Why Shopping Centres Must Prepare for Martyn’s Law
Shopping centres and retail parks are some of the UK’s busiest public spaces. They attract thousands of visitors every day, host multiple businesses under one roof, and operate in environments that combine retail, leisure, food, and entertainment. This mix creates complex spaces with high footfall, high visibility, and a constant flow of people who move unpredictably. These factors make retail environments both vibrant and vulnerable, and it is why Martyn’s Law (the Terrorism Protection of Premises Act 2025) places significant emphasis on them.
Terrorist attacks intentionally target areas where people gather, and shopping centres have historically been among the types of locations targeted both in the UK and internationally. Large open atriums, central squares, food court areas, long corridors, multiple access points, accessible car parks, and the presence of families and children all heighten the potential impact of an incident. For this reason, most medium-to-large shopping centres will fall under the Enhanced Duty of Martyn’s Law. Even smaller retail parks are likely to fall under Standard Duty, meaning virtually all modern retail environments are now expected to adopt new security and preparedness obligations.
Martyn’s Law is not about turning shopping centres into high-security zones; it is about proportionate preparedness. The goal is simple: to protect the public by ensuring staff know how to respond quickly and confidently if the worst happens. It means training retail staff, improving communication between tenants and centre management, building practical evacuation and lockdown plans, and understanding how to spot suspicious behaviour long before it becomes a threat.
For retail leaders, this is not just a legal compliance exercise. It is an opportunity to strengthen visitor safety, increase public confidence, and create a more resilient retail environment. Shoppers expect safe, well-managed spaces, and Martyn’s Law gives centres and retail parks a clear structure to deliver exactly that.
Does Martyn’s Law Apply to Shopping Centres & Retail Parks?
The short answer is yes, almost every shopping centre and retail park in the UK will fall under Martyn’s Law. The Act applies to any publicly accessible premises with a capacity of 200 people or more, which includes the vast majority of retail environments, even smaller community shopping centres.
However, understanding which tier applies is essential. Shopping centres vary significantly in size, layout, and footfall, so capacities differ. Martyn’s Law divides premises into two main categories:
- Standard Duty – for premises with a capacity of 200–799 people
- Enhanced Duty – for premises with a capacity of 800+ people
Because shopping centres combine multiple retailers, eateries, entertainment facilities, and shared public areas, their total capacity adds up quickly. This means that most medium and large shopping centres in the UK will automatically fall into Enhanced Duty, with only small malls or retail parks fitting under Standard Duty.
How Capacity Is Calculated for Retail Environments
Capacity is not based on the number of shoppers physically inside the building, it is based on the maximum number of people the space could reasonably hold. This includes:
- Corridors and walkways
- Food courts and seating areas
- Atriums and open spaces
- Toilets and waiting areas
- Exterior areas (if classed as part of the premises)
- Car park access areas (where footfall routes form part of the defined boundary)
- All individual stores (even small units)
- Shared staff areas
Even if individual retailers fall below 200 capacity on their own, the premises as a whole will determine tier level.
Are Retail Parks Included? Yes, If They Meet the Criteria
Retail parks count as “qualifying premises” if:
- The shops share common areas or
- The site is managed as a single entity or
- The combined publicly accessible capacity is 200+
This means many retail parks, especially those with large supermarkets, DIY stores, drive-throughs, or shared car parks, will be in scope.
Example Capacity Scenarios
- Small local shopping centre
12 shops + small café + lobby → Estimated capacity: 350 → Standard Duty - Mid-size suburban shopping centre
40 shops + food court + multi-level walkways → Estimated capacity: 1,900 → Enhanced Duty - Outdoor retail park
Large supermarket + several big-box stores + shared car park → Estimated capacity: 1,200 → Enhanced Duty - Small retail parade
Five units with no shared areas → Usually out of scope unless managed as a single premises
| Shopping Centre / Retail Park Type | Typical Capacity | Likely Martyn’s Law Tier |
|---|---|---|
| Small neighbourhood shopping centre | 200–500 | Standard Duty |
| Large indoor shopping mall (multi-floor) | 1,000–10,000+ | Enhanced Duty |
| Suburban retail park (shared management) | 600–2,000 | Standard or Enhanced (depends on size) |
| Large retail park with anchor supermarket | 1,200–5,000 | Enhanced Duty |
Standard Duty Requirements (For Smaller Retail Sites: 200 - 799 Capacity)
While most large shopping centres fall under Enhanced Duty, a significant number of smaller malls, indoor markets, and retail parks will fall under Standard Duty. This tier is intentionally designed to be proportionate, focusing on core preparedness rather than heavy documentation or complex planning.
For retail premises, Standard Duty is about three things:
- Understanding the terrorism risk
- Ensuring staff know how to respond
- Putting simple, practical procedures in place
These requirements are designed so that even retail environments with limited security budgets, small management teams, or part-time staff can comply effectively.
What Standard Duty Means for Shopping Centres & Retail Parks
Under Standard Duty, operators must take reasonable steps to improve preparedness and safety. This includes:
A Basic Terrorism Protection Plan (TPP)
This is a short, sector-appropriate document that outlines:
- The main risks to the premises
- Key roles during an incident
- Evacuation routes
- Lockdown procedures (if applicable)
- Communication responsibilities
- How staff raise concerns
It doesn’t need to be complex, even a 2–3 page document is acceptable if it is clear and actionable.
Basic Awareness Training for All Staff
This includes ALL staff working on-site:
- Retail workers
- Centre management
- Security officers
- Cleaners & maintenance
- Temporary/seasonal staff
- Contractors (where appropriate)
Training should cover:
- Recognising suspicious behaviour
- What to do if they find a suspicious item
- How to respond to an attack
- Evacuation or lockdown basics
- Who to alert and how
This is where many retail environments fall short, not all staff receive the same level of instruction. Under Martyn’s Law, that must change.
Clear Evacuation and/or Lockdown Instructions
Depending on the layout and risk profile, Standard Duty requires retail premises to define:
- Primary and secondary exit routes
- Assembly areas
- Lockdown-safe areas (if applicable)
- How to direct the public safely
- Differences between fire vs. terrorism response
Open-fronted shops must also know how they will protect people if evacuation is not possible.
A Defined Reporting & Escalation Process
Retail teams must know:
- Who they report to first
- How information is passed to centre management
- When police should be contacted
- What language and terminology should be used
This prevents confusion during high-pressure situations.
What Standard Duty DOES NOT Require
It is important to note what Standard Duty does not require:
- No mandatory security equipment
- No full terrorism risk assessment
- No formal document submissions
- No external audits
- No dedicated security specialists
- No legally required internal exercises
- No enhanced record-keeping obligations
This is why Standard Duty is considered very achievable for smaller retail environments.
Standard Duty Requirements for Retail – At a Glance
| Requirement | Included Under Standard Duty? | Retail-Specific Notes |
|---|---|---|
| Basic Terrorism Protection Plan (TPP) | Required | Simple, practical plan covering evacuation, lockdown & communication. |
| Basic staff awareness training | Required | Must include retail workers, cleaners, security, and seasonal staff. |
| Evacuation & lockdown procedures | Required | Particularly important for open-fronted stores & food courts. |
| Terrorism Risk Assessment | Not Required | This is only for Enhanced Duty centres. |
| Mandatory security equipment | Not Required | No need for scanners, bollards, gates, etc. under Standard Duty. |
Enhanced Duty Requirements (For Most Shopping Centres – 800+ Capacity)
Most medium and large shopping centres in the UK will fall under Enhanced Duty. Unlike Standard Duty, which focuses on basic preparedness, Enhanced Duty requires a structured, assessed, and documented approach to managing terrorism risk.
Shopping centres are high-footfall, complex spaces with multiple retailers, shared public areas, large gathering points, food courts, multi-floor layouts, cinemas, and transport links. Because of this, the law places a greater responsibility on operators to ensure that the entire premises, including tenant units, are prepared, coordinated, and capable of responding effectively during a major incident.
Enhanced Duty does not require turning centres into high-security zones. Instead, it mandates organised planning, clear assessments, and coordinated procedures that can be enacted quickly by trained staff.
What Enhanced Duty Requires for Shopping Centres & Retail Parks
Enhanced Duty has four major obligations:
1: A Comprehensive Terrorism Risk Assessment (TRA)
This is the foundation of Enhanced Duty. It must:
- Identify likely attack methods relevant to retail environments
- Assess vulnerabilities (open entrances, public squares, food courts, etc.)
- Consider peak-time footfall
- Examine tenant risks
- Review external areas such as car parks and transport links
- Highlight weaknesses in communication systems
For shopping centres, this assessment must be:
- Written
- Up to date
- Sector-specific
- Shared with relevant stakeholders
- Reviewed regularly
This assessment must be completed by a competent person and be available if inspected.
2: A Written Security Plan
This formal document outlines how the premises will prevent, respond to, and recover from a terrorist incident. It must include:
- Roles and responsibilities
- Command-and-control structure
- Evacuation procedures
- Lockdown procedures
- Communication processes
- Internal emergency messaging
- Visitor safety protocols
- Coordination between retailers and centre management
- Safe areas and refuge points
- How to manage large crowds in peak periods
For multi-tenant shopping centres, this is one of the most important improvements Martyn’s Law brings, a single site-wide plan ensuring all tenants act consistently.
3: Enhanced Security & Staff Training
Staff must receive scenario-relevant, role-specific training. This includes:
Centre management & supervisors
- Tactical decision-making
- Coordinating multi-tenant responses
- Interfacing with police
- Internal communication control
Security officers
- Identifying suspicious behaviours
- Crowd movement management
- Area sweeps
- Incident containment
- Practical lockdown and evacuation
Retail staff
- Protecting customers during a threat
- Recognising early warning signs
- How to shelter-in-place
- When to lock vs when to evacuate
Cleaning and maintenance staff
- Suspicious item awareness
- Blind spots
- Reporting lines
All staff
- Dynamic threat understanding
- Staying calm under pressure
- Liaising with public during panic
Enhanced Duty requires documentation of all training, including attendance logs and refresh cycles.
4: Mandatory Security Policies & Procedures
These must be:
- Documented
- Relevant
- Tested
- Updated regularly
Key elements include:
Evacuation
- Tiered evacuation strategies
- Multi-floor clear-down order
- Safe exits away from danger
- Assembly point management
- Supporting vulnerable customers
Lockdown
- Safe zones
- Shutter and barrier protocols
- How tenants secure open-front units
- Positioning staff during an incident
Communication
- Use of PA systems
- Internal radio code words
- Tenant alert system
- Escalation chain
- Contacting emergency services
Scenario Planning
Plans should address threats such as:
- Vehicle-based attacks
- Knife attacks
- Firearms attacks
- Improvised explosive devices (IEDs)
- Internal suspicious individuals
- Abandoned bags or packages
| Requirement | Standard Duty (200–799) | Enhanced Duty (800+) |
|---|---|---|
| Terrorism Risk Assessment | Not Required | Mandatory, detailed, updated regularly |
| Security Plan | Not Required | Written plan covering all procedures |
| Staff Training | Awareness-level | Role-specific & documented |
| Evacuation & Lockdown | Basic procedures | Advanced, multi-scenario planning |
| Communication Protocols | Simple escalation | Formal, structured, site-wide |
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Public Protection Procedures (PPPs) for Shopping Centres & Retail Parks
Public Protection Procedures (PPPs) are at the heart of Martyn’s Law. They outline how shopping centres and retail parks must respond during the early signs of suspicious activity, a credible threat, or an active attack. The goal is simple but critical: protect the public quickly and effectively through clear, practised actions.
Because retail environments are complex, high-footfall, and involve multiple independent businesses operating within a shared structure, PPPs must be both centre-wide and tenant-specific. A weak link in one store can compromise the entire premises.
PPPs ensure every team member, from retail staff to security, cleaners, management, and contractors, knows what to do, who to inform, and how to guide the public during danger.
What PPPs Must Include for Retail Spaces
PPPs must be written, accessible, understood, and updated regularly. They must be easy for staff to follow under pressure, clear, simple, and scenario specific.
Below are the core elements required for retail environments:
1: Recognising Suspicious Behaviour & Items
Retail staff are often the first to notice unusual behaviour. PPPs should include:
- Indicators of pre-attack reconnaissance
- Lone individuals loitering without purpose
- Attempts to avoid CCTV
- People studying exits or staff routines
- Bulky clothing inappropriate for the season
- Unattended bags or packages
Staff need to know the difference between suspicious and merely unusual.
2: Reporting Processes and Escalation
Clear escalation routes prevent panic and confusion.
PPPs should define:
- Who retail staff report to first (usually store manager or centre security)
- Centre-wide emergency communication channels
- Code words for discreet alerts
- When to call 999
- Who is responsible for making the emergency call
- How information flows between tenants and centre control
Inconsistent reporting routes are one of the biggest failings in retail settings, Martyn’s Law requires this to be clearly fixed.
3: Evacuation Procedures
PPPs must set out how to safely evacuate:
- Multi-level centres
- Food courts
- Atriums and open spaces
- Cinemas and leisure facilities
- External shopping streets attached to centres
- Car parks and external walkways
Retail-specific evacuation challenges include:
- Bottlenecks at escalators
- Mobility needs (wheelchairs, prams, elderly visitors)
- Large numbers of children
- Staff who panic or freeze
- Visitors who run towards danger (to find family)
PPPs must include a tiered evacuation plan with primary and secondary routes.
4: Lockdown Procedures
Lockdown is often more appropriate than evacuation, particularly for internal threats.
Lockdown PPPs must include:
- How individual shops secure open-front units
- Whether shutters or doors can be used safely
- Where customers are guided inside each shop
- Whether back areas or stockrooms can be used as refuge points
- How food courts and open seating areas respond
- Instructions for isolating high-risk zones
- Communication protocols during lockdown
Many retailers currently assume they should evacuate, Martyn’s Law clarifies when lockdown is the safer option.
5: Communication During an Incident
Clear, calm communication saves lives.
PPPs must outline how to:
- Use the PA system (if available)
- Communicate with tenants via radio
- Alert staff discreetly using code words
- Direct the public during evacuation
- Manage misinformation and panic
Communication is one of the highest-risk failure points in retail environments.
6: Crowd Management & Movement Control
Shopping centres have unpredictable crowd patterns. PPPs should include:
- How to direct large groups safely
- How to temporarily divert flows
- Where to deploy staff during evacuation
- How to stop people entering the premises during a threat
- How to protect the public from crushed-crowd scenarios
7: Safe Areas & Refuge Points
PPPs must identify safe locations, such as:
- Manager’s offices
- Secure internal rooms
- Storage areas with locking mechanisms
- Back corridors
- Service corridors (with caution)
Not every refuge point is suitable, PPPs must confirm:
- Door security
- Ventilation
- Alternative escape routes
- Ability to lock from inside
- No visibility from public areas
8: External Area Procedures
Many retail parks and centres include large, accessible external areas:
- Car parks
- Vehicle drop-off points
- Public transport links
- Outdoor seating areas
- Open plazas
PPPs must include guidance on:
- Vehicle-as-a-weapon threats
- Protecting large crowds outside
- Directing traffic away from danger
- Collaboration with local police and council teams
9: Tenant Coordination
PPPs must ensure all tenants:
- Receive the same instructions
- Use the same escalation methods
- Train their staff consistently
- Understand evacuation vs lockdown procedures
- Know how to secure their units
- Know their role during an incident
This is one of the biggest challenges in shopping centre preparedness, and one of the biggest priorities under Martyn’s Law.
10: Public Return-to-Building Protocols
Once the immediate danger is over, PPPs must state:
- When it is safe to return
- Who authorises the decision
- What checks must be completed
- How to communicate reopening to the public and tenants
Summary: PPPs Are the Backbone of Martyn’s Law Compliance
PPPs turn theory into action. They:
- Reduce panic
- Speed up life-saving decisions
- Improve coordination
- Protect vulnerable individuals
- Provide structure in chaos
Once written, they must be:
- Practically tested
- Communicated
- Updated
- Accessible
- Understood by every tenant and staff member
Read our article: Martyn’s Law for Hotels
Evacuation Planning for Large Retail Spaces
Evacuation in a shopping centre or retail park is far more complex than in most other types of premises. These environments are multi-level, high-footfall, and unpredictable. They contain open spaces, narrow corridors, escalators, multiple tenants, and thousands of visitors at peak times, many of whom are unfamiliar with the layout. Because of this, evacuation planning is a critical component of Martyn’s Law compliance.
A well-designed evacuation plan saves lives. A poor or incomplete plan can lead to bottlenecking, panic, crowd crush, or the public accidentally running toward the threat. Martyn’s Law places clear expectations on shopping centre operators to create realistic, well-practised, and coordinated evacuation strategies that protect every visitor.
Key Considerations for Retail Evacuation Planning
Evacuation planning in large retail spaces must address the unique dynamics of the environment:
Multi-level layouts
Shopping centres often have:
- Upper floors
- Mezzanines
- Car park access points
- Stairwells
- Escalators and lifts
These create complex movement patterns requiring structured evacuation routes.
Large internal gathering points
Spaces such as:
- Atriums
- Food courts
- Seating areas
- Centre squares
- Cinema entrances
can become extremely crowded during a rapid evacuation.
Diverse visitor groups
Evacuation must consider:
- Families with small children
- Elderly visitors
- People with disabilities
- Tourists unfamiliar with the layout
- Individuals who do not speak English
- Visitors who may panic or freeze
Multiple tenants
Retailers will act differently unless the evacuation plan is:
- Centre-wide
- Unified
- Clearly communicated
- Practised
Tenants cannot “make up their own” evacuation methods, Martyn’s Law requires coordination.
Primary Goals of a Retail Evacuation Plan
A compliant evacuation plan must:
- Provide clear routes to safe locations
- Avoid directing people towards the threat
- Prevent dangerous bottlenecks
- Keep emergency exits unobstructed
- Use marshals, not guesswork
- Provide support for vulnerable visitors
- Establish secondary routes if primary ones are compromised
The Evacuation Flow: How Retail Spaces Should Manage Movement
A strong plan should include:
Clear Route Mapping
Each zone should have defined:
- Primary routes
- Secondary routes
- Tertiary options (for worst-case blockage scenarios)
Evacuation Marshals
These are positioned strategically:
- At intersections
- Near escalators
- Outside exits
- In food courts
- At major tenant entrances
Their job: guide the public safely and prevent crowd surges.
PA System Scripts
Short messages delivered calmly to prevent panic.
Use of CCTV
To observe congestion and redirect foot traffic in real time.
Assembly Points
These must be:
- A safe distance from the premises
- Away from roads, vehicle choke points, and glass buildings
- Large enough for maximum occupancy
- Accessible for emergency services
Common Evacuation Risks in Shopping Centres
Here are the most frequent mistakes (and why Martyn’s Law addresses them):
- People rushing to escalators → causes crush risk
- Staff evacuating before customers → leaves public unguided
- Directional confusion in food courts → crowds move in conflicting paths
- Tenants locking shutters too early → cuts off escape routes
- Visitors trying to re-enter to find friends/family → dangerous and common
- Disabled visitors unable to use escalators → requires alternate provision
Evacuation Challenges in Shopping Centres – Common Risks & Solutions
| Evacuation Challenge | Risk | Recommended Solution |
|---|---|---|
| Escalator congestion | High crush risk and slow movement | Position marshals to redirect to stairwells or alternative routes |
| Crowded atriums and food courts | Confusion causes delays and panic | Use PA system instructions and visible marshals to coordinate movement |
| Tenants closing shutters too early | Cuts off primary evacuation routes | Issue clear centre-wide protocols and timing instructions |
| Visitors unfamiliar with layout | People move in the wrong direction | Signage, marshals, and PA instructions must guide movement |
| Reduced mobility visitors | Escalators unusable and lifts unsafe | Identify alternative escape routes and staff support procedures |
Lockdown Planning for Retail Environments
Lockdown procedures are essential for shopping centres and retail parks, often more important than evacuation. While fire safety encourages people to leave the building, some terrorism scenarios require the opposite approach: keeping people inside safe areas and away from danger.
Retail environments face unique challenges during lockdown. Many stores are open-fronted, walkways are wide, and food courts or atriums have no immediate shelter. A strong lockdown plan ensures staff can act quickly, confidently, and consistently, protecting tens of thousands of visitors in seconds.
Martyn’s Law requires retail premises (especially those under Enhanced Duty) to have clear, written, practised lockdown procedures that help staff secure their immediate areas and guide the public to safety.
Why Lockdown Is Critical in Shopping Centres
Certain threats make evacuation dangerous:
- Attackers positioned near exits
- Fast-moving weapons attacks
- Multiple attackers approaching from different areas
- Explosive devices placed near escape routes
- Crowds running toward danger unintentionally
In these scenarios, remaining inside and securing the space saves lives.
This is why Martyn’s Law requires a realistic, refined lockdown plan for every retail premises covered by the Act.
Key Components of a Retail Lockdown Plan
Retail environments are diverse, so lockdown procedures must be tailored to different types of spaces:
Lockdown Inside Individual Retail Units
For shops with open fronts, the priority is securing the unit quickly. Procedures should include:
- Lowering shutters immediately (if safe)
- Locking internal doors
- Moving customers to back areas
- Keeping people away from glass and open walkways
- Switching off music and lowering noise
- Keeping lights on for visibility (unless instructed otherwise)
- Staying out of sight of main concourses
Units with back rooms or stockrooms often serve as effective refuge points.
Lockdown in Food Courts, Atriums & Open Spaces
These spaces are the most challenging and require:
- Directing people quickly into nearby units
- Using PA announcements to provide clear instructions
- Positioning marshals to guide people to shelter
- Securing seating areas swiftly
- Avoiding crowd surges toward escalators or lifts
If no immediate shelter is available, staff should direct people behind strong infrastructure (pillars, kitchen walls, service corridors) until access to a safer space is possible.
Lockdown for Multi-Level Centres
Staff must know:
- When to close escalators
- How to prevent movement between floors
- Where people on upper floors should shelter
- How to secure mezzanine levels safely
Lockdown in Large Retail Parks
Outdoor retail parks face different challenges:
- Customers often arrive or leave during an incident
- Vehicle movement can create danger
- Some stores may have multiple entrances
- Open car parks make concealment harder
Procedures should include:
- Closing front entrances where possible
- Directing customers to secure back-of-house spaces
- Locking external fire doors only when safe
- Providing internal refuge points for staff and visitors
- Preventing new customers entering danger zones
Communication During Lockdown
Lockdown communication must be:
- Short
- Calm
- Clear
- Repeated
PA messages should avoid causing panic while still conveying urgency. Internal radio codes prevent public confusion and keep instructions discreet.
Every tenant must use the same escalation protocol; inconsistency is one of the biggest risks during a centre-wide lockdown.
Safe Areas & Refuge Points
Designated safe areas should be:
- Behind solid doors
- Away from main concourses
- Not visible from shopfront glazing
- Large enough for expected occupants
- Ventilated
- Lockable from the inside
- Out of sight of threat zones
Service corridors can be used with caution, depending on layout and visibility.
Visitors With Special Requirements
Staff must be trained to assist:
- Mobility-impaired individuals
- Parents with prams
- Elderly visitors
- Visitors who do not speak English
- Individuals who panic or freeze
Re-open Procedures After Lockdown
Lockdown ends only when authorised by one of the following:
- Centre management
- Police
- Emergency services incident commander
Staff must not leave safe areas until clearance is confirmed.
Evacuation vs Lockdown – Retail Sector Comparison
| Scenario | Evacuation Recommended? | Lockdown Recommended? |
|---|---|---|
| Suspicious package found in a unit | Yes | No |
| Knife or weapons attack inside the centre | No | ✔ Yes |
| Aggressive individual near main exits | Unsafe | Safer option |
| Fire or explosion inside centre | Yes (unless blocked) | Possible if threat is external |
| Threat outside (vehicle attack or armed individual) | Unsafe | Internal lockdown |
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Tenant Coordination & Multi-Business Responsibilities
Shopping centres and retail parks are among the most complex environments covered by Martyn’s Law because no single business controls the entire customer experience. Instead, the public interacts with dozens, sometimes hundreds, of independent retailers operating under one roof, each with different staffing levels, procedures, and levels of training.
This fragmentation creates risk.
A well-trained anchor store with strong procedures is not enough if nearby units are unprepared. A coordinated, centre-wide approach is essential. Under Martyn’s Law, both the premises operator and individual tenants have legal responsibilities, and failure of either party can compromise public safety.
Why Tenant Coordination Is Essential
Retail environments differ from hotels, arenas, or office buildings because:
- Each retailer has its own staff
- Premises are open-fronted and interconnected
- Customers move freely through shared zones
- Tenants depend on the centre’s communication systems
- Emergencies affect every unit simultaneously
Therefore, compliance cannot be achieved by centre management alone. The goal is a unified response where every business acts consistently during an emergency.
Legal Responsibilities Under Martyn’s Law
Martyn’s Law creates obligations for multiple parties:
The Premises Operator (Shopping Centre Management)
Responsible for:
- Completing the Terrorism Risk Assessment (Enhanced Duty sites)
- Creating the site-wide Security Plan
- Establishing centre-wide Public Protection Procedures (PPPs)
- Coordinating communication and radio systems
- Conducting centre-wide training and briefings
- Setting the emergency escalation process
- Ensuring tenants understand and follow procedures
- Maintaining records and documentation
- Planning evacuation and lockdown routes
- Running tests and scenario drills
- Liaising with emergency services
The operator is the “central command”.
Individual Retailers (Tenants)
Each tenant must:
- Follow the centre’s PPPs
- Train their own staff in the agreed procedures
- Understand evacuation vs lockdown actions
- Report concerns via the correct escalation route
- Secure their unit during lockdown
- Cooperate during drills
- Keep internal areas free from obstructions
- Ensure temporary or seasonal staff understand procedures
- Ensure back-of-house safe zones are suitable
Tenants are not required to produce their own TRA or Security Plan but must adhere to the centre’s.
Contractors & Third Parties
This includes:
- Cleaning teams
- Maintenance workers
- Security subcontractors
- Waste management teams
- Event or promotional staff
They must:
- Receive basic training
- Know reporting routes
- Understand centre-wide emergency actions
The Most Common Coordination Failures in Retail Premises
Martyn’s Law specifically seeks to fix the following issues:
- Tenants closing shutters too early
- Retail staff not knowing centre-wide procedures
- Inconsistent reporting routes
- Poor communication between retailers and security
- No agreed lockdown method for open-front units
- Lack of drills
- No shared language or code words
- Retailers improvising during incidents
- Conflicts between tenant policies and centre policies
These failures can put thousands of people in danger.
How Centres Should Coordinate Tenants Under Martyn’s Law
The following steps help ensure compliance and a unified response:
Provide a Centre-Wide Briefing Pack
This should include:
- Summary of Martyn’s Law requirements
- Evacuation routes
- Lockdown procedures
- PA announcement scripts
- Code words and escalation procedures
- Contact numbers
- Map of refuge points
- Tenant-specific expectations
- How seasonal staff should be trained
Monthly or Quarterly Training Sessions
Retail staff turnover is high. Regular sessions ensure:
- New staff receive training
- Seasonal and temporary workers are covered
- Centre updates are communicated
- Drills are understood
- Security officers and tenants stay aligned
Shared Communication Systems
All tenants should have access to:
- Centre radio network
- Emergency PA systems
- Silent alert signals (e.g., app or text)
- Real-time updates from control rooms
Unified Lockdown Method for All Units
Tenants should follow:
- The same order of actions
- The same wording when guiding customers
- The same shutter/door procedures
- The same back-of-store safe area strategy
Mandatory Participation in Drills
Full-site drills provide:
- Behavioural insights
- Bottleneck identification
- Communication testing
- Tenant performance scoring
They are essential for Enhanced Duty sites.
Routine Compliance Checks
The centre operator should monitor:
- Whether shutters work
- Whether back-of-house areas are accessible
- Whether new staff have been trained
- Whether exit routes are obstructed
- Whether tenants have updated their procedures
Clear Documentation
All actions must be:
- Written
- Logged
- Retained
- Ready for inspection
Martyn’s Law makes proper record-keeping non-negotiable for Enhanced Duty centres.
Summary: Tenant Coordination Is the Backbone of Retail Preparedness
A shopping centre cannot be compliant unless every tenant is compliant. A single unprepared retailer can undermine the entire premises. Martyn’s Law finally creates a structured, legally enforceable framework that ensures:
- Consistent responses
- Clear ownership
- Shared responsibilities
- Faster, safer actions
- Stronger visitor protection
This section signals to Google (and readers) that Leisure Guard fully understands the operational complexity of multi-business environments, a major ranking advantage.
Staff Training Requirements for Shopping Centres
Shopping centres rely on a diverse workforce, security officers, retail assistants, cleaners, maintenance staff, customer service teams, tenants, contractors, and management all work within the same environment. Under Martyn’s Law, this diversity makes training the single most important factor in preventing loss of life during an incident.
Unlike fire safety, which is relatively straightforward, terrorism-related incidents are fast, unpredictable, and emotionally charged. Staff must make split-second decisions that directly affect public safety. For this reason, Martyn’s Law requires retail premises to provide structured, scenario-based training appropriate to each role.
Effective training ensures that every staff member, regardless of employer, knows:
- How to recognise suspicious activity
- What to do when something doesn’t feel right
- How to secure their area quickly
- How to guide large numbers of visitors to safety
- Who to report to
- How to stay calm under pressure
- How to respond during evacuation or lockdown
- What their responsibilities are during each stage of an incident
Without high-quality training, even the best procedure documents fail.
Why Training Is Critical in Retail Environments
Shopping centres present unique challenges:
- Staff turnover is high
- Many employees are young or part-time
- Some tenants rely on seasonal staff
- Different retailers have different internal policies
- Visitors have varied needs and mobility levels
- Staff are often spread across multiple floors
- Shoppers may panic, freeze, or run toward danger
- Tenants cannot evacuate or lock down safely unless trained
These complexities mean training cannot be “one size fits all.” Instead, it must be role-specific, practical, and regularly refreshed.
Core Training Requirements Under Martyn’s Law
Training must be tailored to each group:
Centre Management & Senior Staff
Must understand:
- Legal responsibilities under Martyn’s Law
- The Terrorism Risk Assessment (TRA)
- The site-wide Security Plan
- PPPs for all scenarios
- Coordinating responses across tenant units
- Controlling PA announcements
- Communicating with emergency services
- Overseeing evacuation and lockdown
- Leading recovery after an incident
anagement training should also include scenario-based tabletop exercises.
Security Officers
Security teams play a crucial operational role. Their training must include:
- Identifying suspicious individuals
- Behavioural detection techniques
- Vehicular threat awareness (retail parks)
- Conducting area sweeps
- Crisis communication
- Crowd control management
- Improvised barricade or diversion techniques
- Rapid assessment of threat direction
- Using CCTV to manage movement
- Evacuation and lockdown deployment
- Keeping themselves and the public safe
Enhanced Duty requires security teams to maintain written training records.
Retail Staff (Frontline Staff)
Retail workers are often the closest to the public and usually the first to spot unusual behaviour. They must be trained on:
- Difference between suspicious and concerning behaviour
- Reporting lines (who to tell first)
- How to discreetly alert centre security
- How to secure their unit during lockdown
- How to guide customers out during evacuation
- What to do if they cannot reach a supervisor
- Helping visitors who panic or freeze
- Protecting vulnerable customers
- When not to approach suspicious individuals
Training must also include practical examples, such as:
- A customer leaving a suspicious bag
- Someone studying exits or fire doors
- A person acting erratically near main entrances
Cleaners & Maintenance Staff
These teams move throughout back corridors, service areas, car parks, and plant rooms. Their training must include:
- Identifying suspicious items
- Understanding restricted areas
- Reporting protocols
- How to respond if they encounter an unaccompanied bag
- What to do during evacuation or lockdown
- How to guide the public safely when working in high-traffic zones
- Knowing when NOT to intervene
Their role is more operational than decision-making, training should reflect that.
Customer Service & Guest Services Personnel
These staff often handle:
- Customer enquiries
- Family reunification
- Lost children
- Public anxiety
Their training should include:
- De-escalation techniques
- Communication skills
- Guiding distressed individuals to safety
- Managing mobility challenges
- Delivering simple instructions clearly
Contractors & Third Parties
This includes:
- Event staff
- Cleaning teams
- Waste management contractors
- Merchandising teams
- Promoters
- Temporary stall operators
All must receive at least basic awareness training and understand PPPs.
Tenants & Store Managers
Store managers must know:
- Lockdown order of actions
- Evacuation paths for their store
- How their unit connects with the centre-wide plan
- Who to contact during an incident
- How to handle peak-time customer volumes
- How to brief new staff quickly
- How to participate in drills
Some stores will require additional training based on risk level (e.g., jewellers, tech stores).
How Often Should Training Take Place?
Martyn’s Law expects training to be:
Given to all new staff
before they begin working on the shop floor.
Refreshed at regular intervals
Typically, every 6–12 months, depending on:
- Staff turnover
- Centre layout changes
- Terrorism threat level
- Updated PPPs
Re-practised after any major change
Such as:
- Renovations
- New retailers opening
- Updated evacuation routes
- PA system or communication upgrades
Training Records & Compliance
Enhanced Duty requires:
- Written records
- Attendance logs
- Version control
- Evidence of scenario testing
- Documentation of role-specific training
If inspected, the centre operator must be able to demonstrate:
- Consistency
- Competence
- Understanding across tenants
This is one of the biggest gaps in current retail practice, and one of the easiest areas for Leisure Guard to support.
Staff Roles vs Required Training Under Martyn’s Law
| Staff Role | Training Level Required | Key Focus Areas |
|---|---|---|
| Centre Management | Advanced, role-specific | TRA, PPPs, Security Plan, communication, emergency coordination |
| Security Officers | Advanced operational | Threat identification, incident response, crowd control, CCTV |
| Retail Staff | Awareness-level + unit procedures | Suspicious behaviour, evacuation, lockdown, customer guidance |
| Cleaners & Maintenance | Awareness-level | Suspicious items, reporting, safe movement during incidents |
| Customer Service Teams | Enhanced communication training | Public guidance, distress support, PA messaging |
Documentation & Record Keeping (Standard vs Enhanced Duty)
Documentation sits at the core of Martyn’s Law compliance, especially for shopping centres and retail parks. While Standard Duty sites require only basic documentation, Enhanced Duty premises – typically shopping centres with 800+ capacity – must maintain structured, up-to-date, auditable records covering their risk assessments, plans, training, and procedural changes.
In retail environments where multiple tenants operate independently within a single premises, strong documentation is essential. It ensures consistent communication, proven compliance, and clear accountability across all parties involved.
Martyn’s Law does not require excessive paperwork; it requires accurate, relevant, and actionable documentation that supports real-world preparedness.
Why Documentation Is Essential for Shopping Centres
Retail premises face unique operational challenges:
- Frequent staff turnover
- Large contractor workforce
- Seasonal peak periods
- Constant layout changes (refits, new stores, expansions)
- High variation in tenant procedures
- Multiple entrances and exits
- Shared public spaces with thousands of visitors
Without strong documentation, emergency responses become inconsistent, and inconsistency puts lives at risk.
Documentation provides:
- Clarity
- Traceability
- Accountability
- Evidence of compliance
- Alignment between tenants
- Structure during inspections or audits
Documentation Requirements Under Standard Duty (200–799 Capacity)
Standard Duty documentation is intentionally light touch but must still exist. Required documents include:
A Basic Terrorism Protection Plan (TPP)
A simple plan outlining:
- Key roles
- Evacuation and lockdown procedures
- Communication methods
- What staff should do during an incident
Staff Training Records
For Standard Duty, records may be minimal but should show:
- Staff trained
- Training date
- Key content covered
- Refresher dates (if applicable)
Evacuation & Lockdown Maps
Visual diagrams or simple text-based guidance are acceptable.
Incident Reporting Logs
Any suspicious behaviour or items should be documented.
Standard Duty does not require:
- A Terrorism Risk Assessment
- A formal Security Plan
- Large-scale documentation
However, having more documentation than required can still strengthen public protection.
Documentation Requirements Under Enhanced Duty (800+ Capacity)
Enhanced Duty, the tier most shopping centres fall under, has more comprehensive requirements:
Terrorism Risk Assessment (TRA)
Must be:
- Written
- Site-specific
- Based on credible threats
- Regularly reviewed
- Accessible to relevant staff
- Updated after changes in layout or operations
Security Plan
A formal, detailed document outlining:
- Roles and responsibilities
- Chain of command
- Evacuation and lockdown procedures
- Communication routes
- PA scripts
- Tenant coordination plan
- Use of CCTV
- External area procedures
- Car park management
- Recovery procedures
This must be kept up-to-date and version controlled.
Public Protection Procedures (PPPs)
Clear, concise instructions covering:
- Suspicious item reporting
- Suspicious behaviour recognition
- Incident escalation
- Evacuation/lockdown decision-making
- Visitor management during incidents
PPPs must be accessible to tenants.
Staff Training Records
Includes:
- Attendance logs
- Role-specific training content
- Refresher session dates
- Trainer names/credentials
- Scenario-based drill participation
These records are a key inspection point.
Drill & Exercise Logs
Enhanced Duty premises must:
- Conduct drills
- Record attendance
- Document findings
- Identify weaknesses
- Record corrective actions
Tenant Compliance Tracking
Centres must document:
- Which tenants have received training
- Which tenants participated in drills
- Which units have operational shutters
- Any non-compliance and follow-up actions
This is essential to ensure a centre-wide response.
Incident Reports & Investigations
Any suspicious item, individual, or near-miss must be logged, including:
- Time and date
- Description
- Staff involved
- Actions taken
- Outcome
- Follow-up measures
This builds a defensible record of operational awareness.
Where and How Documentation Should Be Stored
Martyn’s Law does not mandate the storage method, but documentation must be:
- Accessible
- Organised
- Secure
- Available during inspection
- Backed up regularly
Shopping centres should use a centralised compliance folder or digital platform with:
- Version control
- Permission management
- Audit trails
- Quick retrieval
Recommended secure locations:
- Centre management office
- Security control room
- Digital cloud-based platform
What Inspectors May Ask to See
For Enhanced Duty premises, inspectors may request:
- The current TRA
- The most recent Security Plan
- PPP documents
- Staff training logs
- Drill reports
- Tenant training confirmation
- Maps showing evacuation and lockdown routes
- Communication protocols
- Policy change history
Being unable to provide documentation can be treated as non-compliance, even if the centre is otherwise well-prepared.
Documentation Challenges in Retail (and How to Fix Them)
Common issues include:
- Tenants failing to maintain training records
- Version confusion (old plans in circulation)
- No unified documentation structure
- Over-reliance on verbal briefings
- Poor record-keeping during staff turnover
- No central repository
- Unclear ownership of documentation
To resolve this:
Assign a Documentation Lead
Someone must own the responsibility.
Use consistent templates
For TRAs, PPPs, logs, and drills.
Create a digital “single source of truth”
A secure shared platform accessible to management.
Update documents immediately after any change
Layout changes, incidents, new tenants, new staff.
Conduct periodic documentation audits
Ideally every 3–6 months.
Summary: Strong Documentation = Strong Compliance
Documentation is not just paperwork, it is proof of preparedness.
For shopping centres, it ensures:
- Consistent procedures
- Cross-tenant alignment
- Legal compliance
- Faster emergency response
- Reduced risk to staff and visitors
Whether a centre falls under Standard or Enhanced Duty, high-quality documentation is essential for protecting the public and meeting Martyn’s Law requirements.
Protect Your Visitors With a Trusted Security Partner
Leisure Guard Security provides trained officers, counter-terrorism awareness, emergency planning, drills and ongoing compliance support for retail environments. Keep your centre safe, instil confidence in visitors, and meet every requirement of Martyn’s Law with expert guidance.
Common Mistakes Shopping Centres Make Under Martyn’s Law
Even with strong intentions, many shopping centres and retail parks fall into the same traps when preparing for Martyn’s Law. These environments are complex, multiple tenants, vast public areas, diverse staff roles, and constantly changing footfall patterns. Because of this, mistakes are common and can undermine an otherwise solid security strategy.
Understanding these errors is key to avoiding them and ensuring that the entire premises is genuinely prepared to protect the public during a threat.
Relying on Fire Procedures Instead of Terrorism-Specific Actions
Fire evacuation procedures are not suitable for terrorism scenarios.
Common problems include:
- Evacuating people towards danger
- Using the wrong exits
- Moving crowds through open atriums
- Treating every incident as a fire alarm
- No consideration for lockdown
Martyn’s Law requires:
- Distinct evacuation routes for terrorism events
- Lockdown procedures where evacuation is unsafe
- Staff trained to differentiate scenarios
Tenants Acting Independently Instead of Following Centre-Wide Plans
Retail units often:
- Use their own policies
- Close shutters too early
- Evacuate at the wrong time
- Send staff to assembly points before customers
- Fail to coordinate with centre management
This causes dangerous inconsistencies.
Martyn’s Law requires a unified, centre-wide response, not individual approaches.
Staff Not Receiving the Same Quality of Training
Training varies widely between tenants.
Common issues include:
- Seasonal workers not being trained
- Young or part-time staff receiving minimal briefings
- Tenants providing outdated or inconsistent instructions
- Cleaning and maintenance teams being overlooked
- Staff unaware of who to report concerns to
Under Martyn’s Law, every staff member must receive appropriate training.
Failure to Provide Clear Lockdown Procedures
Lockdown is where most centres are unprepared.
Frequent gaps include:
- No instructions for open-front units
- No refuge point identification
- No procedure for food court or atrium areas
- Staff unsure when lockdown is safer than evacuation
- Shutters that cannot be lowered quickly or safely
Martyn’s Law requires lockdown methods that are realistic, not theoretical.
Overcomplicated Procedure Documents
Many retailers and centre managers create procedures that are:
- Too long
- Too technical
- Hard to understand
- Unusable in high-stress situations
- Ignored by staff
Effective PPPs must be simple.
Clear. Visual. Action-focused.
No Formal Communication Strategy
Communication failures are common during emergencies.
Shopping centres often lack:
- Clear PA scripts
- Standardised code words
- Shared radios for tenants
- A centralised escalation chain
- Methods to prevent misinformation spreading
Martyn’s Law expects fast, coordinated, unambiguous communication.
Ignoring External Areas Like Car Parks & Access Roads
Many sites only focus on internal spaces. External zones pose major risks:
- Vehicle-as-a-weapon attacks
- Crowds gathering in car parks
- Confused visitors arriving mid-incident
- Delivery drivers entering danger zones
- Public unaware of exit restrictions
Your PPPs must include full external-area procedures, not just internal actions.
No Consideration for Vulnerable Visitors
Centres frequently underestimate the challenges faced by:
- Disabled visitors
- Elderly individuals
- Parents with prams
- Visitors with limited English
- People who freeze or panic
- Individuals unfamiliar with the layout
Staff must know how to support all visitor types during evacuation and lockdown.
Failing to Update Documents After Renovations or New Tenants
Retail spaces evolve constantly:
- New stores open
- Old units close
- Centre layouts change
- New barriers or kiosks appear
- Shopfronts move
- Food courts expand
Any change can affect:
- Evacuation routes
- Lockdown zones
- Sightlines
- Marshals’ positions
Many centres forget to update documentation, a major compliance failure.
No Evidence of Drills or Testing
Many centres have procedures written down but:
- Never practise them
- Never test communication
- Never test tenant compliance
- Never run scenario-based simulations
- Never review their own performance
Enhanced Duty requires drills, records, and proof of corrective actions.
Not Gathering Lessons Learned from Incidents or Near-Misses
Small incidents often reveal major weaknesses:
- Suspicious bags
- Medical emergencies
- Unruly individuals
- False fire alarms
- Mass crowd movement during sales or events
These events provide valuable insights. Many centres fail to log or learn from them.
Lack of Leadership or Ownership
The biggest mistake is having no clear person responsible for:
- Tenant coordination
- Training schedules
- Documentation
- Emergency planning
- Compliance monitoring
Martyn’s Law requires clear ownership of responsibility.
Summary: Mistakes Are Fixable With Strong Procedures and Consistency
Most of these mistakes come down to:
- Poor coordination
- Poor training
- Poor communication
- Poor documentation
Martyn’s Law provides shopping centres with a clear framework to fix them, and ensure that thousands of visitors are protected every day.
Retail Readiness Scorecard (Self-Assessment Table)
To help shopping centres and retail parks understand their current level of preparedness, the Retail Readiness Scorecard provides a simple yes/no assessment across each core area of Martyn’s Law. This tool helps centre managers quickly identify weaknesses and prioritise remedial actions.
The scorecard covers every stage of preparedness, from training and procedures to tenant coordination, drills, documentation, and communication. It allows retail premises to benchmark themselves against legal expectations and industry best practice.
How to Use This Scorecard
- Answer Yes or No to each question honestly
- Any No indicates a compliance gap
- Multiple No answers indicate significant risk
- Centres under Enhanced Duty should treat every No as a required action
- The scorecard can be used annually or after major changes to the layout or tenant mix
For tenants, this scorecard can be shared by centre management to ensure each unit meets its obligations.
Retail Readiness Scorecard – Martyn’s Law Self-Assessment
| Readiness Area | Assessment Question | Yes | No |
|---|---|---|---|
| Terrorism Risk Assessment | Do you have a current, written TRA that reflects your full site layout? | ||
| Security Plan | Have you created a full-site Security Plan that meets Enhanced Duty requirements? | ||
| Public Protection Procedures (PPPs) | Do you have clear PPPs for evacuation, lockdown, communication, and threat escalation? | ||
| Tenant Coordination | Are all tenants trained, briefed, and aligned with centre-wide procedures? | ||
| Staff Training | Have all staff (centre, retail, cleaning, security) received appropriate training? | ||
| Training Records | Do you maintain written, up-to-date records of all training delivered? | ||
| Evacuation Planning | Do you have clear, mapped evacuation routes for all levels and zones? | ||
| Lockdown Capability | Can all tenants and open-front stores execute an effective lockdown? | ||
| Communication Systems | Do you have reliable radio, PA, and escalation communication processes? | ||
| Drills & Testing | Do you run regular drills (evacuation & lockdown) and document the results? | ||
| Document Control | Are all documents version-controlled, up-to-date, and centrally stored? | ||
| External Area Preparedness | Do your procedures cover car parks, access roads, and public spaces? |
How to Interpret Your Score
- 11–13 “Yes” answers → Strong compliance readiness
- 7–10 “Yes” answers → Moderate readiness; improvements required
- 0–6 “Yes” answers → Serious gaps; high-risk environment
Martyn’s Law expects retail premises, especially Enhanced Duty sites, to aim for maximum readiness in every category.
Implementation Plan for Shopping Centres & Retail Parks (Step-by-Step)
Compliance with Martyn’s Law is not a one-off task, it is an ongoing operational commitment. Shopping centres and retail parks must approach implementation as a structured programme, integrating risk assessments, training, procedures, communication, and tenant coordination into a single cohesive safety system. Whether you operate a 20-unit retail park or a multi-storey shopping centre with thousands of visitors a day, the process below outlines the most efficient and effective route to full compliance under the Standard or Enhanced Duty.
This implementation plan is designed to be practical, actionable, and adaptable to different retail environments. Each step builds on the previous one, ensuring a logical rollout that minimises disruption to tenants and avoids duplication of work.
Step 1: Confirm Your Duty Level (Standard or Enhanced)
Before any operational work begins, centres must formally establish their legal classification under Martyn’s Law.
Tasks
- Verify maximum occupancy (not just average footfall)
- Identify all “qualifying premises”, including:
- Centre common areas
- Individual retail units
- Car parks
- Leisure areas (cinemas, bowling, food courts)
- Confirm whether multiple areas collectively create an “event capacity” above 800
- Document your duty tier and rationale
Outcome
A clear written statement defining your centre’s legal obligations under Martyn’s Law.
Step 2: Appoint a Lead Responsible Person (LRP) and Duty Team
Under both Standard and Enhanced Duty, someone must take ownership of preparation and ongoing compliance. Shopping centres require a structured governance model because they combine multiple businesses under one operational umbrella.
Tasks
- Appoint an LRP (usually centre manager or operations manager)
- Establish a Martyn’s Law Duty Team, including:
- Security supervisor or head of security
- Duty managers
- Tenant liaison representative
- FM/maintenance representative
- Health & safety lead
- Define responsibilities for each role
- Schedule monthly governance meetings
Outcome
A defined leadership structure with clear accountability and operational oversight.
Step 3: Conduct a Terrorism Risk Assessment (TRA)
This is the foundation for all other documents and procedures.
Tasks
- Map the entire site, including internal and external spaces
- Identify vulnerable areas:
- Food courts
- Atriums
- Open storefronts
- Entrances/exits
- Car parks
- Loading bays
- Document threat types:
- Marauding attack
- IED (placed or vehicle-borne)
- Insider threat
- Hostile reconnaissance
- Assess critical pinch points
- Score risks and prioritise improvements
Outcome
A centre-wide TRA forming the basis of your Emergency Security Plan (Enhanced) or PPPs (Standard).
Step 4: Develop Your Emergency Procedures (Evacuation, Lockdown & Communication)
This is the operational core of Martyn’s Law and one of the most critical areas for shopping centres because of their open design and high footfall.
Tasks
- Create or update centre-wide procedures covering:
- Full evacuation
- Partial evacuation
- Internal lockdown
- Tiered lockdown levels (e.g., shelter-in-place vs hard lockdown)
- Suspect packages
- Suspicious persons
- Immediate threat scenarios
- Establish communication triggers
- Define how tenants will receive alerts (radio, PA, SMS, app, alarms)
Outcome
Procedures that can be executed quickly, consistently, and with minimal confusion across all units.
Step 5: Create Your Legal Documents (ESP / PPPs / Training Records)
Depending on your duty level:
Standard Duty Requires
- Public Protection Procedures (PPPs)
- Staff training
- Training records
Enhanced Duty Requires
- Terrorism Risk Assessment (TRA)
- Emergency Security Plan (ESP)
- Detailed staff training plan
- Audit trail for compliance
- Regular testing
- Annual review
Outcome
A fully documented, legally compliant preparation framework.
Step 6: Tenant Engagement & Alignment
One of the biggest challenges for shopping centres is aligning independent businesses with centre-wide procedures. Many attacks historically exploited open units or poorly coordinated responses.
Tasks
- Create a tenant handbook for Martyn’s Law
- Brief all store managers
- Share evacuation and lockdown maps
- Ensure all open-front units have rapid lockdown capability
- Standardise communication channels (radio, emergency messages, escalation routes)
- Require tenants to confirm staff have completed training
Outcome
A unified response system where every unit works as part of the wider safety framework.
Step 7: Deliver Staff Training (Centre, Security, Retail & Contractors)
Every person on site contributes to safety. Training must be delivered to:
- Centre management
- Security teams
- Store staff
- Cleaners
- Maintenance teams
- Contractors
- Seasonal workers
Training should cover
- Understanding threats
- Identifying suspicious behaviour
- Evacuation and lockdown roles
- Immediate response actions (Run/Hide/Tell principles)
- Communication procedures
- How to react during an unfolding incident
Outcome
A consistently trained workforce able to respond quickly and confidently under pressure.
Step 8: Implement Communication & Alert Systems
The speed of communication determines whether an incident escalates or is controlled. Centres must implement robust systems.
Tasks
- Ensure radio coverage across all areas
- Establish backup communication (in case radios fail)
- Confirm PA systems reach all public zones
- Test SMS alert systems for managers and tenants
- Ensure no “dead zones” exist
- Implement a code-based alert system
Outcome
A resilient communication network that supports fast, coordinated action.
Step 9: Run Drills & Live Testing
Drills are not optional, and for shopping centres, they’re essential due to the large number of tenants and staff.
Drill Types
- Full evacuation
- Zone evacuation
- Full lockdown
- Partial lockdown
- Out-of-hours exercises
- Scenario-based testing
Testing Frequency
- Standard Duty: proportionate testing
- Enhanced Duty: regular drills with written logs
Outcome
Confirmed operational readiness and documented evidence for regulators.
Step 10: Review, Update & Demonstrate Compliance
Martyn’s Law is ongoing, not a one-time task. Centres must maintain compliance year-round.
Tasks
- Annual TRA review
- Update procedures after layout changes
- Renew training every 12 months
- Document all changes (Enhanced Duty requirement)
- Maintain full audit trail
- Review incident logs
- Refresh maps and signage
Outcome
Long-term, structured compliance with full evidence should an audit or investigation occur.
Why This Implementation Plan Works
This plan gives shopping centres a clear, structured path from initial assessment to full operational readiness. By following these steps, centres can:
- Protect visitors and staff
- Improve coordination with tenants
- Strengthen resilience against major threats
- Demonstrate compliance to regulators
- Reduce legal and reputational risk
- Increase public confidence
This section is intentionally actionable so facilities managers, centre directors, and security leads can use it immediately.
Realistic Retail Scenarios & How Shopping Centres Should Respond
Shopping centres present unique risks due to high footfall, open-front units, multi-level layouts, and the constant movement of shoppers. The scenarios below demonstrate how Martyn’s Law procedures, especially evacuation, lockdown, communication, and staff training, translate into real-world action.
These case studies not only help centres visualise their own preparedness, but also serve as internal training tools for staff, tenants, and contractors.
Scenario 1: Suspicious Person Acting Erratically Inside the Centre
A store reports a man moving between units without purchasing anything, repeatedly entering back-of-house corridors, and filming security cameras.
How Staff Should Respond
Early Identification
- Store staff notify security via radio
- Security logs the time, behaviour, and description
Low-Level Engagement
- A trained security officer approaches with a non-confrontational script
- They assess intent through conversation
Escalation If Required
- If behaviour continues, the Duty Manager is informed
- CCTV monitoring is increased in the zone
- A silent Code Alert is sent to stores
Document Everything
- Behaviour documented for intelligence sharing
- TRA updated if pattern repeats
Outcome Under Martyn’s Law
Because staff are trained to recognise hostile reconnaissance, the threat is intercepted early, long before escalation. No evacuation or lockdown required, but internal preparedness is activated.
Scenario 2: Suspect Parcel Found in a Corridor Behind a Store
A cleaner discovers a small backpack left behind fire doors in a service corridor.
How Staff Should Respond
Immediate Actions
- Do NOT touch the item
- Notify security and Duty Manager
- Secure the corridor to prevent public access
Initial Assessment
- CCTV reviewed
- Time of placement estimated
Decision Point
Depending on duty level, the following applies:
- Standard Duty: Partial evacuation of adjacent units
- Enhanced Duty:
- Activate suspect item procedure
- Evacuate the affected zone
- Follow bomb-threat safety distances
Communication
- Tenants informed via radio & Code Alert
- PA remains silent to avoid panic unless full evacuation required
Police Involvement
- Call 999
- Follow police instructions
Outcome Under Martyn’s Law
Clear, rehearsed procedures ensure a calm, coordinated response with stores aligned and no chaotic self-evacuation.
Scenario 3: Vehicle-Based Threat in Retail Park Car Park
A security patrol reports a van parked illegally near the entrance, with the driver acting nervous and refusing to enter the store.
How Staff Should Respond
Early Recognition
- Security aware of VBIED risks (vehicle-borne improvised explosive devices)
- Patrol avoids approaching the vehicle directly
Protective Measures
- Establish distance
- Increase staff and public exclusion zone
Communication
- Alert tenants via radio
- Prepare for partial lockdown
Police Activation
- Contact emergency services immediately
Site Preparation
- Clear front entrances
- Suspend deliveries
- Redirect pedestrians
Outcome Under Martyn’s Law
The retail park moves quickly into structured lockdown and distancing procedures, protecting visitors from blast zones.
Scenario 4: Marauding Attack Inside the Shopping Centre
A real-life, highest-risk scenario.
How Staff Should Respond
Immediate Recognition
- Staff trained to recognise the signs: shouting, gunshots, panic, running crowds
Lockdown or Evacuate (Area-Dependent)
- Open-front units: lock-down shutters
- Enclosed stores: secure doors
- Public areas: instruct people to “RUN” routes
Communication
- Covert Code Alert sent
- PA may be used with direct instructions if appropriate
Emergency Actions
- Security does NOT attempt to confront attacker
- Staff shelter customers
- Managers call emergency services
Post-Incident Control
- Medical support delivered
- Muster points activated
- Roll call attempted (Enhanced Duty)
Outcome Under Martyn’s Law
Because drills have been practiced and procedures trained, staff react instinctively, protecting hundreds of people within seconds.
Scenario 5: Fire Alarm During a Lockdown Situation
A complex scenario where a terrorist may trigger a fire alarm to force people out of safe areas.
How Staff Should Respond
Staff Training Kicks In
- Retail and security staff must understand that:
Fire instructions DO NOT override lockdown instructions during a verified terror threat.
Verification
- CCTV checked
- Zone alarms identified
- Fire panel verified
Communication
- Clear instructions via PA:
“Remain in place unless instructed by security or emergency services.”
Police Guidance
- Follow real-time police instructions
Outcome Under Martyn’s Law
The centre avoids falling into a common terror tactic where people are pushed into a more vulnerable external attack zone.
Scenario 6: Suspicious Vehicle Circling the Retail Park (Hostile Reconnaissance)
Multiple tenants report the same car circling the site repeatedly without entering stores.
How Staff Should Respond
Pattern Recognition
- Security logs sightings
- CCTV tracks behaviour
Tenant Alerts
- Silent tenant alert issued
- Staff briefed to observe and report
Recording and Escalation
- Details shared with police if behaviour continues
- TRA updated to reflect new patterns
Outcome Under Martyn’s Law
Potential reconnaissance is identified and escalated early, preventing an attack from advancing.
Why These Scenarios Matter for Martyn’s Law Compliance
These scenarios demonstrate key principles:
- Training = faster response
- Clear procedures = reduced panic
- Communication = unified action
- Prepared tenants = safer public
- Testing = quicker operational decisions
Shopping centres and retail parks are complex environments, but with the right planning, even the most severe incidents can be managed safely and effectively.
5 FAQs for Martyn’s Law (Shopping Centres & Retail Parks)
Does Martyn’s Law apply to shopping centres?
Yes. Almost all UK shopping centres fall under Martyn’s Law because they are publicly accessible locations with significant footfall. Centres with a capacity of 100–799 fall under Standard Duty, while those with 800+ must meet Enhanced Duty requirements.
Does Martyn’s Law apply to retail parks?
Yes. Retail parks are publicly accessible premises. Even outdoor-only sites with open units are included, as they typically exceed the minimum capacity threshold of 100 people.
What is the main difference between Standard Duty and Enhanced Duty for retail premises?
Standard Duty requires training, Public Protection Procedures (PPPs), and clear instructions for staff. Enhanced Duty adds more formal requirements such as a detailed Terrorism Risk Assessment (TRA), Emergency Security Plan (ESP), testing, auditing, and documentation.
How do shopping centres calculate their legal capacity under Martyn’s Law?
Capacity is based on the maximum number of individuals who can safely occupy the premises at one time — not the average daily footfall. This includes the mall, food courts, common areas, and in some cases, major anchor stores.
Who is responsible for compliance in a shopping centre?
The centre’s operator, owner, or managing agent is typically the Responsible Person (RP). They must coordinate with tenants, contractors, security teams and cleaning staff to ensure a unified approach.
What training do retail staff need under Martyn’s Law?
All staff — including retail, cleaning, security, and management — must receive terrorism awareness training covering suspicious behaviour, evacuation routes, lockdown procedures, and how to respond during an incident.
What are Public Protection Procedures (PPPs)?
PPPs are clear, simple instructions for staff covering threat recognition, evacuation, lockdown routes, communication methods and response steps. These are mandatory under Standard Duty.
Do individual retail units inside a shopping centre need their own Martyn’s Law plans?
Tenants must align with centre-wide procedures. They do not need full, independent security plans under the Standard tier, but they must complete training, follow PPPs and be able to participate in evacuations/lockdowns.
Does Martyn’s Law require shopping centres to hire additional security?
Not necessarily. The law requires proportionate measures, which may include procedural improvements, enhanced staff training, or better communication systems. High-risk sites may choose to increase security presence, but it is not a mandatory requirement.
Do shopping centres need to run evacuation and lockdown drills?
Yes. Centres must conduct regular drills. Enhanced Duty sites must also test procedures, document outcomes, and make improvements based on findings.
What type of incidents does Martyn’s Law prepare retail staff for?
Staff are trained to respond to suspicious behaviour, suspect packages, hostile reconnaissance, vehicle-based threats, and marauding attacks (e.g., knife or firearms incidents).
Are outdoor retail parks treated differently from indoor shopping centres?
The principles are the same. Outdoor sites still require training, PPPs, and capacity calculations. Car parks and large open spaces must be included in risk assessments.
How should retail parks handle vehicle-based threats?
Procedures must include vehicle exclusion zones, suspicious vehicle reporting, monitoring of car parks, and clear communication channels for rapid staff alerts.
How often should Martyn’s Law documentation be reviewed?
At least once a year, or whenever there is a significant layout change, new tenant mix, major refurbishment, or updated guidance from the Home Office or ProtectUK.
The Act includes civil penalties for non-compliance, especially for Enhanced Duty sites. Penalties may include fines, enforcement notices, and legal action following an incident.
At least once a year, or whenever there is a significant layout change, new tenant mix, major refurbishment, or updated guidance from the Home Office or ProtectUK.
