Thanks for the detailed guidance — really helpful.
Just to confirm, I haven’t actually received anything from the Civil National Business Centre yet. The only N180 I’ve got is the Claimant’s draft version that DCB Legal emailed to me.
Should I wait until the court sends me my official N180 (or it shows as “sent” on MCOL) before I complete and submit my own version?
I just want to be sure I don’t send it prematurely.
Having received your own N180 (make sure it is not simply a copy of the claimants N180) or been notified on MCOL that yours has been sent, do not use the paper form. Ignore all the other forms that came with it. you can discard those. Download your own N180 DQ here and fill it in on your computer. You sign it by simply typing your full name in the signature box.
https://assets.publishing.service.gov.uk/media/673341e779e9143625613543/N180_1124.pdf
Here are the answers to some of the less obvious questions:• The name of the court is "Civil National Business Centre".
• To be completed by "Your full name" and you are the "Defendant".
• C1: "YES"
• D1: "NO". Reason: "I wish to question the Claimant about their evidence at a hearing in person and to expose omissions and any misleading or incorrect evidence or assertions.
Given the Claimant is a firm who complete cut & paste parking case paperwork for a living, having this case heard solely on papers would appear to put the Claimant at an unfair advantage, especially as they would no doubt prefer the Defendant not to have the opportunity to expose the issues in the Claimants template submissions or speak as the only true witness to events in question.."
• F1: Whichever is your nearest county court. Use this to find it: https://www.find-court-tribunal.service.gov.uk/search-option
• F3: "1".
• Sign the form by simply typing your full name for the signature.
When you have completed the form, attach it to a single email addressed to both dq.cnbc@justice.gov.uk and info@dcblegal.co.uk and CC in yourself. Make sure that the claim number is in the subject field of the email.
1. The Defendant denies the claim in its entirety. The Defendant asserts that there is no liability to the Claimant and that no debt is owed. The claim is without merit and does not adequately disclose any comprehensible cause of action.
2. There is a lack of precise detail in the Particulars of Claim (PoC) in respect of the factual and legal allegations made against the Defendant such that the PoC do not adequately comply with CPR 16.4.
3. The Defendant is unable to plead properly to the PoC because:
(a) The contract referred to is not detailed or attached to the PoC in accordance with PD 16, para 7.3(1);
(b) The PoC do not state the exact wording of the clause (or clauses) of the terms and conditions of the contract (or contracts) which is/are relied on;
(c) The PoC do not adequately set out the reason (or reasons) why the claimant asserts the defendant has breached the contract (or contracts);
(d) The PoC do not state with sufficient particularity exactly where the breach occurred, the exact time when the breach occurred and how long it is alleged that the vehicle was parked before the parking charge was allegedly incurred;
(e) The PoC do not state precisely how the sum claimed is calculated, including the basis for any statutory interest, damages, or other charges;
(f) The PoC do not state what proportion of the claim is the parking charge and what proportion is damages;
(g) The PoC do not provide clarity on whether the Defendant is sued as the driver or the keeper of the vehicle, as the claimant cannot plead alternative causes of action without specificity.
4. The Defendant submits that courts have previously struck out materially similar claims of their own initiative for failure to adequately comply with CPR 16.4, particularly where the Particulars of Claim failed to specify the contractual terms relied upon or explain the alleged breach with sufficient clarity.
5. In comparable cases involving modest sums, judges have found that requiring further case management steps would be disproportionate and contrary to the overriding objective. Accordingly, strike-out was deemed appropriate. The Defendant submits that the same reasoning applies in this case and invites the court to adopt a similar approach by striking out the claim due to the Claimant’s failure to adequately comply with CPR 16.4, rather than permitting an amendment. The Defendant proposes that the following Order be made:
Draft Order:
Of the Court's own initiative and upon reading the particulars of claim and the defence.
AND the court being of the view that the particulars of claim do not adequately comply with CPR 16.4(1)(a) because: (a) they do not set out the exact wording of the clause (or clauses) of the terms and conditions of the contract which is (or are) relied on; and (b) they do not adequately set out the reason (or reasons) why the claimant asserts that the defendant was in breach of contract.
AND the claimant could have complied with CPR 16.4(1)(a) had it served separate detailed particulars of claim, as it could have done pursuant to PD 7C, para 5.2, but chose not to do so.
AND upon the Court determining, having regard to the overriding objective (CPR 1.1), that it would be disproportionate to direct further pleadings or to allot any further share of the Court’s resources to this claim (for example by ordering further particulars of claim and a further defence, with consequent case management).
ORDER:
1. The claim is struck out.
2. Permission to either party to apply to set aside, vary or stay this order by application on notice, which must be filed at this Court not more than 7 days after service of this order, failing which no such application may be made.
To: Stephen Shaw, Independent Complaints Assessor
Cc: DVLA Complaints Team
Subject: Response to ICA Review – Reference 185 (25/26)
Date: [Insert today's date]
Dear Mr Shaw,
Thank you for your letter dated 16 September 2025, responding to my complaint against the DVLA (Reference: 185 (25/26)).
Regrettably, your response fails to properly address the core of my complaint, and I must now formally register my dissatisfaction with the ICA’s handling of this matter.
1. Mischaracterisation of the Complaint
At no stage did I dispute the lawfulness of DVLA’s initial release of keeper data under Regulation 27(1)(e). My complaint explicitly stated that reasonable cause existed at the point of request. The issue under review was the DVLA’s failure to act upon post-access misuse of that data by G24 Ltd, in breach of the Private Parking Single Code of Practice (PPSCoP) and the KADOE contract.
Your decision fails to engage with this, and instead reverts to boilerplate reasoning around the DVLA's discretion at the point of data release — a point which was never in dispute. This constitutes a fundamental misreading of the complaint and fatally undermines your review.
2. Omissions and Factual Errors
Your response omits, or fails to address, the following:• The explicit terms of the KADOE contract, which confirm that the DVLA remains a joint data controller even after release and must take enforcement action if a recipient breaches the terms under which access was granted.
•The specific PPSCoP breaches by G24 Ltd:• Annex F1(c): Continuing to pursue a charge after I provided evidence of mechanical breakdown.• The DVLA’s obligation to investigate such misuse, particularly where the motorist has already exhausted the ATA’s appeal process and provides credible evidence of ongoing misuse of personal data.
• Section 8.3.1: Misstating the 28-day payment deadline from issue date rather than date of service.
• Failure to address a formal complaint: Proceeding to debt escalation without responding.
These are not policy grievances or “commercial disputes” as described in your letter. They are complaints about maladministration by a government agency in relation to its duties under the Data Protection Act 2018, the KADOE contract, and the DVLA’s own internal governance procedures.
3. Contradictions and Selective Interpretation
You assert that the DVLA "has no legal or administrative duty" to investigate post-release misuse of data. This is contradicted by:• The DVLA’s status as a data controller for all data supplied under KADOE, including liability for downstream processing if it becomes aware of misuse.
• The ICO’s 2022 Opinion, which you partially quote but fail to interpret accurately. While the DVLA is not required to adjudicate individual disputes before data release, it does have a continuing responsibility to monitor use of that data for the purposes it was released and to take proportionate action when misuse is identified.
• Paragraph 2.9 of the KADOE contract, which expressly prohibits use of DVLA data for purposes other than that for which it was provided. Where violations are reported, the DVLA must take investigative and remedial steps.
You further suggest the DVLA cannot “police” the private parking industry. That is not the issue. The question is whether the DVLA has discharged its obligations in light of clear evidence that G24 Ltd violated the conditions under which it received my data. That is a matter of public administration, not policy.
4. Process Failings
Even if you had no authority to comment on the data protection or KADOE aspects, your review still fails to meet the minimum standards of fair complaint handling:• You did not accurately summarise my complaint, misstating it as a challenge to DVLA’s data release decision.
• You failed to acknowledge the evidential material I submitted.
• You did not assess whether DVLA’s refusal to investigate G24’s conduct was a proportionate or reasonable response.
• You excused factual errors and delay in DVLA correspondence but provided no meaningful redress or recommendation beyond a footnote.
Your conclusions appear pre-determined and excessively deferential to DVLA policy rather than properly assessing whether maladministration occurred. In doing so, you have not fulfilled the aims set out in the ICA’s own Terms of Reference, particularly the commitment to “put right any injustice or unfairness suffered by members of the public in consequence of the actions, inactions, or decisions of DfT.”
5. Next Steps
I am therefore escalating this matter further.• I will ask my MP to refer this complaint to the Parliamentary and Health Service Ombudsman, citing both the DVLA’s failure to investigate data misuse and the ICA’s failure to properly consider the complaint.
• I am also lodging a separate complaint with the Information Commissioner’s Office, as advised.
• A copy of this letter will be retained for public record and shared with relevant accountability groups and public interest bodies monitoring DVLA data access practices.
Yours sincerely,
[Your Full Name]
[Contact Details]
Subject: Request for MP Referral to Parliamentary Ombudsman – DVLA Data Misuse Oversight
Dear [MP’s Name],
I am writing to request that you refer a complaint to the Parliamentary and Health Service Ombudsman (PHSO) regarding the Driver and Vehicle Licensing Agency (DVLA) and its failure to uphold its responsibilities as a data controller under the KADOE contract.
This complaint has now completed the full DVLA internal complaints process and has also been considered by the Independent Complaints Assessor (ICA), who upheld my complaint in part but declined to investigate the core issues I raised. The ICA confirmed that this now concludes the Department for Transport’s complaints process and advised me to approach my MP for a referral to the Ombudsman.
Summary of complaint
I do not dispute that G24 Ltd had reasonable cause to request my keeper data initially. My complaint concerns their subsequent misuse of that data — a matter for which the DVLA retains shared data controller responsibility under the terms of the KADOE contract and UK GDPR.
G24 Ltd materially breached the Private Parking Single Code of Practice (PPSCoP) by:• Continuing to pursue a parking charge after I supplied evidence of a vehicle breakdown, in direct breach of PPSCoP Annex F1(c).
• Issuing a Notice to Keeper which misstated the payment deadline, contrary to PPSCoP Section 8.3.1.
• Failing to address a formal complaint, then sharing my personal data with third parties, including debt collectors.
These are clear compliance breaches. The DVLA has a duty to monitor and act on such breaches once reported. Instead, it gave a template response and denied any responsibility for post-release misuse, despite remaining the data controller under KADOE Schedule 2 and the Data Protection Act 2018.
The ICA declined to investigate the substance of these concerns, stating that they could not challenge Government policy. However, my complaint was about maladministration and regulatory failure, not policy. I believe the DVLA has failed in its public duty to protect personal data and has shielded G24 Ltd from accountability.
I would be grateful if you would consider referring this matter to the PHSO, so it can be independently investigated.
I can provide a full timeline of correspondence and a copy of the ICA decision upon request.
Yours sincerely,
[Your Full Name]
[Your Postal Address]
[Constituency Postcode]
[Contact email]
To: DVLA Complaints Team
Ref: 0410774-B2W3C / DVLA Ref 0400043
Date: [Insert today's date]
Dear Mrs N Smith,
Re: Failure to address Step 2 complaint regarding G24 Ltd – formal request for escalation to ICA
Thank you for your letter dated 29 July 2025 in response to my Step 2 complaint. Unfortunately, your response repeats the same generic assertions made at Step 1 and once again fails to engage with the substance of the complaint I raised.
To be absolutely clear:• I do not dispute that G24 Ltd had reasonable cause to request keeper data at the time of the original DVLA data release.
• My complaint concerns G24 Ltd’s unlawful subsequent use of that data, in breach of the Private Parking Single Code of Practice (PPSCoP) and the KADOE contract.
• Your response completely fails to address the post-access misuse, despite this being the central issue from the outset.
Summary of Original Complaint (Reiterated for Clarity):
G24 Ltd used my keeper data to pursue a parking charge in direct breach of the PPSCoP, specifically:• Annex F1(c) – I submitted evidence that the vehicle was broken down and awaiting recovery. G24 continued enforcement regardless, despite the Code expressly prohibiting enforcement where a vehicle is immobilised due to mechanical failure.
• Section 8.3.1 – The NtK misstated the 28-day period for payment as running from the issue date, not date of receipt, which is misleading and non-compliant.
• Failure to address a formal complaint – G24 was given the opportunity to correct these breaches and failed to do so, instead escalating matters by sharing my personal data with third parties (e.g., debt recovery agents) without proper cause.
These are not civil disputes for the courts. They are compliance and data protection matters governed by the PPSCoP, the Data Protection Act 2018, and the terms of the KADOE contract, under which the DVLA remains jointly responsible as Data Controller.
DVLA Obligations
As you will be aware:• The DVLA retains ongoing responsibility for ensuring that data released under the KADOE contract is not subsequently misused.
• The DVLA must investigate post-access misuse where credible allegations are raised.
• The DVLA is required to monitor compliance with the PPSCoP and take proportionate enforcement action when breaches are identified.
Your Step 2 response neither investigates the misuse nor acknowledges that any breach occurred, despite clear evidence being provided. It also fails to mention the Independent Complaints Assessor (ICA) or how to escalate the complaint further, contrary to the DVLA's own published complaints process.
Accordingly, I now require the following:• A formal acknowledgement that my complaint has been mishandled and not properly responded to at Step 2.
• Immediate escalation of this matter to the Independent Complaints Assessor (ICA), including both:• DVLA’s failure to investigate the reported misuse of my data; and
• DVLA’s failure to signpost or facilitate escalation to the ICA at Step 2, as required by its own procedures.
Please confirm in writing that this matter has now been referred to the ICA.
Yours sincerely,
[Your full name]
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.
Because your letter lacks specificity and breaches the requirements of the Pre-Action Protocol for Debt Claims (paragraphs 3.1(a)-(d), 5.1 and 5.2) as well as the Practice Direction - Pre-Action Conduct (paragraphs 6(a) and 6(c)), you must treat this letter as a formal request for all of the documents/information that the protocol now requires your client to provide. Your client must not issue proceedings without complying with that protocol.
As solicitors you must surely be familiar with the requirements of both the Practice Direction and the Pre-Action Protocol for debt claims and your client, as a serial litigator of debt claims, should likewise be aware of them. As you (and your client) must know, the Practice Direction and Protocol bind all potential litigants, whatever the size or type of the claim. Its express purpose is to assist parties in understanding the claim and their respective positions in relation to it, to enable parties to take stock of their positions and to negotiate a settlement, or at least narrow the issues, without incurring the costs of court proceedings or using up valuable court time. It is embarrassing that a firm of Solicitors are sending a consumer a vague and un-evidenced 'Letter of Claim' in complete ignorance of the pre-existing Practice Direction and the Pre-Action Protocol.
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. An explanation of the cause of action
2. whether they are pursuing me as driver or keeper
3. whether they are relying on the provisions of Schedule 4 of POFA 2012
4. what the details of the claim are; for how long it is claimed the vehicle was parked, how the monies being claimed arose and have been calculated
5. Is the claim for a contractual breach? If so, what is the date of the agreement? The names of the parties to it and provide to me a copy of that contract.
6. If the claim is for a contractual breach, photographs showing the vehicle was parked in contravention of said contract.
7. Is the claim for trespass? If so, provide details.
8. Provide me a copy of the contract with the landowner under which they assert authority to bring the claim, as required by the BPA/IPC Private Parking Single Code of Practice (PPSCoP).
9. a plan showing where any signs were displayed
10. Photographs of the signs displayed (size of sign, size of font, height at which displayed) at the time of any alleged contravention.
11. Provide details of the original charge, and detail any interest and administrative or other charges added
12. Am I to understand that the additional £70 represents what is dressed up as a 'Debt Recovery' fee, and if so, is this nett or inclusive of VAT? If the latter, would you kindly explain why I am being asked to pay the operator’s VAT?
13. With regard to the principal alleged PCN sum: Is this damages, or will it be pleaded as consideration for parking?
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]
I am escalating my complaint (Ref: 0400043) to Step 2 of the DVLA complaints process because your response dated 16 April 2025, signed by Carly Williams, failed to engage with the substance of my complaint.
I did not dispute G24 Ltd’s initial request for my keeper data. My complaint was – and remains – about their subsequent misuse of that data, in breach of the Private Parking Single Code of Practice (PPSCoP), specifically Annex F1(c) and Section 8.3.1. These breaches make their ongoing use of my personal data unlawful under the terms of the KADOE contract and UK GDPR.
Ms Williams’ response merely restated the reasonable cause basis for the original request, which I had already accepted. The DVLA has a statutory obligation to regulate how my data is used after disclosure. This includes investigating misuse and taking action under the terms of the KADOE contract.
I have attached a supporting statement setting out the PPSCoP breaches by G24 Ltd and the legal basis for this escalation. Please treat this as a formal Step 2 complaint and confirm that it has been referred to the Head of Complaints for investigation.
SUPPORTING STATEMENT
Step 2 Complaint to DVLA – Unlawful Use of Keeper Data by G24 Ltd
Operator: G24 Ltd
DVLA Ref: 0400043
DVLA Response Date: 16 April 2025
VRN: [insert vehicle registration]
I am escalating this complaint because the DVLA’s Step 1 response from Carly Williams (dated 16 April 2025) entirely failed to address my actual complaint. That letter misrepresented my position and provided a boilerplate defence of DVLA’s data release process.
To be clear: I do not dispute that G24 Ltd had reasonable cause at the time of requesting my data. My complaint concerns what happened afterwards – specifically, that G24 misused that data by pursuing a charge in breach of the Private Parking Single Code of Practice (PPSCoP), which governs lawful use under the KADOE contract.
The specific breaches are as follows:
[indent[• Annex F1(c) breach – I submitted clear evidence that the vehicle was broken down and awaiting recovery. G24 ignored this and continued to pursue the charge, despite the PPSCoP expressly prohibiting enforcement in such circumstances.
• Section 8.3.1 breach – The Notice to Keeper falsely claimed that payment was due within 28 days of the issue date. The PPSCoP requires 28 days from receipt. This misrepresentation is misleading and materially prejudices the recipient.
• Failure to substantively respond to a formal complaint – G24 was given the opportunity to address these issues directly but failed to do so, continuing to process and pass on my data to third parties.[/indent]
These are not minor lapses. They are material breaches of the PPSCoP and render G24’s ongoing use of my keeper data unlawful. The DVLA remains the Data Controller for that data and is responsible for ensuring that AOS operators do not misuse it after access is granted.
Under the terms of the KADOE contract and the Data Protection Act 2018, the DVLA must investigate this misuse and take action, including:• Acknowledging that a breach has occurred
• Issuing sanctions against G24 Ltd for PPSCoP violations
• Suspending or revoking G24’s KADOE access if warranted
I request a full and proper investigation into G24’s misuse of my data. Please confirm receipt and confirm that this Step 2 complaint has been escalated to the Head of Complaints.
Name: [insert your name]
Date: [insert today’s date]
If they come back to you with some rubbish about not accepting complaints at that email address, then, if you have not already done so anyway, send it by post, first class and obtain a free "Proof of Posting Certificate" from any post office.
[Your Name]
[Your Address]
[City, Postcode]
[Email Address]
G24 Ltd
Complaints Department
PO BOX 3320
Gerrards Cross
SL9 8WT
[Date]
By email to: info@g24.co.uk
Subject: Formal Complaint – Parking Charge [PCN Reference] – Breach of PPSCoP
Dear Sir/Madam,
I am writing to formally complain about Parking Charge Notice (PCN [Reference]) issued for an alleged contravention at Chadwell Heath Retail Park. This charge is both unjust and in breach of the BPA/IPC Private Parking Single Code of Practice (PPSCoP).
Background of the ComplaintMy vehicle suffered a mechanical failure and was immobilised while awaiting recovery. Due to the lack of alternative spaces, the vehicle was pushed into a disabled bay to avoid obstructing traffic. I submitted a breakdown report confirming the mechanical failure and subsequent recovery, yet G24 rejected my appeal.Following your rejection, I escalated my case to the Independent Appeals Service (IAS), but the appeal was also unsuccessful. Given your failure to comply with the PPSCoP, I am now lodging this formal complaint before escalating the matter to the DVLA and IPC.
Breach #1 – Incorrect Payment DeadlineYour Notice to Keeper (NtK) unlawfully states that payment must be made within 28 days from the "issue" date. This is a clear misrepresentation of the required timeframe under the PPSCoP, which mandates that recipients have 28 days from the date of "receipt" to respond or make payment. This breach unfairly reduces the time available to challenge the charge, rendering the notice non-compliant with industry regulations.
Breach #2 – Failure to Apply Breakdown Exemption (Annex F1(c))The PPSCoP explicitly prohibits enforcement against a broken-down vehicle awaiting recovery. Clause Annex F1(c) of the PPSCoP states:"A Parking Charge Notice must not be issued where there is evidence that the vehicle was immobilised due to a mechanical fault and was awaiting recovery."Despite submitting irrefutable evidence of the breakdown, including an official breakdown report, G24 wrongfully refused to cancel the charge. This constitutes a clear failure to adhere to the PPSCoP and demonstrates an unfair enforcement policy.
Concerns Regarding Late Delivery of the NtKThe NtK was received after the 14-day deadline for PoFA compliance, and I do not believe that the notice was actually sent on the date it was issued. Furthermore, I have reason to believe that G24 did not use a first-class or equivalent service to comply with the two-working-day delivery assumption under PoFA. Most hybrid mail systems used by consolidators employ a slower 2-3 day delivery service, which does not meet this requirement.As such, I require G24 to provide evidential proof of the actual date the notice was entered into the postal system. The PPSCoP states clearly at section 8.1.2(e) Note 2:"Parking operators must retain a record of the date of posting of a notice, not simply of that notice having been generated (e.g. the date that any third-party Mail Consolidator actually put it in the postal system.)"Therefore, G24 must evidence the actual date the notice was posted, not simply generated. An internally generated certificate of posting by hybrid mail from a consolidator does not satisfy this requirement, and G24 must obtain proof from their mail consolidator of the exact date the notice was submitted into the postal system.
Requested ActionsTo resolve this matter, I require the following:1. A written response addressing the specific breaches of the PPSCoP outlined above.
2. Acknowledgment that the charge should have been cancelled under the breakdown exemption clause.
3. Provision of documented proof from your mail consolidator confirming the exact date the NtK was entered into the postal system and the postal service used.
Response Deadline and Notice of EscalationI expect a full response within 14 days of this letter. Failure to respond satisfactorily will result in the following actions:- A formal complaint to the DVLA for G24's breach of its Keeper At Date Of Event (KADOE) contract, which governs access to DVLA keeper data.
- A formal complaint to the International Parking Community (IPC) for non-compliance with the PPSCoP.
- Further action, including potential legal challenge, if the charge is not cancelled immediately.I trust that G24 will take this matter seriously and respond accordingly.
Yours sincerely,
[Your Name]