Respond to that with the following:
Subject: Formal Request for ICA Referral – DVLA Step 2 Complaint: Misuse of Keeper Data by UKCPM
To: DVLA Complaints Team
Date: [Insert Date]
Vehicle Registration: [Insert VRM]
Reference: Step 2 Complaint – Misuse of Keeper Data by UKCPM
Dear Mrs Smith,
Thank you for your Step 2 response dated [insert date]. I am writing to formally request that this complaint be referred to the Department for Transport’s Independent Complaints Assessor (ICA), as outlined in the DVLA complaints procedure.
Your reply fails to address the core issue raised: the unlawful ongoing use of keeper data by UKCPM in breach of the Private Parking Single Code of Practice (PPSCoP), which governs the conditions under which DVLA data may be processed. The DVLA remains the data controller for personal data disclosed via the KADOE system and cannot absolve itself of responsibility when the conditions of release are violated.
Your assertion that UKCPM becomes the sole data controller upon receipt of the data is a misrepresentation of the DVLA’s obligations under UK GDPR. The DVLA is accountable for ensuring that data is not only disclosed lawfully but also used lawfully thereafter—particularly when misuse is foreseeable and systemic.
I have already provided detailed evidence of PPSCoP breaches by UKCPM, including:
• Failure to specify a valid period of parking
• Conflicting timestamps
• Misleading signage
• Lack of contractual authority
These are not minor infractions. They directly undermine the lawful basis for processing and render the use of my personal data unlawful. The DVLA’s refusal to investigate or suspend KADOE access in light of these breaches constitutes regulatory failure.
Your response also deflects oversight to the IPC, a trade body with no statutory authority, transparency, or credible enforcement mechanism. This is not a lawful substitute for DVLA’s own obligations under UK GDPR.
Given the DVLA’s failure to engage with the substance of my complaint, I now request that this matter be referred to the ICA for independent review. Please confirm that this referral has been made and provide the ICA’s contact details so I may supply any further documentation required.
I expect this referral to be made within 15 working days, in line with the ICA process outlined on GOV.UK.
Yours sincerely,
[Your Full Name]
[Your Address]
[Your Email]
[Your Phone Number]
Interesting that they have a different timestamp for their latest letter. I think it is time to set the DVLA on to them.
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.
...
I've done that and Thank you for your detailled instructions.
Yesterday I received a letter from 'Debt Recovery Plus' dated 13/05/2025 stating I need to pay by 27/05/2025;
Page 1;
(https://i.ibb.co/S7Pg1bF3/DRP-Page-1-2.jpg) (https://ibb.co/S7Pg1bF3)
Page 2;
(https://i.ibb.co/v65WmvhD/DRP-Page-2-2.jpg) (https://ibb.co/v65WmvhD)
Please what do I need to do with/reply to this? The 27th is just 5 days away now.
Thank you.
Interesting that they have a different timestamp for their latest letter. I think it is time to set the DVLA on to them.
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 UK Car Park Management Ltd (UKCPM), a IPC 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: UK Car Park Management Ltd (UKCPM)
Date of PCN issue: 6 April 2025
Vehicle registration: [INSERT VRM]
I am submitting this complaint to report a misuse of my personal data by UKCPM, 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 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, UKCPM has breached the PPSCoP in the following ways:
• The Notice to Keeper (NtK) fails to specify a required period of parking, in breach of Schedule 4, Paragraph 9(2)(a) of the Protection of Freedoms Act 2012. The evidence available shows only that the car was present for approximately 32 seconds, which is not sufficient to establish any contract was formed or breached.
• The PCN and subsequent Final Warning Letter issued by UKCPM contain inconsistent timestamps, raising concerns about the accuracy and integrity of the data used to justify the charge. This misrepresentation further undermines the lawfulness of the data use.
• At the time of the incident, the on-site signage was contradictory and unclear. Hyde Housing displayed a notice stating 30 minutes was allowed for loading/unloading, whereas UKCPM now claim the limit is 15 minutes. The signs were recently changed following a complaint to the estate caretaker, who confirmed UKCPM’s own signage had previously allowed 30 minutes. The driver was using the marked “drop off” zone outside a resident’s home for its intended purpose, under existing estate rules.
• The resident’s tenancy agreement contains no clause that authorises UKCPM to enforce parking, nor any requirement to display a permit or comply with a 15-minute restriction. This means any alleged contract imposed by UKCPM signage is legally baseless, and any charge based on such signage is unjustified.
These are not minor breaches. They show a disregard for the PPSCoP and the governing principles that must be followed when processing keeper data. UKCPM has demonstrated poor compliance and misused the data they obtained from the DVLA.
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. I therefore ask the DVLA to investigate and take appropriate action against UKCPM.
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]
Even
than
Also, gather evidence:
• Take a photo of any “30 minutes free parking” sign to show UKCPM’s own signage contradicts their claim;
• Speak to the caretaker, as planned, to confirm the history and intended use of the drop-off bays.
You have every right to challenge this. Your lease comes first, and neither UKCPM nor Hyde can rewrite it without following proper legal procedures.
Hello,
1. There is 1 other of these "drop off bay" on the housing estate but there are no signs near it about its use.
On a nearby wall there is the sign below which looks like a parking sign I remember seeing on a street;
(https://i.ibb.co/kVgGgRSx/1745488386615.jpg) (https://ibb.co/kVgGgRSx)
2. I spoke with the caretaker and he doesn't remember when the '30 mins loading/unloading' thing started or what the current status is. To be fair he has been off with medical issues so not up to speed with all changes.
He thinks it was introduced when the last parking firm Wing was here and it was something the Property Manager introduced when the PM manager existed.
Now there is something called a neighbourhood officer and he said he will ask when he sees them.
3. Today I notice the '30 min unloading' sign has dissapeared from the notice board;
(https://i.ibb.co/mrZjPXXQ/sign-gone.jpg) (https://ibb.co/mrZjPXXQ)
I will ask the caretaker for an update when I see him.
...Also, gather evidence:
• Take a photo of any “30 minutes free parking” sign to show UKCPM’s own signage contradicts their claim;
• Speak to the caretaker, as planned, to confirm the history and intended use of the drop-off bays.
You have every right to challenge this. Your lease comes first, and neither UKCPM nor Hyde can rewrite it without following proper legal procedures.
Thank you, that's reassured me.
Previously there was a company called Wing doing parking on the estate and I think they went back to when clamping was still allowed.
I will ask some other residents I know what their leases say and if there have been any amendments as they are on top of all things landlord.
I will gather evidence & speak to the caretaker and report back.
Thanks you :)
Even if this were to ever escalate into a court claim, I seriously doubt it would ever reach a hearing. Even if it ever did, it is nothing other than be fearful of. Far too many people have little understanding of the civil court system (as opposed to the criminal system). The County Court is the ultimate dispute resolution service.
Just to try and allay your fears, here is a short video that explains what happens in a hearing for a debt dispute in court:
https://youtu.be/n93eoaxhzpU?feature=shared
Your tenancy agreement is a legal contract, and you have supremacy of contract over the land where you reside and park. From what you have shown us there is no clause in your tenancy that introduces UKCPM, requires you to display a permit, or imposes time restrictions like "30 minutes free." That means UKCPM has no legal basis to issue parking charges — they’re not a party to your contract, and they cannot unilaterally impose new terms.
Unless Hyde Housing has formally varied your lease in accordance with the Landlord and Tenant Act 1987, particularly Section 37 (which requires consultation and a Tribunal), no new contractual obligations can be imposed — especially not by a third party like UKCPM.
What UKCPM are doing amounts to issuing speculative invoices for alleged breaches of a contract you never entered into. Their “contract” signage has no effect on tenants who already have a lease that governs their rights to use the estate, including parking areas. UKCPM’s actions are legally baseless where there is no agreement with you, and they have no right to override your lease.
You should write to Hyde Housing and make it crystal clear that:
• You do not accept UKCPM's authority, as it contradicts your tenancy rights;
• Hyde is vicariously liable for the actions of UKCPM, their appointed agent;
• If you suffer loss, distress, or legal escalation due to UKCPM’s unlawful actions, you will hold Hyde and UKCPM jointly and severally liable.
Let them know that Hyde’s failure to control or properly instruct their agents could result in a formal complaint to the Housing Ombudsman and potential legal action for breach of your tenancy rights and unlawful interference with quiet enjoyment.
Also, gather evidence:
• Take a photo of any “30 minutes free parking” sign to show UKCPM’s own signage contradicts their claim;
• Speak to the caretaker, as planned, to confirm the history and intended use of the drop-off bays.
You have every right to challenge this. Your lease comes first, and neither UKCPM nor Hyde can rewrite it without following proper legal procedures.