There is NO legal obligation for the Keeper to identify the driver to an unregulated private parking company. I really don't understand why people think that a firm of ex-clamper thugs who are unregulated can somehow demand that anyone is obliged to answer to them just because they have issued a speculative invoice for an alleged breach of contract buy the driver.
You have to appeal each NtK separately.
You now have grounds to make a formal complaint to the DVLA as G24 are using your DVLA data unlawfully. They have breached section 8.1.1(d) of the PPSCoP which means that they have breached the conditions of their DVLA KADOE contract.
Here’s how to make a DVLA complaint (only need a single complaint to cover both PCNs:
• 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 G24 Ltd, an IPC Approved Operator with DVLA KADOE access, for breaching the BPA/IPC Private Parking Single Code of Practice (PPSCoP) after obtaining my personal data.
While G24 may have had reasonable cause at the time of their KADOE requests, 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: G24 Ltd
Date of PCN issue: 8 May 2025
Vehicle registration: [INSERT VRM]
I am submitting this complaint to report a misuse of my personal data by G24 Ltd, who obtained my keeper details from the DVLA under the KADOE (Keeper At Date Of Event) contract.
Although G24 may have had reasonable cause to request my data initially, their use of that data afterwards amounts to unlawful processing. This is because they 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, G24 has breached the PPSCoP in the following way:
• G24 issued two Notices to Keeper (NtKs) dated 8 May 2025, for alleged parking events on 25 April 2025 and 27 April 2025 respectively.
• Both NtKs were "given" (delivered) more than 14 days after the dates of the alleged contraventions (outside of the "relevant period"), meaning that keeper liability under the Protection of Freedoms Act 2012 (PoFA) could not be invoked.
• Despite this, G24 falsely stated in both NtKs that the keeper is liable under PoFA.
This directly breaches Section 8.1.1(d) of the PPSCoP, which explicitly prohibits parking operators from stating the keeper is liable under PoFA where such liability cannot lawfully arise:
The parking operator must not serve a notice which in its design and/or language: state the keeper is liable under the Protection of Freedoms Act 2012 where they cannot be held liable.
As the operators KAODE contract is dependent on full PPSCoP compliance, any breach means that the operator is unlawfully using data obtained from the DVLA.
This is not a minor or technical breach. It shows a deliberate or negligent 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 copies of the NtKs showing the date of issue and the alleged contravention dates as supporting evidence. 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]
Probably, but that doesn't confer any obligation on you to provide the same.
Here's an example appeal:
Dear Sirs,
I have received your Parking Charge Notice (Ref: ________) for vehicle registration mark ____ ___, in which you allege that the driver has incurred a parking charge. I note from your correspondence that you are not seeking to hold me liable as the registered keeper, under Schedule 4 of the Protection of Freedoms Act 2012 ("The Act"). You have chosen not to issue a Notice to Keeper in accordance with The Act, and it is now too late for you to do so.
There is no obligation for me to name the driver and I will not be doing so. I am therefore unable to help you further with this matter, and look forward to your confirmation that the charge has been cancelled. If you choose to decline this appeal, you must issue a POPLA code.
Yours,