Show Posts
1
Private parking tickets / Advice on Parking Eye PCN
« on: November 04, 2025, 11:58:32 am »
I am new to this forum so hopefully, i have posted this in the right area, apologies if not!
Background – vehicle, site and alleged event
* Private car (hatchback).
* UK retail park car park managed by ParkingEye.
* Alleged parking contravention at the end of November 2024.
* Operator: ParkingEye.
* Debt recovery agent: DCBL.
ParkingEye’s ANPR stills show the car entering and leaving around 20 minutes apart on the date in question. No driver is identifiable.
Key fact: the car had been sold before the event
* I sold the vehicle a couple of months before the alleged contravention (early autumn 2024).
* I was neither the registered keeper in reality nor the driver on the date of the incident.
* Evidence I hold:
* Dated message thread (social media / messenger) showing advert, negotiation and agreement to buy.
* Contemporaneous messages confirming handover/payment.
* A signed statement from me confirming the date of sale and that I was not keeper/driver on the material date.
* Insurance documents showing that by late 2024 I was insured on a different vehicle, consistent with having disposed of the original car.
Some early letters of mine accidentally refer to the year **2014** instead of **2024** – that’s just a typo; the operator and I both now work on the correct 2024 date.
ParkingEye PCN, appeal and POPLA
* ParkingEye issued a PCN for the late-November 2024 event.
* I appealed to ParkingEye on the basis that I was not the keeper at the time of the event. The appeal was rejected.
* I then appealed to POPLA, which was also rejected.
* ParkingEye then instructed DCBL to recover the charge.
DCBL – debt recovery correspondence
From mid-2025, DCBL began writing and emailing to demand payment.
My side:
* I sent a formal response early August 2025, saying:
* The car had been sold in autumn 2024, well before the event.
* I was not the keeper or driver on the date in question.
* I wanted proof from DVLA of who DVLA showed as keeper at that date.
* I wanted copies of the evidence and treated the letter as a Subject Access Request (SAR).
* Their compliance team acknowledged the SAR.
Further emails from me (Aug–Oct 2025) repeated that:
* I was not keeper/driver.
* They had still not provided DVLA keeper-at-date proof.
* A portal link and a single ANPR image do not satisfy that point.
* Under UK GDPR I:
* Disputed the accuracy of the data being used to chase me;
* Requested rectification and restriction of processing;
* Objected to continued processing in the absence of DVLA proof;
* Asked them to put the account on hold and keep contact in writing only.
DCBL replies (summarised):
* They say they are only instructed for debt resolution and that the timeframe to transfer liability has expired.
* They state that ParkingEye obtained my details from DVLA as registered keeper, therefore I “remain liable” as the person named.
* They say they are not privy to DVLA’s underlying data and will not supply it.
* They insist they have a legitimate interest in pursuing the debt and will continue to do so until their client instructs otherwise.
* In their most recent email (early November 2025) they say:
* The evidence I’ve provided is “not sufficient” to show I notified DVLA promptly of the new keeper.
* “At the time of the contravention, you remained named as the Registered Keeper… your evidence will not be reviewed further by our client.”
* I “remain liable” and should pay to avoid “possible further action”.
DCBL’s SAR response to me is very thin: they list basically my name, address and email as received from ParkingEye and from my correspondence.
ParkingEye – SAR and GDPR correspondence
On 21 September 2025 I emailed ParkingEye’s privacy address with a “Formal Data and Evidence Request” relating to this PCN. I:
* Re-stated that the vehicle had been sold before the event and that I was not keeper/driver at the time.
* Asked for:
* DVLA confirmation of who was registered keeper on the date of the event;
* Copies of all ANPR photos;
* Calibration/service records for ANPR/payment devices;
* Copy of the full contract/terms on the site;
* A full SAR (all personal data they hold on me).
ParkingEye’s privacy team:
* Acknowledged my SAR and said they’d respond within the GDPR timeframe.
* In mid-October 2025, they issued their SAR response. Key points:
* DVLA provided my name and address in early December 2024 as registered keeper of the vehicle in relation to the late-November 2024 incident.
* They say they issued seven letters to that DVLA address before passing the case to DCBL.
* They confirm they shared my data with POPLA and DCBL.
* Their stated lawful bases for processing: Performance of a Contract and Legitimate Interests.
* They refuse to supply calibration records etc. on the basis those aren’t “personal data”.
I then exercised further rights under GDPR:
* Rectification & Erasure (Articles 16 & 17) – mid-October 2025
* Asked them to correct their records to show that I was not keeper/driver at the material time.
* Asked them to erase my data and have their agents (including DCBL and POPLA) do likewise.
* Argued that the DVLA data from early December 2024 was out of date versus the actual sale date, so ongoing processing had no lawful basis.
* ParkingEye responded that:
* The charge was issued correctly;
* They had reasonable cause to request DVLA details;
* They were “not in receipt of sufficient evidence” that I wasn’t keeper at the time;
* They refused rectification/erasure and pointed me to the ICO if I wished to complain.
* Restriction of processing (Article 18) – late October 2025
* I again denied keeper/driver status.
* Formally requested restriction of processing while they verify keeper status for the date of the event (ICO guidance says processing should be restricted while accuracy is checked).
* Asked for documentary DVLA “keeper at date of event” evidence (their KADOE records).
* Set out the evidence I hold (sale messages, statement, insurance, DVLA SAR).
* ParkingEye replied that:
* They are satisfied they have complied with GDPR;
* If I’m unhappy, I should seek legal advice / complain to BPA and ICO;
* They “consider the privacy matter closed”.
* I then sent a final follow-up summarising:
* Keeper-at-date issue (I was not keeper in reality).
* DVLA data provenance (requested enquiry reference, date/time, content).
* Incomplete SAR (no DVLA request/response logs, no internal notes or correspondence logs, no call records etc.).
* Accuracy and restriction, plus a request for a full list of third parties who’ve received my data and the lawful basis for each disclosure.
* Gave them one month to respond. So far they haven’t provided the DVLA log detail.
### DVLA – SAR outcome
Separately, I SAR’d DVLA asking when ParkingEye requested keeper data for this vehicle in relation to the incident and what they supplied.
DVLA’s reply shows:
* A KADOE enquiry from ParkingEye in early December 2024 referencing the late-November 2024 incident, under the usual “breach of terms and conditions (car park)” reason code.
From ParkingEye’s email and DVLA’s letter together, it appears DVLA still had me recorded as registered keeper when ParkingEye pulled the data, despite the actual sale having taken place a couple of months earlier.
Current position
* DCBL say I remain liable because DVLA listed me as keeper when ParkingEye queried the record. They say my sale evidence is “not sufficient” to show prompt DVLA notification and they will keep chasing until their client tells them to stop.
* ParkingEye maintain the charge was correctly issued and that they had reasonable cause to obtain and use my DVLA data. They have refused:
* Rectification of their records;
* Erasure of my data;
* Restriction of processing while DVLA accuracy is investigated.
* Both ParkingEye and DCBL have said, in effect, **“if you don’t like it, complain to ICO/BPA etc.”**
* I am preparing complaints to:
* The Information Commissioner’s Office (ICO) – for accuracy, refusal to rectify/restrict, and incomplete SARs;
* Possibly DVLA – for holding/releasing out-of-date keeper data;
* Possibly BPA/FCA – for DCBL’s conduct in continuing collection during a live accuracy dispute.
What I’d like forum views on
* How strong a county court defence this gives me if ParkingEye (via DCBL or directly) issues a claim.
* Whether my evidence of actual sale and non-keeper status is enough to defeat keeper liability under the Protection of Freedoms Act 2012, Schedule 4, given that DVLA’s record still had me down as keeper on the enquiry date.
* Any additional angles, case law or evidence that might strengthen my position before it progresses further.
Thanks for taking the time to read this.
Background – vehicle, site and alleged event
* Private car (hatchback).
* UK retail park car park managed by ParkingEye.
* Alleged parking contravention at the end of November 2024.
* Operator: ParkingEye.
* Debt recovery agent: DCBL.
ParkingEye’s ANPR stills show the car entering and leaving around 20 minutes apart on the date in question. No driver is identifiable.
Key fact: the car had been sold before the event
* I sold the vehicle a couple of months before the alleged contravention (early autumn 2024).
* I was neither the registered keeper in reality nor the driver on the date of the incident.
* Evidence I hold:
* Dated message thread (social media / messenger) showing advert, negotiation and agreement to buy.
* Contemporaneous messages confirming handover/payment.
* A signed statement from me confirming the date of sale and that I was not keeper/driver on the material date.
* Insurance documents showing that by late 2024 I was insured on a different vehicle, consistent with having disposed of the original car.
Some early letters of mine accidentally refer to the year **2014** instead of **2024** – that’s just a typo; the operator and I both now work on the correct 2024 date.
ParkingEye PCN, appeal and POPLA
* ParkingEye issued a PCN for the late-November 2024 event.
* I appealed to ParkingEye on the basis that I was not the keeper at the time of the event. The appeal was rejected.
* I then appealed to POPLA, which was also rejected.
* ParkingEye then instructed DCBL to recover the charge.
DCBL – debt recovery correspondence
From mid-2025, DCBL began writing and emailing to demand payment.
My side:
* I sent a formal response early August 2025, saying:
* The car had been sold in autumn 2024, well before the event.
* I was not the keeper or driver on the date in question.
* I wanted proof from DVLA of who DVLA showed as keeper at that date.
* I wanted copies of the evidence and treated the letter as a Subject Access Request (SAR).
* Their compliance team acknowledged the SAR.
Further emails from me (Aug–Oct 2025) repeated that:
* I was not keeper/driver.
* They had still not provided DVLA keeper-at-date proof.
* A portal link and a single ANPR image do not satisfy that point.
* Under UK GDPR I:
* Disputed the accuracy of the data being used to chase me;
* Requested rectification and restriction of processing;
* Objected to continued processing in the absence of DVLA proof;
* Asked them to put the account on hold and keep contact in writing only.
DCBL replies (summarised):
* They say they are only instructed for debt resolution and that the timeframe to transfer liability has expired.
* They state that ParkingEye obtained my details from DVLA as registered keeper, therefore I “remain liable” as the person named.
* They say they are not privy to DVLA’s underlying data and will not supply it.
* They insist they have a legitimate interest in pursuing the debt and will continue to do so until their client instructs otherwise.
* In their most recent email (early November 2025) they say:
* The evidence I’ve provided is “not sufficient” to show I notified DVLA promptly of the new keeper.
* “At the time of the contravention, you remained named as the Registered Keeper… your evidence will not be reviewed further by our client.”
* I “remain liable” and should pay to avoid “possible further action”.
DCBL’s SAR response to me is very thin: they list basically my name, address and email as received from ParkingEye and from my correspondence.
ParkingEye – SAR and GDPR correspondence
On 21 September 2025 I emailed ParkingEye’s privacy address with a “Formal Data and Evidence Request” relating to this PCN. I:
* Re-stated that the vehicle had been sold before the event and that I was not keeper/driver at the time.
* Asked for:
* DVLA confirmation of who was registered keeper on the date of the event;
* Copies of all ANPR photos;
* Calibration/service records for ANPR/payment devices;
* Copy of the full contract/terms on the site;
* A full SAR (all personal data they hold on me).
ParkingEye’s privacy team:
* Acknowledged my SAR and said they’d respond within the GDPR timeframe.
* In mid-October 2025, they issued their SAR response. Key points:
* DVLA provided my name and address in early December 2024 as registered keeper of the vehicle in relation to the late-November 2024 incident.
* They say they issued seven letters to that DVLA address before passing the case to DCBL.
* They confirm they shared my data with POPLA and DCBL.
* Their stated lawful bases for processing: Performance of a Contract and Legitimate Interests.
* They refuse to supply calibration records etc. on the basis those aren’t “personal data”.
I then exercised further rights under GDPR:
* Rectification & Erasure (Articles 16 & 17) – mid-October 2025
* Asked them to correct their records to show that I was not keeper/driver at the material time.
* Asked them to erase my data and have their agents (including DCBL and POPLA) do likewise.
* Argued that the DVLA data from early December 2024 was out of date versus the actual sale date, so ongoing processing had no lawful basis.
* ParkingEye responded that:
* The charge was issued correctly;
* They had reasonable cause to request DVLA details;
* They were “not in receipt of sufficient evidence” that I wasn’t keeper at the time;
* They refused rectification/erasure and pointed me to the ICO if I wished to complain.
* Restriction of processing (Article 18) – late October 2025
* I again denied keeper/driver status.
* Formally requested restriction of processing while they verify keeper status for the date of the event (ICO guidance says processing should be restricted while accuracy is checked).
* Asked for documentary DVLA “keeper at date of event” evidence (their KADOE records).
* Set out the evidence I hold (sale messages, statement, insurance, DVLA SAR).
* ParkingEye replied that:
* They are satisfied they have complied with GDPR;
* If I’m unhappy, I should seek legal advice / complain to BPA and ICO;
* They “consider the privacy matter closed”.
* I then sent a final follow-up summarising:
* Keeper-at-date issue (I was not keeper in reality).
* DVLA data provenance (requested enquiry reference, date/time, content).
* Incomplete SAR (no DVLA request/response logs, no internal notes or correspondence logs, no call records etc.).
* Accuracy and restriction, plus a request for a full list of third parties who’ve received my data and the lawful basis for each disclosure.
* Gave them one month to respond. So far they haven’t provided the DVLA log detail.
### DVLA – SAR outcome
Separately, I SAR’d DVLA asking when ParkingEye requested keeper data for this vehicle in relation to the incident and what they supplied.
DVLA’s reply shows:
* A KADOE enquiry from ParkingEye in early December 2024 referencing the late-November 2024 incident, under the usual “breach of terms and conditions (car park)” reason code.
From ParkingEye’s email and DVLA’s letter together, it appears DVLA still had me recorded as registered keeper when ParkingEye pulled the data, despite the actual sale having taken place a couple of months earlier.
Current position
* DCBL say I remain liable because DVLA listed me as keeper when ParkingEye queried the record. They say my sale evidence is “not sufficient” to show prompt DVLA notification and they will keep chasing until their client tells them to stop.
* ParkingEye maintain the charge was correctly issued and that they had reasonable cause to obtain and use my DVLA data. They have refused:
* Rectification of their records;
* Erasure of my data;
* Restriction of processing while DVLA accuracy is investigated.
* Both ParkingEye and DCBL have said, in effect, **“if you don’t like it, complain to ICO/BPA etc.”**
* I am preparing complaints to:
* The Information Commissioner’s Office (ICO) – for accuracy, refusal to rectify/restrict, and incomplete SARs;
* Possibly DVLA – for holding/releasing out-of-date keeper data;
* Possibly BPA/FCA – for DCBL’s conduct in continuing collection during a live accuracy dispute.
What I’d like forum views on
* How strong a county court defence this gives me if ParkingEye (via DCBL or directly) issues a claim.
* Whether my evidence of actual sale and non-keeper status is enough to defeat keeper liability under the Protection of Freedoms Act 2012, Schedule 4, given that DVLA’s record still had me down as keeper on the enquiry date.
* Any additional angles, case law or evidence that might strengthen my position before it progresses further.
Thanks for taking the time to read this.