This response from ECP is contradictory and potentially unlawful, given their earlier written confirmation from their Data Protection Officer (DPO) dated 2 June 2025, stating that:
• The PCN was cancelled;
• Your personal data was erased under Article 17(1)(a) UK GDPR;
• The matter was concluded.
The follow-up from ECP Customer Services on 6 June 2025 completely disregards the DPO's decision and undermines the validity of your erasure request, which they already formally accepted. Continuing to ask for documents and pursue the matter suggests continued processing of your personal data, despite the DPO’s confirmation that this had ceased.
You should now respond to ECP Customer Services (cc'ing the DPO) with the following:
Subject: Formal Complaint – Continued Processing After Article 17 Erasure Confirmation
Dear Sir or Madam,
Re: PCN [reference] – Vehicle Registration [XXXXXX]
Data Protection Reference: [insert DPO ref if given]
Your customer services email dated 6 June 2025 is entirely unacceptable and contradicts the formal determination made by your Data Protection Officer on 2 June 2025, confirming that:
• The parking charge had been cancelled;
• My personal data had been erased from your systems under Article 17(1)(a) of UK GDPR;
• Your processing of my data had ceased.
Yet, your customer services team has now attempted to re-engage with me regarding the same cancelled PCN and demanded further personal documents. This is an outrageous and unlawful continuation of data processing after erasure, in breach of:
• Article 5(1)(a) – Lawfulness, fairness and transparency;
• Article 6 – Lawful basis for processing no longer exists;
• Article 17(1)(a) – Data no longer necessary for the purposes for which it was collected;
• Article 19 – Failure to ensure erasure is communicated internally and to any processors.
This communication is being treated as a formal complaint and notice of further breach. I hereby demand:
• An immediate written apology acknowledging this unlawful contact;
• Written confirmation that no further processing has occurred or will occur;
• Confirmation that this complaint has been escalated internally;
• A full explanation as to why customer services were unaware of the DPO's determination.
I now require a formal written response within 14 days confirming:
1. Why your customer services department unlawfully processed my personal data after the DPO had confirmed erasure;
2. What internal failings led to this breach;
3. What steps you have taken to ensure this does not happen again;
4. Your position on compensating me under Article 82 of the UK GDPR for the distress caused by your unlawful processing and continued harassment.
Failure to respond substantively will be noted in my submissions to the ICO and DVLA as further evidence of your disregard for data protection obligations and regulatory accountability.
I expect your full response by [insert date 14 days from today].
Yours faithfully,
[Your Name]
You also submit a formal complaint about this unlawful processing of your data to the DVLA and the ICO.
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 making a formal complaint against Euro Car Parks (ECP), a BPA member with DVLA KADOE access, for unlawfully continuing to use my personal data after confirming in writing that it had been erased under Article 17(1)(a) UK GDPR.
ECP obtained my details from the DVLA and pursued me for a Penalty Charge Notice dated 3rd January 2022. However, I sold the vehicle on 2nd January 2022. DVLA has confirmed in writing that I was not the registered keeper on the date of the incident.
I submitted a formal data protection complaint to ECP. Their Data Protection Officer responded on 2nd June 2025, confirming that the PCN had been cancelled and my personal data had been erased from their systems.
Yet just four days later, on 6th June 2025, ECP's customer service team contacted me again regarding the same cancelled PCN, unlawfully processing and requesting further personal information — proving that the data had not been erased and was still in active use.
This is a flagrant and deliberate breach of UK GDPR by a DVLA data recipient. I am attaching a full supporting statement with documentary evidence and I expect the DVLA to take enforcement action under the KADOE contract. ECP has continued to use DVLA-supplied data long after they confirmed erasure.
Please 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 – Unlawful Continued Use of DVLA-Supplied Data After Confirmed Erasure
Operator Name: Euro Car Parks (ECP)
PCN Date: 3rd January 2022
Vehicle Registration: [INSERT VRM]
KADOE Data Use Complaint
Date of DVLA Confirmation: [INSERT DATE ON DVLA LETTER]
Date of DPO Erasure Confirmation: 2nd June 2025
Date of Unlawful Continued Use: 6th June 2025
I am making this complaint to report an egregious and unlawful misuse of DVLA-supplied keeper data by Euro Car Parks (ECP), who had no right to process my personal data beyond the date they confirmed that it had been erased.
I sold the vehicle on 2nd January 2022 — a day before the parking event that led to the PCN issued by ECP. The DVLA has since confirmed in writing that I was not the registered keeper on the date of the alleged contravention.
Despite this, ECP used DVLA data to pursue me for a charge, passing my data to a debt collector (DCBL) and sending demands in my name.
I submitted a formal complaint to ECP’s Data Protection Officer, who responded on 2nd June 2025 confirming the following:
• The PCN was cancelled;
• My personal data was no longer necessary for the original purpose;
• My data had been erased under Article 17(1)(a) UK GDPR;
• All processing had ceased.
However, on 6th June 2025, I received an email from ECP Customer Services demanding further documentation relating to the same cancelled PCN — demonstrating that my personal data was still being actively processed four days after erasure was confirmed.
This is a blatant breach of UK GDPR. ECP knowingly misrepresented their compliance, failed to erase my data, and unlawfully continued processing it after formally confirming erasure in writing. Their internal systems reveal either an embarrassing level of incompetence, or they have knowingly lied about data deletion while continuing to use DVLA-supplied data in breach of contract and the law.
This complaint is about the DVLA’s own responsibility as the Data Controller for data released under the KADOE framework. ECP’s access to DVLA data is subject to strict conditions. When DVLA data is misused — especially after a confirmed erasure — DVLA has a duty to act.
I expect the DVLA to take enforcement action, including:
• Confirmation that ECP unlawfully continued to use DVLA-supplied data;
• Full investigation under the KADOE contract;
• Suspension or termination of KADOE access, if appropriate;
• Escalation to the Information Commissioner’s Office as necessary.
I am attaching the following documents as evidence:
• DVLA letter confirming I was not the registered keeper on 3rd January 2022;
• Email from ECP’s DPO (2 June 2025) confirming PCN cancellation and erasure of my data;
• Follow-up email from ECP Customer Services (6 June 2025) unlawfully continuing processing.
Please confirm receipt of this complaint and provide a reference number.
Name: [INSERT YOUR NAME]
Date: [INSERT DATE]
Welcome. You can safely ignore DCBL. They are a powerless debt collector that has no skin in the game, no matter what they say. Never, ever, communicate with a useless debt collector.
You have a couple of choices here. First is to submit a formal complaint to ECP and instruct them to cease and desist. Provide a copy the evidence from the DVLA and warn them that failure to confirm in writing that the matter is now closed and that they have deleted all your data from their systems will lead to sanctions from the DVLA and should they be so stupid as to continue harassing you, either directly or through their debt recovery agents, you reserve the right to sue them for compensation for breach of your GDPR by unlawfully continuing to process your data.
Second option is to wait and see whether they move to the next phase and issue a Letter of Claim (LoC), most likely through the incompetents at DCB Legal (not DCBL) and warn them off in your response. This is a civil contract matter and has nothing to do with any “penalty” or “fine”.
Even if you were to do nothing and a claim was issued, as long as it is defended, it would never reach a hearing as they will eventually discontinue. However, you do not really want have to go down that procedural route.
Email the DPO at ECP and attach a copy of the DVLA letter with the following to DPO@eurocarparks.com and also CC in yourself:
Subject: Formal Complaint – Misuse of Personal Data and Demand to Cease Processing
Dear Sir or Madam,
Re: Penalty Charge Notice dated 3rd January 2022 – PCN No.: [PCN reference] Vehicle registration: [XXXXX]
I write formally to instruct Euro Car Parks to immediately cease and desist all processing of my personal data in connection with the above matter.
The Parking Charge Notice (PCN) issued on 3rd January 2022 relates to a vehicle that I no longer owned or was the registered keeper of at the material time. I sold the vehicle on 2nd January 2022, and the DVLA has confirmed in writing that I was not the registered keeper on the date of the alleged contravention. A copy of the DVLA's confirmation is enclosed for your reference.
Your continued processing of my data and engagement of third-party debt collectors constitutes a serious breach of the UK General Data Protection Regulation (UK GDPR), in particular:
• Article 5(1)(a) – Personal data shall be processed lawfully, fairly and in a transparent manner
• Article 6 – You have no lawful basis to continue processing my data
• Article 17 – I formally request erasure of all my personal data held in relation to this matter
Unless you immediately confirm in writing that:
1. This matter is now closed;
2. My personal data has been permanently erased from your systems;
3. All third-party agents (including DCBL) have been instructed to do the same;
then I will escalate this matter by:
• Lodging a formal complaint to the Information Commissioner’s Office (ICO) for unlawful data processing;
• Reporting your conduct to the DVLA for continued misuse of keeper data in breach of your KADOE contract;
• Reserving my right to pursue compensation under Article 82 of the UK GDPR for any distress or loss caused by your continued unlawful processing and harassment.
Take this as your final notice. Any further contact from you or your agents in relation to this invalid PCN will be treated as harassment.
Yours faithfully,
[Your Full Name]