NR3S

Briefly describe the initiative/ project/service; please include your aims and objectives

NAFN’s NR3S initiative was created with the aim to reduce or remove all instances of licenses being issued to drivers deemed not fit and proper by providing a national central register where all applications could be checked and cross-referenced. This provides significant benefits to licencing authorities and supports the objectives of safeguarding and consistency whilst enhancing the reputation of local government. Without this approach both objectives would be undermined. Over the past 25 years as technology has evolved, so has the way in which we use and manage information. NAFN has developed robust processes seeking to limit the risks inherent in the management of data and ensure compliance, and is the benchmark for best practice in information governance.

NAFN’s reputation as a centre of excellence for all public sector data and intelligence services, was instrumental in the Local Government Association’s decision to commission the development of a solution (NR3) for local authorities licensing teams, to qualify an individual’s status to be award a taxi or Private Hire Vehicle (PHV) driver licence.

The solution (NR3) was driven as a response to a lack of a centralised repository of information on individuals who had been previously had licenses revoked, or been refused a licence, who then sought to gain a licence through the inability of licensing authorities to cross-reference. This lack of joined up information had frustrated the assessment process for many years, inadvertently creating tension between authorities who had refused or revoked licences with good cause, only to have the same driver operating in their area having been permitted a licence by a neighbouring authority. The initiative has ensured that those deemed not ‘fit and proper’ by one local authority are not permitted a licence by others; in simple terms, it allows all licencing authorities to make informed decisions based on its ability to seek evidence of refusals and revocations.

NAFNs central register is crucial in supporting licencing authorities’ duty to ensure only drivers of a suitably high standard are given licences. The initiative, through collaboration, has provided the capability to highlight a potential concern to be investigated further and supports consistency across all licencing authorities. It is instrumental in the creation of a national minimum standard for the ‘fit and proper’ test through inter-local authority engagement and dialogue on the route causes of disqualification. If used effectively, the aim of this initiative is to remove all instances of drivers deemed not fit and proper being permitted licences where appropriate decisions have already been made. 

What are the key achievements?

This initiative has had wider reaching benefits through the collaborative work of licencing authorities. It has become clear that in preventing a previously deemed unfit applicant obtaining a licence, we can also support wider societal benefits to reduce other crimes perpetrated by those individuals, for example sexual misconduct with passengers. All licensing authorities work differently therefore development of a memorandum of understanding supporting the aims and objectives of the initiative required innovative thinking. To support local authorities to access the register NAFN created NR3 guidance, policy and training.

As a national register capable of cross-referencing and matching data in respect of taxi and PHV licencing had never been created before, coordinating and communicating the need for change, requirements (including how to upload data) and benefits for all those involved was a significant undertaking. NAFN supported the migration of historical data to the register in order that information for the last 25 years could be held from all licencing authorities. Our great working relationship with members nationwide allowed for the success of this endeavour and continues to build the perception of NAFN as a part of their teams and organisations.

There are currently 298 Licensing organisations identified within England and Wales, 100% of of which were NAFN Members as at 01 April 2023. At that time there were over 1,000 registered NR3S users who have made 11,000 entries and 84,000 searches – that’s 330 every day. At as November 2023, there were 160k searches and just under 7k searches.

Wide reaching benefits include:
– Improved national standards and best practice
– Effective data sharing and intelligence
– Enhanced national awareness on checks and controls
– Cost-effective central register available to all local authorities that can be further developed as required
– Greater confidence and enhanced public safety.

The Private Members Taxi and PHV Safeguarding Bill sponsored by Peter Gibson, MP for Darlington, has passed the House of Commons Committee Stage and is currently at the second reading stage in the House of Lords.

The Bill is seeks to make provision about licensing in relation to taxis and private hire vehicles relating to the safeguarding of passengers and road safety. It included a mandatory requirement for licensing authorities to add revocations and refusals to a national database. In 2022, the Taxi and Private Hire Vehicles (Safeguarding and Road Safety) Bill was passed in parliament and became the Taxi and Private Hire Vehicle Act 2022.

How Innovative is your initiative?

As the details of refused, revoked or suspended licences nationwide will be retained on the register for a total of 11 years in England and 25 years for the remainder of the UK, the data accessed through this initiative by licencing authorities provides a sufficient amount of historical data to allow for appropriate due diligence. A nationwide taxi and PHV licensing cross referencing tool reaching back 25 years is the essence of innovation, and responds directly to the needs of licensing authorities. The benefits have significantly mitigated the likelihood of licences being permitted for those deemed not fit and proper. This initiative also benefits licencing authorities by creating cross-organisational communication channels where a notification of refusal, revocation or suspension can be expanded upon with additional rationale and supporting evidence where appropriate.

This is most pertinent in cases of assault and sexual assault. As the register holds the decision, the second stage of the process involves a written request to authorities to gather additional insight to decision making. This initiative is therefore strengthening the fraud/crime prevention community and further developing their relationships and willingness to share intelligence. This has also enhanced recognition that use of the register is ‘good practice’, increased participation and also underpinned why prevention is key to this initiative. NAFN has ensured that adding applicants to the register is very simple, as licensing authorities advised the process must not be resource intensive. Licensing authorities also advised that an applicant will move very quickly to submit another application if refused or revoked; therefore our NR3S service is beneficial as it uploads the details immediately, making the information about the individual available nationwide, 365 days of the year, 24 hours a day.

Increased licensing authority awareness and acknowledgement of this innovative and vital service has been validated through the number of Local Authorities using the register, as illustrated by the growing figures and recognition from the Government. Not only have NAFN developed the standard for Licensing Refusals and Revocations and Suspensions, it has been named by the Secretary of State as the host of the register for England, mandating 100% of all licensing authorities to access and use the register.

A challenge we overcame quickly was ensuring the NR3S changes were only applicable to England, as the Taxi and Private Hire Vehicle Act 2022 did not apply to Wales, Scotland or Northern Ireland. The system would therefore need to recognise the location of a licensing authority and ensure the relevant agreement was displayed; the joint data controller agreement for England versus the data sharing and processing agreement for the remainder of the UK and the appropriate fields were made mandatory. Inclusion of Suspensions, national insurance numbers had to be restricted to England. 

What are the key learning points?

NAFN is a small, public sector, not for profit organisation supporting public sector organisations nationally for over 20 years. The key to developing, implementing, growing and sustaining this and all NAFN initiatives is, simply, collaboration. Whilst the Secretary of States has named NAFN the host of the NR3S, the content is submitted both historically and on an ongoing basis by licensing authorities. This continual proactive and collaborative engagement by NR3S users is central to the solution growing, evolving and continuing to provide a centralised capability to mitigate and prevent abuse of licencing standards and practices. As this is now mandated, we have learned to ensure there is flexibility in the system to accommodate potential legislative changes.

NAFN is committed and pivotal in ensuring that this vital UK service is here to stay. NAFN is confident the initiative is sustainable, as it is aligned to NAFN’s core values and principles that have underpinned service delivery that responds directly to local authority needs.