Subject: Formal Complaint – Misidentification of Vehicle & Unlawful Processing of Personal Data
To: UK CPM Ltd
Complaints Department
Date: [Insert Date]
PCN Reference: [Insert PCN Number]
Dear Sir/Madam,
I am submitting this formal complaint regarding the unlawful issuance of a Parking Charge Notice (PCN) against my vehicle. Your CCTV evidence clearly shows a vehicle with the VRM [Incorrect VRM], whereas my registered vehicle’s VRM is [Correct VRM]. Furthermore, the vehicle in your footage is a Nissan Micra, whereas my vehicle is a Citroen Berlingo—a completely different make, model, and body type.
Your operatives have misread the vehicle registration mark (number) (VRM), resulting in the unlawful request and processing of my personal data from the DVLA. This demonstrates a complete failure to follow the mandatory quality control procedures set out in the BPA/IPC Private Parking Single Code of Practice (PPSCoP), specifically section 7.3(d).
Failure to Conduct the Required Manual Quality Control Check
As this PCN was issued based on CCTV footage, your staff were required to manually review and verify the accuracy of the VRM before processing the charge. However, section 7.3(d) of the PPSCoP explicitly states:
“Photographic evidence must not be used by a parking operator as the basis for issuing a parking charge unless:
d) images generated by ANPR or CCTV have been subject to a manual quality control check, including the accuracy of the timestamp and the risk of keying errors.”
This requirement exists to prevent the very kind of error that has occurred in this case. Your operatives failed to carry out even the most basic verification checks, resulting in an entirely unjustified PCN. This failure proves that:
1. Your manual review process is either non-existent or entirely inadequate; or
2. Your operatives are incompetent in carrying out basic quality control checks.
Had your staff properly checked the footage before issuing this PCN, they would have immediately noticed that:
• The registration number captured ([Incorrect VRM]) differs from mine ([Correct VRM]) by a single digit.
• The vehicle make and model do not match my registered vehicle details.
This constitutes clear evidence of a breach of the PPSCoP and a fundamental failure of your internal processes.
Unlawful Processing of My Personal Data – UK GDPR Breach
Since the vehicle in question was not mine, your request for my data from the DVLA was made without lawful cause. This means my personal data was unlawfully accessed and processed, in direct violation of the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018. Your actions violate:
• UK GDPR Article 5(1)(a) – Lawfulness, fairness, and transparency
Personal data must be processed lawfully and fairly. Your unlawful request for my DVLA data breaches this requirement.
• UK GDPR Article 6(1)(f) – Legitimate Interest
There was no legitimate interest in obtaining my personal data, as no contravention involving my vehicle occurred.
• UK GDPR Article 17(1)(d) – Right to Erasure
I now invoke my Right to Erasure and require you to delete all personal data related to this PCN.
• Data Protection Act 2018, Section 170 – Unlawful obtaining of personal data
Your request for my personal data, knowing that no contravention involving my vehicle had occurred, constitutes a breach of data protection law.
Formal Complaint to the DVLA
Regardless of your response to this complaint, I am submitting a formal complaint to the DVLA regarding your unlawful request for my data in breach of your Keeper at Date of Event (KADOE) contract. I will be requesting that the DVLA investigates:
1. Why you were able to obtain my personal data despite the clear mismatch between the VRM and vehicle make/model.
2. Whether this is part of a wider pattern of systemic failures in your data request procedures.
Required Actions
To resolve this complaint, I require the following actions:
1. Immediate Cancellation – The PCN must be cancelled immediately, and written confirmation must be sent to me.
2. Full Data Erasure – Under UK GDPR Article 17, you must erase all personal data you have unlawfully obtained and processed in relation to this PCN and provide written confirmation within 7 days.
3. Review of Internal Processes – You must confirm in writing what steps you will take to ensure that this failure does not happen again.
Escalation if Unresolved
If you fail to provide a satisfactory response within 14 days, I will escalate this complaint by:
• Submitting a complaint to the Information Commissioner’s Office (ICO) regarding your unlawful processing of my personal data.
• Initiate legal action under UK GDPR Article 82 and Section 168 of the Data Protection Act 2018, in a Letter of Claim seeking compensation for the distress caused by your misuse of my data.
I expect your written confirmation of PCN cancellation and data erasure within 7 days and a full response to this complaint within 14 days. Failure to comply will result in further escalation.
Yours sincerely,
[Your Full Name]
[Your Address]
[Your Email]