Vehicle for Hire fully online training: the short answers (and the long ones, too)

Image: DRVRhub

As noted in our June 21st news article, the third supplier approved to deliver training to Toronto’s Vehicle for Hire drivers (Taxi drivers and ride share drivers) is a fully on-line program in which no human instructor ever lays eyes upon the human student.

Concerns were raised by Taxi News and industry members about just how easy it will be for people in a rush to certify drivers to circumvent even the most minimal requirements of an online program with no identification provision. We sent four questions to Toronto’s Media Office staff, who obtained answers from Licensing and Standards.

In this opinion column, I am providing every word sent to me by L&S staff through the Media Office (scroll down to “Full Text”) and also an editted version which removes the “bumpf” wordage and cuts to what I see as the most pertinent points.

Question 1: DRVRhub does not require a student to show up in person anywhere; how can they then confirm that the person who wrote the test is the person who will be driving VFH? Only the drivers’ license number is required, with no photo.

Pertinent point: “When taking any training (either in-class or online), drivers should not share their personal information, drivers licence number, and other unique identifiers as there are risks of identity theft. It is also a criminal offence to use another individual’s identification.”

My best summary: Students are on their honour to be honest. Nothing currently being done will prevent potential fraud.

Question 2: One human being who knows all the test answers could sit at a computer and take the test for hundreds of drivers. How will this be prevented?

Pertinent point: “The expert panel reviewing the course content had examined the online self-paced programs to ensure that the quizzes are randomized. In addition, external audits will be conducted on the approved training programs to ensure that they continue to meet the City’s criteria and to identify areas of improvement.”

My best summary: Nothing will be done to prevent one smart person from sitting at a computer and taking the test for hundreds of drivers. “Randomizing” the quizzes means nothing for professional test takers.

Question 3: Other approved suppliers note that they were required, as part of the RFI, to prove that their instuctors are licensed to provide training. DRVRhub has no instructors. How were they approved?

“The City’s criteria required training providers to submit at least two references to previous adult training delivery and the name and credentials and/or certifications of the instructors attached to the program. Each training provider is required to have an instructor available for questions. The training providers approved by the City met these requirements.”

My best summary: If by “having an instructor available for questions” they mean Jake the DRVR Chatbot, he didn’t have answers to my questions and simply provides an email address to DRVRhub. So far, I have received this: “Hello, Thank you for reaching out. Please note that your media inquiry has been sent to the right contact. 

Thank you, 

DRVR Hub Support Team”

Question 4: I finished the test in 37 minutes. In fact I could have done it a lot more quickly – you only have to Click to Continue at the end of every page to move ahead. One person with a list of 100 drivers’ license numbers could generate 100 certificates in a few hours. How does Toronto see this improving safety on the streets?

Pertinent point: “As with any training program, drivers are expected to fully engage with the content of the training (whether it is taken in-class or online) and understand the topics covered, to ensure that the company they are driving for provides safe, reliable and excellent customer service.”

My best summary: Students are on their honour to be honest. Nothing currently being done will prevent potential fraud.

Full Text

Here is the full, unedited response from Municipal Licensing & Standards:

“The mandatory training program is one of the many licensing requirements to ensure passenger safety in Toronto. We are providing background information on the licensing requirements to provide some context before responding to your specific questions.

The City has robust licensing requirements for drivers of vehicles-for-hire and private transportation companies, in order to ensure the safety of passengers. To obtain a licence, all drivers must: 

1. hold a Class G or higher provincial driver’s licence
2. provide a Criminal Record and Judicial Matters Check
3. provide a three-year driving history recorded by the Ministry of Transportation (MTO)
4. carry $2,000,000 in mandatory insurance coverage

In addition:

1. Drivers are prevented from driving if they have breached the screening criteria for convictions under the Criminal Code, or Highway Traffic Act for things such as careless driving, speeding or failing to stop at the scene of a collision.
2. Drivers are also automatically assessed every seven days to ensure compliance with the driving criteria and have to pass vehicle requirements (such as maximum age of vehicles, number of seats and doors, and annual vehicle inspection).
3. Drivers need to take the mandatory driver training, which aims to improve driver awareness on Vision Zero, transporting passengers in a safe manner, driving in an urban setting, anti-racism and discrimination, and legal requirements. The training is not meant to cover core driving skills or defensive driving training; that is provided by the MTO as part of the provincial driver’s licensing system, which requires in-car examinations.

The training providers approved by the City’s expert panel satisfy the mandatory criteria provided by the City and had submitted course curriculum, which demonstrated how they met the curriculum criteria. These criteria were developed as directed by City Council and the City worked with an external training partner to establish the final set of criteria. Approved training providers are delivering and/or testing certain practical elements of the curriculum requirements through in-car training, video or simulations online, as outlined in the criteria document (attached).

The approved training programs present a range of learning modalities (for example, in-class, online, in-car etc.). A mix of training providers is required to ensure a competitive market, to provide opportunities for drivers to choose the training that better suits their learning style and needs, and to enable thousands of drivers to complete their training in an efficient and timely manner. This approach is consistent with other comparable jurisdictions, such as New York City and Seattle, where in-car, in-class, or online options are permitted and industry members may determine which training is best suited for their needs.

Question 1: DRVRhub does not require a student to show up in person anywhere; how can they then confirm that the person who wrote the test is the person who will be driving VFH? Only the drivers’ license number is required, with no photo.

Response 1: The bylaw requires that drivers not only have solid driving skills (ensured by the  provincial driver’s licensing system and the three-year driving history recorded by the Ministry of Transportation) but also awareness on Vision Zero, transporting passengers in a safe manner, driving in an urban setting, anti-racism and discrimination, and legal requirements (via the mandatory training). The mandatory training is one of the many requirements (listed above) that the City has in place to provide safe transportation options to the public.

The mandatory training program introduced in Toronto has been welcomed by the industry and seen as an opportunity to improve driving in Toronto’s unique urban streets, deliver equitable service to diverse communities and improve public safety. We are confident that the majority of drivers would welcome the opportunity to learn more about how to drive safely in Toronto and ensure their own and their passengers’ wellbeing.

The City will continue to monitor the implementation of the training program. External audits will be conducted to ensure that the programs continue to meet the City’s criteria and to identify areas of improvement. If issues, such as drivers not taking the test themselves, are reported the City will review and adjust as needed.

Lastly, when taking any training (either in-class or online), drivers should not share their personal information, drivers licence number, and other unique identifiers as there are risks of identity theft. It is also a criminal offence to use another individual’s identification.

Question 2: One human being who knows all the test answers could sit at a computer and take the test for hundreds of drivers. How will this be prevented?

Response 2: The expert panel reviewing the course content had examined the online self-paced programs to ensure that the quizzes are randomized. In addition, external audits will be conducted on the approved training programs to ensure that they continue to meet the City’s criteria and to identify areas of improvement.

Going beyond the training, the City also has bylaw enforcement tools to manage compliance with the bylaw. If drivers do not comply with the bylaw, they are guilty of an offence and may be issued a ticket and convicted. The Toronto Licensing Tribunal also addresses issues with drivers not meeting the City’s screening criteria or their responsibilities under the bylaw and Highway Traffic Act. 

Question 3: Other approved suppliers note that they were required, as part of the RFI, to prove that their instuctors are licensed to provide training. DRVRhub has no instructors. How were they approved?

Response 3: The City’s criteria required training providers to submit at least two references to previous adult training delivery and the name and credentials and/or certifications of the instructors attached to the program. Each training provider is required to have an instructor available for questions. The training providers approved by the City met these requirements. 

Question 4: I finished the test in 37 minutes. In fact I could have done it a lot more quickly – you only have to Click to Continue at the end of every page to move ahead. One person with a list of 100 drivers’ license numbers could generate 100 certificates in a few hours. How does Toronto see this improving safety on the streets?

Response 4: As mentioned above, this training has been welcomed by industry members, which is an early indication of voluntary compliance. All approved training providers have met the mandatory and curriculum criteria established by the City, as directed by City Council. The City will continue to monitor the implementation of the training program, including conducting external audits.

As with any training program, drivers are expected to fully engage with the content of the training (whether it is taken in-class or online) and understand the topics covered, to ensure that the company they are driving for provides safe, reliable and excellent customer service.