Information sharing between police and taxi and PHV licensing authorities
Published 13 October 2025
Introduction
This guidance aims to support effective information sharing between licensing authorities and the police concerning taxi and private hire vehicle (PHV) licensing.
What you need to know about taxi and PHV licensing
- Taxis can be hired immediately on the street, while PHVs must be booked in advance.
- Apart from in London, local councils are responsible for taxi and PHV licensing. They are known as ‘licensing authorities’ and there are 263 in England.
- The purpose of the licensing regime is to safeguard the public. Licensing authorities decide whether someone is ‘fit and proper’ before granting them a driver, vehicle or PHV operator licence.
- Licensing authorities can suspend or revoke licences where concerns are raised that cast doubt on whether the person is fit and proper.
- Licensing authorities make their decisions ‘on the balance of probability’ rather than needing to evidence their decision ‘beyond reasonable doubt’. They can act on the information even if the police do not.
What you need to know about police information sharing powers
- Information about convictions is available to licensing authorities through the Disclosure and Barring Service (DBS) criminal records checks. Enhanced DBS with children’s and adults’ barred list checks are available for taxi and PHV drivers.
- The police have common law police disclosure (CLPD) powers to share information with licensing authorities to mitigate a safeguarding risk if there is an urgent ‘pressing social need’.
- The police also have other methods of sharing safeguarding information with licensing authorities, such as through multi-agency safeguarding hubs.
- Licensing authorities can, in limited circumstances, request information from the police to support their licensing decisions.
- There can be challenges identifying individuals as a taxi or PHV driver or finding the correct licensing authority to report to, which closer collaboration can help to resolve.
How sharing information makes a difference
Collaborative working partnerships between local licensing authorities, the police, DBS and local trade are vital to ensuring effective taxi and PHV regulation, because these organisations will hold information that can critically impact the judgement of whether an individual is ‘fit and proper’.
However, it is worth noting that the principles that licensing and law enforcement must consider in carrying out their duties are different.
Licensing authorities make decisions on the balance of probability, so even if a concern is not proven or provable ‘beyond reasonable doubt’, the licensing authority can still act on it as part of their ‘fit and proper person’ test.
As set out in more detail in common law police disclosure, the police require certain tests to be met to share information with third parties, including licensing authorities.
Case study 1: traffic collision
When a licensed PHV driver was involved in 3 traffic collisions in 4 months, the licensing authority worked closely with the lead police officers from 2 of the collisions they investigated until a single point of contact was appointed.
The first collision was reported by the licence holder, but the second and third were only reported to the licensing authority by the police.
The collisions included hitting a cyclist (breaking their leg) and swerving into a central reservation to avoid hitting a braking lorry.
The licensing authority, as data controller, obtained the CCTV footage from inside the vehicle and relevant booking records, which provided valuable evidence to the police.
Based on the evidence it had gathered and police information, the licensing authority decided the driver was not fit and proper and revoked the driver’s licence with immediate effect.
The police also benefited from information shared by the licensing authority, supplementing their case file.
Through collaboration between the licensing authority and police, the driver had their licence revoked and was prosecuted for the relevant motoring offences in court.
Without this collaboration, the licensing authority may have continued to be unaware of the subsequent collisions and the police would not have access to the vital CCTV evidence.
Case study 2: conspiracy to supply drugs
One of several suspects arrested and interviewed regarding suspected involvement in conspiracy to supply drugs was found by police to be a taxi driver.
Following the arrest, the police Disclosure Unit reviewed the case and, using CLPD provisions, alerted the relevant licensing authority.
The licensing authority was then able to consider whether the driver was still ‘fit and proper’ to hold a licence and whether to revoke it.
Safeguarding or road safety-related licence suspensions or revocations are recorded on a national database used by licensing authorities to safeguard the public if a licence is applied for elsewhere.
Case study 3: child sexual exploitation
A suspect was arrested in relation to a child sexual exploitation investigation. This involved a 14-year-old girl who had been groomed and sexually abused by a male. The victim said that this male had been driving her around the city to different venues in a black vehicle, which was consistently used.
Following arrest, police established that the suspect was a private hire vehicle driver who had abused his position by providing the victim free lifts and driving her to venues where she was sexually abused.
The Police Disclosure Unit reviewed the case and, using CLPD provisions, alerted the relevant licensing authority immediately after arrest.
The licensing authority was able to suspend this driver immediately for safeguarding purposes and his licence was revoked following conviction.
As above, the revocation was recorded on the national database used by licensing authorities to safeguard the public if a licence was to be applied for elsewhere.
Collaboration between police forces and licensing authorities
Information sharing is just one aspect of collaborative working between the police and licensing authorities.
Police and licensing officers are strongly encouraged to work together on taxi and PHV enforcement operations to monitor whether licensed drivers remain fit and proper to hold their licence.
Licensing authorities can only suspend or revoke licences that they have issued and do not have powers to stop and search vehicles, which is why the assistance of the police is so important.
Department for Transport (DfT) statutory taxi and private hire vehicle standards and Local Government Association (LGA) guidance recommend that council taxi and PHV licensing officers maintain close links and meet regularly with their local police force, developing good working relationships to ensure effective and efficient information sharing procedures are in place and being used.
Where strong relationships are developed, effective enforcement can take place. The statutory taxi and private hire vehicle standards also recommend that action taken by licensing authorities as a result of information received should be fed back to the police as part of building an effective working relationship and promoting good practice.
The Information Commissioner’s Office (ICO) provides guidance on the content of data/information sharing agreements.
Overview of the taxi and PHV licensing framework
Taxis are often referred to in legislation and regulation as ‘hackney carriages’ and in common language as ‘black cabs’ and ‘cabs’. The term ‘taxi’ is used throughout this document and refers to all such vehicles. Taxis can be hired immediately by hailing on the street or at a taxi rank.
PHVs include a range of vehicles, including minicabs, executive cars, chauffeur services, limousines and some school and day centre transport services. All PHV journeys must be pre-booked via a licensed PHV operator (even if only a few minutes before the journey, using an app). The term ‘PHV’ is used throughout this document to refer to all such vehicles.
Taxi and PHV licensing in England is undertaken by licensing authorities (district and unitary councils), apart from London where Transport for London (TfL) is responsible. Licensing authorities are responsible for ensuring that the public travels in safe, well-maintained vehicles driven by competent, trustworthy drivers.
Whether someone is fit and proper to be a licensed taxi or PHV driver is not a one-off judgement. Licensing authorities will consider this at the point of application for a licence and any time thereafter if new evidence impacting their original judgement becomes available. Licensing authorities make this decision on the balance of probability, often considering whether they would be satisfied with friends or family travelling in the vehicle alone.
For a PHV service to be legal, the driver, vehicle and PHV operator must all be licensed by the same authority.
But it is crucial to note that drivers do not have to be licensed by the local licensing authority where they live or intend to work. They can be licensed anywhere in the country, and both taxis and PHVs can fulfil pre-booked fares wherever they wish.
However, a licensing authority can only revoke or suspend the licence of a driver, vehicle or operator it has licensed. This means any concerns about a licence holder should be raised with the licensing authority that issued the licence. The name of this authority is displayed on the licence plate attached to the vehicle (some are exempt from displaying a plate) and on the driver’s taxi or PHV licence. Some drivers are licensed by more than one licensing authority.
Home-to-school transport
Taxis and PHVs are also often contracted by local education authorities to provide home-to-school transport.
The local authority that licenses a driver is often different from the local authority contracting the home-to-school transport service, either because it is a 2-tier area, where functions are split between different councils, or because a driver has a school contract in a different area. Where concerns are raised with one authority, they should also be raised with the other. This allows action to be taken against the home-to-school contract and the taxi or PHV licence.
The LGA and Institute of Licensing have published guidance for home-to-school transport and taxi and PHV licensing teams in local authorities to improve collaboration between these 2 functions.
The Department for Education has also published statutory guidance on home-to-school travel.
Safeguarding measures used by licensing authorities
Taxi licensing policy
Licensing authorities should publish a single licensing statement or policy for taxi and PHV licensing. This could include policies on convictions, determining the fit and proper person test, licence conditions and vehicle standards. Local police forces may find this document helpful in understanding the council’s safeguarding procedures.
Fit and proper person test
Licensing authorities must not grant a taxi or PHV driver’s licence, or allow the driver to remain licensed, unless they are satisfied that the applicant is a fit and proper person to hold such a licence. To support these considerations, the statutory taxi and private hire vehicle standards suggest posing the following question:
Without any prejudice, and based on the information before you, would you allow a person for whom you care, regardless of their condition, to travel alone in a vehicle driven by this person at any time of day or night? If, on the balance of probabilities, the answer to the question is ‘no’, the individual should not hold a licence. You should not give them the benefit of the doubt.
If a licensing authority does not think a person is fit and proper, they are entitled to refuse, suspend or revoke a taxi or PHV driver’s licence.
Powers to revoke or suspend a licence
Licensing authorities have a range of powers to take action against unsuitable individuals. At application stage, a licensing authority can refuse a licence if the person is not fit and proper or grant a licence with conditions.
Licensing authorities continue to monitor the fitness of a licensee over the course of a licence and can revoke or suspend licences where concerns are raised that an individual is not suitable to have a licence.
Licensing authorities in England are under a duty to share safeguarding and road safety concerns about taxi and PHV drivers licensed by another authority with the authority that issued the licence. Any licensing authority provided with such information must consider whether to suspend or revoke the driver’s licence and inform the authority that provided the information of its decision.
National Register for Refusals, Revocations and Suspensions database
Since 27 April 2023, councils in England have been required to use the National Register for Refusals, Revocations and Suspensions (NR3S).
The NR3S database provides a mechanism for licensing authorities to record details of where a taxi or PHV driver’s licence has been refused, suspended or revoked due to safeguarding or road safety concerns and allows licensing authorities to check new licence applicants against the register.
The simple objective of NR3S is to prevent an authority unknowingly licensing an individual who has already had a licence refused, suspended or revoked elsewhere on safeguarding and road safety grounds.
DfT has published statutory guidance for licensing authorities in England to support them in using this database.
Further information about licensing authorities’ role in taxi and PHV licensing can be found in the LGA’s Councillor Handbook: Taxi and PHV Licensing.
Routes for law enforcement to share relevant information
The police can share data and information with other stakeholders for the purposes of safeguarding. There are various routes to do this in the context of taxi and PHV licensing, the main one being the disclosure and barring regime, through criminal record checks provided by the DBS.
As well as the disclosure and barring regime, there are different mechanisms under which the police may proactively share information. The most common of these is the CLPD. Alternatively, licensing authorities or others can request this information from the police.
Disclosure and barring regime
The Disclosure and Barring (DBS) regime is designed to protect the public, in particular children and vulnerable adults, while enabling those who have offended in the past to move on with their lives.
The disclosure of relevant criminal records and, where applicable, police information helps employers, and in this case licensing authorities, to make informed decisions about the suitability of an individual for a particular role.
Further, DBS barred lists ensures that those who pose a risk of harm to children or vulnerable adults (due to age, illness or disability) cannot work in “regulated activity” with these vulnerable groups.
Read more about the Disclosure and Barring regime.
Reflecting the extent of the responsibility conferred on taxi and PHV drivers, applicants for taxi/PHV driver licences are eligible for enhanced DBS checks with barred list checks (of both the adults’ and children’s barred lists).
The statutory taxi and private hire vehicle standards recommend that all applicants for a new, or renewal of, a taxi or PHV driver’s licence should be subject to an enhanced DBS with barred lists check. If a driver is found on either or both barred lists, the DBS will provide that information to the licensing authority, which can use it as part of its considerations on whether to license that individual.
The standards state that licensing authorities should have a policy not to issue a licence to any individual who appears on either barred list. Chief officers of police can provide non-conviction information as part of enhanced DBS checks if it is considered relevant and proportionate to do so on a case-by-case basis.
Where taxi and PHV drivers engage in regulated activity, additional considerations apply.
A taxi or PHV driver will be carrying out regulated activity if, as part of an arrangement or contract with a third-party organisation, they drive a vehicle only for children (including anyone supervising or caring for the children) on more than 3 days in a 30-day period.
It is an offence for someone who is barred from regulated activity to seek or work in a role that will be in regulated activity. It is also an offence for an employer to employ a barred person in such a role if they know or have reason to suspect they are barred from working with the relevant group.
The statutory taxi and private hire vehicle standards recommend that where a licensing authority decides to refuse or revoke a licence because the individual is thought to present a risk of harm to a child or vulnerable adult, the relevant information should be referred to the DBS to consider whether to add them to a barred list.
In England and Wales, the DBS offers an update service whereby the current status of standard or enhanced certificates can be checked in real time. Licensing authorities, if given permission to do so by the subject of the check, can confirm the most up-to-date status of a check at any time.
The statutory taxi and private hire vehicle standards recommend that all licensed drivers should be required to evidence continuous registration with the DBS update service to enable the licensing authority to routinely check for new information every 6 months.
Where drivers do not sign up, they should be subject to an enhanced DBS with barred lists check every 6 months. The DBS updates:
- Police National Computer (PNC) information (convictions and cautions) and barred list data weekly
- police intelligence/non-conviction information every 9 months
The Home Office has published statutory disclosure guidance to support the disclosure of information as part of an enhanced DBS check, which chief officers must have due regard to.
Common law police disclosure
The CLPD provisions allow a chief officer, in circumstances where there is an urgent ‘pressing social need’, to disclose information to recipients such as licensing authorities so they can implement measures to mitigate the safeguarding risk evident from the information provided.
Pressing social need is a term derived from case law. As a result, it is not defined in legislation. NPCC guidance states:
A pressing social need might be the safeguarding, or protection from harm, of an individual, a group of individuals, or society at large.
Only the police can initiate disclosure under CLPD. Requests from third parties for information cannot be processed under the CLPD provisions.
CLPD does not give chief officers of police authorities powers to disclose information that would be prohibited from disclosure under any existing legislation. The CLPD provisions require the application of tests of relevance and proportionality to any consideration of disclosure.
In essence, the principles guiding disclosure of non-conviction information on a DBS certificate and disclosure under CLPD are the same. It is for each individual chief officer who holds potentially relevant information to apply the test of “reasonably believes to be relevant to the prescribed purpose and considers ought to be disclosed” on an individual case-by-case basis.
The CLPD provisions are included within Authorised Professional Practice (APP) guidance issued by the College of Policing to all chief officers of police, under the Information Management section.
As well as the principles around relevance and proportionality, which guide decisions regarding the disclosure of non-conviction information under the DBS and CLPD provisions, the police must also consider the potential adverse impact on the prevention or detection of crime. This would include, but is not limited to, information that:
- is considered under judgement in terms of court proceedings
- relates to police operations of which the subject is unaware, such as covert operations or communications interceptions
Wider safeguarding powers/provisions
Other legislation exists that either imposes an obligation on, or provides a power to, chief officers to share information with a range of partners, which could in certain circumstances, include licensing authorities. The force will need to decide as to which organisations it is appropriate to share such information with, depending on the relevant legislation.
Examples of legislative gateways include, but are not limited to the:
- Crime and Disorder Act 1998: provides for sharing via Community Safety Partnerships, which includes facilitating multi-agency responses to antisocial behaviour
- Children Act 2004 (as amended by the Children and Social Work Act 2017): provides for sharing between key organisations that have a duty to work together in safeguarding and promoting the welfare of children in their area
- Criminal Justice Act 2003: provides arrangements for assessing the risk posed by different offenders particularly sexual and violent offenders and those who may cause serious harm to the public (this includes children)
Any local authority department receiving police information is accountable for determining whether subsequently providing that information to another part of the authority (such as the licensing department) is lawful and permissible under the terms of any information sharing agreement in place.
Requesting information from the police
Where a licensing authority believes it requires information from the police to carry out its licensing functions, the authority can request it from the force, providing evidence that an appropriate legislative provision exists to support the sharing of that information.
Requests can generally be made to Public Access, Information Management, Information Rights or Data Protection departments within local police services.
The police will then need to assess whether sharing any additional information is proportionate and relevant. A number of requests may not satisfy those principles.
The police may recover expenses for the provision of data where it is not a core policing function and there is no statutory obligation for police to provide it.
The provision of information at the request of regulatory bodies (such as the General Medical Council, the Teaching Regulation Agency, for example) and licensing authorities (such as the Security Industry Authority, local authorities, for example) may, therefore, be subject to the NPCC National Policing Guidelines on Charging for Police Services.
Mechanics of information sharing
In circumstances where the matter under investigation by the police occurred while the individual is actively performing a taxi or PHV driver role, their identification as a licensee is straightforward.
However, there is no statutory obligation for any individual to provide the police with details of their occupation. Unless the individual provides such information, or it is already held on police systems, the chief officer may not be aware that the individual holds a taxi or PHV licence.
In addition, without access to the driver’s taxi or PHV licence or the vehicle licence plate, identification of which authority issued the licence can also be problematic, hindering police in any efforts to communicate with the relevant licensing authority.
If a police officer would like to know which authority has licensed a driver, vehicle or operator, they should contact the local licensing authority, which will be able to advise if it issued the licence and, if it has not, it may be able to give some advice about next steps.
Where a licensing authority becomes aware of safeguarding or road safety concerns about a licensed driver operating in its area but licensed by another authority, it is under a duty to report those concerns to the relevant authority which, in turn, must consider whether to suspend or revoke that licence.
This guidance was produced following consultation with a working group comprising of the Department for Transport, Home Office, Disclosure and Barring Service, National Police Chiefs’ Council, Institute of Licensing, Local Government Association and the National Association of Licensing and Enforcement Officers.