In December 2018, the Department of Transport (DfT) introduced the UK Rental Vehicle Security Scheme (RVSS), including a Code of Practice (CoP) and Supporting Guidance.
In January 2019, as a responsible organisation RTR applied for and have been accepted onto the DfT scheme that has been developed with a number of stakeholders within Government and the Vehicle Rental sector to develop a 10 point code of practice. The 10 point requirements are as follows:-
1. Appoint a recognised security contact (RSC), and where practical a deputy.
2. Payment handling: Only accept electronic forms of payment.
3. When ‘handing over’ vehicles to customers, undertake driver licence verification checks.
4. Train staff to identify and report suspicious behaviours.
5. Support Law Enforcement Counter Terrorism and communication campaigns
6. Share data and information with Law Enforcement Agencies where it can be done, so lawfully and consistent in line with data protection requirements.
7. Based on assessment of risk and available vehicle technologies, the company should ensure that appropriate security equipment is fitted to vehicles.
8. Hiring of Commercial Vehicles: When handing over Commercial Vehicles to customers additional security checks should be undertaken.
9. Vehicle liveries: The code recommends that company liveries are removed prior to onward sale of vehicles.
10. Data Protection Act 2018 (DPA) and the General Data Protection Regulations 2018 (GDPR). The company will ensure that staff have sufficient training in regard to the DPA and GDPR.
In regard to the 10 points of the CoP, RTR have implemented the following:-
1. Recognised Security Contact (RSC)
• We appointed David Harrison, Group Security Advisor on 1st June 2018. David is a former retired Police Detective, who works closely with Ian Woodfinden, EQHS Director. These persons will act as the focal point for the dissemination of Counter Terrorism Security Advice and procedure on the companies behalf.
• The RSC will ensure they are up to date with security training, supplied by their company and, supplied by other sources including Centre for Protection of National Infrastructure (CPNI).
• The RSC will ensure that all staff receive the required level of security training to enable them to fulfil their roles.
• The RSC will act as the point of contact between the organisation of Dft / Law Enforcement Agencies, and will be the person that will receive security related communications.
• The RSC should ensure that on an appropriate basis security related messaging is displayed at the place of business.
• The RSC should ensure that when fleet vehicles are disposed of that any liveries are removed.
• The RSC should ensure that staff are undertaking he necessary checks (as outlined in the code of practice).
2. Payment Handling
RTR as a company do not take cash, credit or debit card payments when hiring vehicles. We only supply vehicles to our existing customer base, where they have a current credit account with us and as such have the passed the appropriate credit checks. We also hold on file the Operator Licence and current Insurance Certificate for each company that we hire to. We do not carry vehicles on a business to consumer basis.
3. Driving Licence Verification
Because we only hire to existing customer and not the general public, and the fact that we hold on file a copy of the customer Operators Licence and current Insurance Certificate, it is the responsibility in accordance with our Terms and Conditions that the Customer is responsible for driving licence verification of their own employees.
RTR currently adopt a system called ‘DAVIS’ to check the Driving Licence validity of all employees to identify potentially fraudulent documents and high risk drivers. Indeed, it is a condition of our insurance that we inform our Insurers of drivers that have 6 penalty points, or other driving convictions.
We verify the Driving Licence of people collecting vehicles from our premises, including those of any 3rd Party organisation that we may use to deliver or collect vehicles on our behalf.
4. Training Staff
The RSC should ensure that Counter Terrorism Guidance is available to staff and ensure they are trained in customer verification procedures to help build a culture of vigilance.
The RSC will have in place a mechanism for reporting suspicious behaviours to the relevant Law Enforcement Authorities and ensure that company procedures and management processes incorporate the use of this mechanism where appropriate.
The RSC will also train staff to ensure that customers are provided with the most suitable vehicle to meet their requirements. (This may offer an opportunity to identify suspicious behaviours).
5. Support Law Enforcement Agencies
We will always support Law Enforcement Agencies in the reporting, detection and prevention of crime.
6. Data Sharing
The RSC will agree to share rental and customer data and information on individual vehicle rentals to Law Enforcement Agencies on request where it can be done so lawfully and consistent with Data Protection requirements.
7. Vehicle Technology
When renewing vehicles within our fleet, based on risk assessment, the company will ensure that security equipment is fitted as appropriate.
Upon official request RSC will cooperate with Law Enforcement Agencies in the activation and use of vehicle security technologies, in support of active investigations.
8. Hiring of Commercial Vehicles
We only hire vehicles to our existing customers and hold on file a copy of their Operators Licence and Insurance Certificate.
9. Vehicle Livery
We always remove vehicle livery prior to disposal.
The RSC will ensure that this has been completed.
10. Data Protection Act (DPA) 2018 and General Data Protection Regulations (GDPR) 2018
The company will ensure that staff have sufficient training in regard to the DPA and GDPR. In the event of a Law Enforcement request, staff understand the overall obligation sand whether they are able to share data when requested.