Martyn's Law for Local Authorities and Council Venues

The Scale of the Challenge

Local authorities own and operate some of the most diverse property portfolios in the country. Town halls, leisure centres, swimming pools, libraries, community centres, theatres, parks with event spaces, museums, galleries, and civic offices. Many of these premises have a capacity exceeding 200, bringing them within the scope of Martyn's Law. Some, particularly leisure centres and theatres, will exceed 800 and fall into the enhanced tier.

The challenge for councils is not just compliance at a single venue. It is compliance across dozens of premises, each with different characteristics, different risk profiles, and different staffing arrangements. This requires a strategic, portfolio-wide approach rather than ad-hoc, venue-by-venue responses.

Identifying In-Scope Premises

The first step is an audit of all council-owned and council-operated premises. For each one, determine the maximum capacity and classify it as below threshold, standard tier, or enhanced tier. Do not forget premises that are managed on the council's behalf by trusts or contractors. The legal responsibility may still sit with the council depending on the management arrangement.

Common council premises likely to be in scope:

• Town halls and civic centres: Often 200+ capacity with public meetings, ceremonies, and events.
• Leisure centres and swimming pools: Frequently 800+ with swimmers, gym users, spectators, and staff.
• Libraries: Larger central libraries can exceed 200 capacity, especially those with event spaces and meeting rooms.
• Community centres: Many accommodate 200+ for events, classes, and community gatherings.
• Theatres and arts centres: Almost always 200+ and often 800+.
• Museums and galleries: Depends on size, but many qualify.
• Parks with event spaces: When hosting events with 200+ attendees, these may come into scope.

The Responsible Person Question

For each qualifying premises, the council needs to identify the responsible person. In a directly managed venue, this might be the facility manager or a senior council officer. In an outsourced venue, the contract and management structure will determine who carries the legal responsibility. Review your contracts and management agreements now to ensure there is clarity on this point before enforcement begins.

A Portfolio Approach to Compliance

Councils can save time and money by developing a standardised compliance framework that is then tailored for each venue. This might include:

• A template risk assessment methodology adapted to each premises
• Standard operating procedures for evacuation, lockdown, and invacuation that are customised for each building's layout
• A council-wide training programme delivered to all venue staff
• A centralised documentation and record-keeping system
• A single technology platform deployed across multiple venues

This approach avoids reinventing the wheel at each venue and ensures consistency in how the council meets its obligations.

Budget Planning

Council budgets are under pressure. Compliance with Martyn's Law needs to be planned and budgeted for across financial years. The main cost areas are:

• Staff time for risk assessments, procedure writing, and coordination
• Training delivery across multiple venues and staff groups
• Technology upgrades where existing CCTV or monitoring capability is insufficient
• Professional support for terrorism risk assessments at enhanced tier venues
• Ongoing maintenance of procedures, training records, and documentation

Start with the measures that cost the least: writing procedures, training existing staff, and auditing current security arrangements. Technology investments can be phased in over the implementation period.

Staff Training at Scale

Councils employ hundreds or thousands of people across their venues. Training all of them is a logistical challenge. Consider a tiered training approach:

• All venue staff: Basic awareness training covering what to do in an emergency, how to report concerns, and who is responsible. This can be delivered online or through brief in-person sessions.
• Venue managers and supervisors: More detailed training on risk assessment, procedure management, and incident coordination.
• Security staff: Comprehensive training on terrorism indicators, hostile reconnaissance, and tactical response.

Technology Across the Portfolio

One of the biggest advantages councils have is scale. Deploying AI behaviour detection across 20 venues is significantly more cost-effective per venue than a standalone installation. A centralised monitoring capability covering multiple council venues can be operated by a small team, with AI handling the continuous analysis of camera feeds and human operators responding to alerts.

This kind of multi-site deployment also gives councils a clearer picture of security across their portfolio, supports consistent reporting, and provides the documented evidence the SIA will want to see during inspections.