess relevance, reliability and fairness. Identify what the notice actually discloses, its source where stated and the conduct or risk said to follow.
Do not equate an allegation with proof, but avoid assuming only a criminal court can consider the information. Licensing serves a preventive public-protection function and applies its own criteria. The response should address accuracy, context and current risk. If the notice uses vague phrases such as adverse intelligence, request enough particularity to answer while recognising that operational or third-party constraints may limit disclosure.
- Record the disclosed source and allegation
- Separate licensing assessment from criminal proof
- Request focused clarification where needed
02
Challenge reliability with primary evidence
Build a timeline from incident reports, messages, CCTV or body-worn video, duty logs, witness accounts and formal investigation outcomes that can lawfully be obtained. Identify mistaken identity, inconsistent dates or missing context with direct sources. A later decision not to prosecute may be relevant but does not automatically establish that every underlying concern was false; obtain the reason where available and explain its evidential significance carefully.
Respect continuing investigations and witness safety. Do not contact complainants to seek withdrawal or ask colleagues for coordinated statements. Request organisational records through the controller and preserve retention-sensitive material promptly. Where disclosure would breach a court restriction, confidentiality obligation or police direction, explain that limit and identify whether a summary, consent or direct regulator-to-regulator transfer can provide a lawful alternative.
- Use primary incident evidence where available
- Explain the meaning of other-process outcomes
- Preserve evidence without interfering with witnesses
03
Address present suitability
Current evidence may include role changes, supervision, retraining, incident-free work and employer controls, but it should connect to the asserted risk. A generic character reference carries limited weight if the writer does not know the information in question. Ask informed referees to describe direct observations, responsibilities and any safeguards. Where the concern involves off-duty conduct, address why it does or does not affect trust and safety in licensed activity.
Set out factual challenge and alternative risk evidence in separate sections. This avoids suggesting that safeguards concede a disputed allegation. State the licensing outcome requested and how it follows from the current criteria. If the SIA maintains its decision, preserve all disclosed material and submissions for the court appeal. Do not post sensitive allegations publicly while the case or connected investigation is active.
- Connect safeguards to the alleged risk
- Use referees aware of the concern
- Separate factual denial from alternative mitigation
Key questions
Keep the analysis tied to this stage.
Whether the information is sufficiently reliable and relevant
Whether it demonstrates a present risk or suitability concern
Whether fairness requires clarification or further opportunity to respond
Advice is provided only by the regulated firm that accepts a matter.
Common questions
Clarifying the route without assuming the outcome.
Can the SIA act if the police did not charge me?
Potentially. The fit-and-proper criteria can consider relevant non-conviction information, but its reliability, relevance and the opportunity to respond remain important.
Will the SIA disclose all police information?
Not always. Disclosure can be limited, but the licence holder should identify what clarification is needed for meaningful representations and address the information actually provided.
Connected guidance
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Use the hub for the full sequence or choose the connected route that matches the notice.
Official sources
Check the material for this question.
Sources checked 19 September 2026. Rules change, so compare the current notice and linked official material and tell the operator if a citation or summary needs correction.