Legal
Equality and Disabled Passenger Policy
Draft for review
This document is supplied for completion and adoption. Highlighted fields are still to be completed, and it has not yet been reviewed by a solicitor for publication.
Golden Transfers is a trading name of Golden Transfers Ltd. We aim to arrange services fairly and accessibly and to meet applicable duties under the Equality Act 2010 and taxi and private hire legislation. This policy applies to staff, booking and dispatch contractors, drivers and providers carrying out Golden Transfers work.
Passengers can discuss assistance or report a problem through [COMPLETE: Golden booking email] or [COMPLETE: Golden telephone]. The responsible manager must make sure these commitments are included in provider training, allocation decisions and complaint handling.
1 Fair treatment
Decisions about enquiries, fares, allocation and service must not unlawfully discriminate. Staff must respond respectfully and assess the actual journey requirements. Assumptions about a disability, age, race, religion, sex, sexual orientation or another protected characteristic must not replace an individual assessment.
We will consider reasonable adjustments to booking communication and service procedures. An assistance request must not automatically be treated as a refusal reason, an extra fare or a safeguarding concern. Genuine legal or safety restrictions should be explained accurately and alternatives considered where practicable.
2 Information needed to arrange assistance
Ask what practical help is required, rather than seeking a diagnosis. Relevant details can include whether the passenger will remain in a wheelchair, the size and weight limits relevant to equipment, storage for a mobility aid, boarding assistance, communication preferences and the presence of an assistance dog.
Explain why a detail is needed, limit its circulation and record the applicable privacy arrangements. Do not label information anonymous merely because a diagnosis is absent. Advance information assists planning but is not a condition that takes away statutory rights when a passenger has not given notice.
3 Selecting a vehicle and driver
Dispatch must check that the actual vehicle, access equipment, restraints, permitted capacity and driver competence are suitable for the agreed task. Confirm arrangements to the passenger. Do not promise a wheelchair-accessible vehicle, a lift, ramp, particular child seat or trained escort unless it is available and approved for that journey.
If the original vehicle becomes unavailable, find a suitable replacement or discuss an alternative with the passenger. Do not send an unsuitable vehicle and rely on a generic substitution clause. If the agreed service cannot be supplied, apply the customer’s cancellation and refund rights and consider any further remedy due.
4 Assistance and charges
Drivers must perform the duties applicable to them and their vehicle, including required reasonable assistance and the carriage of eligible disabled passengers and assistance dogs. Tasks may include helping a person identify the vehicle, boarding or alighting, handling luggage or mobility aids and ensuring the safe use of equipment, subject to the relevant statutory provisions and safe practice.
No prohibited additional charge may be made for complying with these duties. Do not relabel required assistance as waiting time, luggage handling or a specialist surcharge. A different vehicle’s lawfully quoted fare is not automatically unlawful, but pricing must be reviewed to ensure that disability duties and equality obligations are met.
Any exemption must be a valid statutory exemption applying to the relevant duty and circumstances, with any required certificate displayed or produced. A driver’s preference, ordinary inconvenience or unsupported claim of allergy is not sufficient. Dispatch must verify the exemption and arrange a lawful response without simply leaving the passenger without help.
5 Assistance dogs and ordinary pets
Assistance dogs must be treated under the applicable legal duties, rather than an ordinary pet policy. Do not impose an additional pet charge for required carriage. Staff must avoid demanding informal “registration” or documentation that the law does not require.
Ordinary pets can be carried by prior agreement where suitable. A restriction concerning pets does not itself justify refusing an assistance dog. Complaints about refusal or extra charges must be escalated promptly to the responsible manager and relevant authority where required.
6 Safe assistance boundaries
Drivers must use equipment only as trained, follow manufacturer limits, and avoid unsafe manual lifting or improvised restraints. Explain a genuine limitation respectfully and seek an appropriate alternative. “Health and safety” must not be used as an unsupported blanket refusal.
A passenger may direct how they prefer reasonable assistance to be given. Respect dignity, privacy and independence. Where there is an immediate medical emergency, call emergency services and follow the safeguarding procedure. An ordinary journey is not an ambulance or clinical care service unless a separately lawful and approved service is expressly arranged.
7 Booking communication and training
Offer telephone or email alternatives where a website or app is inaccessible. Record the required adjustment so the passenger does not repeatedly have to explain it. Give clear collection information and allow appropriate time for communication.
Before allocating work, ensure that staff and providers understand disability duties, assistance dog requirements, safe equipment use, respectful communication and the escalation route. Record training and refresh it after material legal changes, incidents or identified gaps. Monitor complaints and allocation outcomes for recurring barriers.
8 Complaints and action
Take complaints about refusal, discriminatory conduct, unsafe assistance or extra charges seriously. Record the booking, practical requirements, explanation given, witnesses and any charge. Preserve relevant evidence, seek the passenger’s account and avoid requiring them to argue directly with the driver.
The manager will consider an immediate safe alternative, any refund, provider restriction, retraining and regulatory notification. A complainant may contact the relevant licensing authority directly. We will identify that authority and not require completion of our internal process first. Privacy concerns are also handled under GT25.
9 Ownership and adoption
Policy owner: [COMPLETE: responsible manager and deputy]. Approved vehicle capabilities and assistance arrangements: [COMPLETE: current verified list or controlled register reference]. Effective date: [COMPLETE: date]. Review at least annually and after any significant access complaint or service change.