Children
Anyone under 18, whether accompanied or travelling under an expressly approved arrangement.
TfL Licensed Private Hire Operator
Safeguarding and Passenger Welfare Policy.
Black Fleet London is committed to protecting children, adults at risk and every passenger who may be exposed to abuse, exploitation, neglect, coercion, medical distress or another welfare concern during a private hire journey.
Black Fleet London Ltd is licensed by Transport for London. Safeguarding responsibility applies throughout booking, dispatch, driver allocation, passenger contact, journey delivery, incident reporting and service review.
Purpose
Recognise risk, protect the passenger and report concerns.
The purpose of this policy is to define how Black Fleet London personnel, chauffeurs and licensed operating partners should prevent, recognise, respond to and report passenger-welfare and safeguarding concerns.
No commercial pressure, client status, chauffeur relationship or concern about reputational impact should prevent appropriate protective action.
Scope of this policy
- Children and young people under 18
- Adults at risk or in need of additional support
- Passengers experiencing abuse, neglect or coercion
- Human trafficking and modern slavery indicators
- County-lines and criminal exploitation concerns
- Sexual misconduct, harassment and grooming
- Medical, intoxication and incapacity concerns
- Missing, uncontactable or unsafe passengers
Safeguarding Commitment
Passenger safety is the overriding consideration.
Black Fleet London expects every person involved in booking, dispatch or journey delivery to remain alert to signs that a passenger may be unsafe, controlled, frightened, exploited, unwell or unable to protect themselves.
Notice
Remain alert to behaviour, circumstances and disclosures.
Protect
Take proportionate steps to prevent immediate harm.
Report
Inform the operator and police where required.
Preserve
Record facts and protect relevant evidence.
Who May Be at Risk?
Vulnerability may arise from age, circumstances or inability to protect oneself.
Adults at risk
Adults who need care or support and may be unable to protect themselves from abuse or neglect.
Temporarily vulnerable
Passengers affected by illness, injury, intoxication, shock, exhaustion or emotional distress.
Controlled passengers
People whose money, communication, movement or decisions appear to be controlled by another person.
Possible Indicators
One sign may not prove abuse—but concerns must not be ignored.
Chauffeurs are not expected to investigate or diagnose abuse. Their role is to notice concerning circumstances, remain professional, protect the passenger where immediate action is necessary and report what they saw or heard.
Warning signs may include
- A frightened passenger being controlled by another person
- A child travelling to meet an unknown adult
- Young or vulnerable passengers taken to hotels at unusual hours
- Visible injury, neglect, hunger or poor physical condition
- A passenger unable to retain their own money or documents
- Signs of drug, sexual or criminal exploitation
- A passenger repeatedly moved between unfamiliar locations
- A direct statement that the passenger is unsafe or needs help
Children and Young Passengers
Unaccompanied travel only under an expressly approved arrangement.
Black Fleet London does not treat the transport of an unaccompanied child as an ordinary adult booking. The arrangement must be identified before allocation and accepted only where the journey can be managed safely and lawfully.
The chauffeur must know the approved collection and receiving arrangements and must not independently change them.
Required controls may include
- Authorised adult booking the journey
- Child’s name and relevant age information
- Named collection and receiving adults
- Verified contact routes for responsible adults
- Clear pickup and handover instructions
- Appropriate child-seat information where applicable
- No change of destination without operator approval
- Escalation where the receiving adult is absent or disputed
Never leave a child at an unsafe or unverified destination
Where the authorised receiving adult cannot be identified or contacted, the chauffeur must remain in communication with Black Fleet London and follow operator or emergency-service instructions. A child must not be handed to an unverified person or left alone merely to complete the booking.
Professional Boundaries
Access to a passenger must never be used for personal, sexual or financial benefit.
Do not contact a passenger after the journey for social, romantic or personal reasons.
Sexual comments, propositions, touching or activity with a passenger are prohibited.
Do not offer gifts, free journeys, alcohol, money or favours to create influence or dependence.
Do not photograph or record a passenger without a lawful, approved and necessary reason.
Do not divert the passenger to private work outside the licensed operator.
Physical assistance must be limited to what the passenger requests and what is safely necessary.
Never threaten, shame or contact a passenger because they complained.
Never take advantage of intoxication, confusion, disability or emotional distress.
Passenger details may only be used to complete the assigned journey.
Trafficking and Exploitation
Private hire journeys must never facilitate abuse or coercion.
Chauffeurs may encounter passengers affected by human trafficking, modern slavery, sexual exploitation, forced labour, domestic abuse or county-lines criminal exploitation.
The chauffeur must not confront a suspected exploiter where doing so could increase danger. Immediate risk should be reported to police.
Potential indicators
- Another person holds the passenger’s documents or money
- The passenger appears coached on what to say
- The passenger is frightened to speak freely
- Repeated journeys to hotels, private addresses or isolated sites
- Unexplained young passengers travelling at unusual hours
- Signs of violence, threats, sexual exploitation or drug control
- The passenger asks for police, medical or safeguarding help
- The passenger appears unable to leave or make independent decisions
Intoxication and Incapacity
An impaired passenger must not be treated as an inconvenience.
A passenger affected by alcohol, drugs, illness or another condition may be unable to communicate, protect themselves or reach their destination safely.
Chauffeurs should remain calm, avoid judgement and contact Black Fleet London where the passenger’s welfare or ability to travel safely is in doubt.
Required welfare considerations
- Whether the passenger can communicate their destination
- Whether the passenger can enter and leave the vehicle safely
- Whether a responsible person is available at the destination
- Whether there are signs of overdose, injury or medical distress
- Whether another person appears to be exploiting the passenger
- Whether continuing the journey creates danger
- Whether emergency medical assistance is required
Medical and Immediate Welfare Emergencies
Call emergency services where life, health or immediate safety is at risk.
Stop safely
Bring the vehicle to a safe position without creating further danger.
Call 999
Request police, ambulance or other emergency assistance as appropriate.
Follow instructions
Follow emergency-service guidance and provide first aid only within your competence.
Notify operations
Inform Black Fleet London when safe to do so and preserve the incident record.
Do not prioritise the booking over emergency care
A chauffeur must not continue towards the destination merely to complete the job where a passenger appears unconscious, seriously unwell, injured or in immediate danger.
Passenger Disclosures
Listen carefully, remain calm and do not promise secrecy.
A passenger may directly disclose abuse, exploitation, violence or fear. The chauffeur should listen, reassure the passenger that the concern is being taken seriously and avoid conducting an interrogation.
Appropriate response
- Listen without expressing disbelief or blame
- Use the passenger’s own words where recording the disclosure
- Do not ask leading or unnecessary questions
- Do not promise that information will remain secret
- Explain that help may need to be requested
- Call 999 where immediate danger exists
- Report the concern to Black Fleet London promptly
- Preserve relevant booking and journey information
Reporting and Escalation
Emergency risk to 999. Other police concerns to 101 and the operator.
01
Recognise
Identify concerning behaviour, circumstances or disclosure.
02
Assess
Determine whether immediate danger or medical risk exists.
03
Protect
Take safe proportionate steps without increasing risk.
04
Report
Call 999 in an emergency or 101 for other police concerns.
05
Record
Document facts, times, locations and action taken.
06
Review
Protect evidence and determine further operator action.
Safeguarding Records
Factual, restricted and connected to the relevant booking.
Black Fleet London maintains proportionate records of safeguarding concerns, action taken, external reports and operational decisions.
Records must distinguish observed facts, passenger statements and professional assumptions.
A record may include
- Booking and journey reference
- Date, time and relevant locations
- Passenger and service-participant details
- Exact concern or disclosure
- Observed behaviour or physical indicators
- Police or emergency-service contact reference
- Immediate protective action
- Restriction, investigation and final outcome
Confidentiality and Information Sharing
Confidentiality supports safeguarding—but does not prevent necessary reporting.
Safeguarding information should be restricted to people who need it to protect the passenger, investigate the concern or meet a legal or regulatory duty.
Information rules
- Share only what is necessary for protection or investigation
- Do not discuss concerns with unrelated drivers or passengers
- Never provide client or booker email addresses to chauffeurs
- Use operational passenger contact details only after allocation
- Do not retain passenger information for personal use
- Preserve evidence where police or regulatory review is anticipated
- Report unauthorised disclosure immediately
Allegations Against a Chauffeur or Supplier
Protective action may be taken before a final finding.
Where an allegation concerns violence, sexual misconduct, exploitation, inappropriate contact, discrimination or another safeguarding risk, Black Fleet London may temporarily restrict the individual or supplier from assignments.
A temporary restriction protects passengers and evidence. It does not by itself establish guilt.
Protective response may include
- Immediate removal from the active booking
- Temporary suspension from future allocations
- Preservation of messages, status and allocation records
- Passenger welfare contact through the operator
- Police notification where a possible crime is alleged
- TfL or licensing-authority referral where appropriate
- Supplier investigation and contractual action
- Documented reinstatement or permanent removal decision
Licensed Operating Partners
Safeguarding responsibility follows the booking through the supply chain.
A licensed operating partner must provide safeguards comparable to those required by Black Fleet London and must ensure that the actual chauffeur understands the relevant passenger-welfare requirements.
A partner may not conceal a concern, substitute an unapproved chauffeur or handle an allegation privately without informing Black Fleet London.
Partner requirements
- Use appropriately licensed and suitable chauffeurs
- Communicate safeguarding instructions before service
- Prevent unauthorised onward subcontracting
- Report concerns and allegations immediately
- Preserve booking, communication and driver records
- Cooperate with police, TfL and operator enquiries
- Protect passengers from retaliation
- Implement corrective action where required
Roles and Accountability
Safeguarding responsibility across leadership, dispatch and journey delivery.
01
Director
Owns the policy and oversees serious allegations, regulatory reporting and permanent restrictions.
02
Operations team
Records requirements, manages immediate escalation and preserves the booking and incident history.
03
Licensed operating partners
Provide suitable chauffeurs, communicate concerns and cooperate with protective action.
04
Chauffeurs
Remain professional, recognise indicators, protect passengers and report concerns promptly.
Monitoring and Assurance
Safeguarding assessed through records, complaints and operational evidence.
Incident reporting
Whether concerns were escalated promptly and accurately.
Passenger complaints
Patterns involving conduct, contact or unsafe handover.
Allocation controls
Whether the correct chauffeur and welfare instructions were used.
Corrective action
Whether warnings, restrictions and improvements were completed.
Awareness and Training
Safeguarding expectations communicated before assignments
Relevant staff, chauffeurs and operating partners should understand children and adults at risk, trafficking indicators, professional boundaries, emergency escalation and factual record keeping.
Additional guidance may be required following an incident, complaint, TfL development or identified operating weakness.
Policy Review
Reviewed against TfL expectations and safeguarding experience
This policy should be reviewed at least annually and following a serious passenger-welfare incident, regulatory change, police referral or repeated supplier failure.
Changes may affect booking controls, driver eligibility, escalation, record retention, training and supplier requirements.
Our safeguarding principle
A chauffeur may be the only person who notices that something is wrong. Black Fleet London therefore expects concerns to be taken seriously, reported promptly and handled with discretion, evidence and passenger protection at the centre of the response.
Related Governance
Safeguarding supported by connected passenger and operator controls.
Driver Conduct and Professional Standards Policy
Professional boundaries, confidentiality and chauffeur behaviour.
Accessibility and Assistance Dog Policy
Disability, mobility support and reasonable adjustments.
Complaints and Service Recovery Policy
Complaint investigation, police escalation and passenger remedies.
Data Protection Policy
Sensitive information, confidentiality and lawful sharing.
Booking Records and Dispatch Control Policy
Passenger details, controlled allocation and audit history.
Whistleblowing Policy
Confidential reporting of concealed wrongdoing and passenger risk.
Passenger Welfare
Have a welfare or safeguarding concern connected to a journey?
Contact Black Fleet London promptly with the booking reference and relevant facts. Where anyone is in immediate danger, contact the emergency services first by calling 999.