1. You were not the keeper on the material datesYou sold the vehicle on 14 September 2025 to a motor trader. Both alleged contraventions occurred after that date. Under Schedule 4 of the Protection of Freedoms Act 2012, only the keeper at the time of parking can be pursued. You were not the keeper, so you should deny liability on that basis.
2. Immediate actions before travelDo the following for each PCN.
A. To Secure Parking Solutions Ltd – keeper liability rebuttalSend by email. Attach a copy of your sale receipt or email, screenshots of your messages to the trader, and a copy or proof of your letter to DVLA dated 26 September.
Subject: PCN [reference] – Vehicle sold to motor trader on 14/09/2025 – keeper liability denied
I am the former registered keeper of [VRM]. The vehicle was sold to a motor trader on 14/09/2025 and left my possession that day. I was neither the driver nor the keeper on the date of your alleged incident.
Evidence attached: (i) proof of sale dated 14/09/2025, (ii) messages to the trader requesting DVLA update, (iii) my DVLA letter dated 26/09/2025 confirming disposal and requesting record update.
Under Schedule 4 PoFA, you cannot transfer liability to me as I was not the keeper at the time. Please cancel this PCN and erase my data under UK GDPR. If you refuse, confirm that you have placed the matter on hold for 28 days and are contacting DVLA for the in-trade keeper details.
I have no idea who the driver is. Any continued processing or sharing of my data after you are aware I was not the keeper will be unlawful.
Repeat for the second NtK.
B. To DVLA – confirm disposal to motor tradeYou already wrote on 26 September. Send a brief follow-up email or letter referencing that.
Vehicle [VRM], make and model, VIN if available.
I confirmed disposal to the motor trade on 14/09/2025. Please update the record to “in trade” with that date and confirm in writing. I enclose proof of sale and copies of parking NtKs issued to me in error. The trader took the entire V5C and has not responded. Please treat this as a data rectification and accuracy request under Article 16 UK GDPR.
Keep proof of posting or email delivery.
While you are abroad 16–31 OctoberIn your emails to the operator, mention you will be away until 1 November and ask that the case be held until then. If reminder letters arrive during that time, your earlier correspondence protects you. POPLA time limits start from the operator’s rejection, not from the NtK.
PoFA notesThe NtK appears to include most PoFA elements: creditor, issue date, location, and observation period. Your strongest argument is that you were not the keeper on the material dates, proven by your sale and DVLA notification.
If the operator refusesSend one follow-up reiterating the 14/09/2025 disposal and attach your evidence again. Request a POPLA code. In a POPLA appeal, lead with “not keeper at material time” and include evidence. Add secondary points like signage only if convenient.
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f you later find the trader’s addressProvide their name and postal address to the operator. They must then pursue that person and remove your data from their records.
