Operator:
1.1. The purpose of this Policy is to ensure that Fair Transfer Ltd t/a Timeless Chauffeurs, as a London private hire operator, complies with the requirements of Transport for London ("TfL") and Taxi and Private Hire ("TPH") in relation to staff involved in taking bookings and dispatching vehicles. From 1 July 2024, TfL requires all licensed private hire operators to maintain a register of such staff, obtain Basic DBS checks, and implement an ex-offenders policy.
1.2. A further purpose of this Policy is to protect the public, clients, children and vulnerable persons from the risk that individuals involved in booking or dispatch functions misuse information obtained about clients, drivers or journeys. This approach is supported by the DfT Statutory Taxi and Private Hire Vehicle Standards and related TfL guidance.
1.3. This Policy forms part of the Operator's internal compliance framework and supports the fulfilment of licensing obligations. The Policy shall be made accessible to all relevant persons.
2.1. This Policy applies to all individuals who, whether paid or unpaid, on behalf of or for the benefit of the Operator:
2.2. For the purposes of this Policy, it is not decisive whether the individual is employed by the Operator. The Policy may apply to employees, agency workers, contracted third-party service providers, family members, casual assistants, and the operator itself where such activities are performed. This is consistent with TfL guidance, which interprets the concept of "staff" broadly.
3.1. According to TfL guidance, the terms "taking bookings" and "dispatching vehicles" are not narrowly defined technical terms but should be interpreted in their ordinary meaning. The requirements apply to any person who accepts private hire bookings, determines which driver or vehicle will fulfil a booking, or communicates booking details to drivers.
3.2. For the purposes of this Policy, a relevant role includes, in particular, any activity where an individual:
3.3. Relevant roles within the Operator may include, in particular:
3.4. The above list is not exhaustive. Any person performing such functions shall be considered to be in a relevant role.
4.1. In determining whether an individual holds a relevant role, the key consideration is not their employment status (employee, worker, contractor, agency worker or unpaid helper), but the actual functions they perform on behalf of or under the authority of the Operator.
4.2. This Policy forms part of the Operator's licensing and compliance obligations and does not in itself create or exclude an employment relationship. Employment status shall be determined in accordance with applicable employment law.
4.3. Where an individual in a relevant role is an employee, compliance with this Policy shall form part of the conditions of employment and internal compliance procedures.
4.4. The Rehabilitation of Offenders Act 1974 shall apply. The Operator shall only request information it is legally entitled to obtain; a Basic DBS check discloses only unspent convictions and certain conditional cautions.
5.1. The Operator shall:
5.2. The Operator acknowledges that, during standard compliance inspections, TfL may verify the existence of a booking and dispatch staff register and confirm that appropriate DBS evidence has been obtained.
6.1. The Operator shall maintain a register of all individuals who take bookings and/or dispatch vehicles.
6.2. No individual may perform a relevant role unless they have been recorded in the Operator's register.
6.3. The register shall include at least:
6.4. The register shall be stored securely at the operating centre or within a secure electronic system. TfL guidance permits registers to be maintained electronically or in paper form, provided they are accessible at the relevant operating centre.
6.5. Register storage location:
6.6. The register shall be made available to authorised TfL officers upon request.
7.1. The Operator shall ensure that all individuals in relevant roles hold a valid Basic DBS check.
7.2. No individual may commence duties in a relevant role unless the Operator has verified compliance with DBS requirements.
7.3. In accordance with TfL guidance, DBS checks must be renewed annually in line with licence anniversary requirements.
7.4. Individuals must immediately notify the Operator of any circumstance affecting their suitability, including new criminal proceedings, convictions or cautions.
7.5. Where required by TfL or other applicable regulations, individuals must cooperate in providing additional documentation or undergoing further DBS checks.
8.1. The Operator shall retain sufficient information to demonstrate that DBS checks have been carried out.
8.2. Only data necessary for compliance purposes shall be retained, in accordance with data protection legislation.
8.3. Such records shall be made available to TfL or other authorised authorities upon request.
9.1. Where a DBS check or other reliable information reveals an unspent conviction or relevant information, the Operator shall carry out an individual suitability assessment.
9.2. The assessment shall be conducted in accordance with the criteria set out in Schedule 1.
9.3. The primary consideration shall be the protection of the public, passengers, children and vulnerable persons.
9.4. Where the Operator determines that an individual may be engaged despite a conviction, the reasons shall be documented in writing and retained as part of the record.
10.1. This Policy and Schedule 1 serve as guidance and a decision-making framework.
10.2. The Operator may only depart from the general principles of this Policy where, after careful consideration, it is satisfied that the individual does not pose a risk to the public, clients, drivers or data security.
10.3. Factors to be considered include:
10.4. Any deviation and its justification must be documented in writing.
1.1. The Operator shall assess relevant convictions in accordance with the following main categories:
1.2. In all cases, the primary considerations shall be public safety, safeguarding, and the protection of client data. This approach is consistent with the principles applied by TfL and the Department for Transport (DfT).
2.1. Minor traffic offences will not necessarily, in themselves, preclude an individual from being considered suitable.
2.2. Dangerous driving, careless driving, driving under the influence of alcohol or drugs, and any driving offence resulting in injury or death raise serious concerns and will generally be incompatible with a relevant role.
2.3. Driving-related offences involving dishonesty shall be treated with particular seriousness.
3.1. Offences involving violence, assault, bodily harm or death indicate a significant risk to public safety.
3.2. Offences such as grievous bodily harm (GBH), manslaughter, attempted manslaughter, or other serious violent offences will generally render an individual unsuitable.
3.3. In exceptional cases involving isolated, historic and less serious offences, a positive assessment may be considered, but only with detailed justification.
4.1. Sexual offences are, as a general rule, incompatible with a relevant role.
4.2. Such offences present a particularly high risk, as booking and dispatch roles may involve access to sensitive location, timing and personal data.
5.1. Offences such as theft, fraud, burglary, deception and other dishonesty-related offences give rise to serious concerns.
5.2. Such offences may indicate that the individual could misuse information obtained through their role for personal gain.
6.1. The Operator is required to treat all clients equally and without discrimination.
6.2. Harassment or discriminatory behaviour based on a protected characteristic constitutes a serious compliance concern.
6.3. A positive suitability decision in such cases may only be made where the Operator is satisfied that the individual no longer poses any risk.
7.1. Licensing offences, or licence suspension or revocation, are not in all cases automatic grounds for exclusion.
7.2. However, where such action is linked to public safety concerns or underlying convictions, the matter shall be assessed with particular rigor.
8.1. Offences such as criminal damage or other property-related offences shall be assessed based on their nature and circumstances.
8.2. Where the conduct involves prejudice, intentional harm, or behaviour directed against others, the individual will generally be considered unsuitable.
Policy Effective Date: 15 May 2026
Last Reviewed: 15 May 2026
Version: 1.0