PFD report

Paul Steven Reynolds · Prevention of Future Deaths report

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Issued 11 May 2021•Suffolk

Report record

Published report and response evidence

This page connects the concerns raised in this report with statements found in recipients’ published responses. A link shows a clear evidence connection; it does not assign responsibility.

View original report
Concerns
13

Raised in this report

Recipients
5

Named on the report

Responses found
2

Of 5 recipients

Stated actions
10

Described in responses

Source document

Full report text

This is the full text from the original published report.

Open published report

Concerns and recipient responses

Select any concern, action or position to view the source wording.

Report evidence summary

Concerns raised13

  1. Failure to place a person subjected to prone restraint in the recovery position
    Part of recurring concern: Unsafe use and management of prone restraint
  2. Lack of accurate and clear guidance on information to share with police
  3. Failure to provide or arrange additional training for security staff
Responses linked to these concerns

Each statement is shown once, even when linked to more than one concern.

Actions described in response An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.9

  1. Action

    Investigate engaging external providers to deliver annual refresher training for all security-badged staff.

    Stated by Britannia Jinky Jersey LimitedStated in progressThe respondent said that this action was in progress when they made their response on 18 May 2021.
  2. Action

    Re-emphasise in the Physical Intervention Policy that non-badged staff must not participate in restraint.

    Stated by Britannia Jinky Jersey LimitedStated plannedThe respondent said that this action was planned when they made their response on 18 May 2021.
  3. Action

    Remove ground-restraint references from the Physical Intervention Policy.

    Stated by Britannia Jinky Jersey LimitedStated plannedThe respondent said that this action was planned when they made their response on 18 May 2021.

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.5

  1. Position

    Non-badged staff were not permitted to participate in restraint.

    Stated by Britannia Jinky Jersey LimitedDisputes the concernThe respondent disagreed with part of the concern or the basis for it.

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure to place a person subjected to prone restraint in the recovery position

Wider context from the report

“(1) The Physical Intervention Policy August 2016 places the onus on staff to seek additional training. (2) Pontins do not undertake any internal training or employ external trainers for security staff. (3) Unbadged staff are allowed to participate in restraint (4) Ground restraint remains in the PI policy as an appropriate method to contain an incident even though this is not taught in SIA accredited courses. (5) At no point during the prone restraint was Mr Reynolds placed in the recovery position. Neither did any member of staff appear to seriously consider the potential for positional asphyxia by closely or effectively monitoring Mr Reynolds breathing. (6) There appeared to be no clarity in the Policy about who should take charge of an incident or what the responsibilities are for security staff and Managers. (7) There appeared to be a lack accurate information and clarity around what information should be shared with the police about the incident. (8) There was no documented evidence of the induction or any other training for staff. ”

Is this part of a recurring concern?

Yes — Unsafe use and management of prone restraint.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of accurate and clear guidance on information to share with police

Wider context from the report

“(1) The Physical Intervention Policy August 2016 places the onus on staff to seek additional training. (2) Pontins do not undertake any internal training or employ external trainers for security staff. (3) Unbadged staff are allowed to participate in restraint (4) Ground restraint remains in the PI policy as an appropriate method to contain an incident even though this is not taught in SIA accredited courses. (5) At no point during the prone restraint was Mr Reynolds placed in the recovery position. Neither did any member of staff appear to seriously consider the potential for positional asphyxia by closely or effectively monitoring Mr Reynolds breathing. (6) There appeared to be no clarity in the Policy about who should take charge of an incident or what the responsibilities are for security staff and Managers. (7) There appeared to be a lack accurate information and clarity around what information should be shared with the police about the incident. (8) There was no documented evidence of the induction or any other training for staff. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure to provide or arrange additional training for security staff

Wider context from the report

“(1) The Physical Intervention Policy August 2016 places the onus on staff to seek additional training. (2) Pontins do not undertake any internal training or employ external trainers for security staff. (3) Unbadged staff are allowed to participate in restraint (4) Ground restraint remains in the PI policy as an appropriate method to contain an incident even though this is not taught in SIA accredited courses. (5) At no point during the prone restraint was Mr Reynolds placed in the recovery position. Neither did any member of staff appear to seriously consider the potential for positional asphyxia by closely or effectively monitoring Mr Reynolds breathing. (6) There appeared to be no clarity in the Policy about who should take charge of an incident or what the responsibilities are for security staff and Managers. (7) There appeared to be a lack accurate information and clarity around what information should be shared with the police about the incident. (8) There was no documented evidence of the induction or any other training for staff. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure to control the scene to facilitate assessment of a person’s condition

Wider context from the report

“(4) Officers did not control the scene by clearing the ballroom and switching off the music which would have improved their ability to assess Mr Reynolds’ condition. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of clarity about incident command and staff responsibilities

Wider context from the report

“(1) The Physical Intervention Policy August 2016 places the onus on staff to seek additional training. (2) Pontins do not undertake any internal training or employ external trainers for security staff. (3) Unbadged staff are allowed to participate in restraint (4) Ground restraint remains in the PI policy as an appropriate method to contain an incident even though this is not taught in SIA accredited courses. (5) At no point during the prone restraint was Mr Reynolds placed in the recovery position. Neither did any member of staff appear to seriously consider the potential for positional asphyxia by closely or effectively monitoring Mr Reynolds breathing. (6) There appeared to be no clarity in the Policy about who should take charge of an incident or what the responsibilities are for security staff and Managers. (7) There appeared to be a lack accurate information and clarity around what information should be shared with the police about the incident. (8) There was no documented evidence of the induction or any other training for staff. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure to closely and effectively monitor breathing during prone restraint

Wider context from the report

“(1) The Physical Intervention Policy August 2016 places the onus on staff to seek additional training. (2) Pontins do not undertake any internal training or employ external trainers for security staff. (3) Unbadged staff are allowed to participate in restraint (4) Ground restraint remains in the PI policy as an appropriate method to contain an incident even though this is not taught in SIA accredited courses. (5) At no point during the prone restraint was Mr Reynolds placed in the recovery position. Neither did any member of staff appear to seriously consider the potential for positional asphyxia by closely or effectively monitoring Mr Reynolds breathing. (6) There appeared to be no clarity in the Policy about who should take charge of an incident or what the responsibilities are for security staff and Managers. (7) There appeared to be a lack accurate information and clarity around what information should be shared with the police about the incident. (8) There was no documented evidence of the induction or any other training for staff. ”

Is this part of a recurring concern?

Yes — Unsafe police restraint practices and controls; Unsafe use and management of prone restraint.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure to restrict restraint participation to appropriately badged staff

Wider context from the report

“(1) The Physical Intervention Policy August 2016 places the onus on staff to seek additional training. (2) Pontins do not undertake any internal training or employ external trainers for security staff. (3) Unbadged staff are allowed to participate in restraint (4) Ground restraint remains in the PI policy as an appropriate method to contain an incident even though this is not taught in SIA accredited courses. (5) At no point during the prone restraint was Mr Reynolds placed in the recovery position. Neither did any member of staff appear to seriously consider the potential for positional asphyxia by closely or effectively monitoring Mr Reynolds breathing. (6) There appeared to be no clarity in the Policy about who should take charge of an incident or what the responsibilities are for security staff and Managers. (7) There appeared to be a lack accurate information and clarity around what information should be shared with the police about the incident. (8) There was no documented evidence of the induction or any other training for staff. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Physical intervention policy permitting ground restraint methods not taught in accredited courses

Wider context from the report

“(1) The Physical Intervention Policy August 2016 places the onus on staff to seek additional training. (2) Pontins do not undertake any internal training or employ external trainers for security staff. (3) Unbadged staff are allowed to participate in restraint (4) Ground restraint remains in the PI policy as an appropriate method to contain an incident even though this is not taught in SIA accredited courses. (5) At no point during the prone restraint was Mr Reynolds placed in the recovery position. Neither did any member of staff appear to seriously consider the potential for positional asphyxia by closely or effectively monitoring Mr Reynolds breathing. (6) There appeared to be no clarity in the Policy about who should take charge of an incident or what the responsibilities are for security staff and Managers. (7) There appeared to be a lack accurate information and clarity around what information should be shared with the police about the incident. (8) There was no documented evidence of the induction or any other training for staff. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Reduction in time allowed for officer training

Wider context from the report

“(2) The time allowed for training had been reduced from 12 to 4.25 hours. Positional asphyxia training had been reinforced, but there were questions about the impact of the reduction upon officers. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Officers’ misunderstanding of the circumstances in which pain or pressure testing is justifiable

Wider context from the report

“(1) Officers appeared to be under the impression that pain/pressure testing to determine whether a person was unconscious or simply asleep was an assault rather than being justifiable in certain circumstances. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Insufficient officer skills in non-physical aspects of conflict management

Wider context from the report

“(3) The College of Policing and NPCC Officer and Staff safety Review made two recommendations to include revising the curriculum to ensure greater consistency, and to implement guidelines to ensure officers are sufficiently skilled in non-physical aspects of conflict management. The time scales for implementation were not stated. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of consistency in the training curriculum

Wider context from the report

“(3) The College of Policing and NPCC Officer and Staff safety Review made two recommendations to include revising the curriculum to ensure greater consistency, and to implement guidelines to ensure officers are sufficiently skilled in non-physical aspects of conflict management. The time scales for implementation were not stated. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure to document staff induction and training

Wider context from the report

“(1) The Physical Intervention Policy August 2016 places the onus on staff to seek additional training. (2) Pontins do not undertake any internal training or employ external trainers for security staff. (3) Unbadged staff are allowed to participate in restraint (4) Ground restraint remains in the PI policy as an appropriate method to contain an incident even though this is not taught in SIA accredited courses. (5) At no point during the prone restraint was Mr Reynolds placed in the recovery position. Neither did any member of staff appear to seriously consider the potential for positional asphyxia by closely or effectively monitoring Mr Reynolds breathing. (6) There appeared to be no clarity in the Policy about who should take charge of an incident or what the responsibilities are for security staff and Managers. (7) There appeared to be a lack accurate information and clarity around what information should be shared with the police about the incident. (8) There was no documented evidence of the induction or any other training for staff. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Investigate engaging external providers to deliver annual refresher training for all security-badged staff.

Verbatim wording from the response

“The Company’s policy regarding SIA badged training at the time of the incident was that those being recruited were required to produce their current SIA licence confirming that they had complied with the requirements of the SIA. We take on board your observations regarding external service providers and we are looking into the prospect of engaging external training providers to deliver annual refresher training to all security badged staff.”

Source location

2021-0151-Response-from-Britannia-Jinky-Jersey-Ltd
Page 1 · response
Published 18 May 2021

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Re-emphasise in the Physical Intervention Policy that non-badged staff must not participate in restraint.

Verbatim wording from the response

“I would like to make it clear that it is not the case that non badged staff are allowed to participate in restraint. As part of our revisions to the Physical Intervention Policy we will however re-emphasise this instruction.”

Source location

2021-0151-Response-from-Britannia-Jinky-Jersey-Ltd
Page 1 · response
Published 18 May 2021

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Remove ground-restraint references from the Physical Intervention Policy.

Verbatim wording from the response

“The ground restraint references in the Physical Intervention Policy will be removed. As per the documentation which was provided to prior to and during the inquest the Company emphasise in their training that employees should avoid confrontations and to defuse situations. The incident involving Mr Gladwell was unprecedented as I believe you heard in evidence during the inquest.”

Source location

2021-0151-Response-from-Britannia-Jinky-Jersey-Ltd
Page 1 · response
Published 18 May 2021

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Adopt assessed, scenario-based training replicating the incident to test medical responsibilities, use of force, and scene management.

Verbatim wording from the response

“It will reinforce this learning through practical based assessed scenarios, as part of the nationally revised curriculum design (see paragraph 3), that will specifically test officer’s ability to assess a person being detained and determine whether the circumstances warrant a medical intervention or the reinforcement of restraint.”

Source location

2021-0151-Response-from-Suffolk-Constabulary-Redacted
Page 1 · response
Published 18 May 2021

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Implement the redesigned personal safety training programme when adopted.

Verbatim wording from the response

“The College of Policing is leading the redesign of the personal safety training programme and we will support the College through this period and implement the new programme upon its adoption. We understand that this new programme will come into fruition during 2022 and will be more scenario orientated. From our understanding of the programme design there will be opportunity for us to re-enact scenarios of concern and, as identified in paragraph 1, we will adopt scenario-based assessments that recreates the events of this incident. This will allow Trainers to assess officer understanding of their medical responsibilities and use of force powers.”

Source location

2021-0151-Response-from-Suffolk-Constabulary-Redacted
Page 2 · response
Published 18 May 2021

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Embed acute behaviour disorder and positional asphyxia learning in Personal Safety Training through supplementary videos and Learning Management System guidance.

Verbatim wording from the response

“However, we recognise that nationally there have been changes to the programme that may have created a perception of a reduction in the time assigned to positional asphyxia. The time allocated to individual areas of the curriculum are subject to change and nationally the focus of positional asphyxia has shifted towards the signals and signs of acute behaviour disorder. This is a precursor behaviour but is part of the same continuum. Material surrounding both acute behaviour disorder and positional asphyxia is delivered in accordance with national guidance and time allocations, but the Constabulary will do more to embed this learning within the wider aspects of its Personal Safety Training through supplementary videos and guidance on its Learning Management System.”

Source location

2021-0151-Response-from-Suffolk-Constabulary-Redacted
Page 1 · response
Published 18 May 2021

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Invest in a skills management system linking officers’ training records to the training received.

Verbatim wording from the response

“In response to this learning, we have invested in a new skills management system that will make it easier for our learning and development department to track and identify officer training records as well as link these records to the training the officer received.”

Source location

2021-0151-Response-from-Suffolk-Constabulary-Redacted
Page 2 · response
Published 18 May 2021

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Review learning and development practices and procedures to identify records-management weaknesses and refresher-training lapses.

Verbatim wording from the response

“As reflected within our evidence, the Learning and Development department did undertake a comprehensive review of its practices and procedures following this incident. We acknowledge our responsibilities as a professional organisation to learn lessons and our review identified weaknesses within our records management. This resulted in the lapses surrounding the frequency of refresher training for some of the officers involved, as shared during the inquest.”

Source location

2021-0151-Response-from-Suffolk-Constabulary-Redacted
Page 2 · response
Published 18 May 2021

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Enhance training and guidance on initial assessment, proportionate health checks, and use of force.

Verbatim wording from the response

“The Constabulary’s involvement with Mr Reynolds stemmed from a reported incident of assault by Pontins Security Officers. Upon finding Mr Reynolds being restrained, the Constabulary training would have directed officers to assess the person being detained and review the evidence being presented. It was clear from the Inquest that the officers involved did not fulfil this assessment robustly and we acknowledge that their evidence identified confusion surrounding their police powers. The Constabulary has enhanced its training delivery and supporting guidance to clarify the importance of the initial assessment and the differences between proportionate and necessary checks of health and the application of force.”

Source location

2021-0151-Response-from-Suffolk-Constabulary-Redacted
Page 1 · response
Published 18 May 2021

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Non-badged staff were not permitted to participate in restraint.

Verbatim wording from the response

“I would like to make it clear that it is not the case that non badged staff are allowed to participate in restraint. As part of our revisions to the Physical Intervention Policy we will however re-emphasise this instruction.”

Source location

2021-0151-Response-from-Britannia-Jinky-Jersey-Ltd
Page 1 · response
Published 18 May 2021

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

All staff already receive inductions.

Verbatim wording from the response

“Regarding staff inductions, all staff receive inductions and I understand that prior to or during in the course of the Inquest copies for each of the employees were provided to you via the Company’s Barrister.”

Source location

2021-0151-Response-from-Britannia-Jinky-Jersey-Ltd
Page 2 · response
Published 18 May 2021

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

The incident was unprecedented, and training already emphasised avoiding confrontations and defusing situations.

Verbatim wording from the response

“The ground restraint references in the Physical Intervention Policy will be removed. As per the documentation which was provided to prior to and during the inquest the Company emphasise in their training that employees should avoid confrontations and to defuse situations. The incident involving Mr Gladwell was unprecedented as I believe you heard in evidence during the inquest.”

Source location

2021-0151-Response-from-Britannia-Jinky-Jersey-Ltd
Page 1 · response
Published 18 May 2021

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Staff responded to all police questions and described the circumstances leading to the restraint and police attendance.

Verbatim wording from the response

“Your concern regarding the information given by staff to the police is unclear as I believe you heard in evidence that the employees in question responded to all questions asked of the Police and described the circumstances leading to his restraint and police attendance.”

Source location

2021-0151-Response-from-Britannia-Jinky-Jersey-Ltd
Page 1 · response
Published 18 May 2021

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

The College of Policing leads redesign of the personal safety training programme; the Constabulary will support it and implement the adopted programme.

Verbatim wording from the response

“The College of Policing is leading the redesign of the personal safety training programme and we will support the College through this period and implement the new programme upon its adoption. We understand that this new programme will come into fruition during 2022 and will be more scenario orientated. From our understanding of the programme design there will be opportunity for us to re-enact scenarios of concern and, as identified in paragraph 1, we will adopt scenario-based assessments that recreates the events of this incident. This will allow Trainers to assess officer understanding of their medical responsibilities and use of force powers.”

Source location

2021-0151-Response-from-Suffolk-Constabulary-Redacted
Page 2 · response
Published 18 May 2021

Open published response

Other statements in published responses

These actions and other statements could not be clearly connected to one concern in this report.

Recipient-stated actions An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.1

  1. 1

    Support the College of Policing’s personal safety training redesign during implementation.

    Stated by Suffolk ConstabularyStated plannedThe respondent said that this action was planned when they made their response on 18 May 2021.

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Support the College of Policing’s personal safety training redesign during implementation.

Verbatim wording from the response

“The College of Policing is leading the redesign of the personal safety training programme and we will support the College through this period and implement the new programme upon its adoption. We understand that this new programme will come into fruition during 2022 and will be more scenario orientated. From our understanding of the programme design there will be opportunity for us to re-enact scenarios of concern and, as identified in paragraph 1, we will adopt scenario-based assessments that recreates the events of this incident. This will allow Trainers to assess officer understanding of their medical responsibilities and use of force powers.”

Source location

2021-0151-Response-from-Suffolk-Constabulary-Redacted
Page 2 · response
Published 18 May 2021

Open published response
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Information checked against the published report and official responses · Data reviewed 7 Sep 2026 · About data quality and limitations

Official responses located
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Data last updated 7 September 2026