By Bristol Women’s Voice
Bristol Women’s Voice worked with members to draft a response to the Department of Transport’s inquiry into licensing and standards in the taxis and private-hire vehicles sectors.
You can find a copy of our submission below.
Do current licensing arrangements and tools enable local authorities to effectively regulate and oversee the taxi and private hire vehicle (PHV) sector across England, in terms of safety, accessibility and quality of service? If not, what improvements could be made?
No, current licencing tools and arrangements do not go far enough to ensure safety and accessibility. The local interpretation of the National Standard
We call for:
- Increased mandatory training: adult and child safeguarding training must be supplemented with mandatory training on
- women’s safety and anti-sexual harassment
- disability equality and awareness training.
- equality diversity and inclusion as it relates to supporting access to taxis
- bystander intervention with understanding of effective reporting procedures
- first aid training.
Safeguarding, disability awareness, women’s safety and EDI training should be completed before a driver is issued a licence, even a short term one.
Training should be accessible and available in different languages. Refresher training should also be required at regular intervals.
The regulation should extend to app-based companies (e.g. Bolt, Uber) operating in the area, which should be required to evidence provision or compulsion of this training to their drivers. Apps could pay the council or independent trainers to provide this training for the drivers in their area.
App-based operators should be required to evidence compliance with regional authorities. It might be useful to require them to pay a regional service charge to operate in a given area and to support compliance auditing.
More accessible, consistent and effective reporting and complaints procedures, handled by people trained in sexual harassment, anti-racism, disability awareness and general EDI as well as safeguarding to ensure all reports are appropriate, noted and shared.
What is the impact on the travelling public and drivers of variation between licensing authorities? Is reform needed to bring greater standardisation?
The local interpretation of the National Standard reduces consistency of regulation between areas and therefore reduces safety for vulnerable people because taxi drivers are less accountable to authorities.
We see this variation in the West of England where, for example, training on women’s safety and anti-sexual harassment is possible to incorporate in one area, but reportedly not in another.
Currently if a driver is deemed unfit in one area or, more concerningly, if they have been banned in one area, they can apply to another. This is highly problematic and could easily be avoided if there were a national data base and national policy that was enforced on a more regional basis.
This inconsistency is also made more possible by the lack of adequate complaints processes and procedures,
- which means people do not know how and where to report incidents
- discourage reporting due to lack of faith in the system and the safety of the system
- includes ineffective record holding and information sharing between authorities to prevent this happening.
We strongly feel reform is needed to create standardisation across the country so there is a guarantee of safety and accessibility, and a consistent way to report and received appropriate responses to issues when they arise across all areas.
What would be the practical implications for licensing authorities and operators of more stringent or standardised licensing conditions in respect of safety, accessibility, vehicles and driver conduct?
There would need to be more and appropriately trained staff within the authority to provide a robust and consistent inspection regime. Inspections are carried out currently in Bristol, but with around 59 operators it will be years before all are checked. This isn’t good enough, especially as these reporting structures are poor and reports of disability discrimination and concerns about safety are high.
Staff receiving complaints must receive regular training in safeguarding, women’s safety, anti-racism, disability awareness and EDI so they can respond to complaints appropriately.
More resources would be needed for specialist training, and this would require investment from licensing authorities.
Anonymous reporting structures for concerns and incidents must also be available so that relevant data can be gathered to identify any patterns of problematic behaviour.
A national database must be available, one that notes ‘minor’ concerns as well as more serious code of conduct breaches so as to ensure any patterns of behaviour are recorded and recognised. A points-based system, or ‘three strikes’ type rule should be implemented so as to ensure intervention when there is evidence of such behaviour emergres.
Regional authorities should be held accountable by the Department for Transport for adequate data input.
What steps should the Government take to address the challenges posed by cross-border licensing in the taxi and PHV sector?
We recommend that a single, consistent national policy is implemented consistently on a regional basis, regional licencing, and that PHV could be restricted to the region.
App-based operators should pay a service charge to regional authorities to support the additional requirements for regulation and be required to evidence adherence to the taxi licensing conditions (i.e. training, DBS checks, complaints data, drive data input etc) to the regional licensing authority.
What would effective reform look like in terms of enforcement, passenger safety and safeguarding, and regulatory consistency? Is there a role for regional transport authorities?
As above, Bristol Women’s Voice would urge reforms to ensure
- Mandatory training before being issued with a licence. This should reduce the type of inappropriate and problematic behaviour in taxis that cause women and other more vulnerable people to feel unsafe.
- Licence number clearly visible in a standardised place across all operators – e.g. front and side of the car. Consistency should reduce the frequency people get into unlicensed taxis.
- Requirement for back door locks to be independently accessible to all adult drivers.
- Ability for women and non-binary people to request women drivers.
- A clearer way to check the name and face of the driver who arrives against that of the licence holder as in many cases licences are being shared.
- Effective, confidential and well-advertised complaints/reporting procedures that ensure, and reassure passengers, that:
- Their telephone number and address are immediately blocked from the driver.
- The driver is unable to collect their fare again.
- Their use of services or access to other taxis will not be affected.
- Individual review of all complaints to whether there have been previous complaints, with information added to the national database.
- Active bystander intervention training for all taxi drivers to support their ability to intervene and report where necessary and problematic behaviour with passengers and/or fellow drivers.
- In-car cameras to support passenger and driver safety, with clear policies on how the footage and stored.
- Online and in-app tracking available on digital ride-hailing should be rolled out across all taxi companies, both to improve safety and to help restrict operators to the region where they are licensed.
How are digital ride-hailing platforms impacting standards in the sector, and is further regulation in this area required?
Yes, further regulation in required for this area to provide a more standardised and consistent regulation / standards across all operators. Please see previous responses.
How effective, accessible, and trusted are complaints and incident reporting systems in the taxi and PHV sector, for both passengers and drivers?
The complaints process needs to be strengthened and made more consistent. Reports about current investigation processes are mixed and often disappointing.
At present there is little information available about where and to what end complaints will be treated. Women tell us they are unsure about confidentiality and safety if they complain and reassurance mist be given that their information will be treated in confidence.
We also need anonymous reporting of concerning behaviour in addition to official complaints – this will enable the regional authority to identify patterns and intervene as appropriate.
How effective is the National Register for Revocations, Refusals and Suspensions (NR3S). in supporting consistent licensing decisions across local authorities? What barriers, if any, are limiting its use or impact?
Women are concerned that local authority investigations are not sufficient or consistent.
Furthermore, the lack of consistency means that local licensing department powers are limited in taking action against taxi drivers licensed in a different authority.
The current ability for local interpretation means drivers refused or barred in one area can apply to another and the application must be treated individually. We strongly urge that the rules change so that if a driver is banned in one area, they are banned nationally. Local licencing authorities must also be held accountable if they fail to carry out comprehensive standard checks.
We need a consistent national standard check, with robust and effective audit and investigation processes done at a regional level to reduce the level of inconsistency in licensing metered out across smaller authority areas.
A national database should hold the information. Concerns as well as criminal offences should be logged to support pattern spotting and trend analysis.
Capacity is currently and is likely to remain a barrier to ensure effective impact. New process must be appropriate funded.
What are the implications for taxi and PHV licensing of the future rollout of autonomous vehicles?
These are likely to be safer in some respects for women and other vulnerable passengers. We would want to understand how they can be robustly monitored and safeguarded against hacking or misuse.
Learn more about what Bristol Women’s Voice young women’s street and transport safety project.