The Licensing Technical Support Officers
Environmental Health, Brighton & Hove City Council
Brighton & Hove City Council,

Hove Town Hall,

Norton Road, Hove,

BN3 3BQ

 

24/04/2026

Email: brighton.licensing@sussex.police.uk

Dear Sarah Cornell,

 

RE: APPLICATION FOR A NEW PREMISES LICENCE FOR ISLINGWORD LOCAL, 80 ISLINGWORD ROAD, BRIGHTON, BN2 9SL UNDER THE LICENSING ACT 2003

 

Although we strongly oppose this application and are seeking refusal, we are aware that the panel are in their right to grant it if they believe it will not add to any negative impact and that they have trust in the operator to trade under any new licence responsibly. For this reason, we list below several conditions that we ask the panel to consider should they be minded granting the application. These would be in addition to any offered within the original application or ones that the panel feel are appropriate to adopt once hearing.

General:

1.       Authorised staff employed by Sussex Police in the role of licensing officer shall have the right of access to the licensed premises during hours of operation for the purpose of inspection of the premises and premises records in order to ensure the promotion of the licensing objectives.

Prevention of crime and disorder:

2.       There will be no displays of alcohol in the public area of the shop floor which is accessible to the public. All alcohol in the public area of the shop will be beyond arms reach behind a Perspex or equivalent screen.

 

3.       There will be no advertising of promotions/deals on any alcoholic product that can be seen from outside the premises including window posters and street signage.

 

4.       No beer, lager, cider or perry with an ABV 6% or above shall be sold at the premises save that this shall not apply to premium beer, lager, cider or perry with an ABV 6% or above such as craft or speciality brands or brands produced by a micro-brewery, or brands produced to commemorate a national or local event.

5.       All beer, larger and cider cans excluding premium and craft brands, will only be sold in multipacks of 4 or more cans.

 

6.       The supply of alcohol will only be directly to the customers personally in store. There will be no delivery of alcohol products to customers.

 

7.       Subject to GDPR guidance and legislation:

 

(a)    Digital CCTV and appropriate recording equipment to be installed in accordance with Home Office Guidelines relating to UK Police Requirements for Digital CCTV System (PSDB Publication Number 09/05), operated and maintained throughout the licensable area of the premises. The system shall be on and recording at all times the premises licence is in operation.

 

(b)    The CCTV cameras and recording equipment must be of sufficient quality to work in all lighting levels inside the premises at all times.

 

(c)     CCTV footage will be stored for a minimum of 31 days.

 

(d)    The management will give full and immediate cooperation and technical assistance to the Police in the event that CCTV footage is required for the prevention and detection of suspected or alleged crime.

 

(e)    The CCTV images will record and display dates and times, and these times will be checked regularly to ensure their accuracy.

 

(f)      The management of the premises will ensure that key staff are fully trained in the

operation of the CCTV and will be able to download selected footage onto a disk (or other electronic portable device acceptable to Police e.g. USB) or provide footage via an online link as initiated by Police, without difficulty or delay and without charge.

 

(g)    Any breakdown or system failure will be notified to the police immediately & remedied as soon as practicable. This can be via email - brighton.licensing@sussex.police.uk. Repair records /invoices shall be kept on site for at least 12 months and be readily available to be viewed by all authorised person upon request.

 

(h)    In the event of the CCTV system hard drive being seized as evidence as part of a criminal investigation by Police or for any other reason, the premises will be expected to install a replacement hard drive or a temporary replacement drive as soon as practicable.

 

8.       At all times the premises is open to the public, the management will contract the back up services of an approved mobile support unit (MSU) that operates at all times the premises is open to the public, with a minimum of 2 SIA registered Door Supervisors operating from it. A copy of the MSU contract will be retained at the premises and made available for immediate inspection upon request by Sussex Police or Council Officials. The MSU will be accredited by the Brighton Crime Reduction Partnership (BCRP) or other similar organisation approved by Sussex Police should the BCRP not be in existence.

 

9.       The premises will become a member of the Brighton Crime Reduction Partnership or similar scheme approved by the Licensing Authority. The scheme must operate, subject to local coverage, radios and additionally an exclusion/banning scheme of named individuals within both the day and nighttime economy.

 

Public Safety

10.   An incident log shall be kept at the premises and must be completed within 24 hours of the incident. It can be in paper or electronic form and will record the following:

 

a)       all crimes reported to the venue

b)      any refusals made of alcohol service e.g. underage, intoxication

c)       all ejections of patrons

d)      any complaints received concerning crime and disorder

e)      any incidents of disorder

f)        any seizures of drugs or offensive weapons

g)       any visit by a relevant authority or emergency service.

 

11.   The incident log will:

 

a)       be inspected and signed off by the DPS (or a person with delegated authority) at least once a fortnight.

 

b)      be kept on the premises and be available for inspection at all times the premises are open by authorised officers of the Licensing Authority or the police. An incident will be defined as being one which involves an allegation of a criminal offence or as listed in condition 11 above.

 

c)       be used to give feedback to staff to ensure that the log is used on each occasion that a refusal, ejection or incident occurs at the premises and to identify any patterns or trends.

 

d)      be kept for a minimum of twenty-four (24) months.

 

Prevention of public nuisance:

-       None

Protection of children from harm:

12.   The premises will operate a "Challenge 25" policy whereby any person attempting to buy alcohol who appears to be under 25 will be asked for photographic ID to prove their age. The recommended forms of ID that will be accepted are passports, official Photographic Identity Cards issued by EU states bearing a hologram or ultraviolet feature, driving licences with a photograph, photographic military ID, biometric residence permit cards or proof of age cards bearing the ‘PASS’ mark hologram. The list of recommended forms of ID may be amended or revised with the prior written agreement of Sussex Police, the Licensing Authority and Trading Standards without the need to amend the licence or conditions attaching to it.

 

13.   Signage advertising the “Challenge 25” policy will be displayed in prominent locations in the premises.

 

14.    

(a)    The Premises Licence Holder / Management shall ensure that all staff members engaged or to be engaged in selling alcohol shall receive induction training. If this training is to be conducted in electronic form, it will at a minimum also include a face-to-face discussion session. This training will take place prior to the selling of such products and will include:

 

v  The lawful selling of age restricted products – including but not limited to, the requirement of the staff member conducting the transaction to ensure they carry out Challenge 25 checks regardless of any other staff member checks that may already have taken place

v  Identifying if a person may be intoxicated and refusal of sale

v  Vulnerability initiatives and how to respond to potential drink spiking

 

(b)    Further verbal reinforcement/refresher training covering the above will be carried out thereafter at intervals not to exceed 12 weeks, with the date and time of the verbal reinforcement/refresher training documented.

 

(c)     All such training undertaken by staff members shall be fully documented and recorded. All training records shall be made available to Sussex Police, officers of the local authority and officers from the Trading Standards team upon request

 

As mentioned in our representation dated 26th March 2026, Sussex Police maintain their invite to the Licensing Authority to seriously consider refusing this application taking our comments into consideration as well as the incident/crime data for the local area which will be provided during the hearing.

 

Yours sincerely,

 

 

 

Sgt Kate Hancox o.b.o. Insp Ben Morrison
Operations, Planning & Events (inc. Licensing) Inspector

Brighton & Hove Division

Sussex Police

 

Please address all future correspondence to Brighton & Hove Licensing Unit, Police Station, John Street, Brighton, BN2 0LA.