KEN KIRSCHENBAUM, ESQ
ALARM - SECURITY INDUSTRY LEGAL EMAIL NEWSLETTER / THE ALARM EXCHANGE
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Important comments on central station operators working remotely
September 23, 2022
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Important comments on central station operators working remotely
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Ken
Re: Work From Home, the Pros and Cons
As a preface to this let me state that I wear two hats; my first hat and day job is working for Rapid Response Monitoring Services, it should be no surprise to anyone that Rapid drove its stake in the ground early that Work from Home was not going to be something we were going to do now or in the foreseeable future. My second hat is that I am the President of the Monitoring Association which is the trade association that represents the interests of the monitoring industry. With that comes working with everyone and their needs and issues.
I should also mention that the way UL and other standards organizations that touch our industry create and maintain standards uses a consensus model. What consensus means is that the stakeholders or members of the various committees are responsible for the standards. In the case of UL they don’t have a bunch of UL employees in a room making decisions for the industry; instead they work with the stakeholders to design and execute standards. For this article the stakeholders are the members of the UL 827 Technical Committee which is made of people from all different industries not just central stations. Mr. Zwirn is a member of that Technical Committee.
In addition to the Technical Committee, from time to time, sensitive or critical issues are assigned to separate working groups or subcommittees, in the case of Work from Home TMA was tasked with putting together this working group which worked with UL to create this standard which was ultimately sent to the Technical Committee for approval. I was a member of that work group as well as many other stakeholders. The rest of this article describes the process and rational for how we as an industry got here. I tried to present this as an unbiased article as there are always two sides despite what I or my employer feels is the right solution.
When COVID 19 hit it set the world into a panic that has never been see before and this is especially true for industries that the public has relied on to supply security, medical services, and food. I remember thinking this could be the end of civilization as we know it today if many of these vital industries are forced to slow down, close or shutdown and even before the alarm industry was classified as “essential” the industry started working on how we can send staff home in order to keep them safe but at the same time work towards keeping the same standard of care as we have always had.
Then, if COVID wasn’t enough, once the unemployment checks increased, we were flung into the “great resignation” where it became significantly harder to recruit and hire employees for any job and this really affected monitoring centers across North America.
Initially TMA (The Monitoring Association) worked with UL (Underwriters Labs) to come up with temporary guidelines for those centers that wanted or had to, so they could send their people home to monitor alarm. This guideline was pretty basic; it allowed for a secure connection, a separate workspace for operators to work from and it didn’t allow for certificated accounts to be monitored from home. The guidelines were not perfect, but it allowed centers if needed to quickly deploy people at home during emergency conditions. In the early days the alternative was to shut down which as you can imagine was not a practical option.
At the time TMA started this project it was everyone’s belief we were really thinking about a six month period where if everyone stayed home we could be over and done with COVID and would not be working from home much longer than that.
The original plan was to learn from the temporary guideline exercise and then come up with a codified standard that would allow workers to work from home during any kind of serious government stated emergency, not just COVID. The UL 827 standards technical committee was responsible for getting this permanently into the 827 standards. Initially this was to be for emergencies only but then as time went on and years later it was changed to allow work from home during non-emergency times. The reasoning behind the changing to a permanent model was driven hard by the inability to hire and keep employees. Those centers that moved to a work from home model found it much easier to recruit, hire and keep employees compared to what they had been doing in the past.
There has been a lot of noise around this in the industry and the next part is a breakdown of the various critical parts of the UL 827 Standard that governs where an operator works from.
I encourage all of you to read this section for yourself in UL 827, Because of copyright laws I can’t just cut and paste all the sections here for you, but you all should have these standards in your library at all times, Section 51 which covers the need to have work from home during a disaster and Section 52 – 54 covers the use of Virtual Operators as a full time method. Here are the highlights of what is currently required in UL Section 52 - 54
52.1 Cannot monitor UL2050 accounts from home.
53.1 The actual monitoring center cannot ever be completely unstaffed.
54.1.1 The remote site must connect securely to the host.
54.1.3 The Connection between the Remote and the host must meet, a and b or c
a, Backup communications paths for remote workers
b, A UPS with enough time to gracefully transfer the alarm to another operator
c, There are enough operators working at the same time such that if a remote worker loses communication there are enough people remaining that are already logged to process the alarm and that the automation system will not “loose” the alarm and it gets processed within the normal times required by UL.
Special note for 54.1.3: there is a proposal that’s being worked on that adds some additional C/D options but this proposal has not yet been accepted yet and so for now I have left it out of this article.
54.2 The monitoring center must be in complete control of all the remote hardware, it must patched, running anti-virus, and USB ports have to be locked down for file sharing. If for any reason the remote workstation has any account data residing on it, then the entire disk with the customer data needs to be encrypted.
54.2.2 The remote host needs to be able to send in a remote Duress Signal from the keyboard.
54.3.1 The remote workspace needs to be dedicated space and only being used by the employee when on duty, the screen cannot be viewed from outside the room and remote operators must use headsets while on the phone.
54.3.2 There needs to be a video camera installed such that the monitoring center can look into the room and there needs to be a way to obtain screenshots to verify compliance.
54.3.3 The monitoring center is responsible for validating and documenting compliance of the workspace, computer hardware etc. before the employee starts their first shift monitoring alarms.
54.3.4 There must be a way for the remote employee to be able to communicate with others while on shift.
54.3.5-7 The central station is responsible for documenting the security architecture, adding the remote workers into the business continuity plans and for providing the remote workers training on cyber security.
54.4 Its up the central station to validate and document all this annually for verification by UL.
PRO’s
It’s easier to hire a workforce because you are no longer geographically limited to an area.
Because there is no commute time it makes hiring part time employees more of a viable option
Some employees like it, so there is the potential to reduce employee turnover and satisfaction.
Monitoring Centers could potentially save a lot on real-estate costs because you now have a distributed workforce and don’t need seats for them. Nor do you need training facilities to train in.
For viruses you can isolate your staff to try to slow the spread.
It’s easier to bring on additional staff to handle things like a storm or earthquake.
CON’s
You lose a lot of control of your staff just think about all the things you are doing in your facility now.
It’s very hard to proliferate culture when everyone is separated.
Your ability to enforce security policies like cell phone usage or social media is reduced significantly.
You can’t always control the environment, especially loud sounds like barking dogs, lawnmowers, kids crying.
You are now in most cases relying on the public internet to support both your voice and data traffic, think about all the zoom calls that didn’t work out.
It requires you to rethink and rework all your training methods, review processes and HR requirements.
You must provide, deploy, track, and maintain all the computer equipment at all the homes, this includes things like patch management, hardware failures, software updates etc.
As you can see there are a lot of pros and cons, I didn’t elaborate on them because of space, but you can see this is not necessarily an easy decision for some. What I believe is going to come from this will be a mixed bag of acceptance; some centers have already adopted this model and have moved virtually all their staff home while others have said they won’t be sending any staff home and there are others that would prefer to have everyone in-house but can send them home if necessary. UL doesn’t specify how many employees can work from home as long as the center itself is never completely empty, it also doesn’t specify where the employee is physically located either; they could be domiciled anywhere at this point.
There are lots of strong opinions on this subject but especially with the wholesale centers. The independent dealers are at the mercy of the wholesale center and have to live with the results good or bad every day. The good news is that everyone has choices, there are centers that have adopted one model or another and you have the freedom to choose where you monitor your accounts. I can also share that dealers are getting smart and demanding contract addendums on where their accounts are being processed from. Over time I think this will start to level out. Dealers that are passionate about it either way will make their choice; those full service organizations that choose either way will also have to deal with the results of their choices either way.
For those of you that are reading this and feel passionate for either model the only way things get changed are through these consensus-based Standards Committees and they are open to join, so I encourage you to join and be a part of these discussions and processes. In addition to joining there is also a process where anyone can submit a proposal for change and every one of these things has a public comment period where anyone can comment. So instead of arm chair quarterbacking these, become part of the process in order to invoke changes. Many of these decisions are heavily debated in these committees. Rarely are these just cut and paste and vote so come and join the process
Morgan Hertel, VP of Technology and Innovation
Rapid Response Monitoring
www.RRMS.com
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Ken,
Great commentary on the matter. Thank you for providing the platform.
Regarding Companies or Associations that support the permanent WFH model, the TMA and/or UL working groups should have their committee chairs who have introduced this speak up.
For those who want to research on their own or provide input on the future of our Industry, I suggest participating in UL’s standards development process (CSDS) – you can sign up at the link below (and see who has been presenting this permanent WFH into UL 827).
https://csds.ul.com/Home/Request_Access.aspx
Here are some links to TMA as well:
Committees: https://tma.us/about/our-committees/
UL Standards: https://tma.us/standards/ul-standards/
Contact: https://tma.us/about/contact-us/
All links above are public facing pages available to all.
Stephen Harper
Dispatch Center, Ltd
www.dispatchcenter.net
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Ken,
Something that comes to mind concerning remote monitoring is that we could be unwittingly putting nails in the industry monitoring coffin. Consumer learns of the situation, thinks, hey, if a UL station can do that I can buddy up with my friends or family and we can monitor our own homes and businesses. The $ we'd save! It has the stamp of approval of UL and TMA. (Although, Morgan doesn't seem to be a fan based on his responses and recent marketing efforts.).
I also agree fire departments might see this as a good reason to renter the monitoring business most of them abandoned years ago.
Keep me
Anonymous, please
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Response
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Thank you for these informative comments that explain the issue and reasoning. It is interesting that with all the discussion on this forum not one central station has come forward to support remote operators or admit the central station did or still does permit remote operators and how that has been implemented; perhaps more importantly, how it’s working out.
After all if we can’t identify any central station utilizing work at home or remote operators then what’s the fuss been about? So, any central stations care to come out of the closet or anyone have reliable “intel” on any central stations using remote operators?
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Ken Kirschenbaum,Esq
Kirschenbaum & Kirschenbaum PC
Attorneys at Law
200 Garden City Plaza
Garden City, NY 11530
516 747 6700 x 301
ken@kirschenbaumesq.com
www.KirschenbaumEsq.com
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