The Private Security Act ZZASV-1, Official Gazette of the Republic of Slovenia 17/11 (hereinafter: the Act), regulates the rights and obligations of companies, sole proprietors, state bodies, institutions, public agencies and other legal and natural persons (hereinafter: entities) in the field of security not provided by the state (hereinafter: private security). The Act also provides for private security, forms of security, competences, conditions for private security, standards, professional training and development, measures and duties of a security guard, insignia and working clothes, conditions for private security of foreign persons, compulsory organisation of security and duties of entities, supervision, records and criminal provisions, Private security is the protection of persons and property in a protected area, a specific facility or a place against illegal acts, damage or destruction by security personnel and technical security systems, carried out in the forms provided for in this Law. At the same time, private security is also defined as an economic activity intended for the protection of persons and property, which the Republic of Slovenia regulates in the public interest in order to protect public order, public security, the protection of clients, third parties and security personnel directly carrying out the activity. The Act further provides that private security may be provided in the following forms of security (types of licences): 1. protection of persons and property; 2. protection of persons; 3. transport and protection of cash and other valuables; 4. protection of public assemblies; 5. security for events in catering establishments; 6. management of a Security and Surveillance Centre (hereinafter referred to as the 'SSC'); 7. design of technical security systems; 8. implementation of technical security systems, where a licence is defined as a permit issued in accordance with the Act to carry out one or more forms or tasks of private security; a licence shall be granted to a legal person by means of a licence certificate and to a natural person by means of a service card. The design of technical security systems referred to in Article 5(10) of the Act, as one of the forms of carrying out the activity of private security, includes the drawing up of technical documentation projects for the implementation of technical security systems by a licensed security systems engineer who meets the conditions under the Act and the law governing the construction of buildings. The authorised security systems engineer or authorised security systems engineer (hereinafter referred to as 'PIVS authorised security systems engineer') referred to in Article 5(13) of the Act shall be responsible, in accordance with the provisions of the Act and the Act governing the construction of buildings and the regulations issued pursuant thereto, for drawing up the projects for the implementation of the technical security systems and for supervising the implementation of the technical security systems. The Law stipulates that security personnel shall perform the tasks defined in the professional standard according to the professional qualification acquired. Security personnel must also undergo compulsory (preliminary) professional training and (periodic) further training in order to acquire and improve their professional knowledge and skills, in accordance with professional training and further training programmes for security personnel (hereinafter referred to as 'the programmes') to be determined by the Minister, depending on the type of work carried out by the security personnel in the field of private security. As one of the fulfilment of the conditions for professional competence, security personnel shall be deemed to be professionally qualified in relation to the type of work they carry out under the Act if they have completed professional training and further training as provided for in the Act and have obtained a national vocational qualification in the field of private security in accordance with the regulations governing national vocational qualifications (hereinafter referred to as 'NQF'). In the Catalogue of Professional Skills No 7723015021 (hereinafter referred to as the Catalogue), the NPQ PIVS Authorised Security Systems Engineer is classified at level VI/1 Klasius-SRV, and as a specific condition for obtaining the NPQ PIVS, point 2.2. 2.2 of the Catalogue stipulates that the person must be (i) an authorised electrical engineer with a design authorisation in accordance with the law governing the construction of buildings and at the same time (ii) have completed professional training as an authorised security systems engineer in accordance with the law governing private security. In my view, the requirement in Article 5(10) of the CCPA-1 is substantially, unreasonably and disproportionately excessive. In my opinion, this requirement in practice for the design of technical security systems as one of the forms of carrying out the activity of private security makes it impossible for natural persons with higher professional education (level VI/1) to obtain service cards, which puts them in a subordinate position, or in fact prevents them from carrying out the activity of designing technical security systems as one of the forms of carrying out the activity of private security - even though the system of certification and verification of the NPK as a level of complexity for PIVS provides for level VI. A corresponding change in the legislation would also increase the number of natural persons as economic operators carrying out the activity and thus increase competition - which would be beneficial for the final client. On the basis of the foregoing, I PROPOSE to AMEND THE LEGISLATION to read as follows: A - LAW ZZASV-1: Amendment 01) Article 5, paragraph 10, shall read as follows "10. the design of technical security systems shall include the drafting of technical documentation for the implementation of technical security systems with a certified security systems engineer who meets the conditions under this Act;" Amendment 02) Article 5, point 13, shall read as follows "13. the authorised security systems engineer (hereinafter referred to as the authorised security systems engineer) shall be responsible, in accordance with the provisions of this Law and the regulations issued pursuant to it, for the preparation of the projects for the implementation of technical security systems and for the supervision of the implementation of technical security systems;" B - CATALOGUE OF PROFESSIONAL KNOWLEDGE AND SKILLS No 7723015021: Amendment 03) point 2.2. shall read as follows "2.2. THE SPECIFIC CONDITIONS TO BE FULFILLED BY A PERSON WISHING TO OBTAIN A PROFESSIONAL QUALIFICATION At least an Engineer VI/1 in the field of electrical engineering or computer science/informatics or mechanical engineering or mechatronics and at least eight years of professional experience with the holder of a licence for the design of technical security systems; the submission of at least five projects of technical documentation for the implementation of technical security systems (PZI) shall be taken into account as proof of professional experience.Completion of professional training as a certified security systems engineer in accordance with the law governing private security.".