Good to know that they have said that they cannot provide the evidential photos for the alleged contravention on 19/11/2024.
As this is a single parking event, if the vehicle never moved on 19/11/2024, issuing two PCNs on the same day for the same stationary presence is, in substance, a duplication of the same alleged breach. A private parking charge is a liquidated sum for breach of a single contractual term at a given time/place. Where there is one continuous breach, the correct construction is one cause of action, not multiple rolling causes every time an operative wanders past.
Re-ticketing without any intervening windscreen notice (so the motorist remains unaware) is predatory. Even operators’ own practices and the PPSCoP expect fairness and reasonableness around multiple charges for the same event. Courts regularly view serial ticketing of a single event as unreasonable.
They must have made two DVLA requests for your data and have breached your GDPR and you will be able to sue them for compensation under the Data Protection Act. Never, EVER phone these scammers. EVERYTHING must be in writing, preferably by email.
The first thing you must do immediately is SAR the DVLA. Use this form MIS1065 'DVLA subject access request (SAR)' (https://assets.publishing.service.gov.uk/media/62692f63d3bf7f0e7d5b3dc6/make-a-subject-access-request-to-dvla-form-mis1065_270422.pdf) and complete sections 1 and 3 and email it to subjectaccess.requests@dvla.gov.uk.
At the same time send the following DVLA complaint to kadoeservice.support@dvla.gov.uk and CC yourself:
I am the registered keeper of VRM [ABC123]. I make a formal complaint that DVLA released my keeper data more than once to UK Car Park Management Ltd (UK-CPM) or its agents in relation to a single continuous parking event at the Barkantine Estate in November 2024.
Background
The vehicle did not move at any time on 19/11/2024. UK-CPM issued two Notices to Keeper for that same continuous stationary presence, using different sub-labels for the same estate: (1) “Topmast Point, Barkantine Estate” timed 07:24; and (2) “The Quarterdeck, Barkantine Estate” timed 15:15. A further PCN was issued for 20/11/2024. When asked for evidential photographs for 19/11/2024, UK-CPM stated they could not provide them. I believe DVLA disclosed my data more than once for the same continuous event.
Basis of complaint
Regulation 27 of the Road Vehicles (Registration and Licensing) Regulations 2002 permits disclosure only where there is reasonable cause. The KADOE contract requires requests to be accurate, necessary and proportionate, prohibits duplicate or speculative enquiries, and limits use of data to the specific incident for which it was requested. Using different sub-labels within the same managed estate (Barkantine Estate) for a single continuous stationary presence does not create a fresh reasonable cause to obtain keeper data again.
Industry Code breach
The Private Parking Single Code of Practice (v1.1, 17 February 2025) at section 8.3 states:
“Parking operators must ensure that they only issue Parking Charges in accordance with their advertised terms on any site. Such terms shall not entitle any operator to issue more than one parking charge in the same calendar day for the same parking event.”
UK-CPM issued two PCNs on 19/11/2024 for the same continuous stationary presence. This is inconsistent with §8.3 and indicates that any second KADOE enquiry relating to that same event lacked reasonable cause.
Remedies sought
1. Please consider this apparent PPSCoP §8.3 breach when assessing reasonable cause and KADOE compliance, and liaise with the relevant AOS (BPA/IPC) as appropriate alongside DVLA’s own KADOE sanctions process.
2. Investigate all KADOE enquiries made for VRM [ABC123] between 01/11/2024 and 31/12/2024. Identify each enquiry that relates to Barkantine Estate on 19/11/2024 and determine whether multiple releases were made for the same continuous stationary presence, irrespective of any different sub-labels used.
3. For each relevant enquiry, provide the date and time, DVLA reference, the requesting entity’s legal name, the reason code and any free-text location or reason supplied (including any mention of “Topmast Point” or “The Quarterdeck”), and the incident date and time cited by the requester.
4. Explain the legal and contractual basis on which DVLA authorised multiple releases for one continuous event, or confirm that the duplicate disclosure(s) were non-compliant with Regulation 27 and KADOE requirements.
5. Confirm what compliance action DVLA will take under the KADOE regime (for example warning, sanction points or suspension) for any non-compliant duplicate enquiry.
6. Direct the operator and any agents or solicitors to erase personal data obtained via any duplicate or unlawful request and require written confirmation of erasure to me.
Please acknowledge receipt and provide a written outcome and complaint reference within 20 working days. I ask that all records relevant to these enquiries and this complaint are preserved pending conclusion.
Yours faithfully,
[Full name]
[Postal address]
[Email address]
[Telephone]
You can attach copies of the NtKs to the email.
Also, you send the following email to the UK-CPM DPO at dpo@uk-cpm.com and CC both complaints@uk-cpm.com and yourself:
Subject: Formal complaint and Letter Before Claim. Ref: PCN 1. [PCN number1] & PCN 2 [PCN number2]
Dear Sirs,
I am the registered keeper of VRM [ABC123]. This is a formal complaint addressed to the Data Protection Officer. It concerns UK Car Park Management Ltd’s processing of my personal data in relation to two PCNs issued on 19/11/2024 for a single continuous parking event at Barkantine Estate. The vehicle did not move at any point on 19/11/2024. Nonetheless, you issued two PCNs for the same stationary presence using different sub-labels within the same managed estate: “Topmast Point, Barkantine Estate” timed 07:24 and “The Quarterdeck, Barkantine Estate” timed 15:15. When asked for evidential photographs for that date, your company stated it could not provide them.
You appear to have obtained or caused the obtaining of my keeper data from DVLA more than once for the same continuous event. Re-accessing or re-processing keeper data for a duplicated charge lacks reasonable cause and is not necessary or proportionate. Your conduct breaches the Private Parking Single Code of Practice section 8.3 (no more than one parking charge in the same calendar day for the same parking event) and infringes UK GDPR and the Data Protection Act 2018, specifically Article 5(1)(a) (lawfulness, fairness, transparency), Article 5(1)(c) (data minimisation/necessity) and Article 6(1) (absence of a lawful basis for duplicate processing for the same event). It also constitutes unfair and excessive processing by onward disclosure to agents.
I require the following remedies and actions:
1. Cancel the duplicate PCN for 19/11/2024. Confirm that both 19/11/2024 notices arose from one continuous parking event and that all enforcement activity relating to any duplicate is ceased.
2. Apply Article 18 UK GDPR restriction to all records linked to the 19/11/2024 duplicate. Segregate that record from active workflows and cease processing and dissemination for the duplicate purpose. Preserve (do not delete) all data and logs for regulatory/litigation duties.
3. Under Article 16, rectify your records to reflect a single continuous event and notify all recipients of the rectification; confirm the duplicate PCN reference has been cancelled.
4. Acknowledge my Article 21 objection to any further processing for the duplicate purpose.
5. Identify each DVLA KADOE enquiry you or your agents made for the 19/11/2024 event (date/time, requester identity, reason code/free-text location, incident date/time) and list all third parties to whom you disclosed my data.
6. Pay compensation for distress caused by duplicate processing and multiple PCNs for one event (Article 82 UK GDPR; s.168 DPA 2018). I reserve quantum to be assessed; invite your proposals.
7. Confirm measures to prevent recurrence, including controls to avoid multiple PCNs for one event and duplicate DVLA requests.
Please acknowledge this complaint within 14 days and provide a full written response within 28 days. Treat this as a letter of claim for the purposes of pre-action protocols applicable to data protection claims. Pending resolution, require your agents including BW Legal and any debt recovery firms to cease processing and to place their files on hold. Preserve all records relevant to this complaint, including DVLA request logs, internal notes, patrol notes, images, site plans, and correspondence. I reserve all rights.
Yours faithfully,
[Full name]
And, for the time being, send the following email to BW Legal at SAR@bwlegal.co.uk and also CC enquiries@bwlegal.co.uk and yourself:
Subject: Data processing objection and restriction – Your ref: [BW Legal reference number]
Dear Sirs,
I am the registered keeper of VRM [ABC123]. There will be no identification of the driver.
Your debt recovery “final warning” dated 28/08/2025 refers to two PCNs dated 19/11/2024. Those two notices concern one continuous stationary presence at Barkantine Estate; the vehicle did not move. You are processing my personal data for both PCNs using data supplied by your client.
Your client had no reasonable cause to obtain or reuse my keeper data more than once for the same event (Regulation 27; KADOE). Duplicate PCNs for the same day/event also breach PPSCoP 8.3. Any onward disclosure to you for the duplicate purpose lacks a lawful basis (Articles 5(1)(a), 5(1)(c), 6(1) UK GDPR). As an independent controller you are jointly and severally liable with your client for unlawful processing and the distress caused (Article 82; s.168 DPA 2018).
Accordingly:
1. Record my Article 21 objection and apply Article 18 restriction to all processing relating to the duplicate 19/11/2024 PCN. Segregate that record from active workflows and cease processing and dissemination for the duplicate purpose. 2. Preserve all data and logs for disclosure.
3. Confirm within 7 days the lawful basis you rely upon for processing in relation to each of the two 19/11/2024 PCNs and identify the precise data source for each.
4. Confirm your file is on hold for the 19/11/2024 event pending resolution of my complaints to your client and the DVLA. All rights reserved.
Yours faithfully,
[Full name]
[Postal address]
[Email]
The entrance view in GSV is from September 2024 and whilst the entrance sign is a winning point because it is not suitable for its purpose, the road markings are all there.
My car was behind the 'Hiya' car and like I mentioned before had 0 road markings previously. So all of the new markings must have been in recent times.
The GSV images from May 2022 and September 2024 all show markings. There is nowhere to park "behind the Hiya car". Where the Hiya car and the Audi in the GSV images is, are bot bays marked with a 'V', most likely indicating visitor bays.
There are markings and I doubt you would be able to convince anyone that there were none at the time your vehicle was parked there.
What needs clarifying, is the fact that you say the two PCNs issued on 19/11/2024 for:
1. Topmast Point, Barkantine Estate at 07:24
2. The Quarterdeck, Barkantine Estate at 15:15
were a single parking event and the car never moved at all that day. If so, that introduces even more breaches of the PPSCoP by the operator.
Before I give you the advice you need, please confirm that up to this point you have had no communication with either CPM or either BW Legal or Gladstones.
As far as CPM are concerned, do they know the identity of the driver? You, as the Keeper, could also be the driver but no one could know that except you. As you are under no legal obligation to identify the driver to an unregulated private parking firm and as none of their NtKs comply with PoFA 2012, they can only pursue the driver, if they know the identity, which they don't, unless you've told them.
You say that the car was left in the same spot each time. However, the two NtKs issued on the 19/11/2024 state two slightly different locations as:
1. Topmast Point, Barkantine Estate at 07:24
2. The Quarterdeck, Barkantine Estate at 15:15
Is this correct?
Also, the letter from BW Legal is not an LoC and is just another debt recovery letter which can be safely ignored.
For now, you can respond to the LoC from the utter incompetents at Gladstones with the following:
Subject: UK-CPM v [Keeper] — Your Letter of Claim dated 28/08/2025 — PCN [reference]
Dear Sirs,
Your Letter Before Claim contains insufficient detail of the claim and fails to provide copies of evidence your client places reliance upon and thus is in complete contravention of the Pre-Action Protocol for Debt Claims.
As a firm of supposed solicitors, one would expect you to be capable of crafting a letter that aligns with paragraphs 3.1(a)–(d), 5.1 and 5.2 of the Protocol, and paragraphs 6(a) and 6(c) of the Practice Direction. These provisions do not exist for decoration—they exist to facilitate informed discussion and proportionate resolution. You might wish to reacquaint yourselves with them.
The Civil Procedure Rules 1998, Pre-Action Conduct and Protocols (Part 3), stipulate that prior to proceedings, parties should have exchanged sufficient information to understand each other’s position. Part 6 helpfully clarifies that this includes disclosure of key documents relevant to the issues in dispute.
Your template letter mentions a “contract”, yet fails to provide one. This would appear to undermine the only foundation upon which your client’s claim allegedly rests. It’s difficult to engage in meaningful pre-litigation dialogue when your side declines to furnish the very document it purports to enforce.
I confirm that, once I am in receipt of a Letter Before Claim that complies with the requirements of para 3.1 (a) of the Pre-Action Protocol, I shall then seek advice and submit a formal response within 30 days, as required by the Protocol. Thus, I require your client to comply with its obligations by sending me the following information/documents:
1. A copy of the contract (or contracts) you allege exists between your client and the driver, in the form of an actual photograph of the sign you contend was at the location on the material date, not a generic stock image
2. The exact wording of the clause (or clauses) of the terms and conditions of the contract(s) which is (are) relied upon that you allege to have been breached
3. The written agreement between your client and the landowner, establishing authority to enforce
4. A breakdown of the charges claimed, identifying whether the principal sum is claimed as consideration or damages, and whether the £70 “debt recovery” fee includes VAT
I am clearly entitled to this information under paragraphs 6(a) and 6(c) of the Practice Direction. I also need it in order to comply with my own obligations under paragraph 6(b).
If your client does not provide me with this information then I put you on notice that I will be relying on the cases of Webb Resolutions Ltd v Waller Needham & Green [2012] EWHC 3529 (Ch), Daejan Investments Limited v The Park West Club Limited (Part 20) Buxton Associates [2003] EWHC 2872, Charles Church Developments Ltd v Stent Foundations Limited & Peter Dann Limited [2007] EWHC 855 in asking the court to impose sanctions on your client and to order a stay of the proceedings, pursuant to paragraphs 13, 15(b) and (c) and 16 of the Practice Direction, as referred to in paragraph 7.2 of the Protocol.
Until your client has complied with its obligations and provided this information, I am unable to respond properly to the alleged claim and to consider my position in relation to it, and it is entirely premature (and a waste of costs and court time) for your client to issue proceedings. Should your client do so, then I will seek an immediate stay pursuant to paragraph 15(b) of the Practice Direction and an order that this information is provided.
Yours faithfully,
[Your name]