ZZPS are not a party to any alleged parking contract and have no standing to determine liability for any alleged contravention. However, LDK have chosen to involve ZZPS to process personal data obtained from the DVLA and to conduct administration, appeals handling and enforcement activity on LDK’s behalf.
That email from ZZPS admitting that the PCN was issued with missing dates is significant. A PCN missing mandatory information is defective and should have been cancelled. It cannot lawfully be “re-issued”. Re-issuing is not a correction; it is fresh processing and fresh enforcement based on personal data that should never have been used in the first place. That email is an admission of fault and confirms continued processing despite the defect being known.
Responsibility remains entirely with LDK. ZZPS are LDK’s agent. Any data processing by ZZPS is done at LDK’s direction and for LDK’s purposes. LDK is therefore responsible for ZZPS’s conduct and for any unlawful processing carried out by them. Writing to ZZPS does not legitimise them or accept their standing; it simply puts them on notice as a data processor or joint controller so they cannot later claim ignorance.
At this stage the issue is no longer an “appeal”. It is unlawful obtaining and continued processing of personal data. The objective is cancellation of the PCN, erasure of personal data, and preserving evidence for regulatory complaints and a Data Protection Act claim.
LDK must be put on notice, as principal, that:
• the PCN is unlawful and must be cancelled;
• ZZPS must be instructed to cease processing immediately;
• all personal data relating to the PCN must be erased, save only for a minimal suppression record to prevent further contact or DVLA requests;
• any third party already given the data must be instructed to erase it; and
• failure to comply will result in a county court claim for compensation under the Data Protection Act 2018.
Separately, ZZPS must be served with a narrow data protection notice only. This is not engagement on the merits of the PCN. It is simply an instruction to stop processing and erase data. If they continue after that notice, they expose themselves to ICO action and civil liability regardless of what LDK does.
The only purpose of correspondence now is not to persuade LDK or ZZPS to “do the right thing”, but to put them on formal notice so that:
• continued processing becomes deliberate;
• regulatory complaints are supported by clear evidence; and
• a Data Protection Act claim can be issued cleanly without any argument that they were not warned.
ZZPS’s “re-issued today” email is excellent evidence. It shows admission of fault, continued processing, and active enforcement. Preserve it. It materially strengthens DVLA, ICO and court complaints.
You now need to send two emails, one to LDK and one to the ZZPS DPO. For LDK send the following to info@ldkgroup.co.uk and CC compliance@ldkgroup.co.uk and yourself:
Subject: PCN [ref] – addendum: your agent ZZPS is continuing processing/“re-issuing”
Dear LDK Group Ltd,
Further to my email dated [date], I now have correspondence from “appeals@paymyparkingcharge.com” stating that, due to an admitted “administration fault” (missing dates), the charge has been “re-issued” and a fresh 14-day discount period is being demanded.
This is unacceptable. ZZPS is your agent. You are responsible for its conduct and for any processing/disclosures of my personal data.
You are required to instruct ZZPS immediately to cease all processing and to erase my personal data, and to confirm to me in writing that:
- the PCN is cancelled and closed; and
- all recipients (including ZZPS) have erased my data save for a minimal suppression record.
- No further demands or “re-issued” notices are to be sent by any agent.
If you do not confirm compliance within 14 days I will proceed with my reports and will issue a county court claim for compensation under the Data Protection Act 2018 without further notice.
Yours faithfully,
[Name]
[Address]
And send the following to the ZZPS DPO at dataprotection@zzps.co.uk:
Subject: Data rights notice – cease processing and erase my data (LDK PCN [ref] / VRM [ ])
FAO Data Protection Officer, ZZPS Ltd,
I do not recognise ZZPS as having any standing to pursue any alleged parking charge. This notice concerns data protection only.
You are processing my personal data in relation to an alleged LDK Group Ltd PCN and you have now stated the charge has been “re-issued”. I formally object to that processing (UK GDPR Article 21) and require you to restrict processing immediately (Article 18) and to erase my personal data relating to this PCN (Article 17).
You must confirm within 14 days that:
1. you have erased my personal data relating to this PCN; and
2. you have not disclosed it to any third party, or if you have, you have instructed each recipient to erase it and cease processing, and you have complied with Article 19.
The only permitted retention is a minimal suppression record solely to ensure ZZPS does not contact or process my data again regarding this PCN. If you claim any other retention, identify the data fields, lawful basis, and retention period.
Failure to comply will be reported to the ICO and I will pursue compensation under the Data Protection Act 2018 without further notice.
Yours faithfully,
[Name]
[Address]
That letter is from the utterly powerless ZZPS. DO NOT respond to ZZPS. They have zero standing to do anything. This is still a matter for LDK. ZZPS are irrelevant to the alleged contract and you are entitled to deal only with LDK as principal. However, you must instruct ZZPS to erase your data and if they don't, you can sue them of compensation under the Data Protections Act 2018.
Send there following email to LDK as info@ldkgroup.co.uk and CC compliance@ldkgroup.co.uk and yourself. You can copy in ZPS if you want, just to shut them down:
Subject: PCN [reference] – formal notice to LDK Group Ltd only / cancellation and data misuse
Dear LDK Group Ltd,
Re: Parking Charge Notice [PCN reference] – Vehicle [VRM]
I write to you as the registered keeper. This correspondence is directed to LDK Group Ltd as principal. I do not recognise ZZPS Ltd as having any standing in this matter and I will not engage with them further. Any involvement of ZZPS is entirely a matter between you and your agent.
The recent email from ZZPS stating that the account has been placed on “indefinite hold” is not an outcome. It is an attempt to avoid addressing the substance of the matter and is wholly inadequate.
Your own evidence shows the vehicle was on the public highway/adopted footway and was never parked on land you are authorised to manage. No contract could arise, no breach occurred, and no parking charge was ever lawfully issued. You therefore had no reasonable cause to obtain my keeper data and no lawful basis to process it.
This is not a marginal or technical issue. Issuing parking charges based on CCTV captures of vehicles on the public highway, re-labelling those incidents as “private land” contraventions, and then using that false premise to obtain DVLA data and demand payment is a serious matter. It has now been identified and documented.
Accordingly, I require the following from LDK Group Ltd:
1. Written confirmation that this PCN is cancelled, the matter is closed, and no further action will be taken by LDK or by any agent acting on LDK’s behalf (including no debt recovery, no solicitor referral, no tracing, and no litigation).
2. Written confirmation that my personal data relating to this PCN has been erased from LDK’s systems. The only exception is a minimal suppression/audit record strictly limited to what is necessary to evidence closure and to prevent any further DVLA requests, re-ticketing, tracing, debt recovery activity, or litigation in relation to this VRM and alleged event. You must identify precisely what minimal data fields (if any) are being retained, the lawful basis relied upon, and the retention period.
3. Written confirmation that any third party already provided with my personal data in relation to this PCN (including ZZPS and any other debt recovery agent, solicitor, or tracing agent) has been instructed to cease processing immediately and to erase that data, and that those instructions have been complied with.
4. Confirmation of the date on which my keeper data was obtained, the source relied upon (DVLA or otherwise), and a complete list of all recipients to whom my data has been disclosed (with the date of each disclosure).
For the avoidance of doubt, I do not consent to any further contact from ZZPS Ltd or any other agent. Any future correspondence must come from LDK Group Ltd directly.
I am already reporting this matter, with evidence, to the DVLA, the BPA, the ICO and the CMA. This email is a formal pre-action notice: unless you provide the confirmations demanded above (cancellation, erasure, and downstream erasure) within 14 days, I will commence county court proceedings for compensation under the Data Protection Act 2018 for unlawful obtaining and processing of my personal data. No further warning will be given.
You have 14 days to confirm cancellation and compliance.
Yours faithfully,
[Name]
[Address]
This should cuts ZZPS out completely, forces LDK to own the conduct — contract, data, DVLA access, everything. If they later try to resurrect the charge, this email becomes Exhibit A showing they were warned and chose to continue.
However, you should send the following email to the ZZPS Data Protection Officer (DPO) at dataprotection@zzps.co.uk and CC yourself:
Subject: Formal complaint to DPO – Erasure notice and objection to processing (LDK Group PCN [ref] / VRM [ ])
FAO: Data Protection Officer, ZZPS Ltd
I write as the data subject. This is a formal complaint and a formal notice exercising my rights under UK GDPR and the Data Protection Act 2018.
Background
ZZPS Ltd has contacted me and/or processed my personal data in relation to an alleged parking charge issued by LDK Group Ltd (PCN reference [ ] / VRM [ ] / alleged event date [ ]). On the evidence relied upon by the operator, the vehicle was not parked on land controlled by the operator and no parking contract could have been formed. In those circumstances there is no lawful basis for ZZPS Ltd to process my data for “debt recovery” or any related purpose.
Notice of objection and restriction
I formally object to any processing by ZZPS Ltd of my personal data connected with this PCN (UK GDPR Article 21). You must immediately restrict processing (Article 18) pending completion of the actions demanded below. You must not contact me further about payment, debt recovery, escalation, tracing, or litigation.
Erasure demand
I require ZZPS Ltd to erase all personal data it holds relating to me in connection with this PCN (UK GDPR Article 17), including (without limitation) my name, address, VRM, correspondence, notes, call logs, recordings, images, internal case references, and any data received from LDK Group Ltd, DVLA-derived keeper data, or any other source.
The only permissible exception is a minimal suppression record strictly limited to what is necessary to ensure that ZZPS does not process or contact me again in relation to this PCN (e.g., a “do not contact/do not process” marker). If you contend any further retention is necessary, you must specify precisely:
1. what data fields you propose to retain,
2. the lawful basis relied upon for retention, and
3. the retention period.
Third-party disclosure and downstream erasure
If ZZPS has shared my data with any third party (including any solicitor, tracing agent, or any other processor/sub-processor), you must:
1. identify each recipient and the date of disclosure, and
2. confirm you have instructed each recipient to erase the data and to cease all processing, and
3. confirm compliance with UK GDPR Article 19 (notification of erasure/restriction to recipients).
Lawful basis and source of data
Within 14 days, provide your written position on:
1. the lawful basis ZZPS claims for processing my data in relation to this PCN (Article 6),
2. the source(s) of the data ZZPS received, including whether it was supplied by LDK Group Ltd and when, and
3. your retention policy applicable to this category of data.
Timescale and notice of intended claim
Given the circumstances and the clear dispute, continued processing or failure to comply with this notice will be treated as unlawful processing. If ZZPS does not confirm erasure (and downstream erasure) within 14 days, I will escalate the matter to the Information Commissioner’s Office and I will also consider issuing a county court claim for compensation under the Data Protection Act 2018 for distress arising from unlawful processing, without further notice.
All future contact must be in writing by email only, addressed to the points above.
Yours faithfully,
[Full name]
[Postal address]
[Email address]
[VRM]
[PCN reference]