Dear Sir or Madam,
I am the defendant in the above claim, which has been listed for hearing on 23 June 2025 at Edmonton County Court.
I am writing to ask whether the claimant has paid the hearing fee by the due date of 13 June, and whether the claim is still proceeding. I have not received any Notice of Discontinuance or any hearing bundle from the claimant.
Could you please confirm:• Has the claimant paid the hearing fee?
• Has the claim been discontinued or struck out?
• Is the hearing on 23 June still going ahead or has it been vacated?
Thank you for your assistance. I would be grateful for a prompt reply as the hearing date is fast approaching and the allocation order is dated 4th June which arrived after the bundles deadline of 9th June.
Yours faithfully,
[Your full name]
[Your address]
[Your contact email and phone number]
[Claim Number]
Nothing really besides court papersSuch as?
Sorry, but you want help but you leave a huge 3 month gap here, the details of the “papers” might be important.
You say you want help by next Monday but you’re not forthcoming with any details.
Nothing really besides court papersSuch as?
Sorry, but you want help but you leave a huge 3 month gap here, the details of the “papers” might be important.
You say you want help by next Monday but you’re not forthcoming with any details.
Nothing really besides court papersSuch as?
Please note that we comply with the Protection of Freedoms Act 2012 (POFA).
With the address you have provided, we cannot conveniently contact the driver as we only have power to enforce within the UK.
This means that we are unable to take steps to enforce against the driver. According to POFA, if we are unable to take steps to enforce against the driver of the vehicle, we have the right to recover any unpaid parking charges from the keeper of the vehicle (Schedule 4 Para 4(1)).
Right to claim unpaid parking charges from keeper of vehicle:
The right under this paragraph may only be exercised after the end of the period of 28 days beginning with the day on which the notice to keeper is given.
Conditions that must be met for purposes of paragraph 4:
5(1) The first condition is that the creditor—(a)has the right to enforce against the driver of the vehicle the requirement to pay the unpaid parking charges; but
(b)is unable to take steps to enforce that requirement against the driver because the creditor does not know both the name of the driver and a current address for service for the driver.
Subject: Formal Complaint Regarding NPC’s Unlawful Processing of Keeper Data and Failure to Adhere to PoFA
Dear Ms Sparrowhawk (if that is indeed your real name),
I am writing in response to your wholly inadequate and legally illiterate reply to my formal complaint regarding National Parking Control’s (NPC) flagrant breach of the Protection of Freedoms Act 2012 (PoFA) and its continued misuse of DVLA keeper data in direct violation of its KADOE contract.
Your response is riddled with inaccuracies, a fundamental misunderstanding of PoFA, and a disturbing disregard for basic legal principles. Given your role as “Head of Customer Services,” one would expect at least a rudimentary comprehension of the law underpinning your company’s operations. Instead, you have cited non-existent provisions, ignored statutory obligations, and doubled down on NPC’s unlawful behaviour.
Let us dissect your errors one by one.
1. Failure to Adhere to PoFA and Unlawful Resubmission of the Notice to Keeper
Your email asserts that because NPC is “unable to conveniently contact the driver,” liability reverts to the keeper. This is an entirely fictitious assertion, devoid of any basis in PoFA.
PoFA Schedule 4, Paragraph 5(1) explicitly states that a creditor may only hold the keeper liable if they do not know both the name and a current address for service for the driver. I provided you with both the name and a valid, serviceable U.S. address for the driver, thereby discharging my liability.
You are seemingly under the delusion that a serviceable address must be in the UK. Nowhere in PoFA does such a requirement exist. Your refusal to accept an international address is nothing more than a convenient excuse to continue your harassment of the wrong party.
Furthermore, PoFA does not permit the reissuing of a Notice to Keeper once liability has been transferred. NPC’s decision to disregard the lawful transfer of liability and proceed against me is a flagrant abuse of process and will not go unchallenged.
2. Legal Violations & Misuse of Keeper Data
Your actions constitute clear breaches of your KADOE contract with the DVLA. By continuing to process my personal data and pursuing me for a charge I am not liable for, NPC has engaged in unlawful data processing.
As per the KADOE contract, registered keeper data may only be accessed and processed for legitimate enforcement purposes where liability for the parking charge exists. Given that I am not liable under PoFA, NPC’s continued retention and use of my data is both unlawful and a clear breach of your contractual obligations.
I will be escalating this to the DVLA’s compliance team, as NPC’s actions warrant an urgent review of whether you should retain access to keeper data at all.
3. Complete Fabrication of PoFA Provisions
You reference “Schedule 4, Paragraph 4(1)” in an attempt to justify NPC’s misconduct. No such provision exists. If you are going to attempt to use PoFA to defend your unlawful conduct, you might at least make the effort to cite an actual section of the statute.
Paragraph 4(4), which I assume is what you meant to reference, merely states that a parking operator’s right to claim against the keeper arises after 28 days if liability has not been transferred. Given that liability was transferred in accordance with PoFA, NPC never had the right to pursue me in the first place.
Your misrepresentation of PoFA demonstrates a staggering level of incompetence and reinforces why NPC’s conduct needs to be scrutinised by regulatory bodies.
4. NPC’s Reliance on the IPC as a Shield from Accountability
You suggest I take my complaint to the IPC. The very notion is laughable. As you are well aware, the IPC is an utterly discredited entity that functions more as a rubber stamp for its members than as a genuine regulator.
The Private Parking Single Code of Practice (PPSCoP) is quite clear in stating that PoFA must be adhered to. NPC has failed to do so, meaning this matter is for the DVLA, the ICO, and potentially the courts, not the IPC.
5. Formal Demands & Next Steps
NPC is now on notice that I will escalate this matter further unless the following actions are taken immediately:1. Cease all unlawful processing of my data. You are in clear breach of PoFA and have no legitimate grounds to retain or use my personal information.
2. Confirm that you have cancelled this charge in full. Given that liability was transferred, there is no legal basis for pursuing this claim.
3. Provide an explanation for your blatant misinterpretation of PoFA. Your inability to grasp the basic tenets of the very law you are attempting to rely on raises serious concerns about NPC’s competence and integrity.
4. Discipline Ms Sparrowhawk for her demonstrable failure to comprehend statutory law. Assuming that she exists, her complete lack of understanding of PoFA suggests she is wholly unqualified for her role. If she is a fabricated persona, NPC’s decision to respond to legal complaints under a false name further underscores the deceitful nature of your operations.
5. Confirm that a full investigation has been launched into NPC’s misuse of keeper data. The DVLA will be informed of your actions, and unless corrective measures are implemented, your access to keeper data should be revoked.
Failure to comply with the above will result in immediate escalation to the DVLA, the ICO, my MP, and further legal scrutiny. Given that this matter is already subject to litigation, NPC’s continued misconduct will only serve to strengthen my position in court and increase the likelihood of costs being awarded against you for unreasonable behaviour. Your flagrant disregard for the law will not go unnoticed or unchallenged.
I expect a full written response within 7 days. If NPC fails to act, I will have no hesitation in pursuing all available legal and regulatory avenues to hold you to account.
Final Warning
NPC’s continued pursuit of this charge in defiance of PoFA and the KADOE contract is nothing short of vexatious litigation. Given that this claim has already been issued and defended in the county court, your ongoing misconduct will only serve to reinforce my position in proceedings. While I do not seek an immediate strike-out, I fully expect your legal representatives to discontinue before they have to pay the hearing fee, as is your standard modus operandi. However, such a late discontinuation will not prevent me from applying for a costs order against NPC for unreasonable behaviour, including your refusal to acknowledge a legally valid transfer of liability.
Your ignorance of the law will not shield you from the consequences of your actions. Consider this your final opportunity to correct your misconduct before I escalate this further.
Yours sincerely,
[Your Name]
5(1)The first condition is that the creditor—and it’s their problem if the address is abroad. They have both the name and a current address.
(a)has the right to enforce against the driver of the vehicle the requirement to pay the unpaid parking charges; but
(b)is unable to take steps to enforce that requirement against the driver because the creditor does not know both the name of the driver and a current address for service for the driver.
4(1)The creditor has the right to recover any unpaid parking charges from the keeper of the vehicle.
(2)The right under this paragraph applies only if—
(a)the conditions specified in paragraphs 5, 6, 11 and 12 (so far as applicable) are met; and
(b)the vehicle was not a stolen vehicle at the beginning of the period of parking to which the unpaid parking charges relate.
(3)For the purposes of the condition in sub-paragraph (2)(b), the vehicle is to be presumed not to be a stolen vehicle at the material time, unless the contrary is proved.
(4)The right under this paragraph may only be exercised after the end of the period of 28 days beginning with the day on which the notice to keeper is given.
(5)The maximum sum which may be recovered from the keeper by virtue of the right conferred by this paragraph is the amount specified in the notice to keeper under paragraph 8(2)(c) or (d) or, as the case may be, 9(2)(d) (less any payments towards the unpaid parking charges which are received after the time so specified).
(6)Nothing in this paragraph affects any other remedy the creditor may have against the keeper of the vehicle or any other person in respect of any unpaid parking charges (but this is not to be read as permitting double recovery).
(7)The right under this paragraph is subject to paragraph 13 (which provides for the right not to apply in certain circumstances in the case of a hire vehicle).
Subject: Formal Complaint – Breach of KADOE Contract by National Parking Control (NPC)
Complaints Team
DVLA
Swansea
SA6 7JL
By email to: dataprotection@dvla.gov.uk
Date: [Insert Date]
Dear Sir/Madam,
I am making a formal complaint regarding National Parking Control’s (NPC) misuse of DVLA keeper data, in breach of the Keeper at Date of Event (KADOE) contract. NPC has continued to process my personal data unlawfully, despite my full compliance with the transfer of liability process as set out in Schedule 4 of the Protection of Freedoms Act 2012 (PoFA).
Background of the Complaint1. I received a Notice to Keeper for an alleged parking contravention at Montefiore Court, London, N16 5TY, dated 18/04/2024 for my vehicle VRM [VRM of the vehicle].
2. I immediately complied with their stated process to transfer liability to the actual driver, my brother, who was visiting from the USA, providing a valid and serviceable address in the United States.
3. NPC acknowledged receipt of my transfer of liability request via email.
4. Despite this, NPC:• Reissued the same PCN to me, continuing to pursue me as the keeper.
• Instructed debt collectors (DCB Legal) to pursue me, despite having no lawful grounds to do so.
• Issued a County Court claim against me, despite my lack of liability under PoFA Schedule 4.
Breach of the KADOE Contract
1. Misuse of Keeper Data in Breach of PoFA Schedule 4
NPC had no legal right to continue processing my personal data after I provided the driver's details.
PoFA Schedule 4, Paragraph 5(1)(b):"The creditor has the right to recover any unpaid parking charge from the keeper of the vehicle, but only if the following conditions are met—"
(b) The creditor does not know both the name of the driver and a current address for service for the driver.
I provided both the name and a valid serviceable address for the driver, meaning NPC no longer had any lawful basis to continue processing my data. Their actions are therefore a clear misuse of DVLA keeper data under the KADOE contract.
2. PoFA and the BPA/IPC Private Parking Single Code of Practice (PPSCoP) Do Not Require a UK-Based Serviceable Address
Nowhere in PoFA Schedule 4 or the PPSCoP does it state that the serviceable address must be in the United Kingdom.
The only requirement is that the parking operator is provided with a "current address for service". There is no geographical restriction on what qualifies as a serviceable address, meaning my provision of a valid U.S. address fully discharged my liability as the keeper.
NPC’s refusal to accept a lawful transfer of liability simply because the address is outside the UK has no legal basis, and its continued enforcement against me constitutes an abuse of its access to DVLA data.
3. Failure to Comply with the KADOE Contract’s Data Protection Obligations
The KADOE contract only permits parking operators to obtain and process keeper data for legitimate enforcement purposes. Continuing to pursue the keeper when liability has been transferred to the driver is not a legitimate purpose under PoFA.
NPC’s failure to act in accordance with PoFA and its continued processing of my personal data has resulted in:• Unlawful processing of my personal data beyond what PoFA Schedule 4 permits.
• Harassment by debt collectors, despite NPC having no right to enforce the charge against me.
• A court claim being issued unlawfully, further misusing my data.
NPC’s continued access to DVLA data while disregarding its obligations under the KADOE contract raises serious concerns about their fitness to retain access to registered keeper information.
Formal Complaint Resolution Demands
I request that the DVLA:1. Conduct an investigation into NPC’s misuse of keeper data and its non-compliance with the KADOE contract.
2. Confirm what enforcement action will be taken if NPC is found to have breached its obligations.
3. Clarify whether NPC has faced previous complaints or sanction points for similar misconduct.
4. Confirm what measures will be put in place to ensure that NPC cannot misuse DVLA keeper data in this manner again.
I expect a full response within 10 working days, failing which I will escalate the matter to my MP and the Information Commissioner’s Office (ICO) for further action.
Yours sincerely,
[Your Name]
[Your Address]
[Your Email]
Subject: Formal Complaint – Breach of PoFA Schedule 4 & KADOE Contract Non-Compliance
National Parking Control
Complaints Department
The Pinnacle
Station Way
Crawley
RH101JH
Delivered by email: DPO@nationalparkingcontrol.co.uk
Date: [Insert Date]
Dear Sir/Madam,
Re: Parking Charge Notice (PCN) [Insert PCN Number] – Formal Complaint Regarding Procedural Breaches
I am making a formal complaint regarding National Parking Control’s (NPC) unlawful pursuit of keeper liability, despite my full compliance with the transfer of liability process, in direct breach of the Protection of Freedoms Act 2012 (PoFA) Schedule 4. Furthermore, your conduct in this matter is a clear breach of the Keeper at Date of Event (KADOE) contract with the DVLA, and I will be requesting a full investigation into your continued access to DVLA data.
Breach of PoFA Schedule 4 – Keeper Liability Ceases Once Driver Details Are Provided
Paragraph 5(1)(b) – Keeper liability only applies if the driver's name and address are unknown. PoFA explicitly states that the creditor may only hold the keeper liable if the creditor does not know both the name and serviceable address of the driver.
PoFA Schedule 4, Paragraph 5(1)(b):"The creditor has the right to recover any unpaid parking charge from the keeper of the vehicle, but only if the following conditions are met—"
(b) The creditor does not know both the name of the driver and a current address for service for the driver.
Since I provided both the name and a serviceable address for the driver, NPC no longer has any legal right to hold me liable.
PoFA does not require the serviceable address to be in the UK
PoFA does not impose a geographical restriction on what qualifies as a "serviceable address." The only requirement is that the parking operator is provided with a "current address for service." I provided a valid and serviceable address in the United States, meaning NPC had no lawful basis to continue pursuing me.
NPC’s continued pursuit of keeper liability is an abuse of process
By continuing to pursue me despite acknowledging the transfer of liability, NPC has:• Breached PoFA Schedule 4 by wrongly pursuing the keeper when the driver’s details had already been provided.
• Misused my personal data by continuing to process it unlawfully when I was no longer the liable party.
• Engaged in unreasonable behaviour by referring the matter to debt collectors and ultimately issuing a county court claim against an individual who cannot be held liable.
Breach of the KADOE Contract – Request for Investigation by the DVLA
Your failure to comply with PoFA Schedule 4 and the BPA/IPC Private Parking Single Code of Practice (PPSCoP) means that you have also breached the KADOE contract, which governs your access to DVLA data.
By unlawfully continuing to process my personal data and issuing a claim against me despite my transfer of liability, you have misused personal data obtained from the DVLA. I will be submitting a formal complaint to the DVLA Data Protection Team requesting a full investigation into whether NPC is fit to retain access to the DVLA database. If the DVLA finds that you have repeatedly breached the terms of the KADOE contract, this could result in NPC losing its ability to access registered keeper data entirely.
Formal Complaint Resolution Demands
I require NPC to take the following actions immediately:1. Discontinue the county court claim against me and confirm this in writing.
2. Provide a full explanation as to why NPC unlawfully pursued the keeper despite acknowledging the transfer of liability.
3. Cease all further unlawful processing of my data and confirm in writing that my details will only be retained for the duration of any ongoing legal proceedings.
4. Provide a data protection audit detailing why my data was processed in breach of PoFA and the KADOE contract.
Failure to respond within 14 days will result in immediate escalation to:• The DVLA, requesting an investigation into NPC’s misuse of keeper data under the KADOE contract.
• The Information Commissioner’s Office (ICO) for GDPR violations regarding unlawful data processing.
• The IPC, highlighting multiple breaches of the Code of Practice.
NPC is now on notice that if you continue to pursue this claim, you may also face further legal consequences for your data protection failings and potential unreasonable behaviour costs under CPR 27.14(2)(g).
Yours sincerely,
[Your Name]
[Your Address]
[Your Email]
"...they checked and said I am right they can see it on system and they are unsure why it wasn't dealt with i can ignore it and they will deal with it."