Key management in a guarding company

• Code: unique to each key, the same on the tag and in the register.
• What it opens: a description the guard understands (“loading door B”), written only in the register, never on the key.
• Copies: how many exist in total and who holds the others, so you know what is missing when one goes.
• Chain of custody: who took it, from whom, when, why, and when it came back — signed by both.
• Handover from the client: a receipt at the start of the contract listing every key and card handed over, signed by both parties.

The key register is not the post log. Keep it separate, so it can be checked on its own and is not read by everyone who opens the log.

• Sealed or coded tags: a number or barcode, with no company name, address or logo.
• Separate code list: stored away from the keys, open only to the supervisor and the people named in writing.
• Key cabinet or safe: locked, fixed in place, opened by named people. Keys in a desk drawer are not key control.
• Sealed emergency keys: in an envelope or bag with a numbered seal; if the seal is broken, the reason is written down.
• Electronic key cabinet: where installed, it logs who took which key and when. That log is personal data too — see below.

The general handover checklist is in the guide to shift briefing and handover. For keys, add three things:

1. Count by code, not “all fine”: the incoming guard sees every code in the cabinet or the register.
2. Keys out of the cabinet: who has them (contractor, cleaning crew, client staff) and when they are due back.
3. Broken seals: every sealed envelope opened during the shift, with the reason and a new seal.

A key that is “somewhere” at the end of a shift is an open issue from that moment — not the next morning, when someone needs it.

1. Report: the guard tells the supervisor as soon as the loss is noticed, and the supervisor tells the client — with time, code and last holder from the register.
2. Assess: what does it open? Did the tag show an address or logo? When was it last seen? Are there copies in other hands?
3. Immediate measures: deactivate the card in the access control system, add patrols at that point, check whether the door can be secured another way.
4. Client decision: change the cylinder, change the codes, or record the loss without a change — in writing, with a date.
5. Close-out: update the register, and settle who pays for any change as the contract says.

Log the loss as an incident, not a note. Where guarding runs on OVIT’s Guardly platform, the client sees incidents in the same live picture as patrols and reports.

The keyholder’s role and the order of actions when an alarm goes off are covered in the guide to alarms and the police. What remains here is the keys themselves:

• Which keys and codes the response guard is given — only what their route needs, not the whole bunch.
• Where they are kept when not in use, and who may break the seal.
• How they are returned after the event, and who signs.
• What happens to them if the client’s keyholder changes or the contract ends.

Article 5 of the GDPR requires, among other things, that data be collected for specified purposes, limited to what is necessary, kept accurate, retained only as long as the purpose requires, and protected against unauthorised processing and accidental loss. The controller must be able to demonstrate compliance (art. 5 §2).

• Minimisation: name, time, key code, signature. Not ID numbers or home addresses unless they are needed.
• Accuracy: the keyholder list is updated when someone leaves or changes number.
• Retention: agree in writing how long old pages and electronic cabinet logs are kept, and what happens when the contract ends.
• Access: people with access to the register process it only on the controller’s instructions (art. 32 §4); a locked book, passwords on the electronic system.

If the register itself or the code list is lost, that may be a personal data breach: the GDPR requires notification to the supervisory authority without undue delay and, where feasible, within 72 hours, unless it is unlikely to result in a risk (art. 33 §1). Set out in the contract who the controller is and who notifies whom.

• In the [contract](/guides/security-guard-contract-terms): which keys and cards are handed over, receipts on handover and return, who decides and who pays for a lock change after a loss, personal data in the register, return of everything at the end.
• In the [post orders](/guides/security-post-orders): where the cabinet is, who opens it, which keys are issued to whom (contractors, cleaners), what the guard does if a key is missing.
• Supervisor counts: at intervals set in writing, every code is checked against the register and every discrepancy becomes an incident.
• Client checks: ask to see the register and have the cabinet opened in front of you, as part of auditing your security provider.