Policy on the Employment of Ex-Offenders

IMMY EXECUTIVE LTD

1. Policy Purpose

IMMY EXECUTIVE LTD is committed to maintaining the highest standards of safety, professionalism, and regulatory compliance. This policy outlines our approach to employing individuals with criminal records in roles subject to Transport for London (TfL) licensing requirements.

2. Policy Scope

This policy applies to all applicants, employees, contractors, chauffeurs, private hire drivers, dispatch staff, and administrative personnel. It covers roles requiring Disclosure and Barring Service (DBS) checks in accordance with TfL regulations.

3. Legal & Regulatory Framework

This policy complies with the Rehabilitation of Offenders Act 1974, Equality Act 2010, TfL Private Hire Operator Licence requirements, TfL Suitability Guidance, and UK GDPR.

4. Assessment Criteria

Each case involving a criminal record will be assessed individually, considering:

• Nature of the offence
• Time elapsed since the offence
• Relevance to the role
• Evidence of rehabilitation
• Public safety risk assessment

5. 2024 Compliance Requirements

• All staff must self-report arrests, charges, cautions, or convictions within 48 hours.
• Overseas criminal record certificates are required where applicable.
• Annual DBS monitoring and record retention will be maintained.

6. Confidentiality

All criminal record information is handled confidentially and processed in accordance with UK GDPR and data protection legislation.

7. Equal Opportunities

IMMY EXECUTIVE LTD is committed to fair treatment and non-discrimination. Employment decisions are based solely on safety, suitability, and regulatory compliance.

8. Appeals Process

Applicants or employees may submit a written appeal within 14 days of any decision relating to their criminal record.

9. Policy Review

This policy will be reviewed periodically to ensure continued compliance with regulatory requirements.

Approved by: Imran Latif, Director