HFC Privacy Policy
HFC Travel Services Ltd are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection Act 1998 (the “Act”), the data controllers are HFC Travel Services Ltd
1. INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
2. IP ADDRESSES AND DEVICE INFORMATION
2.1 We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
2.2 We may collect information about your mobile telephone or handheld device (“Device”) or any computer you may use to download or stream a copy of our app onto your Device, including, where available the Device’s or Computer’s unique Devise identifiers, operating system, browser type and mobile network information as well as the Device’s telephone number, for system administration.
2.3 When you use one of our location-enabled services, we may collect and process information about your actual location. Some of our services require your personal data for the feature to work. If you wish to use a particular feature, you will be asked to consent to your data being used for this purpose. Your consent can be withdrawn at any time by switching off the location-based services on your Device. If you require further details of how we use location based services, you can request such information by contacting us on our website.
3. COOKIES
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies. More details on how we use cookies can be found on the Cookie Policy page.
4. WHERE WE STORE YOUR PERSONAL DATA
4.1 The data that we collect from you is not transferred to, nor stored at, a destination outside the European Economic Area (“EEA”). Staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
4.2 All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.
4.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site or our app; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
5. USES MADE OF THE INFORMATION
5.1 We use information held about you in the following ways:
5.2 We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or permitted third parties may contact you about these by post, email or telephone.
5.3 If you are an existing customer of ours, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which we have previously supplied to you.
5.4 If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
5.5 If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please let us know by ticking the relevant box situated on the form on which we collect your data.
6. DISCLOSURE OF YOUR INFORMATION
6.1 We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
6.2 We may disclose your personal information to third parties:
7. YOUR RIGHTS
7.1 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
7.2 You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us on our website.
7.3 Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
8. ACCESS TO INFORMATION
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.
9. CHANGES TO OUR PRIVACY POLICY
Any changes we may make to our privacy policy in the future will be posted on this page.
10. CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and contact should be made through our website.
HFC Travel Services Ltd are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purpose of the Data Protection Act 1998 (the “Act”), the data controllers are HFC Travel Services Ltd 1. INFORMATION WE MAY COLLECT FROM YOU We may collect and process the following data about you. Information that you provide to us on the telephone, on our website (“our site”) or on our mobile application (“our app”). This includes information provided at the time of making bookings for our services or for any other reason if you need to make a complaint or report a problem with our site or our app. If you contact us, we may keep a record of that correspondence. If you contact us by telephone, your telephone call may be recorded. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them. Details of transactions you carry out through our site or our app and of the fulfilment of your bookings. Details of your visits to our site and our app and the resources that you access.
2. IP ADDRESSES AND DEVICE INFORMATION
2.1 We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
2.2 We may collect information about your mobile telephone or handheld device (“Device”) or any computer you may use to download or stream a copy of our app onto your Device, including, where available the Device’s or Computer’s unique Devise identifiers, operating system, browser type and mobile network information as well as the Device’s telephone number, for system administration.
2.3 When you use one of our location-enabled services, we may collect and process information about your actual location. Some of our services require your personal data for the feature to work. If you wish to use a particular feature, you will be asked to consent to your data being used for this purpose. Your consent can be withdrawn at any time by switching off the location-based services on your Device. If you require further details of how we use location based services, you can request such information by contacting us on our website.
3. COOKIES Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies. More details on how we use cookies can be found on the Cookie Policy page.
4. WHERE WE STORE YOUR PERSONAL DATA
4.1 The data that we collect from you is not transferred to, nor stored at, a destination outside the European Economic Area (“EEA”). Staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
4.2 All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.
4.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site or our app; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
5. USES MADE OF THE INFORMATION
5.1 We use information held about you in the following ways to carry out our obligations arising from any bookings that you have made with us to sharing such information with third party fulfilment companies for the purposes of fulfilling a booking requested by you which is not being carried out by us to ensure that content from our site and our app is presented in the most effective manner for you and for your computer to provide you with information, products or services that you request from us or which we feel may interest you, where (if required to do so) you have consented to be contacted for such purposes to allow you to participate in interactive features of our service, when you choose to do so; and to notify you about changes to our service.
5.2 We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or permitted third parties may contact you about these by post, email or telephone.
5.3 If you are an existing customer of ours, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which we have previously supplied to you.
5.4 If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
5.5 If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please let us know by ticking the relevant box situated on the form on which we collect your data.
6. DISCLOSURE OF YOUR INFORMATION6.1 We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. 6.2 We may disclose your personal information to third parties in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets if HFC Travel Services Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of supply and/or any other agreements; or to protect the rights, property, or safety of Canterbury Sky Taxis, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
7. YOUR RIGHTS
7.1 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
7.2 You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us on our website.
7.3 Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
8. ACCESS TO INFORMATION The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.
9. CHANGES TO OUR PRIVACY POLICY Any changes we may make to our privacy policy in the future will be posted on this page.
10. CONTACT Questions, comments and requests regarding this privacy policy are welcomed and contact should be made through our website.
HFC Safeguarding Policy
Introduction
HFC Travel Services LTD is committed to ensuring, as far as it reasonably can, that it has clear arrangements to safeguard children, young people and adults at risk of abuse or neglect that we may have contact with and to support the Home Office Counter Terrorism Strategy CONTEST, which includes a specific focus on PREVENT (preventing violent extremism / radicalisation). Safeguarding is everyone’s responsibility.
This policy sets out the collective and individual requirements of all directors, staff, drivers, agents and contractors in order to promote the expectations of Canterbury Sky Taxis.
This policy describes the definitions of abuse for both adults and children and how HFC Travel Services LTD staff and others should report such abuse or suspicions of abuse.
HFC Travel Services LTD promote equality and respect for the diversity of the people living in, working in or visiting the areas it serves, regardless of age, gender, culture, religion, faith, language, physical or learning disability or impairment, or sexual orientation.
Everyone must be sensitive to the differing family patterns and lifestyles which vary across racial, ethnic and cultural groups.
Harm can occur within circumstances which are as diverse as the number of people at risk; however, abuse cannot be condoned or ignored for religious, cultural or for any other reasons.
Purpose
This policy sets out the key principles that everyone should comply with in relation to safeguarding children, young people and adults at risk of harm or abuse.
Anyone carrying out duties on behalf of HFC Travel Services LTD needs to be aware of the need to support children, young people and adults at risk of abuse or neglect, in particular those in need of protection.
This policy will be reviewed every year unless legislative, procedural or other changes necessitate an earlier review.
Scope
This document covers all the business activities of HFC Travel Services LTD, its clients, suppliers and infrastructure.
This policy applies to all HFC Travel Services LTD directors, staff, drivers, agents and contractors, including students and interns. For ease of reference, hereafter all such persons who fall under these groups will be uniformly referred to as ‘staff’ in this document (whether they are, as a matter of law and fact, employees of the company or not).
Objectives
HFC Travel Services LTD recognise that safeguarding children, young people and adults at risk is a shared responsibility with the need for joint working between agencies and professionals who have different roles and expertise, including LADO, local authorities, the Police, Social Services and the Independent Safeguarding Authority.
In order to achieve effective liaison, there must be constructive relationships at all levels promoted and evidenced by:
Concerns about children
Safeguarding is fundamental to protecting people’s health, wellbeing and human rights and allows them to live free from harm, abuse and neglect. Safeguarding responsibilities apply to children, young people and adults.
A child is anyone who has not reached their 18th birthday; young people between their 16th and 18th birthdays who may be living independently, in further education, in custody or who are a member of the Armed Forces are still to be considered as children. Sometimes the needs of older children can be overlooked, this may be due to the fact they look older and may be mistaken for or treated as adults. Safeguarding children guidance should be applied to people aged 16 and 17; staff should be aware that older children may be in intimate relationships, may suffer domestic abuse and be parents themselves.
An adult at risk is an individual who has care and support needs and who is experiencing, or at risk of experiencing abuse or neglect.
The Government has issued a policy statement on adult safeguarding which sets out six principles for safeguarding adults. Whilst not legal duties, these do represent best practice and provide a foundation for good outcomes.
Process including Concerns around a Person in a Position of Trust
If you have concerns about a child, young person or adult at risk of abuse or neglect should be referred using the following process:
Should a child make a disclosure, never tell the child you do not believe them or promise to keep secrets.
If the child, young person or adult at risk are in immediate danger the police must be contacted on 999 without delay.
It is the responsibility of the staff member who has concerns about a child, young person or adult to make the referral; it should not be assumed that someone else will have done so or will do so.
The safeguarding of children, young people and adults at risk is the responsibility of all members of staff and all have a duty to report concerns they may have.
The Safeguarding Officer / Corporate Director can be contacted for additional advice and support between Monday to Friday 10:00 to 18:00. Outside these hours a Director can be contacted via the office for advice about a child, young person or adult at risk.
The Safeguarding Officer will involve the expertise of LADO and the Independent Safeguarding Authority
Drivers to follow the same procedure for any concerns of CSE / radicalisation / other vulnerability
Escalation of concerns following a referral
There may be occasions when a staff member feels the company has not taken appropriate action. In this situation the staff member should contact the relevant local authority safeguarding team or the police evidencing a clear rationale of their concerns.
Mental Capacity Act 2014
The legislative framework relating to the Mental Capacity Act 2014 is detailed in Appendix A.
Police and Licensing investigations, prosecutions and disciplinary action
Serious Case Reviews and Learning Lessons
In the event of a Serious Case Review (SCR), Safeguarding Adult Review (SAR), Learning Lessons Review (LLR), Child Death Overview Panel (CDOP) or Domestic Homicide Review (DHR), HFC Travel Services LTD will co-operate fully in such matters, providing records and / or witness evidence, as may be appropriate.
Training
HFC Travel Services LTD is committed to have arrangements in place to ensure effective training of all staff.
Each driver has been trained in safeguarding and / or child sexual exploitation awareness to the standards required by their relevant licensing authority and the company aims to provides additional training to those drivers who study the Level 2 BTEC course for professional taxi and private hire drivers.
The Business Manager and Director is the SPOC (single point of contact) by other organisations in connection with all safeguarding.
All staff have received safeguarding training and refresher training from the Business Manager.
Support, supervision and mentorship will be provided for safeguarding professionals within the company.
Support for Staff Members
HFC Travel Services LTD has a duty of care to look after the psychological and physical wellbeing of staff when they have been exposed to traumatic, distressing or challenging incidents; it is recognised that incidents that require a safeguarding referral may fall into this category. Any member of staff who considers they have been involved in such a stressful incident and / or would like support should contact the Managing Director.
There may be occasions where staff will be required to be interviewed / provide statements for police and / or licensing investigation and / or in connection with a SCR, SAR, CDOP, LLR or DHR. The relevant line manager will provide support to the staff member.
Safe Recruitment
Recruiting managers shall ensure the relevant level of DBS check (if any) is obtained before the applicant commences employment and / or engages in a regulated activity, including where necessary, referral to the Independent Safeguarding Authority.
As a pseudo employer of staff in a ‘regulated activity’, the company has a responsibility to refer concerns to the DBS in accordance with the Safeguarding Vulnerable Groups Act 2006.
Managers should report concerns to the Managing Director, who is responsible for making such referrals on behalf of the company to the DBS. Individuals who are already in post and receive a positive disclosure (renewal) are removed from duties with access to children or vulnerable adults whilst an investigation is carried out.
Social Media
Staff should be mindful when accessing the internet either at work or out of work as posting information on social media sites that could be linked to a customer / passenger or staff members, e.g. bullying, exploitation, encouraging self-harm or violence, may result in disciplinary action being taken and / or driver, agent or contractor contracts being terminated.
Information Sharing
It is important that information sharing and confidentiality is handled in compliance with the Data Protection Act 1998 / GDPR. It is important that all customers and passengers remain confident that their personal information is kept secure and safe and that staff maintain privacy rights of the individual while sharing information to deliver betters services.
Staff should ensure they are familiar with data protection laws and principles and associated policies and procedures. For support relating to information sharing and safeguarding, contact your line manager or the Corporate Director.
There are seven golden rules for information sharing:
Consent to Share Information
Children and Young People
Where there are concerns for a child or young person’s welfare, staff should notify the parents or those with parental responsibility (if known) unless there is cause to suspect the child has been abused and / or there is a risk of causing further harm to the child.
When abuse of a child or children is known or suspected it is important to gain as much information as you can, which might include taking a history about what has happened. If staff feel it is safe to do so they should discuss the need for referral with the parents unless doing so would put the child at risk of further or significant harm.
Parents or those with parental responsibility must not be informed of the intent to make a referral if:
Adults at risk
Informed consent to make a referral should always be obtained if making a referral, if this is not possible and others are at risk (e.g. Residential care setting), it may be necessary to override this.
When an adult at risk refuses consent to share information
Adults have the right to take risks and may choose to live at risk if they have the capacity to make such a decision and have been provided with all the information to be able to make fully informed choice; this must be respected and decisions documented.
If a passenger is identified as lacking capacity there is no need to seek consent to share the information as you would be acting in their best interest. Where actions are taken or a referral made without a passenger’s consent, any actions must be clearly recorded and a clear rationale should be given in the referral.
Implementation Plan
The latest approved version of this policy will be posted on driver and staff notice boards for all members of staff to view. New members of staff will be signposted to this policy and associated guidance during induction.
Monitoring compliance and effectiveness
Board meetings will be utilised to assess the compliance and effectiveness of this policy. Safeguarding referrals and feedback from staff and other organisations will be reviewed as part of the audit process; trends, themes or lessons learned will be communicated to staff through staff notices and updates.
Appendix A
Legislative Framework
Responsibilities for safeguarding are enshrined in legislation. Some duties apply only to children, some only to adults and some to both. The differences between the legislative framework stems from who can or cannot make decisions.
Adults have a legal right to make their own decisions, even if they are unwise, as long as they have capacity to make decisions and are free from coercion or undue influence.
The decision-making power for children lies in those who parental responsibility for the child. Children under the age of 16 are presumed to lack capacity, however, if it is believed they have maturity, intelligence and understanding the law gives them a greater say in decisions made about them. Once a child is able to fully understand the information about a decision and the consequence of their choice, the child’s view prevails; this is known as the ‘Gillick Competent using Fraser guidelines’.
It should not be assumed that children or young people with learning difficulties are unable to make decisions about their care or treatment; information should be presented to the child or young person in an appropriate way.
The Metal Capacity Act 2005 covers and empowers children aged 16 and 17 and they are presumed to have sufficient capacity to make their own decisions, unless there is evidence to suggest otherwise. Although the young person can make their own decisions about what happens to them, it is good practice to involve family members in any discussions that take place.
Children and Young People
The legislation and guidance relevant to safeguarding and promoting the welfare of children includes the following:
A full explanation of statutory provisions relating to children’s safeguarding can be found in Appendix B of the statutory guidance document ‘Working together to safeguard children (2015)’.
There are some broad, fundamental safeguarding duties covering children’s service, namely:
A child-centred approach is required, as far as is reasonably possible.
It is essential that all agencies recognise that safeguarding is everyone’s business. No individual agency can assume that safeguarding issues will be picked up by others.
Adults at risk of harm or abuse
The legislation and guidance relevant to safeguarding adults at risk of harm or abuse includes the following:
