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Just for the record as my original post did not show.. The DVLA request was 08/05/2024 and date of event was 06/12/2023

I do change these dates in the drafted letters.

Regards

Basil_Brush

Hi all,

Latest response from DVLA

No response from MP

Complaints Team (D11)
Driver and Vehicle Licensing Agency
Longview Road
Morriston
Swansea
SA6 7JL
Website: www.gov.uk/dvla
Our Ref:
Date: 4 June 2025
Dear Mr
Thank you for your email of 30th April 2025 regarding the release of information from the
Driver and Vehicle Licensing Agency’s (DVLA) vehicle register to Euro Parking Collection
PLC (EPC). This is being answered as a step 2 complaint.
I can only reiterate the advice previously provided in the DVLA letter dated 29th April 2025,
that Regulation 27(1)(e) of the Road Vehicles (Registration and Licensing) Regulations
2002 allows vehicle keeper details to be disclosed to third parties who can demonstrate that
they have a reasonable cause to receive it.
The need to contact drivers who have chosen to use toll roads abroad and may not have
complied with the terms and conditions applying is considered a reasonable cause.
Information is provided to EPC to seek recovery of unpaid road or bridge toll charges on
behalf of non-UK Central and Local Government organisations within the EU. EPC’s
operations are based in the UK. EU authorities pass evidence of contraventions, and the
registration marks of the vehicles involved to EPC who pursue the charges on behalf of
those organisations using vehicle keeper data from the DVLA. No DVLA data is passed to
the EU authorities.
EPC is a customer of the DVLA’s Keeper at Date of Event (KADOE) service and subject to
strict contractual terms, with the DVLA being aware of the reasons for each request for
information. Each permitted purpose for requesting registered keeper data from the DVLA
has a unique enquiry code which is provided by the requestor as part of the secure
electronic links used when the data is requested. Companies are only able to request
registered keeper data for the purposes outlined within their KADOE contract with the
DVLA.
Recipients of DVLA data are audited regularly, to ensure that requests for data are justified
and that the information is used appropriately. A clear legal basis and appropriate
safeguards apply to the disclosure of vehicle keeper information for the purposes
described.
Additionally, the DVLA’s Privacy Policy advises vehicle keepers that their details may be
released in a number of lawful circumstances and there is a note to that effect on the
Vehicle Registration Certificate (V5C) (under the heading ‘Data Protection’). The note also
provides a link to the DVLA’s online privacy policy which highlights the information about
who DVLA shares vehicle keeper information with. For ease of reference, the Privacy Policy
can be found here: http://www.gov.uk/government/publications/dvla-privacy-policy
I do hope this explains the position on this matter. You also have the right to complain to
the ICO if you believe that the DVLA has not handled your data appropriately. Further
information on how to raise a complaint with the ICO may be found at the following link:
Make a complaint | ICO.
Yours sincerely
Mrs N Smith
DVLA Complaints Team
Find out about DVLA’s online services



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Hi all,

Here is the reply from DVLA

Email: DataProtection.Policy@dvla.gov.uk
Date: 29th April 2025
Dear xxxxx,
Thank you for your email regarding the release of information from the Driver and Vehicle
Licensing Agency’s (DVLA) vehicle register to Euro Parking Collections PLC (EPC).
I can assure you that the DVLA takes the protection and security of the information it
holds very seriously and has appropriate procedures in place to handle personal data in
line with the relevant data protection principles applying.
Regulation 27 of the Road Vehicles (Registration and Licensing) Regulations 2002 allows
vehicle keeper details to be disclosed to third parties who can demonstrate that they have
a reasonable cause to receive it. Where reasonable cause has been shown, we disclose
information on the condition that it will only be used for the purpose specified and that
the recipient will protect its confidentiality. Although reasonable cause is not defined in
legislation, the Government’s policy is clear. Requests should relate to the vehicle or its
use following incidents where there may be liability on the part of the driver.
Drivers choosing to use toll roads do so subject to the terms and conditions applying.
The need to contact individuals who may not have complied with these conditions is
considered a reasonable cause.
There is no direct agreement between the UK and foreign authorities to share information
for this purpose. EPC is a customer of the DVLA’s Keeper at Date of Event (KADOE)
service and is subject to strict contractual terms. The data provided cannot be used for
any other purpose and may not be shared outside of the UK. Recipients of information
from DVLA records are audited regularly to ensure that information is only requested and
used in accordance with the contract terms.
A clear legal basis and appropriate safeguards apply to the disclosure of vehicle keeper
information for the purposes described.
EPC are a member of the BPA Approved Operator Scheme but this membership only
relates to requests made for parking in the UK, requests for toll roads is a separate issue
and ATA membership is not required in these circumstances.
You have queried why the SAR response you received made no reference to the fact
that the incident had occurred outside of the UK. Information relating to the location of
the toll road is not required to be provided when EPC submit requests. This is not
something that would be recorded by the DVLA. However, as explained above recipients
of DVLA data are audited regularly to help ensure that requests for data are justified and
that the information is used appropriately.
You have made reference to the Cross Border Enforcement Directive. This provides for
the exchange of vehicle keeper information to aid the recovery of financial penalties for
eight road traffic offences committed by non-resident offenders: They are as follows:
• Speeding
• Drink driving
• Non-use of a seat belt
• Failing to stop at a red traffic light
• Use of a forbidden lane
• Driving under the influence of drugs
• Failing to wear a safety helmet
• Using a mobile phone or any other communication devise whilst driving
Therefore, this does not apply in these circumstances
I hope you will appreciate that EPC’s compliance with the UK General Data Protection
Regulation (UK GDPR) and management of its contracts with third parties is not
something the DVLA can comment on.
Similarly, the way in which a foreign authority operates its schemes is a matter for them.
If you feel that you have been subject to an unfair penalty, you may wish to raise the
matter with EPC to seek advice on how best an appeal may be pursued.
I do hope this explains the position on this matter.
Yours sincerely
Sent unsigned via email

Thank you for your prompt reply.

Will send it today.

Hi All,

I have not received the DSAR request from the DVLA and here is the reason they provided the information. Does not say it was a foreign road toll at all.

Would they have had access if they had and if so is there a data breach ?

Reg Number ******** 08/05/2024 06/12/2023 Euro Parking Collection PLC, Other, Unit 6 Shepperton House, 83-93 Shepperton Road, London To identify the registered keeper/driver of a vehicle which failed to pay the appropriate fee at a Toll road/bridge


Regards
Basil Brush

Hi All

Received the Letter of Claim from Moorside Legal for a unpaid road toll vignette in Hungary.

I ignored all other concocted invoices and binned them.

Their claim is concocted to fool the courts that it was a parking infringement on land opererated by their client EPC.

Should I reply or ignore the LoC and wait for the summons?

I attach herewith LoC.

Regards



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