If you follow the advice you receive here, you will not be paying a penny to MET parking. You are now in the centre of a very long running scam being operated by this rogue company.
I note that the Notice to Keeper (NtK) is addressed to "The company secretary". Is the vehicle registered to a company (your company)?
For now, you only need to know that MET have no idea who the driver is. All they know is that you (or your company) are the Keeper. As the location is within the boundary of Stansted airport, there can be no Keeper liability because it is not relevant land for the purposes of PoFA 2012.
There is no legal obligation on the known Keeper to identify the unknown driver to an unregulated private parking company. As MET cannot rely on the provisions of PoFA to transfer liability from the unknown driver to the known Keeper, you should appeal (only as the Keeper) as follows:
I am the registered keeper. MET cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control. As a matter of fact and law, MET will be well aware that they cannot use the PoFA provisions because Stansted Airport is not 'relevant land'.
If Stansted Airport wanted to hold owners or keepers liable under Airport Bylaws, that would be within the landowner's gift and another matter entirely. However, not only is that not pleaded, it is also not legally possible because MET is not the Airport owner and your 'parking charge' is not and never attempts to be a penalty. It is created for MET's own profit (as opposed to a bylaws penalty that goes to the public purse) and MET 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. MET have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.
They will reject the appeal but you will then get a POPLA code which we can use for a secondary appeal.
However, MET have also breached their KADOE contract with the DVLA and are therefore using your data unlawfully. As the DVLA is the data controller, you should submit a formal 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 MET Parking Services, a BPA AOS member with DVLA KADOE access, for breaching the BPA/IPC Private Parking Single Code of Practice (PPSCoP) after obtaining keeper data relating to a limited company.
While MET Parking Services may have had reasonable cause at the time of their KADOE request, their subsequent misuse of that 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.
In this case, MET Parking Services issued a Notice to Keeper to a corporate entity and falsely claimed the right to hold the company liable under the Protection of Freedoms Act 2012 (PoFA). However, PoFA Schedule 4 only allows keeper liability where the keeper is a natural person, and only on “relevant land”. The location in question—Southgate Park, Stansted Airport—is not relevant land due to statutory control under airport byelaws.
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 setting out the nature of the breach and request a full investigation. Also attached is an official map of Stansted Airport boundary and the location of Southgate Park highlighted to prove it is within the byelaws boundary of the airport.
Please acknowledge receipt and confirm a 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: MET Parking Services
Date of PCN issue: 22 April 2025
Vehicle registration: [INSERT VRM]
I am submitting this complaint to report a misuse of personal data by MET Parking Services, who obtained keeper details from the DVLA under the KADOE (Keeper At Date Of Event) contract.
Although MET Parking Services may have had reasonable cause to request the data initially, their subsequent use of that data amounts to unlawful processing because they have acted in breach of the BPA/IPC Private Parking Single Code of Practice (PPSCoP). The PPSCoP forms a mandatory component of the regulatory framework governing DVLA data release to private parking operators.
The KADOE contract explicitly limits data use to the pursuit of an unpaid parking charge in accordance with the Code of Practice. If an operator breaches that Code after receiving DVLA data, their use becomes unlawful as it no longer serves a permitted purpose.
In this case, MET Parking Services has breached the PPSCoP in the following ways:
• The Notice to Keeper was issued in relation to Southgate Park at Stansted Airport, which is situated on airport land under statutory control. Such land is excluded from the definition of “relevant land” under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA).
• Despite this, the NtK falsely asserts that the registered keeper is liable under PoFA, contrary to the facts and the law.
• Further, the NtK was addressed to a limited company, not a natural person. PoFA Schedule 4 only provides for the transfer of liability from driver to a keeper who is an individual. There is no lawful basis under PoFA to hold a corporate entity liable.
• These false representations breach Section 8.1.1(d) of the Private Parking Single Code of Practice, which prohibits operators issuing notices which state the keeper is liable under the Protection of Freedoms Act 2012 where they cannot be held liable.
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. 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]
Include a copy of this map with your formal complaint:
(https://i.imgur.com/6rddEB2.jpeg)