Free Traffic Legal Advice

I am appealing your Parking Charge Notice (PCN) [Insert PCN Number] issued as a postal Notice to Keeper (NtK).

You have failed to perform the mandatory manual quality control checks required under Section 7.3 of the Private Parking Single Code of Practice (PPSCoP). Note 1 under that section makes it explicitly clear that such checks are vital for identifying situations such as “double dipping” and for correctly assigning orphan ANPR images to separate visits.

Had you fulfilled this requirement, it would have been obvious that the vehicle in question made two distinct, separate visits. Your failure to assign the orphan images correctly has resulted in a completely false allegation of overstaying.

Because of this operational failure, your request to the DVLA for the registered keeper’s data was made without reasonable cause, as required by your KADOE contract. The data was obtained unlawfully. You are therefore on notice that a complaint will be submitted to the DVLA and escalated as appropriate.

In the meantime, this appeal constitutes a formal notification that your data processing is also in breach of the UK GDPR. You had no lawful basis to obtain and continue processing the keeper’s personal data, and you are hereby instructed to delete all data relating to this PCN from your systems.

This Parking Charge Notice must be cancelled immediately. Please confirm cancellation and data erasure in writing.

I am submitting a formal complaint against Britannia Parking Group, a BPA AOS member with DVLA KADOE access, for unlawfully requesting and misusing my personal data in breach of both the KADOE contract and the Private Parking Single Code of Practice (PPSCoP).

This complaint concerns the unlawful initial request for my data. Britannia Parking failed to carry out the required manual quality control checks under Section 7.3 of the PPSCoP before applying to the DVLA for my keeper details. Had they complied with the Code, they would have identified that this was a “double dip” scenario involving orphan ANPR images that should have been assigned to separate visits. This failure meant they had no reasonable cause to request my data in the first place.

Their non-compliance with the PPSCoP invalidates their access to DVLA data and puts them in breach of their KADOE contract. I am attaching a supporting statement setting out the details and ask that the DVLA investigate this breach, together with their own responsibilities as the ultimate data controller and confirm the reference for this complaint.

SUPPORTING STATEMENT

Complaint to DVLA – Breach of KADOE Contract and PPSCoP

Operator name: Britannia Parking
Date of PCN issue: [INSERT DATE]
Vehicle registration: [INSERT VRM]

I am submitting this complaint to report that Britannia Parking unlawfully requested and processed my personal data in breach of the KADOE contract and the Private Parking Single Code of Practice (PPSCoP), which governs all DVLA data access by AOS operators.

This complaint is not limited to their post-access conduct. The initial request for my keeper data was unlawful because Britannia failed to conduct the mandatory manual quality control check of their ANPR records, as required under Section 7.3 of the PPSCoP. Note 1 under this section specifically highlights the importance of these checks for identifying scenarios such as “double dipping” — where a vehicle enters and exits a site more than once but the system fails to match images correctly. The PPSCoP requires operators to manually assign orphan images before taking enforcement action.

Had Britannia Parking carried out the required manual quality control check under Section 7.3 of the PPSCoP, they would have identified that this was a multi-visit event involving orphan ANPR images. In other words, they would have had no cause of action whatsoever and therefore no justification to request my keeper data from the DVLA.

By failing to conduct this required check, Britannia Parking submitted a KADOE request without reasonable cause, thereby unlawfully obtaining my personal data. This is a direct breach of the KADOE contract and an unlawful intrusion under the UK General Data Protection Regulation (UK GDPR).

The breach does not stop there. Britannia has continued to store, use, and process my unlawfully obtained data — including sending me a PCN and subsequent correspondence. Each act of data processing constitutes a further breach of the GDPR, compounding the original misuse.

The DVLA, as the Data Controller for the data it releases under KADOE, is not a passive party. It has a statutory obligation under UK GDPR and the Data Protection Act 2018 to take enforcement action against its contractors who misuse personal data. Furthermore, because the breach flows from the DVLA’s own release of data to a non-compliant operator, I expect the DVLA to self-report this incident to the Information Commissioner’s Office (ICO) as a controller involved in the chain of misuse.

I request a full investigation into Britannia Parking’s unlawful request and misuse of my data, and I expect the DVLA to take all appropriate action, including sanctions under the KADOE contract and regulatory reporting to the ICO.

Please confirm receipt and provide a reference for this complaint. I am happy to provide further evidence if required.

Name: [INSERT YOUR NAME]
Date: [INSERT DATE]