Heathrow Nexus Chauffeurs

Company number 14916804

Last reviewed: September 2026

1. Our Commitment

Heathrow Nexus Chauffeurs is committed to fair, responsible and inclusive recruitment while maintaining high standards of passenger safety, safeguarding and regulatory compliance.

Having a criminal record does not automatically prevent someone from working with Heathrow Nexus Chauffeurs. Where criminal-record information is lawfully available to us, each case is considered individually, taking into account the requirements of the role, the circumstances of the offence and any potential risk to passengers, the public or our business.

We actively promote equality of opportunity and select candidates on the basis of their skills, experience, qualifications and suitability for the position.

2. Purpose of This Policy

This policy explains how Heathrow Nexus Chauffeurs considers criminal-record information when recruiting or engaging employees, contractors and other personnel.

It supports our obligations as a licensed Transport for London private hire operator and our commitment to treating applicants fairly while protecting passengers and the wider public.

3. Who This Policy Applies To

This policy applies, where relevant, to:

• job applicants;
• employees;
• booking and dispatch staff;
• controllers;
• agency workers;
• contractors and third-party personnel involved in booking or dispatch functions;
• managers and other office personnel; and
• licensed private hire drivers engaged by Heathrow Nexus Chauffeurs.

Different criminal-record checking requirements apply depending on the role.

4. Legal and Regulatory Framework

Heathrow Nexus Chauffeurs operates this policy with regard to applicable legislation and regulatory guidance, including:

• Rehabilitation of Offenders Act 1974;
• Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975, where applicable;
• Data Protection Act 2018;
• UK General Data Protection Regulation;
• Disclosure and Barring Service Code of Practice;
• Transport for London private hire operator licensing requirements; and
• applicable TfL Taxi and Private Hire policies and guidance.

We will only request and consider criminal-record information that we are legally entitled to obtain for the particular role.

5. Fair Recruitment

Heathrow Nexus Chauffeurs will not unfairly discriminate against an applicant simply because they have a criminal record.

Our recruitment decisions are based on the requirements and responsibilities of the individual position.

Where a criminal-record check is required, applicants will be informed of the requirement and the reason for it.

Where relevant information is disclosed, we will normally give the individual an opportunity to discuss the circumstances before a final recruitment decision is made.

We recognise that people can rehabilitate and that previous offending should not automatically prevent someone from obtaining employment where the information is not relevant to the role or where any identified risk can reasonably be managed.

6. Booking and Dispatch Staff

Transport for London requires licensed private hire operators to maintain a register of individuals who take bookings and/or dispatch vehicles.

Accordingly, anyone undertaking these functions for Heathrow Nexus Chauffeurs must satisfy the applicable TfL requirements before beginning those duties.

This includes employees, agency workers, contractors, relevant third-party service providers, family members and any other person carrying out booking or dispatch functions on our behalf.

A Basic DBS check is required for individuals placed on our booking and dispatch staff register. TfL requires the check to be completed and the individual entered on the register before they begin taking bookings or dispatching vehicles. (Transport for London)

A Basic DBS check shows convictions and conditional cautions that are considered unspent under the Rehabilitation of Offenders Act 1974.

Where an individual provides their own Basic DBS certificate, TfL recommends that it should normally have been issued no more than four months before the person is entered on the register. (Transport for London)

7. Spent Convictions

For roles that are not legally exempt from the Rehabilitation of Offenders Act, Heathrow Nexus Chauffeurs will not require applicants to disclose spent convictions and will not take spent convictions into account where we are not legally entitled to do so.

We will only ask questions about convictions or cautions that may lawfully be considered for the particular position.

8. Licensed Private Hire Drivers

Licensed private hire drivers are subject to Transport for London’s separate driver licensing requirements.

TfL is responsible for determining whether an individual is suitable to hold a London private hire driver’s licence, including the appropriate enhanced DBS and other licensing checks.

Heathrow Nexus Chauffeurs will only allocate private hire work to drivers who hold the appropriate valid TfL licence and meet our applicable onboarding and compliance requirements.

Where a booking or dispatch staff member also holds a current London private hire driver’s licence, TfL permits the enhanced DBS obtained for that licence to be used for the booking/dispatch register instead of requiring an additional Basic DBS check. (Transport for London)

9. How We Assess Criminal-Record Information

Where relevant criminal-record information is lawfully disclosed, we assess each case individually.

Factors we may consider include:

• the nature and seriousness of the offence;
• its relevance to the particular role;
• the circumstances surrounding the offence;
• the time that has passed since the offence;
• the individual’s age at the time;
• whether the offence was an isolated incident or part of a pattern;
• subsequent conduct and evidence of rehabilitation;
• employment history and references;
• any explanation provided by the individual;
• the degree of contact with passengers or the public;
• access to passenger, booking, financial or confidential information;
• safeguarding responsibilities;
• any reasonable safeguards that could reduce an identified risk; and
• any applicable legal or TfL requirements.

No individual will normally be rejected solely because a DBS certificate contains criminal-record information.

10. Safeguarding and Positions of Trust

Private hire operations involve significant positions of trust.

Booking staff, dispatch personnel and drivers may have access to information relating to passenger identities, contact details, home addresses, airport arrivals, hotels, travel itineraries and other personal information.

We therefore give particular consideration to offences that may be relevant to passenger safety, safeguarding, trust or the proper performance of the role.

These may include offences involving:

• violence or threats of violence;
• sexual offending;
• children or vulnerable persons;
• exploitation, trafficking or grooming;
• harassment or stalking;
• domestic abuse;
• fraud, theft or serious dishonesty;
• misuse of confidential information;
• serious drug offences; or
• other offences directly relevant to the responsibilities of the position.

The existence of an offence within one of these categories does not automatically create a blanket lifetime exclusion from employment. The circumstances and relevance to the particular role will be considered individually, subject to any legal or regulatory restrictions.

Where an identified safeguarding or public-safety risk cannot reasonably be managed, we may determine that the individual is unsuitable for the relevant position.

11. Existing Employees and New Convictions

Booking and dispatch staff are expected to inform Heathrow Nexus Chauffeurs of new convictions where disclosure is required under their employment or engagement arrangements.

TfL recommends that operators include such a notification requirement in the employment arrangements of booking and dispatch staff. (Transport for London)

Where new relevant information comes to our attention, we will consider the circumstances fairly and carry out an appropriate risk assessment.

Depending on the circumstances, measures may include additional supervision, changes to duties, temporary removal from certain functions or, where justified, termination of employment or engagement.

12. DBS Information and Confidentiality

Information relating to criminal records will be handled confidentially and securely.

Access will be restricted to authorised personnel who require the information for recruitment, compliance, safeguarding or other lawful purposes.

TfL guidance states that once an operator has assessed a DBS certificate, the certificate should not normally be retained or copied and should be returned to the individual. (Transport for London)

Any information we retain will be processed in accordance with applicable UK data-protection legislation and kept only for as long as there is a lawful and legitimate need.

13. Booking and Dispatch Staff Register

Heathrow Nexus Chauffeurs maintains the booking and dispatch staff register required by TfL.

The register contains the information required by TfL, including relevant identity and DBS-check details.

TfL requires register entries to be retained for 12 months after an individual ceases taking or dispatching bookings. (Transport for London)

The register itself is an internal compliance record and is not published publicly because it contains personal information.

14. Reviewing a Recruitment Decision

If an applicant believes a decision concerning criminal-record information was based on inaccurate information or did not properly take relevant circumstances into account, they may ask us to review the decision.

Where appropriate, additional information supplied by the applicant will be considered before the review is concluded.

15. Training and Responsibility

Managers involved in recruitment, onboarding and compliance are expected to understand the requirements relevant to their responsibilities, including:

• Rehabilitation of Offenders Act requirements;
• appropriate levels of DBS checking;
• TfL booking and dispatch requirements;
• fair and proportionate assessment of criminal records;
• safeguarding; and
• appropriate handling of sensitive information.

16. Accessibility

Heathrow Nexus Chauffeurs publishes this policy to make our recruitment and safeguarding approach transparent and accessible to applicants, employees, contractors, passengers and other interested parties.

If you require this policy in an alternative format or need assistance understanding any part of it, please contact us and we will make reasonable efforts to provide an accessible version.

17. Contact Us

Questions about this policy can be directed to:

Heathrow Nexus Chauffeurs
450 Bath Road
Longford, Heathrow
UB7 0EB
United Kingdom

Email: bookings@heathrownexuschauffeurs.com
Telephone: +44 (0)20 4534 7302 , +44 (0)7958512431

Those contact details are consistent with the contact information currently published by Heathrow Nexus Chauffeurs. (Heathrow Nexus Chauffeurs)

18. Policy Review

This policy is reviewed at least annually and may be reviewed sooner following:

• changes to legislation;
• changes to TfL licensing requirements;
• changes to DBS requirements; or
• relevant operational or safeguarding developments.

Last reviewed: September 2026
Next scheduled review: September 2027

Regulatory References

This policy has been prepared with reference to:

• Transport for London – Private Hire Operator Register and Booking Records Guidance
• Transport for London – Private Hire Operator Licensing Requirements
• Disclosure and Barring Service – Recruitment of Ex-Offenders Guidance
• Disclosure and Barring Service – Code of Practice
• Rehabilitation of Offenders Act 1974
• Data Protection Act 2018 and UK GDPR