GDPR, Complaints, Lost Property, Employment

Coralia Policies

UK General Data Protection Regulation (GDPR) and Data Protection Act (DPA) 2018 

Coralia GDPR and DPA Policy

About this policy 

 This policy sets out how Coralia Ltd manages the personal data that it receives, predominantly from its customers but also from it’s staff, suppliers and cooperations partners.  This Policy is evidence of the company’s understanding and compliance with the UK General Data Protection Regulation (GDPR) and Data Protection Act (DPA) 2018.  

Processing Personal Data 

Personal data is any information about a living individual that can be used on its own or with other data to identifying that person. For instance, your name, address, telephone number or email address.  Processing means doing any of the following with your data:  Collecting, recording, organising, storing, using retrieving, altering, erasing, and disclosing. 

The Data Controller and the Information Commissioner’s Office 

The Operator processes personal data in order to provide its service and therefore is a Data Controller required to be registered with the Information Commissioners Office (ICO).  The ICO number for Coralia Limited is ZB538655.  

Why do we need your data? 

 We need your data in order to provide you with our service. When providing private hire vehicles to you we are required to comply with the provisions of the Supervising and Licensing Authority. This requires us to record the booking and the vehicle and driver dispatched. The supervising authority licensing conditions also specify the information that we must record.  

When we provide you with relocation services we perform Anti Money Laundry and Know Your Customer checks to verify the client’s identity and source of funds among a list of other information.

Data is provided by you voluntarily, but we need it to provide the service to you and comply with the law. This usually involves your name and contact details but further information such as the details of onward travel arrangements such as flights or trains and return journey times, if booked, may need to be provided. This may, or may not, constitute personal data. In some instances, we will also require you to provide credit card details for payments via the credit card machine on site. 

Your consent 

Clients making a booking and providing their data to Coralia are consenting to that data being used in order to fulfil their booking and to be used in order to comply with our licence conditions. Staff and Contractors working with Coralia agree when undertaking an assignment that they driving licence, private hire licence may be shared with customers for their safety and assurance. 

What we will not do with your data  

 We will not keep or use your data for the purposes of marketing or advertising our service, nor share it with any other third party, save where required by law, or without your express consent. We may share your data with regulatory authorities, without your consent where there is an existing lawful basis to do so. For instance, if you report the occurrence of a serious crime but fail to notify the Police, we may tell them that you made an allegation in order to protect other people.  

What we will do with your data 

 Your data will be provided to a licensed driver and vehicle dispatched by us to fulfil your booking request.  The driver will be given as much detail as necessary that is needed to provide the service to you and comply with any additional requests that you have made.  Equally, the drivers details will be provided to the customer in order for the booking and services to be delivered smoothly and compliantly. 

As a licensed operator, we are required by the supervising authority to record certain information about a booking and retain it in our records.  We may also use your data to contact you about matters in relation to your booking (for instance if we need to make a change to it).  

Retention of your data 

 This information will be kept within our records for at least 12 months as required by our licence conditions but in any event, without your express consent, shall be kept no longer than 3 years after the last booking. Data may be kept longer when the concerned parties have been involved in property transactions, for AML and accounting purposes. 

How your data will be kept secure until destroyed  

 Your data will be retained electronically using: SharePoint, Dropbox, and Dispatch Software provided by Deva Software. In addition, we have a reputable and long-established IT security, Connective Technology Ltd. which has implemented stringent measures to protect the entire firm’s data from any security bridges.  

Only Coralia Limited, its staff, and agents will be able to access the data and for no other reason than to provide you with the service or to comply with licence conditions.  

Once we no longer need your data it will be securely destroyed as follows: We will deploy Secure deletion to ensure that all sensitive data is irretrievably erased from our systems, preventing any potential data breaches and complying with privacy laws, and secure shredding for any printed stuff. 

Breaches of data protection 

 If, for any reason, there is a breach of the security of the data that is held by us we will record the breach. We shall notify you immediately if, as a result of the breach, your personal data has been accessed by, or was capable of being accessed by, any third party not authorised by Coralia ltd. Where personal data has been compromised following any security breach, or where otherwise required to do so by law, we will notify the ICO, and the Licensing Authority, immediately. 

 If you require further information about our data protection policy and procedures you can contact:  

Lidia-Gabriela Zilkha,

What to do when you think you left an item in the car?

Lost Items Policy

About this Policy

Coralia Limited and its drivers are licensed and are conditioned to take certain steps to record, retain, and return lost property. Coralia Limited provides a service of accepting bookings for private hire vehicles and facilitating drivers of private hire vehicles to fulfil such bookings.  Occasionally customers may leave property behind in a private hire vehicle despatched by us. This  Policy sets out the steps that we will take in order to return property to you if lost.  

Lost Property

Property remains the responsibility of its individual owner and the customers are encouraged to take good care of their own belongings and not to leave them behind on a private hire vehicle. Coralia Limited is not responsible for any property that is left behind until it is given to Coralia Limited at its offices. The safe keeping or return of your property does not form part of any contract for a private hire vehicle formed between us and you.   

Discovery of Lost Property by a Driver

Private hire drivers are conditioned by the Supervising Authority to check their vehicle for lost property after the termination of each booking. If any lost property is identified it should be returned to the customer immediately where possible.  

If lost property is discovered after a customer has left the vehicle and is no longer in the vicinity of the driver’s vehicle, the driver may: 

  1. a) seek to return the item to the customer within 24 hours;
  2. b) give the lost property to Coralia Limited, no later than 24 hours after its discovery.

A driver will not retain lost property for more than 24 hours.  

If the Driver seeks to return the item directly:

The driver may return the item directly to the customer if they are able to do so. For instance, by visiting the customers drop off destination.  If the driver has the details to do so, he may contact the customer to make arrangements for the return of the property.  

The driver may leave the property with another reasonably responsible person – for instance, at the reception of the customer’s place of work.  The driver will be responsible for this and should get a receipt if considered necessary.  

Items of Value

If the item is of value, whether monetary or personal, the driver should contact Coralia Limited immediately upon discovery of the item and confirm if the driver intends to return the item directly or to give it to Coralia Limited.  

Examples of an item of value are:  

  • Mobile phone; 
  • Wallet 
  • Purse 
  • Recently purchased shopping 
  • Business folders 

It is important that the driver notifies Coralia Limited as it is likely the customer will notice the missing item and will contact Coralia Limited. Coralia Limited can then make arrangements with the driver and customer of the safe return of the items. Early notification will also reduce any concern or accusation that the driver is seeking to keep the item if it is not reported missing.  

If the item is not of significant value, for instance, a newspaper the driver is not obligated to inform the Coralia Limited within the first 24 hours if he expects to return the item. However, the driver should not ever discard or destroy the lost property.   

Payment/ reward for return of lost property by Driver

The return of the property does not form any part of the private hire contract between the customer and the Coralia Limited. No charge is payable for the return of property by the driver – it is a duty imposed on the licence holder. The customer may pay the driver a reward for returning the item but the driver should not insist on this.   

End of Drivers responsibility 

If the driver has not returned the property to the owner within 24 hours, he or she must, within that time, give the lost property to Coralia Limited.  Once it is given to Coralia Limited, the driver is no longer responsible for its return unless there is further agreement between Coralia Limited/customer and the driver.  

The Coralia Limited role

When a lost property is received Coralia Limited will make a record of its receipt and keep it at its office.  The record shall identify the driver providing the lost property, the journey it was in relation to, and to whom it was returned (if claimed).  

Valuable items

If the item is of value (monetary or personal) Coralia Limited will take reasonable steps to notify the customer that their property is held. This may be by making reasonable interrogation of the lost property (i.e. checking for address), reviewing who made the booking, and the pick-up/drop-off locations in relation to the booking. 

If the item has an issuing Authority, such as passport, bank, or driving licence the item will be returned to that Authority within 72 hours.  

If Coralia Limited cannot make contact with the owner of the property or identify who it belongs to, Coralia Limited shall retain the item in a secure place at its offices for 14 days.   

If, after this period the owner has not come forward or collected the item Coralia Limited shall deposit it at its local police station obtain a reference number from the Police, and enter this into its lost property record.   

Non-Valuable Items

Perishable items (i.e. food, flowers, etc.) will be kept for as long as they are in date, where the Coralia Limited has the means to do so. The Coralia Limited is not obliged to refrigerate, water, or otherwise maintain or care for lost property other than to hold it. The Coralia Limited may however choose to do so. Items that have a date, or are of use only on a particular date (such as a newspaper or lottery ticket) may be disposed of after that date. All other items will be kept for a minimum of 14 days and will then be disposed of.  

Disposal of non-value items

Any item that is out of date, or has been kept for 14 or more days without being claimed, will be disposed of as the Coralia Limited sees fit, save for any item that may contain personal data, which will be securely destroyed.  

Illegal Items

If the driver of a vehicle discovers an item left behind that is illegal – for instance, a weapon or drugs, the driver must hand it to the Police or Coralia Limited immediately. No such item will be retained or held on to and will not be returned to its owner.  

Allegations against a driver for theft of property

The Coralia Limited cannot resolve complaints against a driver for any allegation that property lost has been kept (stolen) by the driver.  Such allegations should be made to the Police and the Supervising Authority. Before making such an allegation the property owner should be satisfied that the property was left in the vehicle with the driver.  

Any driver found to have retained a valuable item without notifying Coralia Limited, taking steps to return the item, or for longer than 24 hours will be disciplined by Coralia Limited and reported to the Supervising Authority.  

Queries regarding lost property should be made to:  Lidia-Gabriela Zilkha, + 44 20 3397 3767  or 

Coralia Wide policy for employment or cooperating with persons with a criminal record

Policy On The Employment Of Booking And Dispatch Staff

Purpose of this Policy

The Transport Secretary issued statutory guidance to all licensing authorities in July 2020 under the Policing and Crime Act 2017. This guidance, known as the Statutory Taxi and Private Hire Vehicle Standards recommended that all Private Hire Operators are conditioned to have a criminal record policy in place and applicable to their ‘booking and dispatch’ staff.  This is to protect members of the public from the possibility that the staff of an operator could gain and use their knowledge of an operator’s customers or drivers to facilitate crime. Customers of a private hire operator expect to feel safe when using that operators service.  Employing individuals with some unspent convictions will cause concern to our customers who will expect that the operator to promote a safe and responsible service.  Private hire operators must ensure that customers feel safe and that knowledge of their data and whereabouts will not be used to harm them in any way. Coralia Ltd., ‘the Operator’ will maintain a register of all staff employed, and to have their criminal record checked and assessed in line with this policy.  

Staff Register

A register of all staff employed, whether paid or unpaid, shall be kept. Our register is in Annex 2 to this Policy which can be requested from the Head of Compliance. The staff register is kept securely online, on the business Sharepoint Cloud. It can be viewed upon request by an authorised officer. 

Relevant Role

Licensing conditions define a “Relevant Role” to be any activity undertaken by an individual that involves them receiving bookings for private hire vehicles, despatching private hire vehicles or otherwise having access to the personal data of customers or drivers. A person will be defined as falling into a relevant role, and within the confines of this Policy, if they are allowed by the operator to undertake any part of a function that involves receiving bookings for, or despatching, private hire vehicles, or having access to the personal data of customers or drivers of the Operator, in any way, shape or form.  

Employment status and relation with employment law

When determining if a person is fulfilling a relevant role, it does not matter whether an individual is employed or considered to be employed by the Operator or whether the individual is paid or unpaid. The overriding factor as to whether an individual is in a relevant role shall be based on the acts, activities, functions and responsibilities that the individual is asked, encouraged or permitted to undertake by the Operator.  The application of this policy is a requirement of a licensing condition and should not, in itself, be considered as evidence of an employee/employer relationship between the Operator and an individual. The existence of such a relationship is governed by separate law. Where the relevant role individual is an employee compliance with this policy shall be a term of the employment contract. A relevant role may be carried out by a person who is employed by the Operator, as well as by, for example, the operator themselves (if an individual or partner), by a director of the operator, family member, friend or person undertaking work experience. A relevant role falls within the Rehabilitation of Offenders Act 1976. Any person wishing to undertake a relevant role shall not be asked to provide information in relation to any offence that is spent nor will any decision be made on the suitability of an individual based on a spent offence. 

The Operators duties:

As a licensed operator, Coralia Ltd must be fit and proper to be allowed to operate private hire vehicles. The supervising authority will not only consider the compliance of an operator with its licence conditions but, with respect to this policy, the suitability of it to achieve the intended aims of protecting the public. 

As a licensed Private Hire Operator we undertake to comply with the requirements of supervising authorities by: 

  • Having this Policy in place; 
  • Complying with this Policy and making it available to staff.  
  • Requiring all individuals that will undertake or engage in a relevant role to provide a Basic Criminal Record Check before being allowed to do so.  
  • Assessing the criminal record of all individuals in line with this Policy before allowing any person to undertake or engage in a relevant role.  
  • Keeping a list of all individuals who undertake or engage in a relevant role with confirmation that their criminal record has been checked and considered suitable.  
  • Once an individual has been assessed, to not keep the original or any copy, of the criminal record provided to them. The top of the DBS displaying the individual’s name, address, Date of Birth and certificate number should be kept. 

When a criminal record check will take place

All persons engaged in a relevant role will be required to provide a Basic criminal record disclosure upon starting to work in the relevant role. This can be obtained by the individual from:  A further basic criminal record check will be required every 3 years. Any individual in a relevant role must inform the operator if they are convicted of any offence and will be required to undertake a further basic DBS at that time.  

Evidence of check to be retained

Coralia Limited shall take a photocopy of the top portion of the criminal record disclosure displaying the name, address and certificate number as proof that the record has been checked. This information will be provided to the supervising authoritiy or Police on inspection.  

 If the proposed individual has a conviction revealed on their DBS the Compliance Officer will assess their suitability for working in a relevant role by applying the considerations set out in Annex 1 of this Policy.  

Should the Compliance Officer be satisfied that an individual is suitable to work in a relevant role despite a conviction falling within the policy outlined at Annex 1 to this Policy. The Compliance Officer shall record their reasons clearly and keep it with the staff register. 

Annex 1 – Policy on convictions

Private Hire Operator:  Coralia Limited

Convictions will be split into the following broad categories: 

  • Road traffic offences 
  • Violence offences
  • Sexual or indecency offences
  • Dishonesty offences 
  • Offences involving harassment or discrimination
  • Licensing offences
  • Property offences

Road Traffic Offences

 As a private hire operator, our customers expect us to promote safe and responsible driving and some offences are incompatible with this and employing such individuals would harm the reputation of Coralia LTD.  Minor traffic offences on their own shall not ordinarily be a barrier to a person working in a relevant role for Coralia LTD. Offences such as reckless or careless driving or driving whilst under the influence of drink or drugs will not normally be considered suitable. However, where the offence is an isolated incident, the individual has no other convictions and the offence did not result in any injury, Coralia LTD may exercise discretion if satisfied that the offence did not call into question the honesty or motivation of the individual. Offences that involve the death or injury of another person or that result in death or injury will not be considered suitable and considered in line with the principles stated in respect to violent offences below. Traffic offences that involve dishonesty, or elements of dishonesty, such as the theft of a vehicle, driving without insurance, failure to submit a specimen when requested, failure to give the identity of a driver or failure to stop after an accident will be considered seriously using the principles outlined in respect to dishonesty offences below.   

Offences involving Violence

 Offences that involve violence or result in any physical harm, injury or death to a person indicate that a person is not suitable.  The employment of such a person would cause concern to members of the public using Coralia LTD service, particularly if that conviction is motivated by or involves any form of, discrimination (sexual, race, sexual orientation etc.) or as a result of trying to gain advantage over another. GBH, murder, attempted murder and other offences that involve violence will cause concern to the public and the reputation of Coralia LTD and any person convicted of such offences will not be suitable to work in a relevant role. Assault, battery and similar offences are not considered acceptable but an individual who has committed an isolated offence may be shown some discretion. 

 Offences of a sexual nature

The use of individuals with a conviction for a sexual offence would cause concern to members of the public and harm the reputation of Coralia LTD. The past commission of such an offence creates a risk that customers, particularly those who are vulnerable, may be targeted by an individual or that information gained during working in a relevant role may provide an opportunity for an offence to be committed.  Any sexual assault or other offence motivated by sexual gratification presents a risk that is too great to be taken by Coralia LTD.   

Dishonesty Offences

Any conviction for an offence of dishonesty, such as theft, burglary, fraud etc. will cause concern. A conviction for such an offence will raise concerns that an individual is not trustworthy and may use any information gained in a role for their own benefit. It is unlikely that anyone convicted of such an offence will be allowed to work until the offence is spent.  

Offences involving harassment or discrimination

Operators are required to provide a public transport service that does not discriminate in anyway shape or form against a person with a protected characteristic under the Equality Act 2010. Individuals who have convictions for previously showing a bias against a person with a particular protected characteristic must be able to satisfy Coralia LTD that they no longer hold this prejudice and will not treat any customer differently. Coralia LTD should expect a reasonable time to have passed since the commission of such an offence in order to be confident the individual poses no risk. An individual guilty of offences involving harassment will not normally be considered suitable, but Coralia LTD will take into account the specifics of the offence. Harassment motivated by a protected characteristic or involving violence, abuse or acts over a sustained period of time will not be acceptable.  

Licensing Offences

 Individuals who have committed a licensing offence, or have had a licence revoked or suspended will not automatically be prevented from working in a relevant role. If the individual has had a licence suspended or revoked due to a conviction the consideration of this Policy will apply in respect to that conviction. However, an Operator is expected to lead by example and individuals who have fallen foul of the licensing regime due to conduct which has resulted in a customer being mistreated, injured or taken advantage of will not ordinarily be allowed. 

Property offences

 Individuals convicted of offences such as graffiti, or damage to property may be suitable to work in a relevant role depending on the nature of the offence. An individual will not be suitable if the conviction resulted from an act motivated by discrimination or a desire to cause financial or physical harm to another. 

 Application of the Policy 

The above considerations are a guide and Coralia LTD may depart from them if satisfied that an individual poses no harm to their customers. Where an operator decides to employ someone with a conviction, and this policy indicates that an individual should not be permitted to undertake that role, Coralia LTD shall record clearly their reasons for being satisfied that the individual will not cause any risk of harm to the public. For instance, Coralia LTD may consider that the circumstances applicable to the offence are so unique and isolated that they are not likely to re-occur and do not raise concerns about the individual’s motivations or choices. Alternatively, an operator may take into account how long ago the offence occurred and the individual’s age at the time. Finally, Coralia LTD may consider how satisfied they are that the individual is rehabilitated.   


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Complaints Policy

Coralia’s relationship with you, our customer

Upon the acceptance of your booking for a private hire vehicle a contract of service is formed between us, the Coralia Ltd. and you, the customer. This contract is, unless stated or agreed otherwise, governed by Law of England and Wales and falls within the protections set out in the Consumer Rights Act 2015.  

When we accept your booking we will provide you with a licensed private hire vehicle and driver and meet any extra requirements that you may have requested and we have agreed to. We will allocate and despatch a vehicle and driver to you, with the expectation that the driver arrives on time with a clean and safe vehicle. The journey should be to your reasonable satisfaction – safe and comfortable and gets you to your destination at the expected time.  

Our drivers and vehicles are licensed by the Supervising Authority and the conduct of our drivers is regulated by them. 

Complaint types

Complaints are split into two categories. Those that are about our service and those that are about the conduct of a driver, the Coralia Ltd. or a member of the Coralia Ltd.’s staff. Service complaints are those that involve any element of the performance of our service to you that does not meet your expectations. For instance, if you consider that the vehicle was too small, the ride was uncomfortable, the price was too high or the driver was late. Conduct complaints relate to matters where an individual behaves in a way that you consider to be unacceptable and outside the remit of poor service.  For instance, if a driver says something offensive to you, tries to overcharge you, discriminates against you or intentionally causes harm or damage to you or your property. Sometimes a complaint can fall into both categories. 

Who to complain to:

Complaints about our service should be made to us. We have a designated Compliance Officer Lidia-Gabriela Zilkha, Email:, Call: +44 203 397 3767 

Complaints about the conduct of a driver (or us) should be made to Supervising Authority.  You should email for details. 

Information we need

The information that we need will depend on the nature of your complaint but as a general rule, we will need you to provide as much information as possible, and to do so as soon as possible after the incident. For example, the type of information we may need is as follows: 1.The booking confirmations document and reference number; 2. The pick-up/drop off locations and the time of each; 3. The vehicle make, colour, reg number and plate number; 4. Description of driver and badge number,  5. Description of what happened; 6. Details of any witnesses; 7. Details of any loss or damages incurred by you – for instance, if a driver spilled coffee on you and you had your suit dry cleaned we would need an invoice/ receipt from you.

  • Informal Complaints about our service – Stage 1

  • Sometimes things do not go as we wish, we are all human and despite our best efforts mistakes are made. We encourage feedback in order to improve our service and you may simply want to let us know about an issue but not require any further action other than an apology. All complaints about our service will be treated informally in the first instance. We will look into the matter and investigate in order to continually improve our service.  You will be advised of this, and that if you wish to make a formal complaint you may do so in writing.  
  • Formal Complaints about our Service – Stage 2

  • If you are not satisfied with our initial response or if we consider the matter to be serious we will advise you to submit a formal complaint in writing by email or post.

Actions we take when we receive 

We will record all complaints made, and reference the driver or vehicle that the complaint was made about. We will deal with your complaint, as far as we are able, in the strictest confidence. However, it is likely that it will relate in part to a driver or vehicle and some details may need to be shared with the driver in order to investigate the matter. We shall only share as much detail with the driver as necessary. We have a data protection policy that details how your data will be recorded and kept when a complaint is made. We will investigate your complaint and provide a response to you. We aim to do this within seven days. A response will be provided to you in writing. If we uphold your complaint we will seek to address it in a number of ways: 

  1. By apologising to you; 
  1. Providing you with some form of compensation or good will gesture; 
  1. Recompensing you for any loss, damage or suffering; 
  1. Referring the matter to the Supervising Authority if necessary; 
  1. Referring the matter to the Police if necessary; 

If we do not agree with your complaint we will inform you and refer you to this document of other actions that you may have open to you.

Matters to be referred to the Supervising Authority or Police 

As we are regulated by the Supervising Authority you may complaint to them in the first instance. However, where a complaint relates to service the Supervising Authority will not normally investigate and will refer to us.  We ask that customers do not complain to the Supervising Authority about the service we provide without first giving us the option to address your matter. Some matters we cannot resolve, and whilst we welcome you letting us know, it is important that you let the appropriate authorities know. Due to data protection issues, we cannot complain to them on your behalf. If you allege that a crime has occurred you must report it to the police. If you are unhappy with the conduct of a driver or an individual working for the Coralia Ltd. you should complain to the Supervising Authority. We will not ordinarily refer such matters on. We will, however, refer to the Police and Supervising Authority where an allegation is made that a criminal offence of a violent, sexual or dishonest nature is alleged. We will not pass on your details and request that you make the complaint to them. However, if you do not make a complaint to them the Police or Supervising Authority may request your details under the exemptions of the Data Protection Act. 

If you are not satisfied with our response

If you are not happy with our response you can email the Supervising Authority and explain your complaint and the reasons you remain dissatisfied. You should forward on to them all the communication you have had with us. The Supervising Authority will let you know if they think the nature of your complaint is within their remit. Alternatively, you may wish to seek your own independent legal advice about the matter.  

To discuss a complaint with us or contact us about our policy please contact: Lidia-Gabriela Zilkha Compliance Officer, +44 20 3397 3767 ,