Ex-Offenders Policy (2026) – TfL Compliant

Goldline Car Services Ltd

 

1. Purpose

Goldline Car Services Ltd is committed to fair and lawful recruitment while ensuring full compliance with Transport for London (TfL) licensing requirements. This policy outlines how the company assesses individuals with criminal records, balancing rehabilitation with the overriding duty to protect passenger safety and public trust.

 

2. Scope

This policy applies to:

  • All job applicants
  • Licensed private hire drivers
  • Employees, contractors, and agency staff

 

3. Legal and Regulatory Framework

This policy complies with:

  • Rehabilitation of Offenders Act 1974 (ROA)
  • Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975
  • Data Protection Act 2018 and UK GDPR
  • TfL Private Hire Driver Licensing Requirements
  • TfL “Fit and Proper Person” test
  • Disclosure and Barring Service (DBS) Code of Practice

 

4. Core Principle: Fit and Proper Person Test

Goldline Car Services Ltd will only engage or continue to employ individuals who meet the TfL requirement of being a “fit and proper person” to hold a private hire licence. This also applies to all office staff who work within a customer facing role from within an operating centre.

This means the company must be satisfied that the individual:

  • Does not pose a risk to the safety of the public
  • Is trustworthy and acts with integrity
  • Can be relied upon to safeguard passengers, including children and vulnerable adults

Public safety is the primary consideration at all times.

 

5. Disclosure Requirements

5.1 Applicants

  • All applicants must declare unspent convictions.
  • Driver applicants must disclose all convictions, cautions, warnings, and reprimands in line with TfL requirements.

 

5.2 Licensed Drivers

  • Drivers must immediately notify both TfL and the company of any arrest, charge, caution, or conviction.
  • Failure to disclose may result in termination and/or reporting to TfL.

 

5.3 DBS Checks

  • All drivers must undergo an Enhanced DBS check with barred list information.
  • Drivers must subscribe to the DBS Update Service and maintain continuous registration.

 

6. Assessment of Criminal Records

Each case will be assessed individually in line with TfL guidance, considering:

  • Nature and seriousness of the offence
  • Relevance to the role
  • Time elapsed since the offence
  • Pattern of behaviour
  • Vulnerability of passengers

 

6.1 Zero-Tolerance Categories

The following will normally result in refusal or termination (subject to TfL decisions):

  • Sexual offences
  • Offences involving children or vulnerable persons
  • Exploitation, trafficking, or grooming offences

 

6.2 High-Risk Offences (Presumption Against Approval)

A licence or role will normally be refused unless exceptional circumstances apply:

  • Violence (e.g., assault, GBH)
  • Domestic abuse
  • Hate crimes
  • Serious dishonesty (e.g., fraud)
  • Drug supply offences

 

6.3 Driving and Road Safety Offences

Particular consideration will be given to:

  • Drink or drug driving
  • Dangerous driving
  • Repeated motoring offences

Applicants must meet TfL minimum conviction-free periods.

 

7. TfL Licensing Priority

  • Where TfL has refused, suspended, or revoked a licence, the company will not override that decision.
  • Continued engagement is conditional upon maintaining a valid TfL licence.

 

8. Recruitment Decision Process

  • All disclosures are risk assessed against TfL policy.
  • Applicants may be invited to provide further context.
  • Decisions are documented with justification.
  • Senior management approval is required for borderline or high-risk cases.

 

9. Existing Employees and Drivers

  • Ongoing employment is conditional upon maintaining TfL licensing.
  • Any new offence will trigger an immediate risk review.
  • The company reserves the right to suspend duties pending investigation.

 

10. Safeguarding Commitment

Goldline Car Services Ltd recognises that private hire drivers are in positions of trust. The company will:

  • Prioritise safeguarding of children and vulnerable adults
  • Act immediately on any safeguarding concerns
  • Cooperate fully with TfL, police, and regulatory bodies

 

11. Data Protection and Confidentiality

  • Criminal record data will be processed in accordance with UK GDPR and DBS requirements.
  • Information will be handled securely and only by authorised personnel.
  • Data will not be retained longer than necessary.

 

12. Training and Compliance

  • Managers will receive training on TfL requirements and safe recruitment.
  • The company will maintain awareness of updates to TfL policy.

 

13. Policy Review

This policy will be reviewed annually or immediately following changes to TfL regulations.

 

14. Responsibility

Senior management is responsible for implementation and compliance. All staff must adhere to this policy.