We lease a warehouse unit and are seeking TAPA FSR certification. Can the CCTV system be under the total and sole control of the owner of building?
TAPA takes the view that the flexibility of the FSR and practical use of waivers with appropriate mitigation allows for the opportunity for the LSP (Certification Applicant) to obtain FSR certification. In this example it is unlikely that an auditor or TAPA could approve any of the CCTV requirements without a waiver being approved. Except where waivers are requested and approved, all other relevant requirements must be compliant regardless of who owns the CCTV system.
· Waiver(s) to cover the business relationship between the building owner and the LSP/Applicant must be submitted and approved.
· A formal agreement between the building/CCTV systems owner and the LSP/Applicant must be attached to the main waiver. The formal agreement shall include:
o A listing of the items from the TAPA FSR that the building owner will be responsible for
o Agreement in place that the building owner is liable to supply and maintain CCTV equipment on site that is required to meet the CCTV certification requirements listed in the TAPA FSR;
o Special attention should be taken to list the mitigation controls and establish which party owns the alternative measures;
o Where dual ownership or operation of a requirement is needed these shall be listed separately in the formal agreement with accountability for maintaining the requirement clearly documented;
· Additional waivers may be justified using the standard waiver request process.
· In the event of challenges or disputes with LSP clients. The LSP shall be the responsible party and cannot defer to the building owner for resolution.