Verify before use
Required records must be reviewed before a driver or vehicle becomes eligible for assignments.
TfL Licensed Private Hire Operator
Driver and Vehicle Compliance Policy.
Black Fleet London operates a compliance-led allocation framework designed to ensure that only suitably licensed, insured, documented and operationally appropriate drivers and vehicles are made available for passenger journeys.
Black Fleet London Ltd is licensed and regulated by Transport for London as a London private hire operator. The company is subject to continuing TfL regulatory oversight and regular compliance inspection, with its operating records and controls reviewed for compliance.
Purpose
Compliance before allocation—not after an incident.
The purpose of this policy is to define how Black Fleet London verifies, records and monitors the drivers, vehicles and licensed operating partners available to deliver private hire journeys.
No commercial urgency, passenger status or supplier relationship should override the requirement to use lawful, insured and suitable operating capacity.
Scope of this policy
- TfL-licensed private hire drivers and vehicles
- Hertsmere-licensed drivers, vehicles and operators where applicable
- Approved licensed private hire operating partners
- Driver, vehicle and operator onboarding
- Insurance and ownership or rental documentation
- Document expiry, suspension and ongoing validity
- Allocation, replacement and substitution controls
- Compliance audits, incidents and corrective action
Regulatory Framework
Controls designed around the duties of a licensed London private hire operator.
Black Fleet London applies the requirements and guidance relevant to licensed operators, including the Private Hire Vehicles (London) Act 1998, supporting regulations, TfL licence conditions, the TfL Private Hire Operator’s Handbook and current operator-inspection guidance.
Licensed operator
Bookings are accepted and managed through an authorised operator.
Verified records
Required driver and vehicle particulars are maintained.
Insured journeys
Hire-and-reward cover must apply when a vehicle is used.
Inspection-ready
Records and controls are maintained for regulatory review.
TfL Oversight and Inspection
Compliance independently checked by the licensing authority.
Black Fleet London is subject to regular compliance inspection by Transport for London Authorised Officers. The company’s experience is that its compliance arrangements are checked and reviewed by TfL on an annual basis, while TfL may inspect more frequently or without prior notice where necessary.
A TfL inspection is not treated as a one-day exercise. The company seeks to maintain inspection-ready records and operating controls throughout the licence period.
TfL may inspect
- Driver and vehicle records
- Booking and dispatch records
- Hire-and-reward insurance evidence
- Regular licence-validity checks
- Document fraud-detection measures
- Booking-confirmation processes
- Complaints, lost property and safety records
- Operating-centre and corporate documents
Inspection outcomes form part of wider fitness assessment
TfL may consider inspection findings as part of a broader assessment of the fitness of the company’s responsible persons, operating centres and service. Material or repeated non-compliance may lead to follow-up inspection or licensing action.
Compliance Principles
Seven controls supporting lawful and dependable allocation.
Match the authority
Licensing must be assessed according to the relevant authority and operating arrangement.
Maintain current records
Expiry, suspension and document changes must be reflected promptly.
Detect inconsistency
Submitted information should be checked for alteration, mismatch and possible fraud.
Restrict automatically
Expired or materially incomplete records should prevent allocation.
Preserve traceability
Allocation records should identify the actual driver, vehicle and operating party used.
Escalate change
Material compliance changes must be reported without unnecessary delay.
Audit and improve
Exceptions, inspections and incidents should inform corrective action.
Driver Compliance
Driver eligibility established before allocation.
Black Fleet London maintains the required particulars for drivers made available to the operation and verifies the licensing authority, identity, validity and relevant operating relationship.
A driver must not receive an assignment where required particulars are unavailable, expired, inconsistent or subject to unresolved concern.
Driver records may include
- Full legal identity and current contact information
- Residential address where required
- Private hire driver licence and licensing authority
- Driver badge and associated licence identifiers
- Driving licence and applicable entitlement
- DVLA check information where required
- Profile photograph and identity verification
- Relevant operating or contractual relationship
Vehicle Compliance
Vehicle legality, insurance and suitability independently assessed.
A licensed vehicle must also be properly insured, roadworthy and appropriate for the assignment. Vehicle licensing alone does not replace the operator’s responsibility to verify hire-and-reward insurance and required supporting records.
Black Fleet London distinguishes between vehicles licensed by TfL and those licensed by Hertsmere Borough Council or another applicable authority within an authorised operating arrangement.
Vehicle records may include
- Registration mark, make, model, colour and year
- Private hire vehicle licence and licensing authority
- Hire-and-reward insurance
- MOT and roadworthiness evidence
- V5C, rental agreement or ownership information
- Permission letter where the provider is not the owner
- Vehicle-class, capacity and luggage suitability
- Compliance concerns, restrictions and expiry dates
Licensing Authority Control
TfL and Hertsmere records assessed according to the correct framework.
Black Fleet London does not treat all driver and vehicle licences as if they were issued by the same authority. The relevant authority must be recorded and the operating arrangement must support lawful delivery.
Transport for London
London private hire licensing
TfL-licensed drivers and vehicles are checked against applicable London private hire requirements and current TfL licence information.
Black Fleet London remains subject to TfL operator obligations, inspection powers and record-keeping requirements.
Hertsmere Borough Council
Locally licensed operating capacity
Hertsmere-licensed drivers, vehicles and operators may be used only where the licensing and subcontracting arrangement is lawful and appropriately controlled.
Hertsmere documentation is recorded as Hertsmere-issued and is not represented as TfL licensing.
Document Validation
A document is not accepted merely because an image was uploaded.
Compliance review considers validity, consistency, ownership, authenticity and whether the document applies to the actual driver, vehicle, operator and period concerned.
Names, photographs, licence identifiers and other personal particulars should correspond.
Registration, make, model and ownership information should identify the same vehicle.
Effective, expiry and issue dates should cover the assignment period.
Issuing authorities and available official records should be checked.
Cover should apply to hire-and-reward use, the vehicle, driver and relevant operating period.
Alteration, inconsistent formatting, missing pages or suspicious particulars should be escalated.
Rental, permission and ownership records should support lawful use.
Required pages, schedules, conditions and endorsements should be available.
Material changes should trigger renewed assessment rather than reliance on historic approval.
Compliance Lifecycle
Qualification, monitoring and restriction through one controlled process.
01
Collect
Obtain required driver, vehicle and operator information.
02
Verify
Check identity, authority, dates, insurance and consistency.
03
Approve
Grant eligibility only after required checks are complete.
04
Monitor
Track expiry, change, incidents and ongoing validity.
05
Restrict
Prevent allocation where compliance is incomplete or doubtful.
06
Reinstate
Restore eligibility only after satisfactory evidence and review.
Expiry and Renewal Control
Expired documentation means no allocation.
Time-limited documents are monitored so that renewal can be requested before expiry. Approval is not assumed to continue merely because a renewal application may have been submitted.
Where current lawful authority or insurance cannot be established, the relevant driver or vehicle must remain unavailable.
Expiry-control actions
- Record relevant expiry dates
- Issue renewal reminders where appropriate
- Request complete replacement evidence
- Recheck validity and document consistency
- Restrict eligibility at or before expiry
- Record temporary extensions only where officially supported
- Reinstate only after satisfactory validation
Compliance-Led Allocation
The approved record must match the person and vehicle assigned.
Allocation should use the actual driver and vehicle intended to perform the booking. An approved supplier relationship does not create blanket approval for every person or vehicle connected to that supplier.
Black Fleet London’s central operating structure supports allocation, record visibility, replacement control and audit history.
Allocation checks include
- Driver eligibility and current licensing
- Vehicle eligibility and current licensing
- Valid hire-and-reward insurance
- Driver-to-vehicle authorisation
- Vehicle class and capacity
- Availability and journey-conflict assessment
- Passenger or contractual requirements
- Active restrictions or unresolved compliance concerns
Replacement and Substitution
No unauthorised driver, vehicle or onward allocation.
The assigned driver or vehicle must not be replaced without the change being reported and accepted through the appropriate operating process.
Report immediately
Notify operations as soon as replacement may be required.
Identify replacement
Provide the proposed driver, vehicle and operator particulars.
Recheck compliance
Confirm current licensing, insurance and suitability.
Await approval
Do not disclose passenger information or proceed without approval.
Update records
Ensure the booking identifies who and what actually delivered it.
Inform the passenger
Issue revised allocation information where required.
Record the reason
Preserve the reason and timing of the operational change.
Review patterns
Repeated replacements may affect supplier eligibility.
Passenger Allocation Information
Passengers should be able to identify the authorised service.
Before travel, Black Fleet London provides or makes available relevant allocation information in accordance with applicable operator requirements and the confirmed booking channel.
Changes to the driver or vehicle should trigger updated information rather than leaving the passenger to accept an unidentified substitute.
Allocation information may include
- Booking reference and journey details
- Driver’s name
- Driver’s private hire licence details
- Driver photograph where required and available
- Vehicle make, model, colour and registration
- Relevant vehicle licence particulars
- Black Fleet London contact route
Hire-and-Reward Insurance
Insurance must cover the journey—not merely exist as a certificate.
Vehicles used for private hire must hold appropriate insurance covering hire-and-reward use. The evidence must relate to the relevant vehicle, driver or fleet arrangement and assignment period.
Where insurance cannot be verified or material doubt remains, the vehicle must not be used until satisfactory evidence is obtained.
Insurance controls
- Review policyholder and vehicle particulars
- Confirm hire-and-reward use
- Review effective and expiry dates
- Check named-driver or fleet application
- Retain relevant certificate and schedule evidence
- Reassess following vehicle or ownership change
- Restrict where cover cannot be established
Roadworthiness and Presentation
Licensing is the minimum—not the complete service standard.
A licensed and insured vehicle may still be unsuitable if affected by a safety defect, material warning, poor condition, inadequate capacity or unacceptable presentation.
Safety systems
Tyres, brakes, lights, glass, seat belts and passenger equipment must be serviceable.
Warning indicators
Material warning lights, shaking, overheating or other serious defects require withdrawal.
Cabin condition
The passenger area should be clean, secure and free from avoidable hazards.
Correct capacity
Passenger and luggage capacity must suit the confirmed booking.
Accessibility
Known mobility and assistance requirements must be considered.
Climate control
Heating, ventilation and cooling should function appropriately.
Service class
Presentation should remain consistent with the confirmed vehicle class.
Defect reporting
Drivers and suppliers must report material defects immediately.
Continuing Duty to Disclose
Material changes must not wait for the next renewal.
Drivers, vehicle providers and licensed operators must notify Black Fleet London promptly where a change may affect legal authority, insurance, roadworthiness, suitability or ability to deliver assignments.
Failure to disclose material information may itself affect continued eligibility, regardless of whether an incident has occurred.
Reportable changes include
- Licence suspension, revocation, expiry or restriction
- Insurance cancellation or material amendment
- Vehicle ownership or rental change
- Collision, serious defect or vehicle prohibition
- Arrest, charge, caution or conviction where reportable
- Medical or driving restriction affecting safety
- Change of operator or subcontracting arrangement
- Suspected falsification or misuse of documentation
Compliance Restriction
Access removed where lawful suitability cannot be demonstrated.
Black Fleet London may restrict a driver, vehicle or supplier from assignments where records are expired, incomplete, inconsistent, apparently fraudulent or affected by a material safety or licensing concern.
A protective restriction may be applied while information is reviewed and does not necessarily represent a final finding.
Restriction triggers may include
- Expired driver or vehicle licence
- Missing or unverified insurance
- Material identity or registration mismatch
- Suspected altered or fraudulent document
- Serious vehicle defect or collision
- Unauthorised substitution
- Failure to disclose a material change
- Regulatory or public-safety concern
Internal Compliance Review
Records tested against actual operating activity
Black Fleet London may sample driver, vehicle, booking, allocation, replacement and insurance records to confirm that approved procedures are followed in practice.
Reviews may be scheduled, risk-based or triggered by an incident, complaint, document anomaly or regulatory development.
Regulatory Inspection Readiness
Records available to authorised inspectors
Relevant staff should be able to locate required booking, driver, vehicle, insurance, complaint and lost-property records when requested by a TfL Authorised Officer.
Records should not be inaccessible merely because one responsible person is absent from the operating centre.
Inspection and Non-Compliance Response
Findings corrected promptly and verified.
Where TfL or an internal review identifies non-compliance, Black Fleet London seeks to understand the finding, protect affected passengers, correct the immediate issue and reduce the likelihood of recurrence.
Formal notices, regulatory correspondence and required actions should be reviewed carefully and escalated to the responsible director.
Corrective response
- Record the finding and applicable requirement
- Restrict affected resources where necessary
- Correct missing or inaccurate information
- Identify process and control causes
- Assign actions and responsible owners
- Provide evidence to TfL where required
- Verify completion and continued effectiveness
Record Control
Accurate, secure and inspection-ready records
Compliance records should be maintained in a form that supports timely retrieval, authorised inspection and clear connection to the relevant driver, vehicle, operator and booking.
Records should be protected against unauthorised alteration, accidental loss and inappropriate disclosure.
Retention
Records retained according to regulatory and operational need
Black Fleet London retains driver, vehicle, booking, complaint and related records for the periods required by applicable private hire legislation, licence conditions and legitimate business needs.
Retention does not permit unlimited use or unnecessary disclosure of personal information.
Licensed Operating Partners
Subcontracting does not remove the need for compliance control.
Where an approved licensed operator supports service delivery, the relevant operator must maintain its own lawful records and controls and cooperate with Black Fleet London’s due diligence.
Black Fleet London may request evidence concerning the actual driver, vehicle, insurance and operating arrangement used for a booking.
Partner requirements
- Maintain a valid operator licence
- Use appropriately licensed drivers and vehicles
- Maintain required booking and allocation records
- Verify hire-and-reward insurance
- Prevent unauthorised onward subcontracting
- Notify Black Fleet London of material changes
- Cooperate with complaints and regulatory enquiries
- Preserve evidence connected to an assignment
Roles and Accountability
Compliance ownership across leadership, operations and suppliers.
01
Director
Owns the policy, oversees regulatory compliance and responds to material TfL findings and licensing risks.
02
Compliance administration
Collects, validates, records and monitors driver, vehicle and operator information.
03
Operations team
Uses approved records during allocation and escalates substitutions, defects and compliance exceptions.
04
Drivers and suppliers
Provide accurate information, maintain lawful status and report material changes immediately.
Monitoring and Assurance
Compliance assessed continuously—not only at onboarding.
Expiry status
Time-limited driver, vehicle and insurance documentation.
Validity checks
Regular checks against available official licensing information.
Insurance changes
Renewal, cancellation and vehicle or driver amendments.
Substitution frequency
Repeated post-allocation driver and vehicle replacements.
Document anomalies
Mismatches, alterations and suspected fraudulent submissions.
Vehicle defects
Breakdowns, warnings, collisions and roadworthiness concerns.
Regulatory findings
TfL inspections, notices and other licensing-authority matters.
Corrective action
Completion and effectiveness of required compliance improvements.
Awareness and Training
Operator responsibilities understood across the business
Relevant staff should understand TfL operator obligations, record access, licensing-authority distinctions, insurance controls, substitution rules and escalation routes.
Staff who may support an inspection should know how to retrieve required records and refer regulatory enquiries appropriately.
Policy Review
Reviewed annually and following regulatory change
This policy is reviewed at least annually and following a material TfL inspection finding, legal development, licensing-authority change or significant compliance incident.
Changes may affect onboarding, validation, allocation, document retention, system controls and supplier requirements.
The operator remains accountable
Black Fleet London’s responsibility is not satisfied by relying solely on a driver, vehicle owner or supplier’s assurance. Proportionate records and verification must support the decision to make operating capacity available.
Related Governance
Compliance supported by connected operational controls.
Health and Safety Policy
Vehicle safety, passenger welfare, risk control and incident response.
Supplier Code of Conduct
Mandatory legal, insurance, conduct and disclosure requirements.
Quality Management Policy
Controlled processes, audit, corrective action and improvement.
Safeguarding and Passenger Welfare Policy
Passenger protection, welfare escalation and safer working boundaries.
Complaints and Service Recovery Policy
Regulatory complaint records, investigation and supplier accountability.
Business Continuity Policy
Controlled replacement, disruption response and service continuity.
Compliance and Corporate Due Diligence
Need licensing, fleet-compliance or operator-assurance information?
Corporate clients and prospective partners may contact Black Fleet London regarding TfL operator licensing, driver and vehicle controls, supplier due diligence, inspection readiness or proportionate supporting evidence.