You should also drop them in the mire with a formal complaint about them to the DVLA. Here’s how to make a DVLA complaint:
• Go to: https://contact.dvla.gov.uk/complaints
• Select: “Making a complaint or compliment about the Vehicles service you have received”
• Enter your personal details, contact details, and vehicle details
• Use the text box to summarise your complaint or insert a covering note
• You will then be able to upload a file (up to 19.5 MB) — this can be your full complaint or supporting evidence
That’s it.
The DVLA is required to record, investigate and respond to every complaint about a private parking company. If everyone who encounters a breach took the time to submit a complaint, we might finally see the DVLA take meaningful action—whether that means curtailing or removing KADOE access altogether.
For the text part of the complaint the webform could use the following:
I am submitting a formal complaint against Britannia Parking Group Ltd, a BPA AOS member with DVLA KADOE access, for breaching the Private Parking Sector Single Code of Practice (PPSCoP) and misusing my personal data, which they obtained from the DVLA.
It is questionable whether Britannia had reasonable cause to request my data at all. The alleged contravention is based entirely on ANPR timestamps from two separate visits — a known failure mode referred to as a “double dip.” Under PPSCoP 7.3(d), operators are required to carry out manual checks for “orphan images” to ensure ANPR records are accurate before issuing a PCN. Had Britannia conducted the required quality control checks, they would have identified the error and had no cause whatsoever to request my data. Their failure to do so undermines any claim of reasonable cause from the outset.
Moreover, Britannia then issued a Notice to Keeper which falsely claimed that the keeper could be held liable under the Protection of Freedoms Act 2012. This was legally impossible due to the late issue date. They later admitted in writing that the NtK was not PoFA compliant, yet continued to pursue the keeper, and attempted to justify this using discredited pre-PoFA arguments. This constitutes a breach of Paragraph 8.1.1(d) of the PPSCoP and reflects a serious and deliberate misuse of my data.
The DVLA remains the data controller for personal data released via KADOE, and therefore bears responsibility for how that data is used. This complaint raises serious concerns under the UK GDPR and the Data Protection Act 2018, and I request that the DVLA report this matter to the Information Commissioner’s Office (ICO), and investigate both Britannia’s conduct and the DVLA’s own data sharing practices in this instance.
Please confirm receipt and provide a reference number for this complaint. Supporting evidence is attached.
Then you could upload the following as a PDF file for the formal complaint itself:
SUPPORTING STATEMENT
Complaint to DVLA – Breach of KADOE Contract, PPSCoP and UK GDPR
Operator name: Britannia Parking Group Ltd
Date of PCN issue: 06/02/2025
Vehicle registration: [INSERT VRM]
I am submitting this complaint to report the unlawful acquisition and misuse of my personal data by Britannia Parking Group Ltd, who accessed my DVLA keeper details via the KADOE (Keeper At Date Of Event) service.
Britannia Parking’s request for my data was made without reasonable cause, which makes the request itself — not just any later actions — a breach of:
• the KADOE contract,
• the UK General Data Protection Regulation (UK GDPR), and
• the Private Parking Sector Single Code of Practice (PPSCoP).
1. The KADOE request was unlawful – no reasonable cause due to failure to conduct mandatory checks
Britannia issued a PCN based on ANPR images showing my vehicle entering and exiting a site nearly two hours apart. That access road leads to a Waitrose car park monitored by a different ANPR system. The facts clearly establish that two separate visits occurred — a well-documented ANPR failure known as a “double dip”.
Before accessing any keeper data, operators are required under PPSCoP Paragraph 7.3(d) to conduct full quality control checks — including manual review of all ANPR captures — to identify orphan images and rule out double visits.
Britannia Parking failed to carry out these mandatory checks. Had they done so, they would have seen the two separate visits and realised that no contravention had occurred. There was never any reasonable cause to request DVLA data.
Accordingly, their KADOE request itself was unlawful. This is not just a breach of the Code and KADOE contract terms — it is a breach of the UK GDPR, because the personal data was obtained and processed without a lawful basis.
This breach occurred at the point of the request — not merely through subsequent use. The DVLA, as data controller, must treat this as a clear misuse of its data-sharing system.
2. False legal claims in the NtK – misrepresentation of keeper liability under PoFA 2012
Britannia then compounded the breach by issuing a Notice to Keeper dated 06/02/2025, falsely stating that the keeper was liable under Paragraph 9(2)(f) of the Protection of Freedoms Act 2012 (PoFA). However, the alleged contravention occurred on 26/01/2025, meaning the NtK was deemed delivered 15 days later — outside the statutory 14-day window required to establish keeper liability.
This wasn’t a clerical error. In correspondence dated 26/02/2025 (attached), Britannia again asserted PoFA liability, continuing to mislead the recipient about the legal basis for the charge. It was only in a subsequent letter dated 20/03/2025 (also attached) that they admitted the NtK was non-compliant — but even then, they attempted to justify their position using long-rejected “pre-PoFA” legal arguments.
This constitutes a deliberate breach of PPSCoP Paragraph 8.1.1(d), which prohibits operators from claiming keeper liability under PoFA unless the notice meets all statutory conditions — which this one did not.
3. Unlawful processing of personal data – breach of UK GDPR continues
Having obtained my data unlawfully, Britannia then used it to pursue a charge they had no legal authority to enforce, issuing misleading legal threats in an effort to extract payment. This is a textbook example of unlawful processing under the UK GDPR and Data Protection Act 2018, in violation of the principles of lawfulness, fairness, transparency, and purpose limitation.
As the data controller for keeper data released via the KADOE system, the DVLA has an obligation to investigate serious misuse and to protect data subjects whose personal data has been wrongly obtained.
I therefore request that the DVLA:
• Confirms that a breach has occurred
• Takes enforcement action against Britannia Parking Group Ltd
• Refers both the operator and this incident to the Information Commissioner’s Office (ICO)
• Reviews its internal data release procedures to ensure future requests meet the required threshold of lawful basis and reasonable cause
Britannia Parking’s conduct represents a fundamental abuse of the data access rights conferred under KADOE. This is not a minor infraction. They failed to carry out the required checks, had no reasonable cause to request my data, misrepresented their legal position in formal correspondence, and continued to misuse my personal data with no lawful basis.
I have attached the relevant supporting evidence.
Name: [INSERT NAME]
Date: [INSERT DATE]
Remember to include the copies of the relevant responses from Britannia. You'll have to combine it all into a single PDF. Use this free website to combine all the copies and the statement into a single pdf file:
https://www.pdf2go.com
Just send the following as your POPLA appeal and include copies of the two responses you received from Britannia dated 26/02/2025 and 20/03/2025, highlighting the relevant sentences as they are referred to in the appeal. Make sure you mark them Exhibit A and B as necessary:
POPLA Verification Code: [INSERT CODE]
PCN Reference Number: [INSERT PCN REFERENCE]
Vehicle Registration: [INSERT VRM]
Operator: Britannia Parking Group Ltd
Site: Bromley – Bromley Police Station Access Road
Date of Alleged Contravention: 26/01/2025
Date of Notice to Keeper (NtK): 06/02/2025
1. No keeper liability – NtK issued outside the 14-day period required by Schedule 4 of the Protection of Freedoms Act 2012 (PoFA)
Britannia Parking claims that it can pursue the registered keeper under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA). However, the alleged contravention occurred on Sunday 26th January 2025, and the Notice to Keeper (NtK) was issued on Thursday 6th February 2025.
Under PoFA Schedule 4 Paragraph 9(5), if no Notice to Driver was issued, the operator must deliver the NtK within 14 days of the alleged incident. Under Paragraph 9(6), a notice sent by post is deemed “given” on the second working day after posting — in this case, Monday 10th February 2025, which is 15 days after the contravention.
As such, the NtK is non-compliant with PoFA, and the operator cannot pursue the keeper. Britannia’s subsequent correspondence dated 20/03/2025 (attached as Exhibit A) admits that the NtK is not PoFA compliant, which reinforces the Keeper’s position. Despite this admission, Britannia had previously asserted in a letter dated 26/02/2025 (attached as Exhibit B) that it could pursue the keeper under Paragraph 9(2)(f) of PoFA. That misrepresentation is a breach of Paragraph 8.1.1(d) of the Private Parking Sector Single Code of Practice (PPSCoP), which prohibits operators from claiming PoFA liability where the legal conditions are not met.
2. No right to pursue the Keeper where PoFA does not apply
Britannia stated the following in its 20/03/2025 letter (see Exhibit A):
"This Parking Charge is not POFA compliant, however, payment can still be sought under the old 'implied-contract-with-the-driver' rules used prior to POFA."
This argument is legally incoherent. PoFA was enacted precisely to create a statutory route for pursuing the keeper of a vehicle where the driver is unknown. If Britannia has chosen to invoke PoFA, then they are bound by its terms — and if they fail to comply, they cannot fall back on outdated pre-2012 case law. That legal framework was superseded by PoFA over 12 years ago.
Britannia is pursuing the registered keeper, not the driver. There is no evidence whatsoever that the keeper was driving, and no right to infer such a connection. The operator’s suggestion that it can still pursue the keeper is plainly wrong.
If Britannia were foolish enough to take this to court, they would be met with persuasive appellate authority such as VCS v Edward (2023) [HOKF6C9C], where the judge confirmed that driver liability cannot be inferred solely from registered keeper status.
POPLA is therefore invited to recognise that, in the absence of PoFA compliance and absent any identification of the driver, the operator is pursuing the wrong person and the charge must be cancelled.
3. No evidence of parking or stopping – operator has not demonstrated that a contravention occurred
The PCN alleges that the vehicle was “parked/stopped in a no parking area.” However, Britannia has only supplied two still images from ANPR cameras showing the vehicle entering and exiting the access road nearly two hours apart.
There is no evidence whatsoever that the vehicle was stationary, parked, or stopped in breach of any terms and conditions during that time. In fact, the site in question leads to a Waitrose car park, where parking is permitted for 90 minutes without payment. That car park is separately monitored by its own set of ANPR cameras.
The actual sequence of events was:
• The vehicle entered the access road, dropped off a passenger at Waitrose, and exited;
• The vehicle returned later via the same road, parked legally in the Waitrose car park, collected the passenger, and departed.
The ANPR system has erroneously paired an entry from the first visit with an exit from the second. This is a well-known error referred to as a “double dip”.
Under Paragraph 7.3(d) of the PPSCoP:
“Operators using automatic number plate recognition (ANPR) technology must ensure that their systems are working correctly and are able to detect and prevent errors that can occur, including... identifying 'orphan images' that could indicate a double dip.”
I put Britannia to strict proof that it followed the correct procedure and manually reviewed all ANPR captures from the date of the alleged contravention to rule out a double-dip scenario. If the operator cannot provide an audit trail or clear evidence of such a check, then its ANPR evidence is unreliable, and the charge must be cancelled.
4. Signage – operator has not shown that the signage meets the required standard
No evidence has been supplied to show that any signage was:
• Visible and legible upon entry;
• Compliant with the PPSCoP in terms of layout, prominence, and wording;
• Capable of forming a valid contract.
If signage displays prohibitive terms such as “No Stopping,” this is not an offer of contractual terms but a forbidding notice. Such signs are incapable of forming a contract. The only possible cause of action in such cases would be trespass, which only the landholder can pursue — not the operator.
Accordingly, Britannia has failed to establish that a contract existed, or that its signage was adequate.
5. Operator is put to strict proof of landowner authority
Britannia has provided no evidence that it has the authority to issue and enforce PCNs at Bromley Police Station Access Road.
Under the PPSCoP (Annex C), an operator must hold written authorisation from the landowner that explicitly entitles it to:
• Issue PCNs;
• Pursue payment in its own name; and
• Take legal action if required.
I put Britannia to strict proof by way of a contemporaneous, unredacted copy of the landowner agreement in force at the time of the alleged contravention. If the operator cannot produce such a document, it has no standing and the charge must be cancelled.
Conclusion
This PCN is invalid for multiple reasons:
• The NtK was not served within 14 days, and Britannia has no right to pursue the keeper.
• Britannia falsely claimed PoFA liability and then later admitted the NtK was non-compliant.
• Britannia is pursuing the registered keeper despite knowing it cannot rely on PoFA.
• The allegation relies on flawed ANPR data, and no evidence has been produced that any contravention occurred.
• No valid contract has been shown to exist due to inadequate signage.
• The operator has not proven that it has authority from the landowner to issue charges at the site.
For these reasons, I respectfully request that POPLA allow the appeal and direct Britannia Parking to cancel this charge.
Hilarious. Reply with the following...
Subject: Re: Pathetic Attempt at Damage Control – PCN #[REFERENCE]
Dear Britannia Parking,
Thank you for your recent response to my formal complaint — a response so staggeringly inept, so devoid of legal coherence, that it deserves to be preserved in a glass case as a masterclass in how not to respond to a regulatory breach.
Let’s be clear: I informed you, plainly and politely, that your Notice to Keeper was non-compliant with Schedule 4 of the Protection of Freedoms Act 2012 (PoFA), and that as such, you had no lawful basis to pursue the registered keeper for payment. Instead of acknowledging your error, you doubled down with a letter dated 26/02/2024, brazenly claiming that you had the right to recover the charge from me under PoFA.
This is not a minor mistake. It is a knowing and deliberate misstatement of statutory law — a textbook breach of paragraph 8.1.1(d) of the Private Parking Sector Single Code of Practice (PPSSCoP), and of Clause C1.1 of your KADOE contract with the DVLA. You do not get to falsely threaten people with keeper liability under legislation you have utterly failed to comply with. That’s not “non-ideal training”; it’s misrepresentation. You should be grateful this is merely being escalated to regulators and not challenged before a judge.
And yet, with astonishing audacity, your response tries to salvage this mess with the tired, wheezing argument that you can “still pursue the driver under the old implied contract theory.” Do you truly not grasp how pathetic this is?
This desperate fallback has been booted out of court more often than a politician dodges a question. Judges are no longer tolerating operators like you clinging to it like a rubber ring on a sinking ship. You’re not clever. You’re not persuasive. You’re just repeating obsolete nonsense and hoping nobody notices. Spoiler: we notice.
Then comes your pièce de résistance — the absurd fantasy that you’ll ask a judge to “review the insurance certificate” to magically identify the driver. Have you any idea how the civil court process works? The court will not embark on a speculative fishing expedition on your behalf because you couldn’t be bothered to gather proper evidence. This is small claims, not a psychic hotline.
You compound your embarrassment by stating: “Not quoting PoFA does not mean the charge was incorrectly issued”. Let me explain this in words short enough for your compliance team to be able to digest: if you don’t meet PoFA requirements, you don’t get keeper liability. If you claim you do—when you don’t—you’ve misrepresented the legal position. You cannot have it both ways. Your claim fails at the starting gate.
Your conduct reeks of opportunism, ignorance, and contempt for both regulatory compliance and the public you routinely mislead. You are an embarrassment to the industry — and that is no small feat.
Let me make this simple:
• Cancel the charge
• Issue the formal apology you owe
• Reflect seriously on the astonishing incompetence that led you to send such a response
Failure to do so will result in a formal complaint to the DVLA and BPA, including a copy of your unintentionally hilarious letter — a document so riddled with legal and logical fallacies it could be used as a training tool, were it not so embarrassing.
I look forward to watching you try to explain this to your trade association.
Yours sincerely,
[Your Name]
That response is risible. So much so that I'd be minded to file a formal complaint about their conduct, to complaints@britannia-parking.co.uk (complaints@britannia-parking.co.uk).
Here's a suggestion. I've knocked it together fairly quickly so others may suggest improvements. You could also attach a copy of that letter to your complaint for clarity.
Subject: Formal Complaint, PCN #[REFERENCE]
Dear Sirs,
I am writing to make a formal complaint about your correspondence in respect of PCN #[REFERENCE], which amounts to a breach of the Private Parking Sector Single Code of Practice (PPSSCoP) and, by virtue of this, your KADOE contract with the DVLA.
Following receipt of your PCN, I appealed as the registered keeper, pointing out that due to your failure to deliver a Notice to Keeper within the relevant period of 14 days as required by Schedule 4 of the Protection of Freedoms Act (PoFA), you are unable to recover the charge from me as the keeper. You responded with a letter dated 26/02/2024, which is attached, claiming to be notifying me under PoFA that you have the right to recover the charge from me as the keeper. This is a clear breach of the PPSSCoP and the KADOE contract for the following reasons:
1. Breach of the PPSSCoP
Section 8.1.1 of the PPSSCoP states:
8.1.1 The parking operator must not serve a notice or include material on its website which in its design and/or language:d) state the keeper is liable under the Protection of Freedoms Act 2012 where they cannot be held liable.
In my appeal, I explained that Britannia had failed to serve a notice compliant with the requirements of PoFA, having given the notice outside of the relevant period of 14 days. You then responded on 26/02/2024 with the attached letter, claiming the ability to recover the charges from me under PoFA. This is a deliberate misrepresentation, and a breach of 8.1.1 of the PPSSCoP.
As per Annex H of the PPSSCoP, this constitutes at least a Level 1 sanction for non-conformance.
2. Breach of the KADOE Contract
Clause C1.1 of your KADOE Contract with DVLA states:
The Customer shall ensure that signage, terms and conditions of service for parking customers and correspondence with data subjects comply with the Law and with the requirements of the ATA’s Code of Practice or Conduct.
By knowingly and falsely claiming compliance with PoFA, you have failed to comply with the terms of your KADOE contract, bringing into question your suitability to have access to sensitive registered keeper data.
As a result of these serious failings you should:
- Confirm that the parking charge has been cancelled and that no further action will be taken
- Explain why your correspondence falsely claims the ability to recover charges under PoFA when you are, or ought to be, fully aware this is not true
- Issue a formal apology
I expect a thorough response to my complaint within 14 days. Following your response, I reserve the right to escalate this matter to the British Parking Association, and the DVLA.
Yours etc...
For completeness, can you show us the back page?
The good news for you is that, based on those dates, they have issued the notice too late to comply with the requirements of Schedule 4 of the Protection of Freedoms Act (there's a link in my signature underneath my posts), meaning they cannot transfer liability for the charge from the driver, who they don't know, to the registered keeper.
You can therefore appeal with the below:
Dear Sirs,
I have received your Parking Charge Notice (Ref: ________) for vehicle registration mark ____ ___, in which you allege that the driver has incurred a parking charge. I note from your correspondence that you are not seeking to hold me liable as the registered keeper, under Schedule 4 of the Protection of Freedoms Act 2012 ("The Act"). You have chosen not to issue a Notice to Keeper in accordance with The Act, and it is now too late for you to do so.
There is no obligation for me to name the driver and I will not be doing so. I am therefore unable to help you further with this matter, and look forward to your confirmation that the charge has been cancelled. If you choose to decline this appeal, you must issue a POPLA code.
Yours,
If appealing online, be careful there are no drop down/tick boxes that cause you to identify who was driving, and keep a close eye on your spam folder for their response. If they do not respond within 28 days, chase them.
Thank you. What is the time limit for them to issue the notice please?
Picture of the back of the notice below.[attachimg=2]
[attachment deleted by admin]
For completeness, can you show us the back page?
The good news for you is that, based on those dates, they have issued the notice too late to comply with the requirements of Schedule 4 of the Protection of Freedoms Act (there's a link in my signature underneath my posts), meaning they cannot transfer liability for the charge from the driver, who they don't know, to the registered keeper.
You can therefore appeal with the below:
Dear Sirs,
I have received your Parking Charge Notice (Ref: ________) for vehicle registration mark ____ ___, in which you allege that the driver has incurred a parking charge. I note from your correspondence that you are not seeking to hold me liable as the registered keeper, under Schedule 4 of the Protection of Freedoms Act 2012 ("The Act"). You have chosen not to issue a Notice to Keeper in accordance with The Act, and it is now too late for you to do so.
There is no obligation for me to name the driver and I will not be doing so. I am therefore unable to help you further with this matter, and look forward to your confirmation that the charge has been cancelled. If you choose to decline this appeal, you must issue a POPLA code.
Yours,
If appealing online, be careful there are no drop down/tick boxes that cause you to identify who was driving, and keep a close eye on your spam folder for their response. If they do not respond within 28 days, chase them.