I presume that that is G24's response to the formal complaint letter you were advised to send. Did you make a formal complaint to the DVLA? If not, I will provide advice on how to do that. It takes minutes to do online.
As this is likely to escalate to a court claim, which is a good thing, I propose a few things...
As the core defence will be the fact that no contract was formed due to the deficient signage and their failure to comply with section 4.1 of the PPSCoP, as outlined in your formal complaint, it is not worth pursuing the no Keeper liability angle because it would become obvious that the Keeper was also the driver in this instance.
I suggest a formal complaint to the IPC. Not because I expect them to challenge G24 meaningfully or that you can expect a reversal of the PCN or any finding in your favour, but because it establishes a paper trail of reasonable conduct by you.
If G24 escalate this to a court claim, being able to show you pursued every formal complaint route, including their ATA, reinforces your reasonableness. It paints G24 as unresponsive and inflexible, especially when the IPC fail to engage with the PPSCoP breach or visible signage issue.
A weak, dismissive, or copy-paste response from the IPC (which is highly likely) can be used as evidence of:
• Lack of genuine oversight by the ATA
• Lack of meaningful redress in the system for disabled motorists
• Support for a Parliamentary or DVLA complaint about KADOE access oversight
The breach of Section 4.1 of the PPSCoP is specifically within IPC’s remit. Even if they brush it off, you’ve now anchored your complaint to their own Code, and their failure to uphold it supports a future claim of systemic failure.
So, I suggest the following as your formal complaint to the IPC by email to complaints@theipc.info and CC in yourself:
To: complaints@theipc.info
Subject: Formal Complaint – G24 Ltd – Failure to Comply with PPSCoP Section 4.1
Dear Sir/Madam,
I am submitting this formal complaint regarding G24 Ltd and their handling of Parking Charge Notice [insert PCN reference], issued in relation to Edmonton Green Shopping Centre, 62 Smythe Close, London, N9 0TZ.
The complaint concerns G24’s failure to comply with Section 4.1 of the Private Parking Single Code of Practice (PPSCoP). Specifically, the only signage visible from the disabled bay stated:
“Disabled bays are for disabled badge holders only. All Disabled Blue Badge Holders must clearly display their badge to prevent being issued with a PCN.”
The Blue Badge was correctly displayed at all times. No other terms were visible from the vehicle. Therefore, even if a contract could have been formed, the driver complied fully with all terms actually conveyed, meaning no breach occurred. If other terms existed elsewhere, they were not visible to the driver and cannot form part of any alleged agreement.
As I was with my disabled son who requires constant attention, it is not feasible to leave the vehicle to search for hidden signs elsewhere in the car park. Section 4.1 of the PPSCoP requires that at least one sign containing the terms and conditions must be viewable without the driver needing to leave the vehicle, particularly for disabled motorists.
G24’s signage setup failed to comply with this requirement, resulting in a charge issued despite full compliance with the only visible sign. This is both a breach of the Code and potentially discriminatory.
I raised these issues clearly in both the initial appeal and a formal complaint to G24. The operator failed to 'respond meaningfully' to the formal complaint and did not engage with the specific points raised. This is a further breach of PPSCoP Section 11.2, which requires operators to provide a transparent complaints procedure and to issue a 'meaningful response' to such complaints, particularly when they concern the handling of a Parking Charge Notice.
This complaint is submitted for the record and in case G24 escalate the matter to court or debt recovery. While I hold limited expectations regarding impartial redress, I nonetheless expect the IPC to demonstrate that it is capable of holding its members to account, as required under the Private Parking Single Code of Practice.
If the IPC is unwilling or unable to ensure that operators respond meaningfully to formal complaints or comply with mandatory signage requirements under Section 4.1 of the PPSCoP, I will be forced to draw adverse inferences about the efficacy and independence of the IPC's complaints process and may raise this with the DVLA and other relevant authorities.
Please acknowledge receipt and confirm that this complaint will be recorded.
Yours faithfully,
[Your Name]
[Your Address]
[Vehicle Registration Number]
[PCN Reference Number]
So, for now, get that off to the IPC. Below is the instruction on how to make the 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 submitting a formal complaint against G24 Ltd, an IPC AOS member with DVLA KADOE access, for breaching the BPA/IPC Private Parking Single Code of Practice (PPSCoP) after obtaining my personal data.
While G24 may have had reasonable cause at the time of their KADOE request, their subsequent misuse of my data—through conduct that contravenes the PPSCoP—renders that use unlawful. The PPSCoP forms an integral part of the DVLA’s governance framework for data access by private parking firms. Continued access is conditional on compliance.
Specifically, G24 issued a PCN based on alleged breach of parking terms that were not visible from the vehicle. They failed to provide signage in accordance with Section 4.1 of the PPSCoP, especially critical for disabled motorists, and ignored a formal complaint which raised this point. A Blue Badge was properly displayed and the only visible sign had been fully complied with.
The DVLA, as data controller, is obliged under UK GDPR and the Data Protection Act 2018 to investigate and take enforcement action when data is misused following release. This complaint is not about whether the data was obtained lawfully at the outset, but whether its subsequent use breached the terms under which it was provided.
I have attached a supporting statement outlining the breach and request that this matter be fully investigated. Please acknowledge receipt and confirm the reference number for this complaint.
Then you could upload the following as a PDF file for the formal complaint itself:
SUPPORTING STATEMENTComplaint to DVLA – Breach of KADOE Contract and BPA/IPC Private Parking Single Code of Practice (PPSCoP)
Operator name: G24 Ltd
Date of PCN issue: 7th February 2025
Vehicle registration: [INSERT VRM]
I am submitting this complaint to report a misuse of my personal data by G24 Ltd, who obtained my keeper details from the DVLA under the KADOE (Keeper At Date Of Event) contract.
Although G24 may have had reasonable cause to request my data initially, the way they have used that data amounts to unlawful processing. This is because they have acted in breach of the Private Parking Single Code of Practice (PPSCoP)—the mandatory framework which governs their access to DVLA data.
The breaches are as follows:
1. Failure to Comply with Section 4.1 of the PPSCoP – Signage AccessibilityG24 failed to provide a sign containing the full terms and conditions of parking that could be viewed from the vehicle. The only sign visible in the disabled bay stated:
“Disabled bays are for disabled badge holders only. All Disabled Blue Badge Holders must clearly display their badge to prevent being issued with a PCN.”
This sign was complied with in full. No other terms (e.g. payment requirements or Blue Badge registration) were visible or available from the vehicle. This directly contravenes PPSCoP Section 4.1, which requires that:
“The parking operator must ensure that at least one sign containing the terms and conditions for parking can be viewed without the driver needing to leave the vehicle...”
2. Discriminatory and Unlawful Conduct Toward Disabled MotoristsThe driver was accompanied by a disabled child who required constant supervision. Expecting a parent in such a situation to leave the vehicle to hunt for signage is both unreasonable and discriminatory. G24 failed to make reasonable adjustments, breaching the spirit of the Equality Act 2010 and the accessibility obligations embedded within the PPSCoP.
3. Failure to Respond Meaningfully to a Formal ComplaintG24 failed to engage with the substance of a formal written complaint. The response was generic and ignored the specific allegations, including the signage breach and the display of a valid Blue Badge. This contravenes PPSCoP Section 11.2, which requires operators to provide a transparent complaints procedure and a meaningful response to complaints relating to PCNs.
4. Misleading Appeals Information – PPSCoP Section 8.1.2(e) BreachG24’s Notice to Keeper informs the Keeper that any appeal “must be made within 28 days of the date of issue” of the NtK. This directly contradicts Section 8.1.2(e) of the PPSCoP, which states:
“The parking operator must ensure that a notice informs the recipient: that if the recipient appeals within 28 days of receiving the parking charge, the right to pay at the rate applicable...”
By unlawfully shortening the Keeper’s appeal window, G24 has misrepresented the appeals process and placed an unfair restriction on the Keeper’s rights. This breach is not merely technical — it may cause a recipient to believe they are out of time when, in fact, the 28-day period has not yet started.
These are not minor breaches. They show a disregard for the regulatory framework that governs the use of DVLA Keeper data. Once that data has been obtained, the KADOE contract allows it to be used only for pursuing charges in full compliance with the Code of Practice.
G24’s failure to follow the Code renders their continued use of my data unlawful. I therefore ask the DVLA, as data controller, to investigate this breach and consider whether enforcement action — including suspension of KADOE access — is appropriate.
The DVLA is the data controller for keeper data released under KADOE and is therefore responsible for ensuring that such data is not misused by operators. I request that the DVLA:
1. Investigates this complaint in full
2. Confirms whether a breach has occurred
3. Considers appropriate enforcement action, including suspension or termination of KADOE access if necessary
As the DVLA complaints form only permits uploading a single file, I can provide further evidence upon request should it be required.
Name: [Insert your name]
Date: [Insert today’s date]