I already mentioned earlier that a POPLA decision is not binding and, as you can see, irrelevant when their own assessors are too intellectually malnourished to understand the most basic contract law and PoFA.
You must ignore all upcoming useless debt recovery letters. As already pointed out, debt collectors are powerless to do anything except to try and persuade the low-hanging fruit on the gullible tree to pay up out of ignorance and fear.
If you ever receive a Letter of Claim (LoC) then come back and we can easily deal with it. For the time being, you can send the following complaint to POPLA but it will not alter their decision but it will keep a paper trail that evidences their utter uselessness.
To: complaints@popla.co.uk
Subject: Formal Complaint – Flawed Adjudication and Material Errors in POPLA Decision [POPLA REF]
Dear POPLA Complaints Team,
I am writing to raise a formal and extremely serious complaint regarding the handling of my appeal against a Parking Charge Notice issued by Saba Park Services UK Ltd at North Greenwich Station Car Park (PCN ref: [INSERT PCN REF]). The decision issued by your assessor is factually flawed, legally unsound, and has utterly failed to address the key grounds raised in the appeal. The conduct and competence of the assessor fall far below any acceptable standard for a supposed adjudicative body.
This is not merely a difference of opinion. The decision was reached on the basis of material misstatements of the law, a failure to consider the evidence, and a complete lack of engagement with the arguments advanced. I set out below the specific failings:
1. Incorrect Creditor Identified on the Notice to Keeper – PoFA Non-Compliance
The appeal clearly explained that the Notice to Keeper (NtK) was non-compliant with Paragraph 9(2)(h) of Schedule 4 of the Protection of Freedoms Act 2012 because Saba Park Services UK Ltd is not the creditor. The contract provided by Saba themselves explicitly states on page 1:
“The Landowner is the creditor for all notices of parking charge issued...”
That landowner is TTL Properties Limited, as named throughout the contract. This alone invalidates the NtK for the purpose of transferring liability to the registered keeper.
However, the POPLA assessor ignored this decisive contractual clause and, without justification or analysis, accepted the false premise that Saba is the creditor. This is a demonstrable misreading of the operator’s own evidence. As a result, the entire decision is based on an unsound legal foundation. This represents an inexcusable level of negligence in evaluating the evidence and is a fundamental flaw in the decision.
2. Failure to Specify a Period of Parking – PoFA 9(2)(a) Breach Overlooked
The NtK does not specify a period of parking. It merely lists a date of contravention, without any entry or exit time or stated duration. The requirement under PoFA is clear: a “period of parking” must be identified. A single observation or timestamp is not sufficient.
This was clearly explained in the appeal and supported by persuasive County Court appellate authority in Brennan v Premier Parking Solutions (2023) [H6DP632H], which was cited and ignored. This fundamental error shows either the assessor’s lack of basic legal competence or an unwillingness to apply PoFA correctly.
3. PPSCoP Breach – Appeal Response Overdue
A postal appeal was received by Saba on 23 March 2025 (confirmed in their evidence), yet no response or POPLA code was issued within the 28-day period required by Clause 8.4.1(b) and Annex C.1.1 of the Private Parking Single Code of Practice.
The assessor wrongly claimed that “there is no timeframe for a response”, a statement which is demonstrably false and suggests a complete lack of familiarity with the relevant Code. This alone undermines the integrity of the entire decision.
4. Failure to Address the Land Status – No Relevant Land under PoFA
The appeal made it clear that the car park forms part of land historically subject to statutory control under Transport for London (TfL) byelaws. Such land is not relevant land for the purposes of PoFA and therefore keeper liability cannot arise.
The assessor completely ignored this point. POPLA cannot lawfully assume PoFA applies when the statutory status of the land has been questioned and left unresolved. Again, no attempt was made to examine this issue, even though it fundamentally impacts liability.
5. Lack of Accountability and Systemic Concerns
POPLA is widely recognised as operating without external oversight. It is not subject to regulation by any truly independent ombudsman or appeals mechanism. When a decision is plainly wrong, as in this case, there is no recourse or appeal – only this opaque internal “complaints process”, which never reverses a decision, even where an error is accepted.
Your assessor in this case has shown such a profound lack of understanding of both the legislation and evidence that their competence to make judicial-style decisions must be questioned. There is an urgent need for either retraining or removal from their role.
These systemic issues will, I believe, be addressed when the Private Parking (Code of Practice) Act 2019 is finally implemented and an independent appeals service replaces POPLA. When that happens, few outside the parking industry will mourn the loss of a body that has become synonymous with misjudgments, inconsistency, and a refusal to accept accountability.
I formally request the following:
• That this case is reviewed by a senior legal assessor or adjudicator not involved in the original decision;
• That a written response is provided addressing each of the above points and outlining what action will be taken to remedy this miscarriage of justice.
Should POPLA fail to acknowledge or rectify this defective decision, I will treat the matter as further evidence of POPLA’s structural unfitness to serve as an independent adjudicator and will ensure that this case is included in future submissions to Parliament and the Department for Transport regarding the need for urgent reform and replacement of POPLA under the Private Parking (Code of Practice) Act 2019.
Yours sincerely,
[Your Name]
[Your Contact Details]
[Date]
Finally received a reply to my complaint about the original fob-off response to the FoI and it is revealing, whilst attempting to obfuscate at the same time:
Dear B789
I am contacting you in relation to your request for an internal review concerning the response provided to FOI-0703-2526. Following your email of 29 May a review has been carried out by an independent review panel (‘the panel’) consisting of individuals who were not involved in the handling of your request.
To confirm, your original request asked for the following -
Please confirm whether the North Greenwich Station Car Park (postcode SE10 0PH), currently managed by Saba Park Services UK Ltd on behalf of TTL Properties Limited, remains subject to the TfL Railway Byelaws 2011. If the site was ever subject to those byelaws and they have since been revoked or superseded, please provide details of the revocation or modification.
Following the response to FOI-0703-2526 your subsequent email of 29 May stated -
This is an evasive and legally inadequate answer that does not address the substance of the request. The question was not whether Saba UK chooses to enforce parking under PoFA, but whether the land itself at North Greenwich Station remains subject to TfL Railway Byelaws 2011, as made under the Greater London Authority Act 1999.
My request was specific and factual. It sought:
• Confirmation of whether byelaws currently apply to the land at SE10 0PH;
• If they do not apply, whether and when they were formally revoked or superseded, and by what legal or administrative mechanism.
Your answer did not provide this. It simply restated the operator’s current enforcement choice, which is
legally irrelevant to the land’s status under PoFA 2012 Schedule 4.
For the record, unless and until TfL formally revokes its byelaws over a specific site, or unless the site is reclassified through a published legal instrument, that land remains subject to statutory control. A contractor’s self-declared reliance on civil enforcement does not alter the legal classification of the land.
I therefore request the following as part of this internal review:
1. A proper response confirming the legal status of the land, not the practices of the contractor;
2. Copies or references to any documents or orders showing revocation, disapplication or amendment of the TfL Railway Byelaws 2011 as they apply to North Greenwich Station Car Park;
3. An explanation of why my original question was not properly addressed.
The panel have liaised with the appropriate subject matter experts and we have been unable to identify the specific information you seek in the contract that we hold with SABA UK. Additionally our legal team have liaised with SABA UK and they have also been unsuccessful in locating recorded confirmation of what you seek. Therefore on the balance of probabilities the panel agree that it’s likely the information is not held. Please accept our apologies for any inconvenience that may have been caused.
With respect of the Byelaws the contract with SABA UK states the following -
- 21. Compliance with Policies and Law21.1.2 shall provide the Services in compliance with and shall ensure that the Service Provider's Personnel comply with all requirements of all Acts of Parliament, statutory instruments, court orders, regulations, directives, European Community decisions (insofar as legally binding), bye-laws, treaties and other regulatory requirements relevant to either or both of the Service Provider's or the Authority's business, from time to time in force which are or may become applicable to the Services. The Service Provider shall promptly notify the Authority if the Service Provider is required to make any change to the Services for the purposes of complying with its obligations under this Clause 21.1.2;
SCHEDULE 9 – FORM OF COLLATERAL WARRANTY1.3 shall comply with all the requirements of any Act of Parliament, Statutory Instrument or Order or any other regulation having the force of law or bye-law and all regulatory requirements relevant to the Subcontractor's business and/or the Authority's business from time to time in force which are or may become applicable to the Subcontract Services;
[/i]
The panel hope the above information provides satisfactory clarification, however if you are dissatisfied with the internal review actions to date please do not hesitate to contact me or alternately you can refer the matter to the independent authority responsible for enforcing the Freedom of Information Act, at the following address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
A complaint form is also available on the ICO’s website (www.ico.org.uk).
Yours sincerely
Emma Flint
Principal Information Access Adviser
FOI Case Management Team
Transport for London
foi@tfl.gov.uk
So, what does this mean? TfL has not explicitly confirmed that the land was ever subject to the TfL Railway Byelaws 2011 or otherwise under statutory control.
Their responses:
• Avoid the historical status of the land entirely;
• Only state that “Saba UK are not subject to TfL Byelaws” (an irrelevant point about the contractor's operations, not land classification);
• Admit they have no record of any revocation, disapplication, or amendment.
This means:
• They have not confirmed that the land was ever subject to byelaws;
• But also cannot show that the land is not subject to them now.
The legal consequence of that omission is that under public law and statutory interpretation, the principle is that Byelaws remain in force until formally revoked or superseded. So if the land was ever covered by TfL Railway Byelaws (as is likely for a car park attached to a TfL station), the absence of revocation supports the presumption that the land is still under statutory control.
Therefore, the burden lies with TfL to prove that the byelaws do not apply. TfL has no documentary record revoking the application of byelaws to North Greenwich Station Car Park.
TfL and SABA have no documentation revoking the Railway Byelaws or reclassifying the land. This supports the original position: byelaws remain in force unless explicitly revoked.
They do not state the land is “relevant land” under Schedule 4 of PoFA. They merely say that SABA enforces under PoFA contractually, which (as I pointed out) is not determinative of land status.
TfL cites general legal compliance clauses from its SABA contract (Clause 21.1.2 and Schedule 9) — but these do not answer the question of whether the land itself is legally subject to byelaws. They simply say that the contractor must obey laws in general.
So, in the absence of a formal statutory instrument, a TfL resolution repealing byelaws over the land or a reclassification of the site under Schedule 4 of PoFA, the legal presumption is that North Greenwich Station Car Park remains land under statutory control.
As such:
• SABA cannot rely on PoFA to hold the registered keeper liable;
• The NtK naming SABA as creditor is non-compliant with PoFA para. 9(2)(h);
• Continued pursuit of the keeper is a breach of both the Private Parking Single Code of Practice and DVLA’s KADOE contract;
• The ICO and BPA should now be formally notified of TfL’s admission and the implications of SABA continuing enforcement against the keeper.
I have responded to Ms Flint with the following:
Re: Internal Review – FOI-0703-2526 – North Greenwich Station Car Park
Dear Ms Flint,
Thank you for your response to the internal review concerning FOI-0703-2526.
I note that the panel has not confirmed whether the land at North Greenwich Station Car Park (postcode SE10 0PH) was ever subject to the TfL Railway Byelaws 2011. However, given the car park is physically attached to a TfL-operated station, it is reasonable to presume that it was, at some stage, subject to statutory control. The fact that neither TfL nor its contractor holds any record of a formal revocation, disapplication, or legal modification of those byelaws strengthens the legal presumption that the land remains under statutory control.
The Freedom of Information Act requires a public authority to confirm or deny the existence of the requested information. The internal review outcome confirms that there is no record revoking or superseding the byelaws in relation to this land. That omission is highly significant: under settled legal principles, byelaws remain in force unless expressly repealed or amended by a competent authority.
In this context, your statement that “Saba UK are not subject to TfL Byelaws” is legally irrelevant. The issue is not whether SABA chooses to operate under PoFA, but whether the land itself is “relevant land” for the purposes of Schedule 4 of the Protection of Freedoms Act 2012. That is a statutory question which cannot be determined by contractor preference or enforcement style.
This raises a serious concern: SABA UK is currently enforcing parking charges against registered keepers under PoFA 2012, on land which appears to remain under statutory control. Additionally, the Notice to Keeper issued in this case identifies SABA Park Services UK Ltd as the creditor, despite SABA’s own authorisation document confirming that TTL Properties Ltd is the landowner and creditor. These errors suggest breaches of both PoFA and the DVLA’s KADOE contract.
Thank you again for confirming that no record of revocation is held. This correspondence will be submitted to the DVLA and the Information Commissioner’s Office as part of a formal complaint regarding unlawful data processing and improper use of the PoFA framework on land presumed to remain non-relevant for statutory purposes.
Yours sincerely,
B789
Update: I had a response to my FoI request but they have failed to answer the question in a spectacular fashion. Their response, as you will see, is inadequate:
Dear b789,
Our ref: FOI-0703-2526
Thank you for your request received by Transport for London (TfL) on 21 May 2025 asking for information about North Greenwich Station Car Park.
Your request has been considered under the requirements of the Freedom of Information Act 2000 and our information access policy.
I can confirm that we do hold the information you require. You asked:
”Please confirm whether the North Greenwich Station Car Park (postcode SE10 0PH), currently managed by Saba Park Services UK Ltd on behalf of TTL Properties Limited, remains subject to the TfL Railway Byelaws 2011. If the site was ever subject to those byelaws and they have since been revoked or superseded, please provide details of the revocation or modification.”
No, Saba UK are not subject to TfL Byelaws, as Saba UK operate under private land enforcement and under the Protection of Freedoms Act 2012.
If you are not satisfied with this response please see the attached information sheet for details of your right to appeal.
Yours sincerely,
Tahsin Prima
FOI Case Officer
General Counsel
I have responded with the following:
Subject: Request for Internal Review – FOI-0703-2526 (North Greenwich Station Car Park)
Dear FOI Team,
I am writing to request an internal review of your response to my FOI request (reference FOI-0703-2526), regarding the status of North Greenwich Station Car Park and whether it remains subject to the TfL Railway Byelaws 2011.
Your response states:
“No, Saba UK are not subject to TfL Byelaws, as Saba UK operate under private land enforcement and under the Protection of Freedoms Act 2012.”
This is an evasive and legally inadequate answer that does not address the substance of the request. The question was not whether Saba UK chooses to enforce parking under PoFA, but whether the land itself at North Greenwich Station remains subject to TfL Railway Byelaws 2011, as made under the Greater London Authority Act 1999.
My request was specific and factual. It sought:
• Confirmation of whether byelaws currently apply to the land at SE10 0PH;
• If they do not apply, whether and when they were formally revoked or superseded, and by what legal or administrative mechanism.
Your answer did not provide this. It simply restated the operator’s current enforcement choice, which is legally irrelevantto the land’s status under PoFA 2012 Schedule 4.
For the record, unless and until TfL formally revokes its byelaws over a specific site, or unless the site is reclassified through a published legal instrument, that land remains subject to statutory control. A contractor’s self-declared reliance on civil enforcement does not alter the legal classification of the land.
I therefore request the following as part of this internal review:
• A proper response confirming the legal status of the land, not the practices of the contractor;
• Copies or references to any documents or orders showing revocation, disapplication or amendment of the TfL Railway Byelaws 2011 as they apply to North Greenwich Station Car Park;
• An explanation of why my original question was not properly addressed.
If you cannot provide evidence of revocation or reclassification, you must confirm that the land remains subject to the 2011 Byelaws.
Yours sincerely,
B789
However I expect further obfuscation as their “councel” tries to protect their agent, SABA, from the fact that the land is indeed still under byelaws and therefore not relevant for the purposes of PoFA.
So, in your POPLA appeal you can add this important piece of evidence that they have not complied with PoFA:
The NtK fails to comply with Schedule 4 of the Protection of Freedoms Act 2012, paragraph 9(2)(h), because it wrongly names SABA Park Services UK Ltd as the creditor. However, the landowner (TTL Properties Ltd), as confirmed in the landowner authorisation provided by SABA, is the only party legally entitled to be the creditor.
This renders the notice non-compliant and invalidates any keeper liability under PoFA.
Hoisted by their own petard!
Seeing as you already have said landowner document, I would also include it as an appendix in your POPLA appeal, to pre-emptively shoot down any attempt by SABA to produce some sort of different document suggesting otherwise (I wouldn't put it past them). This also makes it easier to make your point - "As stated on page X of their agreement with the landowner (Appendix A)"- for example.
The NtK clearly states at the top:
Creditor: SABA PARK SERVICES UK LIMITED
This is legally significant because this is a breach of PoFA paragraph 9(2)(h):
“The notice must— (h) identify the creditor and specify how and to whom payment or notification to the creditor may be made.”
Here’s why this NtK fails:
• Saba Park Services UK Ltd is not the creditor in law.
• The landowner — TTL Properties Limited — is the actual creditor, as confirmed in their own authorisation document:
“The Landowner is the creditor for all notices of parking charge issued...”
This false identification of the creditor:
• Invalidates keeper liability under PoFA;
• Confirms your position that Saba cannot rely on PoFA to pursue the registered keeper;
• Reinforces the argument that only the driver could ever be liable (under contract law), and only if the land were not under statutory control (which it is).
So, in your POPLA appeal you can add this important piece of evidence that they have not complied with PoFA:
The NtK fails to comply with Schedule 4 of the Protection of Freedoms Act 2012, paragraph 9(2)(h), because it wrongly names SABA Park Services UK Ltd as the creditor. However, the landowner (TTL Properties Ltd), as confirmed in the landowner authorisation provided by SABA, is the only party legally entitled to be the creditor.
This renders the notice non-compliant and invalidates any keeper liability under PoFA.
Hoisted by their own petard!
Ignore ZZPS (and their follow up letters from GCTT). They are powerless debt collectors and can be safely ignored. Their only purpose is to try and make the low-hanging fruit on the gullible tree pay up out of ignorance and fear.
As for the DVLA response, you now escalate to Step 2. It is exactly the same as step 1 but the link is now to the Head of Complaints.
Use the following as your webform text and attach the Supporting Statement as a PDF. The link for the step 2 complaint is:
https://contact.dvla.gov.uk/head-of-complaints
Webform text:
I am requesting escalation to Step 2 of the DVLA complaints process.
My Step 1 complaint (submitted on 15 May 2025) concerned Saba Park Services UK Limited, a BPA AOS member, and their misuse of DVLA keeper data obtained via the KADOE system.
The Step 1 response (dated 20 May 2025) does not resolve my complaint and fails to address the core issue raised—namely, that the parking operator acted in breach of the Private Parking Single Code of Practice (PPSCoP) after obtaining my data.
The DVLA's response merely recites the correct principle that the recipient of data becomes the Data Controller, but it fails to explain how the DVLA satisfies its own obligations as a Data Controller at the point of release and in overseeing compliance with the KADOE contract.
My complaint is not about Saba's initial request, but rather the subsequent unlawful use of my personal data in breach of their contractual and Code obligations—specifically, pursuing the Keeper despite PoFA not applying, failing to respond to an appeal, and passing data to a debt collector without offering independent appeal rights.
As this constitutes a breach of the KADOE contract and renders the use of my data unlawful, I request a full Step 2 review by the Head of Complaints. A supporting statement is attached.
For the supporting statement, use this:
SUPPORTING STATEMENT – STEP 2 COMPLAINT
DVLA Complaint – Misuse of Keeper Data by Saba Park Services UK Limited
Operator name: Saba Park Services UK Limited
Date of PCN issue: [Insert Date]
Vehicle registration: [Insert VRM]
This is a Step 2 escalation of my formal complaint to the DVLA, concerning the misuse of my personal data by Saba Park Services UK Limited following their request through the KADOE system.
Although Saba may have had reasonable cause to request keeper data at the outset, their subsequent use of that data was unlawful due to multiple breaches of the Private Parking Single Code of Practice (PPSCoP) and their KADOE contract obligations.
Summary of Breaches:
• The PCN was issued for a location—North Greenwich Station Car Park—which is not ‘relevant land’ under PoFA 2012, as it is owned by Transport for London. Therefore, keeper liability cannot arise.
• Saba issued a PCN under civil contract law, and never alleged a byelaws offence. The driver remains the only party liable, yet Saba continued to pursue me as Keeper despite my appeal clearly stating this.
• A detailed appeal was submitted on 19 March 2025. Saba failed to respond with a rejection or provide a POPLA code, as required under Clause 8.4.1(b) and Annex C.1.1 of the PPSCoP.
• Saba then unlawfully escalated the charge to debt collection (ZZPS) while the appeal process remained unresolved and without offering access to independent adjudication.
Why the DVLA remains responsible:
The DVLA's Step 1 response incorrectly implies that it holds no further responsibility after disclosing keeper data. However, the DVLA remains the Data Controller at the point of release, and the KADOE contract explicitly requires that data is only used for the purposes consistent with the Code of Practice.
For the avoidance of doubt, this complaint is not about whether Saba had reasonable cause initially, but about their misuse of my personal data in breach of the PPSCoP and KADOE conditions. Once Saba failed to follow the Code, their lawful basis for processing my data ceased to exist.
I therefore request that the DVLA:
• Investigate this matter fully at Step 2
• Confirm whether a breach of the KADOE contract has occurred
• Confirm what, if any, action has been or will be taken against Saba
• Provide a reference and response from the Head of Complaints
I am happy to provide further details if needed.
Name: [Insert Your Name]
Date: [Insert Date]
The response from Saba is legally flawed and confirms several clear breaches of the Private Parking Single Code of Practice (PPSCoP), their KADOE obligations, and misrepresentation of PoFA.
Here is a follow-up that you can send back to Saba’s complaints address, with the purpose of:
• Refuting their misstatements,
• Reasserting the absence of Keeper liability,
• Reinforcing that the DVLA complaint has already been filed,
• Documenting that no appeal rejection or POPLA code was issued, and
• Putting Saba on notice of their ongoing breach.
Subject: Misuse of Keeper Data and Breach of Code – Further to Formal Complaint
Dear Sirs,
Further to your recent response to my formal complaint dated [insert date of your complaint email], I must place on record my serious concern regarding the continued misuse of my personal data and your ongoing breach of the Private Parking Single Code of Practice (PPSCoP), Schedule 4 of the Protection of Freedoms Act 2012 (PoFA), and your DVLA KADOE obligations.
Your reply attempts to claim that you are entitled to pursue me as the registered keeper under PoFA, but that is plainly incorrect. You acknowledge that the site is owned by Transport for London, and even describe it as "the direct car park for the North Greenwich Station." As such, the land is not 'relevant land' for the purposes of Schedule 4 of PoFA, which excludes land subject to statutory control. There is no ambiguity here. This is not private land within the scope of PoFA and you are not entitled to invoke keeper liability.
Moreover, you admit that no penalty has been issued under railway byelaws and that you are pursuing a contractual Parking Charge only. Therefore, this PCN may only be pursued against the driver, not the registered keeper. You were informed of this in my original appeal dated 19 March 2025, and again when I declined your improper request to identify the driver. At no time have you issued a rejection or provided a POPLA code as required under:
• Clause 8.4.1(b) – requiring a response to appeals within 28 days,
• Annex C.1.1 – requiring access to the Appeals Service if the appeal is rejected.
Your failure to do so renders your escalation of the charge to ZZPS a further breach of the Code. The complaint to the DVLA Data Sharing Team has already been submitted and includes a supporting statement referencing your misuse of DVLA data. For the avoidance of doubt, that complaint relates not to your initial request, but to your continued unlawful processing and misuse of my keeper data in breach of the KADOE contract.
Your attempt to argue that there is no requirement to name the car park’s legal designation is a red herring. My appeal did not argue that your PCN was non-compliant for omitting a postcode; it clearly raised a jurisdictional issue — namely, that this is land subject to statutory control and therefore PoFA does not apply. You have failed to engage with this point or to provide any legal justification for continuing to pursue a registered keeper on such land.
You now claim you are "not reviewing [my] correspondence as an appeal," yet your earlier reply admitted to placing the charge on hold for seven days while requesting the driver's details. The PPSCoP makes clear that any correspondence raising issues about a PCN must be treated as an appeal or complaint — not ignored or arbitrarily diverted to a debt collector. There has been no lawful conclusion to the appeal process and no access to the appeals service has been offered.
I now require the following:
• Confirmation that the PCN is cancelled,
• Confirmation that ZZPS have been instructed to close the file,
• Written confirmation that my personal data is no longer being processed or shared in connection with this PCN,
• A formal explanation of why no POPLA code was ever issued.
If I do not receive a satisfactory response within 7 days, I will escalate this further to the BPA and pursue a complaint with the Information Commissioner’s Office (ICO) concerning misuse of my personal data.
Yours faithfully,
[Your Name]
[Your Address]
[Date]
Did you send the DVLA complaint?
Ignore ZZPS (and their follow up letters from GCTT). They are powerless debt collectors and can be safely ignored. Their only purpose is to try and make the low-hanging fruit on the gullible tree pay up out of ignorance and fear.
Send a formal complaint to SABA as follows:
To: complaints@sabaparking.co.uk
Cc: dpo@sabaparking.co.uk
Subject: Formal Complaint: Failure to Respond to Appeal and Improper Escalation to ZZPS
Dear Sirs,
PCN Reference: [Insert PCN reference]
Date of Alleged Contravention: [Insert date]
Vehicle Registration: [Insert VRM]
Location: North Greenwich Main
I write to raise a formal complaint regarding your handling of my appeal against the above-referenced Parking Charge Notice (PCN), which was issued under civil contract law by Saba Park Services UK Ltd.
I am the registered keeper of the vehicle, and my written appeal was submitted by recorded post and delivered on 19th March 2025. It clearly stated that Saba Park Services UK Ltd cannot hold a registered keeper liable under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA), because the site—North Greenwich Main—is not ‘relevant land’. This is land owned by Transport for London (TfL) and under statutory control.
Your response, sent via paymyparkingcharge.com on 2nd April, failed to address any of the substantive points raised in my original appeal. Instead, it merely requested the name and address of the driver and stated that the charge would be placed on hold for seven days. I responded to that request by referring you back to the original appeal, which had already set out the legal position clearly. Since then, you have provided no further reply, no decision on the appeal, and no POPLA code. This is in breach of Clause 8.4.1(b) and Annex C.1.1 of the Code, which require parking operators to respond to appeals within 28 days and to provide access to the Appeals Service upon rejection.
Instead of responding properly, the charge has now been escalated to ZZPS Limited, whose letter falsely implies enforceability based on ParkingEye v Beavis. That ruling is entirely irrelevant here. This PCN is issued under contract law, with no mention of any statutory enforcement mechanism, no reference to byelaws, and no indication of landowner authority to issue penalties. As such, the only party who could potentially be liable is the driver. The registered keeper has denied liability and has not been identified as the driver.
The continued pursuit of this PCN—despite your failure to respond to the appeal or provide access to independent adjudication—is unreasonable and in breach of the requirements imposed on all BPA members.
Accordingly, I require the following:
• Immediate written confirmation that the PCN has been cancelled;
• A full explanation for your failure to respond to the appeal or issue a POPLA code;
• Confirmation that ZZPS have been instructed to cease contact and close the file;
• Written confirmation that my data has not been further processed or misused.
If I do not receive a satisfactory reply within 14 days, I will escalate this complaint to the British Parking Association (BPA) in addition to the formal complaint to the DVLA that has now been submitted.
Yours faithfully,
[Your Full Name]
[Your Postal Address]
[Date]
You should also submit a complaint to the DVLA.
Here’s how to make a DVLA complaint:
• Go to: https://contact.dvla.gov.uk/complaints
• Select: “Making a complaint or compliment about the Vehicles service you have received”
• Enter your personal details, contact details, and vehicle details
• Use the text box to summarise your complaint or insert a covering note
• You will then be able to upload a file (up to 19.5 MB) — this can be your full complaint or supporting evidence
That’s it.
The DVLA is required to record, investigate and respond to every complaint about a private parking company. If everyone who encounters a breach took the time to submit a complaint, we might finally see the DVLA take meaningful action—whether that means curtailing or removing KADOE access altogether.
For the text part of the complaint the webform could use the following:
I am submitting a formal complaint against Saba Park Services UK Limited, a BPA AOS member with DVLA KADOE access, for breaching the Private Parking Single Code of Practice (PPSCoP) after obtaining my personal data.
While the Operator 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.
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 prepared a supporting statement setting out the nature of the breach and the Operator’s actions, and I request a full investigation into this matter. I have attached the supporting document.
Please acknowledge receipt and confirm the reference number for this complaint.
Then you could upload the following as a PDF file for the formal complaint itself:
SUPPORTING STATEMENT
Complaint to DVLA – Breach of KADOE Contract and PPSCoP
Operator name: Saba Park Services UK Limited
Date of PCN issue: [INSERT DATE]
Vehicle registration: [INSERT VRM]
I am submitting this complaint to report a misuse of my personal data by Saba Park Services UK Limited, who obtained my keeper details from the DVLA under the KADOE (Keeper At Date Of Event) contract.
Although the parking company may have had reasonable cause to request my data initially, the way they have used that data afterwards amounts to unlawful processing. This is because they have acted in breach of the BPA/IPC Private Parking Single Code of Practice (PPSCoP), which is a mandatory requirement for access to DVLA keeper data. The PPSCoP forms part of the framework that regulates how parking companies must behave once they have received keeper data from the DVLA.
The KADOE contract makes clear that keeper data may only be used to pursue an unpaid parking charge in line with the Code of Practice. If a parking company fails to comply with the PPSCoP after receiving DVLA data, their use of that data becomes unlawful, as they are no longer using it for a permitted purpose.
In this case, Saba Park Services UK Limited has breached the PPSCoP in the following ways:
• They pursued a registered keeper despite the location (North Greenwich Main) not being ‘relevant land’ under Schedule 4 of the Protection of Freedoms Act 2012, meaning keeper liability cannot lawfully arise.
• They issued a PCN under civil contract law only, and never claimed any statutory basis (e.g. byelaws), therefore liability lies with the driver only, who was not identified.
• They failed to respond to a detailed appeal submitted by the Keeper on 19 March 2025. Instead, they sent a generic email asking for the driver’s details and placed the charge on hold for 7 days.
• The Keeper responded by referring them back to the original appeal, but no further response or appeal decision was issued, and no POPLA code was provided, breaching Clause 8.4.1(b) and Annex C.1.1 of the PPSCoP.
• Saba then unlawfully passed the Keeper’s data to ZZPS Ltd, a debt collection agency, while the appeal remained unresolved and access to independent adjudication had not been provided.
These are not minor or technical breaches. They show a clear disregard for the standards required under the current single Code. As a result, the operator is no longer entitled to use the keeper data they obtained from the DVLA, because the purpose for which it was provided (a fair and lawful pursuit of a charge under the Code) no longer applies.
The DVLA remains the Data Controller for the data it releases under KADOE, and is therefore responsible for ensuring that personal data is not misused by third parties. This includes taking action against AOS operators who breach the conditions under which the data was provided. For the avoidance of doubt, this complaint does not concern whether Saba Park Services UK Limited had reasonable cause at the point of requesting my data. Rather, it concerns their subsequent breach of the KADOE contract in the way that data was used, contrary to the requirements of the Private Parking Single Code of Practice. I am therefore asking the DVLA to investigate this breach and to take appropriate action under the terms of the KADOE contract.
This may include:
• Confirming that a breach has occurred
• Taking enforcement action against the operator
•Suspending or terminating their KADOE access if warranted
I have attached relevant supporting material with this statement. Please confirm receipt and provide a reference for this complaint. I am also happy to provide further information if required.
Name: [INSERT YOUR NAME]
Date: [INSERT DATE]