image: ©narvo vexar | iStock

A single-venue operator gets to master one building. Show after show, they work with the touring crews in a very similar way: the same control room; the same safety, security, medical and fire teams; and so on. Martyn’s Law asks something harder of a local authority: to apply the same discipline across a greenfield site that might host a cheese and chutney festival one month and a headline act the next, put together by people who might be volunteers with no skills or history in events, or serious professionals who do it worldwide, and everyone and everything in between. Leeds City Council can go from Ed Sheeran to the Caribbean Carnival within a single season: different promoters, different budgets and different levels of experience, from seasoned professionals to community volunteers running an event for the first time. That’s before we get into all the boroughs that make up London.

This broad variation is the thing a single-venue operator rarely has to plan for. The types of activities are different, but all within the same controllable variables. That’s where a benchmark, a shared standard, and a bit of consistency earn their keep.

Local authority budgets have been cut hard enough, in enough places, that some councils have stopped many activities altogether. However, underneath Martyn’s Law sits an older legal duty: the Civil Contingencies Act 2004 requires local authorities, as Category 1 responders, to assess risk and maintain it in a community risk register through their local resilience forum. Add safety advisory group responsibilities on top, and it’s not hard to see how, in a council running thousands of events a year, emergency planning and events functions have started merging into one team by necessity, not design. Likewise, for council traffic, health and safety, or planning teams, what was traditionally a part-time ‘add-on’ to attend SAGs or look at events has increasingly become a full-time activity as events thrive and grow. Whichever way you look at it, fewer humans doing more will always create stress in the system and risk somewhere in the process.

These departmental mergers are a reasonable response to an unreasonable squeeze. But without a process and a system to support it, the people doing these double jobs will burn out, miss things, and make mistakes a properly resourced team wouldn’t. The gap doesn’t announce itself; it shows up later in an audit (or worse).

It’s already shown up once. At Detonate Festival 2016 in Nottinghamshire, a crush outside a tent came close to killing people and was only prevented by police officers on the night and the work Nottingham City Council did afterwards. That was some years ago, but funding for every agency involved has only tightened since. What was recoverable then, with good people making the right calls under pressure, gets harder to recover from every year funding keeps shrinking. This isn’t an isolated example either; it’s just the one example listed here.

Luton Borough Council has run Halo since 2018 and has extended its contract to 2028. They’ve been thinking in these terms — shared visibility, consistent standards, and a system that holds up under scrutiny — for as long as any local authority we work with. The council’s Luton International Carnival, Britain’s largest one-day event of its kind, celebrating its golden 50th anniversary this year, has run with real-time coordination across dozens of teams and agencies, protecting over 150,000 people across sixteen or more partner agencies since May 2018, when it became the first-ever paying client for the Halo System.

“We bought Halo after seeing it in action at the Ashes Test match at Edgbaston the previous summer. We were really impressed with Halo’s features, especially how it logs all aspects of an event or incident, ready for post-event reporting. We also like the fact that we can restrict what different users can see so that the overall picture can be maintained by the control room, and individual users are not bombarded with constant information.” — Pritesh Mistry, Civil Protection & Business Community Manager, Luton Borough Council.

Before the Halo System, finding a missing person in a crowd that size – one of the most urgent jobs on any carnival day, and one of the most dangerous if dealt with slowly – meant relying on radio relays and inconsistent logging between whichever teams happened to be nearby. Halo replaced that with a shared picture across every agency: instant incident reporting, with photos and descriptions shared securely across security, stewards, welfare, and police the moment someone was reported missing.

With Halo, the three people who went missing during 2019’s event were located and safely reunited within minutes rather than hours. They were among 21 emergencies the Carnival’s teams managed through Halo that year, with every one of those sixteen-plus agencies working from the same information, rather than dropping some detail entirely in the handoff.

The Halo System has also been part of the council’s daily operations outside of their events: in 2020, Luton and Bedford’s COVID marshals used Halo to log and escalate their day-to-day enforcement work – social distancing, face coverings, track and trace — coordinating in real time rather than through phone calls and paper records. It was exactly this kind of local, on-the-ground effort that the Prime Minister singled out that October, telling the House of Commons that Luton’s success in exiting local COVID restrictions was “the way forward for the entire country.”

Both Luton Borough Council and Bedford Borough Council, alongside several other local authorities and government agencies, continue to rely on the Halo System to coordinate multi-agency operations as they happen and to build a record that can stand up to the highest burden of proof, which is precisely the standard UK law is about to hold every one of them to.

Martyn’s Law already asks for a reliable audit trail. One of its clearest requirements is that actions, communications and decisions are recorded consistently and contemporaneously, not reconstructed from memory once the questions start. Done properly, a well-implemented system gives a single source of truth: time-stamped records that hold up under scrutiny and haven’t been edited. Done badly, the technology reflects the same confusion it was meant to fix: if reporting is inconsistent, the data will be incomplete; if teams aren’t properly engaged, the system gets bypassed; if anyone has missed anything or done anything wrong, they can just add it in later.

Hillsborough Law raises that bar again and asks the public sector for something more specific than Martyn’s Law does. Officially the Public Office (Accountability) Bill, it has passed through the House of Commons and is progressing through the House of Lords, with a duty of candour for public officials at its centre. It won’t apply to a private venue operator the way it will to a local authority — much like the Human Rights Act.

There’s a saying in policing and emergency services: start with the inquiry, then work backwards. Once you ask whether a record can be trusted, the question has already tainted it. Martyn’s Law sets the baseline for what a good audit trail looks like; Hillsborough Law raises what’s specifically expected of a public authority on top of it. Trust. Councils are about to face a higher threshold for decision-making and record-keeping than the legacy systems and email chains that used to be good enough — and that threshold is coming whether or not the systems keep pace.

To a council safety lead who says there’s no budget or people to do more than the legal minimum: the minimum just moved. No public sector organisation can afford to stop at it any more — Health and Safety law, Corporate Manslaughter law, the Terrorism (Protection of Premises) Act and the incoming duty of candour now add up to something far bigger than any one of them alone, especially once insurers, auditors, enforcers and the public start asking the same questions.

The starting point doesn’t have to be complicated. When data protection law tightened, organisations ran Data Protection Impact Assessments rather than overhauling everything at once. The equivalent here is a single, external review: walk one incident, or a short series of them, through in full — the decisions, the policies followed, who was accountable — as one table-top exercise. It tells a council exactly where its exposure sits, before an inquiry does it for them.

Public safety will never be strengthened by paperwork alone. It’s strengthened by people, culture, coordination, and the discipline to keep improving before an incident forces the issue and costs more than prevention ever would have.