In the response there is a complaint number in the format 12345678-01PP, but on first look I thought that was just their internal complaint number not the BPA complaint number that we asked for, they didn't make it clear.
You have now exhausted our internal company complaints procedure. If you remain unsatisfied by our response you may contact the British Parking Association (BPA) for further escalation for complaints pertaining to parking enforcement.
Dear Sir/Madam,
Your response dated [insert date] fails to discharge your obligation under the Private Parking Single Code of Practice (PPSCoP).
Under Section 11.2, you were required to treat my formal complaint—because it relates to a parking charge—as an appeal. You have failed to properly consider the points raised, provided no meaningful response to the detailed issues of Keeper liability under PoFA, and crucially, have failed to issue a POPLA code, which is required if you reject an appeal.
If you continue to fail in your duties under the Code of Practice, I will report this separately as non-compliance. For the avoidance of doubt, I am also submitting a formal complaint to the DVLA regarding your misuse of keeper data and your failure to engage properly with the data subject. That complaint will proceed regardless of the outcome of your internal processes.
I expect your full response and the required reference number within 7 days.
Yours faithfully,
[Your Name]
I wish to raise a formal complaint regarding Premier Park Ltd and their breach of the Keeper at Date of Event (KADOE) contract.
Premier Park obtained my keeper data from the DVLA under the terms of the KADOE contract, which requires full compliance with the Private Parking Single Code of Practice (PPSCoP). However, they have failed to comply with key requirements of that Code.
Specifically, I submitted a formal complaint under Section 11.2 of the PPSCoP, which requires a complaint relating to a parking charge to be treated as an appeal. Premier Park failed to consider the appeal on its merits and did not issue a POPLA code, as they are required to do if rejecting an appeal.
This failure amount to breaches of the PPSCoP and therefore a breach of the KADOE contract. I request that the DVLA investigates this matter and takes appropriate enforcement or sanction action against Premier Park Ltd.
PCN Reference: [Insert PCN Reference]
Vehicle Registration Number: [Insert VRM]
That section requires operators to engage with complaints in a structured and transparent way, and where the complaint cannot be resolved, to confirm that the internal complaints process has been exhausted and issue a complaint reference number for escalation to the BPA.
They also failed to deal with the complaint as a complaint under Section 11.1, and have refused to confirm that their internal complaints procedure has been exhausted or to issue a BPA complaint reference number, thereby obstructing escalation.
You have now exhausted our internal company complaints procedure. If you remain unsatisfied by our response you may contact the British Parking Association (BPA) for further escalation for complaints pertaining to parking enforcement.
9(2)(e)(i) breach – failing to invite the Keeper to pay, instead stating the driver is liable.
Subject: Re: PCN [Insert Reference] – Failure to Address Formal Complaint and Appeal (PPSCoP Sections 11.2 and 11.1)
Dear Sir/Madam,
Your response dated [insert date] fails to discharge your obligations under the Private Parking Single Code of Practice (PPSCoP) in two respects.
Firstly, under Section 11.2, you were required to treat my formal complaint—because it relates to a parking charge—as an appeal. You have failed to properly consider the points raised, provided no meaningful response to the detailed issues of Keeper liability under PoFA, and crucially, have failed to issue a POPLA code, which is required if you reject an appeal.
Secondly, you were also obliged to address the matter as a formal complaint in its own right, under Section 11.1 of the PPSCoP. That section requires operators to engage with complaints in a structured and transparent way, and where the complaint cannot be resolved, to confirm that the internal complaints process has been exhausted and issue a complaint reference number for escalation to the BPA.
You have done neither.
I now require you to:
1. Confirm that my formal complaint has been fully considered and exhausted;
2. Provide a complaint reference number so that I may escalate the matter accordingly.
If you continue to fail in your duties under the Code of Practice, I will report this separately as non-compliance. For the avoidance of doubt, I am also submitting a formal complaint to the DVLA regarding your misuse of keeper data and your failure to engage properly with the data subject. That complaint will proceed regardless of the outcome of your internal processes.
I expect your full response and the required reference number within 7 days.
Yours faithfully,
[Your Name]
I wish to raise a formal complaint regarding Premier Park Ltd and their breach of the Keeper at Date of Event (KADOE) contract.
Premier Park obtained my keeper data from the DVLA under the terms of the KADOE contract, which requires full compliance with the Private Parking Single Code of Practice (PPSCoP). However, they have failed to comply with key requirements of that Code.
Specifically, I submitted a formal complaint under Section 11.2 of the PPSCoP, which requires a complaint relating to a parking charge to be treated as an appeal. Premier Park failed to consider the appeal on its merits and did not issue a POPLA code, as they are required to do if rejecting an appeal. They also failed to deal with the complaint as a complaint under Section 11.1, and have refused to confirm that their internal complaints procedure has been exhausted or to issue a BPA complaint reference number, thereby obstructing escalation.
These failures amount to breaches of the PPSCoP and therefore a breach of the KADOE contract. I request that the DVLA investigates this matter and takes appropriate enforcement or sanction action against Premier Park Ltd.
PCN Reference: [Insert PCN Reference]
Vehicle Registration Number: [Insert VRM]
Subject: Formal Complaint & Appeal Under PPSCoP Section 11.2 – Incorrect Service of PCN & Keeper Liability Dispute
PCN Reference: [PCN Reference]
Dear Premier Park,
I am submitting a formal complaint under Section 11.2 of the Private Parking Single Code of Practice (PPSCoP)regarding the procedural handling of Parking Charge Notice [PCN Reference]. As this complaint concerns a parking charge, you are required to consider it as an appeal and, if rejected, issue a POPLA code so that I can escalate the matter.
1. Formal Complaint – NtK Not Correctly Served
The Notice to Keeper (NtK) was originally sent to an incorrect address for service because, at the time, my V5C had not yet been updated. As a result, the NtK was not "given" to me in accordance with Paragraph 9(6) of the Protection of Freedoms Act 2012 (PoFA) within the required timeframe.
By the time I received the NtK, it was too late to appeal within your standard deadlines. Upon receipt, I immediately served a Data Rectification Notice (DRN) to update my address, which you have since acknowledged.
Under PPSCoP Section 11.2, you must treat this formal complaint as an appeal and respond accordingly.
2. Appeal – No Keeper Liability Under PoFA
Even if the NtK had been properly served, it fails to meet the strict requirements of PoFA, meaning I cannot be held liable as the Keeper.
(a) Misrepresentation of the Amount Recoverable (PoFA 4(5))
The NtK states:
"If we are required to take further action to recover the Parking Charge, the amount due may increase up to £170."
This contradicts PoFA Paragraph 4(5), which states:
"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 9(2)(d)."
-PoFA strictly limits the amount recoverable from the Keeper to the sum stated in the NtK, which is £100.
-Stating that the charge may increase misrepresents the Keeper’s liability and renders the NtK non-compliant.
This fact is already fully established in persuasive appellate case law in Excel v Wilkinson (2022), where the court ruled that inflating charges beyond the original NtK amount was unenforceable.
(b) No Invitation for the Keeper to Pay (PoFA 9(2)(e)(i))
PoFA Paragraph 9(2)(e)(i) requires an NtK to:
"Invite the keeper to pay the unpaid parking charges; or if the keeper was not the driver, to notify the creditor of the name of the driver and a current address for service for the driver and to pass the notice on to the driver."
Your NtK fails to include a clear invitation for the Keeper to pay. Instead, it:
-States that the driver is liable to pay.
-Tells the Keeper to provide the driver’s details and to pass the notice on.
As the Keeper is under no legal obligation to identify the driver, the only fulfilled requirement is to "pass the NtK on." There is no explicit invitation for the Keeper to pay, meaning the NtK is defective under PoFA.
3. PoFA Compliance is an All-or-Nothing Requirement
PoFA is like pregnancy—you either are or you aren’t. You cannot be “a little bit” pregnant, just as an NtK cannot be “a little bit” PoFA compliant.
For an NtK to trigger Keeper liability, it must be fully compliant with every requirement of PoFA. Your NtK fails multiple PoFA requirements, meaning it does not transfer liability to the Keeper. The only party that can be held liable is the driver, who has not been identified.
4. Resolution Required
As this is a formal complaint and an appeal under PPSCoP Section 11.2, you are required to:
1. Provide a response to this complaint and appeal.
2. If you reject my points of appeal, issue a POPLA code so that I can escalate the matter.
Please confirm your response within 14 days, as required under the PPSCoP.
Yours sincerely,
[Your Name]
Do you know if the land is part of the Pub?
I am the keeper of the vehicle and I dispute your 'parking charge'. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.
As your Notice to Keeper (NtK) does not fully comply with ALL the requirements of PoFA 2012, you are unable to hold the keeper of the vehicle liable for the charge. Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving and no inference or assumptions can be drawn. Premier Park has relied on contract law allegations of breach against the driver only.
The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your NtK can only hold the driver liable. Premier Park have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.