Author Topic: Blue Badge parking - failed to authorize Blue Badge  (Read 1160 times)

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Blue Badge parking - failed to authorize Blue Badge
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Hi,
I have recently received two PCNs for parking at Edmonton Green shopping centre in Enfield. I was there with my son, who is disabled. I parked at disabled spot which looked like this: https://ibb.co/3mF1KsCw.
I have displayed the Blue Badge upon parking.
Few weeks later I received two PCNs which looked pretty much identical save for the date/duration of the infraction - please see here: https://ibb.co/rfRbVq1X.
Turned out there was another sign elsewhere in the parking lot specifying the conditions for the Blue Badge users, which can be seen here: https://ibb.co/zTmDpKM0
I should mention that my son's disability requires my full attention.
I have responded to both of them as follows:
I arrived at the Edmonton Green Shopping Centre parking lot with my disabled son and parked in the disabled bay displaying the Blue Badge. The bay was clearly signposted as per the attached picture. The signage did not mention any requirements regarding the Blue Badge parking. Posting additional requirements elsewhere in the parking area is not sensible as my son requires assistance and I do not go around the whole parking lot looking for further instructions. Not to mention the fact that the requirement of registering the Blue Badge with some office is onerous and discriminatory to the disabled people, who often have difficulty moving around. 

As per wording on your signage: All Disabled Blue Badge Holders must clearly display their badge to prevent being issued with a PCN. We had done so, therefore I request the PCN be cancelled.


I have promptly received two identical responses last week, please see here: https://ibb.co/Pf1z5V7
The company in question is G24 Ltd.

What should be my next steps? Appealing to IAS? I find this "authorization of the Blue Badge" process quite repulsive. I would have no problem with paying the parking charge had I not been misled by the signage.
Thank you in advance for any help on this.

Chris

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Re: Blue Badge parking - failed to authorize Blue Badge
« Reply #1 on: »
Don’t worry. You won’t be paying a penny to these scammers if you follow our advice. Please show the full Notice to Keeper (NtK) and the back, redacting only your personal details, the PCN number and your VRM. Leave all dates and times visible.

It’s too late to rely on PoFA failures as you have inadvertently admitted to being the driver. However, the signs you showed are in breach of the BPA/IPC Private Parking Single Code of Practice (PPSCoP) section 4.1 which states:

”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, in order for drivers with a disability to be able to make an informed decision on whether to park at the premises.”

The Parking Charge Notices (PCNs) were not issued for not displaying a blue badge but for not paying the tariff for parking. The terms signs require blue badge holders to register their vehicle at a terminal for three hours free parking.

However, you were not aware of this condition of parking because the operator did not display the terms and conditions in a position that they could be read without needing to leave the vehicle. What condition that was visible, you complied with.

Any claim would not stand up in court, which is the most likely whay his will be defeated. G24 are a vexatious firm of ex-clampers. We will assist you in defeating this but you will have to follow the advice we give.

Are you prepared to fight this all the way if necessary?
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Re: Blue Badge parking - failed to authorize Blue Badge
« Reply #2 on: »
Dear b789, thank you kindly for your response and offer to help. Yes, I am prepared to fight it all the way. Please see full Notices to Keeper here:
First notice: https://ibb.co/Nqcjm1r and https://ibb.co/Jjz7m43V
Second notice: https://ibb.co/WNbjBhjq and https://ibb.co/CpdpKrGh.
Please let me know if you need anything else. Thank you, Chris.

Re: Blue Badge parking - failed to authorize Blue Badge
« Reply #3 on: »
Maybe you didn't reveal the drivers identity if they are requesting it in their response to your appeal. If so, send the following as a formal complaint, separately for each PCN, to G24:

Quote
Subject: Formal Complaint Regarding Unlawful Parking Charge & KADOE Breach

G24 Ltd
Complaints Department
PO BOX 3320
Gerrards Cross
SL9 8WT.

By email to: info@g24.co.uk

Dear G24 Ltd,

Re: Parking Charge Notice [PCN Reference]

I write in response to your recent correspondence requesting the driver’s details and to escalate this as a formal complaint regarding your unlawful issuance of a Parking Charge Notice (PCN) and your potential breach of the DVLA’s Keeper at Date of Event (KADOE) contract.

1. No Contract Was Formed – The Driver Fully Complied with the Only Visible Terms

Your signage at the disabled bays clearly states:

"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 driver complied fully with these terms by displaying the Blue Badge. No other terms were visible, and no requirement to register the badge or pay a tariff was mentioned on the only sign at the disabled bays.

Any additional terms—if they exist—were not visible from within the vehicle and were not in the immediate vicinity of the disabled bays. The driver could not have agreed to any hidden terms, making this charge unenforceable.

2. Breach of the Private Parking Single Code of Practice (PPSCoP)

Your failure to provide visible terms near the disabled bays directly contravenes Section 4.1 of the PPSCoP, which states:

"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, in order for drivers with a disability to be able to make an informed decision on whether to park at the premises."

Since there was no such sign near the disabled bays, you have failed to comply with the PPSCoP, meaning no enforceable contract was formed. This also raises concerns about discriminatory practices against disabled motorists.

3. No Keeper Liability – Your Notice to Keeper Fails PoFA 2012

Your Notice to Keeper (NtK) was issued too late to comply with the 14-day limit for delivery as required under Schedule 4, Paragraph 9(5) of PoFA 2012, meaning you cannot transfer liability to the registered keeper.

Furthermore, your NtK contains the following unlawful and misleading statement:

"If we do not know both the name of the driver and a current address for service for the driver, we may assume you to be the driver and you may incur further charges."

This is not permitted under PoFA, and any attempt to infer keeper liability outside of PoFA is misrepresentation of legal position, which can be considered fraudulent misrepresentation under the Fraud Act 2006, Section 2.

Since you are not relying on PoFA, you cannot lawfully pursue the registered keeper. Any further demands directed at me as the keeper will be reported as harassment.

4. Misuse of Keeper Data & Breach of the DVLA’s KADOE Contract

Since your signage fails to form a contract, and you cannot establish liability under PoFA, you had no reasonable cause to obtain my Keeper data from the DVLA.

The DVLA’s KADOE contract strictly requires that Keeper data can only be accessed where:

• A parking charge is lawfully enforceable
• The operator fully complies with relevant legislation and the applicable Code of Practice

You have failed on both counts. As a result, I am formally reporting this case to the DVLA and demanding an investigation into your unlawful data access and potential suspension of your KADOE access.

I will also be escalating this to the Information Commissioner’s Office (ICO) for data protection breaches under UK GDPR.

5. Required Action from G24 – Formal Complaint

I now require the following within 14 days:

1. Immediate cancellation of the PCN due to lack of enforceability.
2. Written confirmation that my Keeper data has been erased and will not be processed further.
3. A full response to this formal complaint, including an explanation of why you obtained my Keeper data without a lawful basis.

Failure to respond adequately will result in further action, including complaints to:

• The DVLA – for a full KADOE contract breach investigation
• The ICO – for UK GDPR violations
• My MP – regarding the misuse of DVLA data by private parking firms

6. Data Protection Warning – Cease & Desist Further Processing of My Data

Under UK GDPR, you are unlawfully processing my personal data. You had no legal basis to obtain or retain my information. If you fail to cancel this charge, I will escalate this as a data protection breach to the ICO, and you may face enforcement action.

I expect a substantive response within 14 days. If you fail to cancel the charge, I will escalate this further.

This is your final warning. If I receive any further demands, I will take all necessary legal action to hold you accountable.

Yours faithfully,

[Your Name]
Registered Keeper of Vehicle [Registration Number]

You can also submit a complaint to the DVLA at the same time.
« Last Edit: March 08, 2025, 07:34:19 pm by b789 »
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Re: Blue Badge parking - failed to authorize Blue Badge
« Reply #4 on: »
Thank you. I have emailed the letters and will send copies by email tomorrow. I will let you know what happens next. Kind Regards, Chris

Re: Blue Badge parking - failed to authorize Blue Badge
« Reply #5 on: »
Make sure you do the DVLA complaint too. That is probably the one they most fear. If there are enough regular complaints about their KADOE breaches, the DVLA will be forced to act and they risk having their access to DVLA data suspended or completely withdrawn.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Re: Blue Badge parking - failed to authorize Blue Badge
« Reply #6 on: »
Hello again,
I have received the responses from G24. Unsurprisingly, they have stuck to their guns. Standard reply, not addressing issues raised in my complaint. Responses to both PCNs are identical, please see here:
https://ibb.co/HTH89xv1
https://ibb.co/HLR5v17R
https://ibb.co/gbfcGPtH

What should be my next step?

Thank you, Chris

Re: Blue Badge parking - failed to authorize Blue Badge
« Reply #7 on: »
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:

Quote
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 STATEMENT

Complaint 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 Accessibility

G24 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 Motorists

The 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 Complaint

G24 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) Breach

G24’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]
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Re: Blue Badge parking - failed to authorize Blue Badge
« Reply #8 on: »
Thank you, I really appreciate your help with this problem.
I will submit the complaint to IPC as well as DVLA.
I am actually not a Keeper of the vehicle, my wife is. I was the driver in both instances though. I am not sure if that makes any difference at this point?
Kind Regards,
Chris

Re: Blue Badge parking - failed to authorize Blue Badge
« Reply #9 on: »
Yes, potentially. In your opening post you said that you had received PCNs. Was it actually your wife who received them?

Re: Blue Badge parking - failed to authorize Blue Badge
« Reply #10 on: »
Yes, it was my wife who received them, and I was a driver in both instances, as I mostly drive my son around. However, I am not exactly sure what I stated in the original response (https://www.appealyourcharge.co.uk/Home/MakeAnAppeal) as I haven't taken a screenshot of it.

Re: Blue Badge parking - failed to authorize Blue Badge
« Reply #11 on: »
In which case everything must be done in your wife's name as the NtK was addressed to her. She can transfer liability away from herself by simply telling the operator your name and address as the driver.

However, if the drivers identity has not been revealed, your wife has the added benefit of being to appeal only as the Keeper and simply refer to the driver in the third person. So, any correspondence suggested should be from your wife and referring to you only as the driver. She is not under any legal obligation whatsoever to identify you.

So, please clarify what has been said so far in this matter. Has your name, as the driver, been mentioned or not? When you initially appealed, was it appealed in your name or your wife's name?

Either way, if this were to ever get as far as a court hearing, either you as the driver or your wife as the Keeper have a very god defence. If this is not cancelled and they issue a claim, that is excellent news for you. The county court is the ultimate dispute resolution service. There is absolutely no danger of a CCJ or anything else by following this route.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Re: Blue Badge parking - failed to authorize Blue Badge
« Reply #12 on: »
I cannot access the appeal details and therefore I am not sure if I appealed in my wife's name or mine. However, their response was to my wife, which would imply I put her name in the online appeal form.

Re: Blue Badge parking - failed to authorize Blue Badge
« Reply #13 on: »
They would not have responded to anyone except the person named on the NtK. In which case, it may be worth adapting everything I have given you to send as from your wife, the Keeper, and to simply make all references to "the driver".
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Re: Blue Badge parking - failed to authorize Blue Badge
« Reply #14 on: »
I have sent the complaint to IPC by email but it bounced back. I had to use their portal for complaints (https://portal.theipc.info/cases/complaints), where the complaint cannot be copied and pasted, it needed to be typed in (twice in my case, for each PCN received). They do not make it easy, and I do not expect them to be objective. I have sent the complaint about G24 to DVLA and will send another one about the IPC if necessary.
Many thanks for your help, @b789, you have been absolutely amazing. I hope this will get resolved soon. Kind Regards, Chris