The passenger appears unusually frightened, withdrawn, distressed or afraid of another person.
TfL Licensed Private Hire Operator
Safeguarding and Passenger Welfare Policy.
Black Fleet London is committed to protecting children, adults at risk, vulnerable passengers and every person whose safety or welfare may be affected by a journey delivered through our operation.
Black Fleet London Ltd is licensed by Transport for London as a private hire operator. Safeguarding responsibility extends across booking, dispatch, communication, allocation, passenger contact, journey delivery and incident escalation.
Purpose
Preventing harm and responding when welfare concerns arise.
The purpose of this policy is to establish how Black Fleet London identifies, prevents, reports and responds to concerns involving abuse, exploitation, neglect, coercion, sexual misconduct or other risks to passenger welfare.
Safeguarding is not limited to child transport. It includes adults whose health, disability, circumstances or care and support needs may make them more vulnerable to abuse, neglect or exploitation.
Scope of this policy
- Children and young people under 18
- Adults at risk of abuse, neglect or exploitation
- Passengers affected by disability, illness or cognitive impairment
- Unaccompanied or separated passengers
- Passengers affected by distress, intoxication or disorientation
- Suspected trafficking, coercion or exploitation
- Sexual misconduct, harassment and inappropriate behaviour
- Welfare incidents arising before, during or after a journey
Policy Statement
Passenger welfare takes priority over commercial convenience.
No booking value, client status, operational target or supplier relationship should prevent appropriate action where a passenger may be at risk of harm.
01
Welfare first
Immediate safety and welfare should take priority over routine journey completion.
02
Do not ignore concerns
A concern should not be dismissed merely because complete proof is not available.
03
Listen respectfully
A passenger should be listened to calmly without blame, interrogation or disbelief.
04
Share appropriately
Safeguarding information should be shared only where necessary and proportionate.
05
Do not investigate personally
Service personnel should report concerns rather than conduct an unauthorised investigation.
06
Preserve evidence
Relevant messages, records and factual observations should be protected.
07
No retaliation
Retaliation against a passenger, witness or reporting person is not tolerated.
08
Escalate proportionately
The response should reflect the urgency, seriousness and nature of the risk.
Operator Responsibility
Safeguarding begins before the vehicle reaches the passenger.
Black Fleet London’s responsibilities include accepting accurate bookings, selecting suitable licensed operating capacity, communicating relevant requirements, protecting passenger information and maintaining operational visibility throughout the assignment.
Book safely
Capture relevant age, welfare, assistance and handover information.
Allocate carefully
Select suitable licensed capacity for the known requirement.
Monitor actively
Maintain contact and respond to material journey exceptions.
Escalate responsibly
Refer welfare concerns to an appropriate authority where needed.
Children and Young People
Additional care where a passenger is under 18.
A person under 18 is treated as a child for safeguarding purposes. Bookings involving children should clearly identify the responsible booker, collection arrangements, authorised handover and any relevant assistance requirement.
Black Fleet London does not assume parental responsibility. The operator’s role is to deliver the confirmed transport safely and to act appropriately if the agreed arrangements fail or a welfare concern arises.
Child-journey controls may include
- Confirming the age or age range where relevant
- Recording the responsible adult or organisation
- Identifying authorised collection and handover contacts
- Confirming whether the child travels accompanied
- Recording relevant seat or accessibility requirements
- Avoiding unauthorised changes to the destination
- Escalating any failed handover or unexpected absence
- Protecting the child’s identity and itinerary
Unaccompanied Young Passengers
Acceptance subject to clear arrangements and operational approval.
An unaccompanied child journey should not be treated as an ordinary adult transfer. The booking must be assessed before acceptance and may be declined where suitable safeguards cannot be established.
The child must not be left alone at an uncertain location merely because the booked journey has reached its stated destination.
Before acceptance, confirm
- Identity and contact details of the responsible booker
- The child’s age and ability to travel independently
- Named collection and receiving persons
- A secure handover method
- Contingency arrangements if the receiving person is absent
- Relevant medical, communication or mobility information
- Whether additional contractual safeguards are required
Failed handover
Where an authorised receiving person cannot be located, the child should remain in a safe and supervised situation while Black Fleet London contacts the responsible booker and determines an appropriate next step. Emergency or safeguarding authorities should be contacted where risk cannot be resolved safely.
Adults at Risk
Individual circumstances considered without removing independence.
An adult may be at greater risk because of care and support needs, disability, illness, frailty, cognitive impairment, coercion, dependency or other personal circumstances.
Vulnerability should not be assumed solely from age, appearance or disability. Service personnel should respect the passenger’s autonomy while responding appropriately to clear signs of danger, distress, abuse or neglect.
Additional care may involve
- Allowing reasonable additional boarding time
- Confirming a safe collection or handover arrangement
- Communicating clearly and patiently
- Avoiding assumptions about mental capacity
- Respecting mobility and assistance requirements
- Identifying unexplained distress or fear
- Escalating suspected abuse, coercion or neglect
Indicators of Concern
Warning signs should be considered together with context.
A single sign does not necessarily establish abuse or exploitation. However, unusual combinations of behaviour, injury, fear, control or inconsistent information may justify escalation.
Another person speaks for the passenger, controls documents, money, communication or movement.
The passenger appears unaware of the destination, purpose or person arranging the journey.
Visible injury, pain, poor condition or signs of possible neglect without a clear explanation.
A child or vulnerable passenger is expected to enter an uncertain, isolated or apparently unsafe situation.
Inappropriate sexual comments, touching, grooming, exploitation or behaviour causing discomfort.
Frequent unusual journeys, multiple addresses or movements suggesting exploitation or trafficking.
The passenger is prevented from speaking privately, making a call or retaining personal documents.
A passenger is left without support despite apparent care, health or communication needs.
Exploitation and Trafficking
Transport must never facilitate abuse or exploitation.
Private hire services may be misused to move individuals who are being sexually exploited, criminally exploited, trafficked, coerced or controlled.
Service personnel should not place themselves or the passenger in greater danger through confrontation. Relevant observations should be reported promptly through the appropriate emergency or safeguarding route.
Where exploitation is suspected
- Prioritise immediate safety
- Avoid confronting a suspected controller
- Do not promise complete secrecy
- Record factual observations rather than assumptions
- Note relevant locations, times and vehicle information
- Contact emergency services where danger is immediate
- Notify Black Fleet London without unnecessary delay
Sexual Misconduct and Harassment
Zero tolerance for sexualised or predatory conduct.
Sexual comments, unwanted questions, staring, exposure, touching, propositions, requests for personal contact or any other sexualised behaviour towards a passenger are incompatible with Black Fleet London service.
A serious allegation may result in immediate protective restriction from assignments while the matter is referred and assessed.
Prohibited behaviour includes
- Comments about a passenger’s body or appearance
- Intrusive questions about relationships or sexual activity
- Unwanted touching or physical contact
- Showing sexual content or exposing oneself
- Requesting dates, personal contact or social-media access
- Following or contacting a passenger after the journey
- Exploiting intoxication, disability or dependency
Reporting sexual misconduct
Where sexual harassment or a sexual offence is alleged, passenger safety should be addressed immediately. The passenger should be supported to contact the police, and Black Fleet London should preserve relevant booking, allocation and communication records.
Safer Working Boundaries
Professional boundaries protect passengers and service personnel.
No private relationship
Do not use journey access to pursue personal, romantic or commercial contact.
No unnecessary touching
Physical assistance should be appropriate, explained and limited to the genuine need.
No private photography
Do not photograph or record passengers without proper authority and lawful purpose.
No personal gifts
Do not give children or vulnerable passengers unauthorised gifts, money or personal items.
No destination changes
Do not change a child or vulnerable passenger’s destination without authorised instruction.
No unnecessary isolation
Avoid situations that create unnecessary secrecy or isolation outside the transport requirement.
No confidentiality promises
Do not promise to keep abuse or safety disclosures secret.
No unauthorised passenger
No unauthorised person may accompany or participate in the assignment.
Responding to a Disclosure
Listen calmly and pass the concern to the right people.
A passenger may disclose abuse, fear, coercion or neglect during a journey. The person receiving the disclosure should remain calm and avoid asking leading or investigative questions.
The passenger should be told that information may need to be shared with appropriate people to protect them or another person.
Recommended response
- Listen without interruption where safe
- Take the concern seriously
- Avoid blame or expressions of disbelief
- Do not ask the passenger to repeat unnecessary detail
- Explain that the concern may need to be shared
- Record the passenger’s own words where possible
- Report immediately through the appropriate route
Emergency Response
Immediate danger requires immediate action.
Routine internal reporting must not delay emergency assistance where a child, adult or member of the public faces immediate danger, serious injury or a crime in progress.
Protect life and safety before protecting the journey schedule.
Stop safely
Move to a safe location where circumstances require it.
Call emergency services
Use 999 where danger, serious injury or crime is immediate.
Stay available
Remain with the passenger where safe and appropriate.
Notify operations
Inform Black Fleet London as soon as emergency action permits.
Safeguarding Response Process
A controlled path from observation to appropriate action.
01
Recognise
Identify a disclosure, warning sign or unusual welfare concern.
02
Protect
Address immediate danger, injury or unsafe circumstances.
03
Listen
Receive information calmly without conducting an interrogation.
04
Record
Document factual observations, times and the person’s own words.
05
Escalate
Refer the concern through internal, police or safeguarding routes.
06
Review
Protect records and complete proportionate corrective action.
Missing, Separated or Abandoned Passengers
Unexpected absence or abandonment treated as a welfare concern.
Where a child, adult at risk or otherwise vulnerable passenger cannot be located, is separated from their group or appears to have been abandoned, the situation should be escalated promptly.
Service personnel should not leave a vulnerable passenger in an unsafe or uncertain location solely because the booked waiting period has ended.
Response considerations
- Confirm the last known location
- Contact the responsible booker or authorised contact
- Inform Black Fleet London operations
- Avoid unsafe independent searching
- Contact venue, airport or station personnel where appropriate
- Contact police where the risk justifies it
- Record the actions taken and outcome
Intoxication, Distress and Disorientation
Impairment increases the need for professional boundaries.
A passenger affected by alcohol, medication, illness, distress or disorientation may be less able to protect their own interests.
The passenger’s condition must never be exploited. Where safe transport cannot reasonably be completed, the matter should be escalated and appropriate assistance considered.
Welfare expectations
- Maintain professional and physical boundaries
- Avoid unnecessary handling or restraint
- Confirm the intended destination where possible
- Do not abandon the passenger in an unsafe location
- Seek medical assistance where condition causes concern
- Contact a responsible person where appropriate
- Record material welfare or conduct concerns
Confidentiality and Information Sharing
Privacy should not prevent necessary safeguarding action.
Safeguarding information is sensitive and should not be circulated unnecessarily. However, confidentiality should not be used as a reason to ignore a credible risk of serious harm.
Information sharing should be necessary, proportionate, relevant, accurate, timely and limited to an appropriate recipient.
Information controls
- Share only information relevant to the safeguarding purpose
- Use secure and authorised communication routes
- Distinguish facts from suspicion or opinion
- Avoid discussing concerns with unrelated parties
- Protect the identity of the passenger and reporting person
- Retain records according to legal and operational need
- Record significant sharing decisions
Safeguarding Records
Factual, secure and sufficiently detailed
A safeguarding record should identify the relevant journey, time, location, persons involved, observations, words disclosed and actions taken.
Records should avoid speculation, inflammatory language or unsupported conclusions.
Evidence Preservation
Operational evidence protected from alteration
Relevant booking, allocation, communication, status and supplier records should be preserved where a material welfare or misconduct concern is raised.
No person should delete, alter or fabricate information connected to a safeguarding concern.
Supplier and Operating-Partner Standards
Safeguarding requirements extend through the operating network.
Licensed private hire operators and suppliers supporting Black Fleet London must cooperate with safeguarding controls, reporting and investigation.
A serious concern involving a service participant may result in immediate protective restriction while the matter is assessed.
Mandatory supplier expectations
- Use appropriately licensed and authorised personnel
- Communicate applicable safeguarding expectations
- Report concerns immediately
- Preserve relevant records
- Do not contact or influence the passenger improperly
- Cooperate with police, TfL or safeguarding enquiries
- Implement proportionate corrective action
- Disclose material suitability concerns
Protective Restriction
Immediate controls where passenger safety may be affected.
Black Fleet London may temporarily prevent an individual, vehicle, supplier or account from receiving or delivering assignments where a credible safeguarding or serious-conduct concern requires protection.
A protective restriction does not itself determine guilt. It allows risk to be controlled while information is assessed and appropriate authorities are engaged.
Restriction may be considered for
- Alleged sexual or violent misconduct
- Suspected exploitation or trafficking
- Serious boundary violations
- Unexplained child or vulnerable-passenger incidents
- Retaliation or witness interference
- Falsified safeguarding records
- Failure to cooperate with a serious enquiry
Safeguarding Awareness
Awareness proportionate to role and passenger contact
Personnel involved in booking, dispatch, passenger communication and service delivery should understand common safeguarding indicators, professional boundaries and escalation routes.
Black Fleet London supports safeguarding-awareness learning relevant to the taxi and private hire sector and may require evidence or additional instruction according to role and contract.
Refresher Communication
Lessons reinforced through incidents and operational change
Guidance may be refreshed following a safeguarding concern, legal change, TfL instruction, client requirement or identified weakness in operating practice.
Training must not replace immediate escalation where a real passenger is at risk.
Roles and Accountability
Safeguarding responsibility assigned across the operation.
01
Director
Owns the policy, oversees serious concerns and determines material protective, regulatory or contractual action.
02
Operations team
Identifies booking risks, maintains journey oversight and escalates welfare concerns through appropriate routes.
03
Licensed operating partners
Ensure relevant personnel understand expectations and cooperate with safeguarding action and evidence requests.
04
Authorised service personnel
Maintain professional boundaries, recognise concerns and report any passenger-welfare risk promptly.
Monitoring and Improvement
Safeguarding experience used to strengthen controls.
Black Fleet London may review safeguarding reports, passenger complaints, failed handovers, boundary concerns, supplier responses and corrective actions to identify recurring risk.
Welfare incidents
Type, seriousness and circumstances of reported passenger concerns.
Failed handovers
Child or vulnerable-passenger collections and handovers that did not proceed as planned.
Supplier concerns
Patterns connected to particular operators, individuals or operating arrangements.
Reporting speed
Whether concerns were escalated promptly and through the correct route.
Record quality
Completeness, accuracy and security of safeguarding records.
Protective action
Restrictions, referrals and immediate controls applied where necessary.
Corrective action
Improvement measures completed and reviewed for effectiveness.
Training needs
Areas where greater awareness or additional guidance is required.
Policy Review
Reviewed against regulation, incidents and operating experience
This policy should be reviewed at least annually and following a serious welfare incident, material TfL requirement, significant client contract or relevant legal development.
Review outcomes may include revised booking controls, escalation routes, supplier conditions, training or technical safeguards.
Breach of Policy
Serious breaches may result in immediate restriction
Failure to report a serious concern, sexual misconduct, exploitation, retaliation, evidence interference or deliberate disregard of passenger safety may result in removal from assignments or termination of the relevant relationship.
Matters may also be referred to TfL, the police, safeguarding authorities or another competent body where appropriate.
Safeguarding is shared responsibility
No person involved in a Black Fleet London journey should assume that someone else will report a credible concern. Where a passenger may be at risk, appropriate action should be taken promptly.
Related Governance
Passenger protection supported by connected controls.
Health and Safety Policy
Passenger safety, risk control, incident response and welfare.
Complaints and Service Recovery Policy
Complaint investigation, safety escalation and passenger remedies.
Supplier Code of Conduct
Mandatory passenger-care, conduct and incident-reporting standards.
Equality, Diversity and Inclusion Policy
Dignity, accessibility, reasonable adjustments and fair treatment.
Data Protection Policy
Secure and proportionate handling of sensitive passenger information.
Whistleblowing Policy
Protected reporting of serious wrongdoing and public-interest risks.
Safeguarding and Passenger Support
Need to report a safeguarding or passenger-welfare concern?
Contact Black Fleet London with the booking reference, relevant facts and any immediate safety concern. Where someone is in immediate danger, contact the emergency services first.