I am submitting a formal complaint against G24 Ltd, an IPC AOS member with DVLA KADOE access, for breaching the BPA/IPC Private Parking Single Code of Practice (PPSCoP) after obtaining my personal data.
While G24 may have had reasonable cause at the time of their KADOE request, their subsequent misuse of my data—through conduct that contravenes the PPSCoP—renders that use unlawful. The PPSCoP forms an integral part of the DVLA’s governance framework for data access by private parking firms. Continued access is conditional on compliance.
Specifically, G24 issued a PCN based on alleged breach of parking terms that were not visible from the vehicle. They failed to provide signage in accordance with Section 4.1 of the PPSCoP, especially critical for disabled motorists, and ignored a formal complaint which raised this point. A Blue Badge was properly displayed and the only visible sign had been fully complied with.
The DVLA, as data controller, is obliged under UK GDPR and the Data Protection Act 2018 to investigate and take enforcement action when data is misused following release. This complaint is not about whether the data was obtained lawfully at the outset, but whether its subsequent use breached the terms under which it was provided.
I have attached a supporting statement outlining the breach and request that this matter be fully investigated. Please acknowledge receipt and confirm the reference number for this complaint.
SUPPORTING STATEMENTComplaint to DVLA – Breach of KADOE Contract and BPA/IPC Private Parking Single Code of Practice (PPSCoP)
Operator name: G24 Ltd
Date of PCN issue: 7th February 2025
Vehicle registration: [INSERT VRM]
I am submitting this complaint to report a misuse of my personal data by G24 Ltd, who obtained my keeper details from the DVLA under the KADOE (Keeper At Date Of Event) contract.
Although G24 may have had reasonable cause to request my data initially, the way they have used that data amounts to unlawful processing. This is because they have acted in breach of the Private Parking Single Code of Practice (PPSCoP)—the mandatory framework which governs their access to DVLA data.
The breaches are as follows:
1. Failure to Comply with Section 4.1 of the PPSCoP – Signage AccessibilityG24 failed to provide a sign containing the full terms and conditions of parking that could be viewed from the vehicle. The only sign visible in the disabled bay stated:
“Disabled bays are for disabled badge holders only. All Disabled Blue Badge Holders must clearly display their badge to prevent being issued with a PCN.”
This sign was complied with in full. No other terms (e.g. payment requirements or Blue Badge registration) were visible or available from the vehicle. This directly contravenes PPSCoP Section 4.1, which requires that:
“The parking operator must ensure that at least one sign containing the terms and conditions for parking can be viewed without the driver needing to leave the vehicle...”
2. Discriminatory and Unlawful Conduct Toward Disabled MotoristsThe driver was accompanied by a disabled child who required constant supervision. Expecting a parent in such a situation to leave the vehicle to hunt for signage is both unreasonable and discriminatory. G24 failed to make reasonable adjustments, breaching the spirit of the Equality Act 2010 and the accessibility obligations embedded within the PPSCoP.
3. Failure to Respond Meaningfully to a Formal ComplaintG24 failed to engage with the substance of a formal written complaint. The response was generic and ignored the specific allegations, including the signage breach and the display of a valid Blue Badge. This contravenes PPSCoP Section 11.2, which requires operators to provide a transparent complaints procedure and a meaningful response to complaints relating to PCNs.
4. Misleading Appeals Information – PPSCoP Section 8.1.2(e) BreachG24’s Notice to Keeper informs the Keeper that any appeal “must be made within 28 days of the date of issue” of the NtK. This directly contradicts Section 8.1.2(e) of the PPSCoP, which states:
“The parking operator must ensure that a notice informs the recipient: that if the recipient appeals within 28 days of receiving the parking charge, the right to pay at the rate applicable...”
By unlawfully shortening the Keeper’s appeal window, G24 has misrepresented the appeals process and placed an unfair restriction on the Keeper’s rights. This breach is not merely technical — it may cause a recipient to believe they are out of time when, in fact, the 28-day period has not yet started.
These are not minor breaches. They show a disregard for the regulatory framework that governs the use of DVLA Keeper data. Once that data has been obtained, the KADOE contract allows it to be used only for pursuing charges in full compliance with the Code of Practice.
G24’s failure to follow the Code renders their continued use of my data unlawful. I therefore ask the DVLA, as data controller, to investigate this breach and consider whether enforcement action — including suspension of KADOE access — is appropriate.
The DVLA is the data controller for keeper data released under KADOE and is therefore responsible for ensuring that such data is not misused by operators. I request that the DVLA:
1. Investigates this complaint in full
2. Confirms whether a breach has occurred
3. Considers appropriate enforcement action, including suspension or termination of KADOE access if necessary
As the DVLA complaints form only permits uploading a single file, I can provide further evidence upon request should it be required.
Name: [Insert your name]
Date: [Insert today’s date]