Have you already sent an appeal? In what capacity did you send it? Keeper, Driver or both?
Your "receipts" do not evidence anything that will assist you except to expose you as the driver. Those receipts do not evidence that the vehicle did not remain on the property.
You have been advised on what to say and that there has been no breach of contract by the driver. However, GroupNexus t/a CP Plus Ltd have breached the PPSCoP section 7.3(d) and therefore requested and obtained your DVLA data unlawfully, which merits a formal complaint about CP Plus 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 CP Plus Ltd trading as Group Nexus, a BPA AOS operator with DVLA KADOE access. This operator unlawfully accessed my data on 30 April 2025 in breach of Section 7.3(d) of the Private Parking Single Code of Practice (PPSCoP) and therefore, the KADOE contract.
The breach occurred at the point they requested my data. The Operator failed to carry out a manual quality control check of ANPR images, as required by PPSCoP Clause 7.3(d).
Note 1 to Clause 7.3 highlights that this check is "particularly important for detecting issues such as ‘double dipping’, where image camera systems might have failed to accurately record each instance when a vehicle enters and leaves controlled land.” This is precisely what occurred here. The Operator has failed to search for orphan images from two separate visits which would have confirmed that there was no single stay and therefore they had no reasonable cause to obtain my keeper data.
This was a misuse of my personal data at the point of acquisition, not merely in its processing after the fact. A full supporting statement is attached. Please confirm receipt and provide a complaint reference number.
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: CP Plus Ltd trading as Group Nexus
Date of PCN issue: 30 April 2025
Vehicle Registration: [INSERT VRM]
This is a formal complaint regarding an unlawful request for my keeper data made by CP Plus Ltd under the DVLA’s KADOE (Keeper At Date Of Event) contract. The operator did not have reasonable cause to obtain my personal data because the Parking Charge Notice (PCN) issued was based on fundamentally flawed ANPR evidence and a clear breach of Section 7.3 of the Private Parking Single Code of Practice (PPSCoP).
The nature of the breach
The PCN alleges that the vehicle remained on site at Ashford Retail Park from 09:19 to 12:37 on 30 April 2025, constituting a parking period of 3 hours 17 minutes. However, this is not supported by a complete ANPR event log. The images relied upon show only a first entry and second exit, with no corresponding data for a first exit or second entry. This is a known failure mode referred to in the PPSCoP as “double dipping.”
CP Plus Ltd breached Clause 7.3(d) of the Private Parking Single Code of Practice, which mandates that:
“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.”
Note 1 to Clause 7.3 makes clear:
“The manual quality control check for remote ANPR and CCTV systems is particularly important for detecting issues such as ‘double dipping’, where image camera systems might have failed to accurately record each instance when a vehicle enters and leaves controlled land...”
Had CP Plus conducted the required manual quality control check, they would have identified orphan images — i.e. unpaired ANPR timestamps not yet assigned to any valid event. This is precisely what the PPSCoP requires operators to review before issuing any PCN based on ANPR data.
By failing to carry out this check, CP Plus wrongly assumed a continuous stay where none could reasonably be inferred. No contravention was evidenced, and therefore no reasonable cause existed to request my keeper data. The breach occurred at the point of data access, not afterwards.
This conduct is in clear breach of the KADOE contract, which only permits access to DVLA data for the purpose of pursuing a charge issued in full compliance with the relevant Code of Practice.
Requested action
This is a serious breach of the DVLA’s data governance regime. As the Data Controller, the DVLA is responsible for ensuring that personal data is not accessed or used unlawfully by private parking operators.
I request that the DVLA:
• Confirm that a breach has occurred
• Investigate CP Plus Ltd’s data access request
• Take appropriate enforcement action, including suspension or termination of KADOE access if warranted
Please confirm receipt and provide a reference number for this complaint. I am willing to provide any further information if required.
Name: [INSERT YOUR NAME]
Date: [INSERT DATE]