Free Traffic Legal Advice

• Both pages of the notice
• All dates and times on the notice
• Exactly what you submitted as your appeal
• Their reply to your appeal (I've removed the document as you left your full name and home address showing)

I responded as per the advice saying that there ticket was not valid etc and i received the response attached.

Here’s how to make a 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:

Quote

I am submitting a formal complaint against [INSERT PPC NAME], an [INSERT IPC or BPA] AOS member with DVLA KADOE access, for breaching the BPA/IPC Private Parking Single Code of Practice (PPSCoP) after obtaining my personal data.

While the Operator 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.

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 prepared a supporting statement setting out the nature of the breach and the Operator’s actions, and I request a full investigation into this matter. I have attached the supporting document.

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:

Quote

SUPPORTING STATEMENT

Complaint to DVLA – Breach of KADOE Contract and PPSCoP

Operator name: [INSERT PPC NAME]
Date of PCN issue: [INSERT DATE]
Vehicle registration: [INSERT VRM]

I am submitting this complaint to report a misuse of my personal data by [INSERT PPC NAME], who obtained my keeper details from the DVLA under the KADOE (Keeper At Date Of Event) contract.

Although the parking company may have had reasonable cause to request my data initially, the way they have used that data afterwards amounts to unlawful processing. This is because they have acted in breach of the BPA/IPC Private Parking Single Code of Practice (PPSCoP), which is a mandatory requirement for access to DVLA keeper data. The PPSCoP forms part of the framework that regulates how parking companies must behave once they have received keeper data from the DVLA.

The KADOE contract makes clear that keeper data may only be used to pursue an unpaid parking charge in line with the Code of Practice. If a parking company fails to comply with the PPSCoP after receiving DVLA data, their use of that data becomes unlawful, as they are no longer using it for a permitted purpose.

In this case, [INSERT PPC NAME] has breached the PPSCoP in the following ways:

[INSERT A SHORT SUMMARY OF THE BREACH(ES), e.g. failure to follow grace periods, misleading notices, refusal to engage with a complaint, pursuing a charge despite having evidence of disability or mitigation, etc.]

These are not minor or technical breaches. They show a clear disregard for the standards required under the current single Code. As a result, the operator is no longer entitled to use the keeper data they obtained from the DVLA, because the purpose for which it was provided (a fair and lawful pursuit of a charge under the Code) no longer applies.

The DVLA remains the Data Controller for the data it releases under KADOE, and is therefore responsible for ensuring that personal data is not misused by third parties. This includes taking action against AOS operators who breach the conditions under which the data was provided. I am therefore asking the DVLA to investigate this breach and to take appropriate action under the terms of the KADOE contract.

This may include:

• Confirming that a breach has occurred
• Taking enforcement action against the operator
•Suspending or terminating their KADOE access if warranted

I have attached relevant supporting material with this statement. Please confirm receipt and provide a reference for this complaint. I am also happy to provide further information if required.

Operator name: Britannia Parking Group Limited
Date of PCN issue: 21/03/2025

Then you could upload the following as a PDF file for the formal complaint itself:

Quote

SUPPORTING STATEMENT

Complaint to DVLA – Breach of KADOE Contract and PPSCoP

Operator name: [INSERT PPC NAME]
Date of PCN issue: [INSERT DATE]
Vehicle registration: [INSERT VRM]

I am submitting this complaint to report a misuse of my personal data by Britannia Parking Group Limited, who obtained my keeper details from the DVLA under the KADOE (Keeper At Date Of Event) contract.

Although the parking company may have had reasonable cause to request my data initially, their subsequent use of that data is unlawful. Britannia Parking has acted in breach of the BPA/IPC Private Parking Single Code of Practice (PPSCoP), a mandatory requirement for DVLA data access.

The KADOE contract makes clear that keeper data may only be used to pursue unpaid parking charges in accordance with the Code of Practice. When a parking operator breaches the PPSCoP after receiving DVLA data, their continued use of the data becomes unlawful, as it is no longer being used for a permitted purpose.

In this case, Britannia Parking has breached the PPSCoP in the following ways:

• Issued a Notice to Keeper which they admit is non-compliant with the Protection of Freedoms Act 2012 (PoFA), thereby undermining any lawful basis to pursue the keeper.
• Attempted to mislead the keeper into believing they could be held liable under outdated "implied contract" arguments, which have been redundant since the introduction of PoFA and have been rejected repeatedly by the courts.
• Issued threats to improperly demand disclosure of insurance documentation in an attempt to identify the driver, an act of coercion entirely unsupported by law or the civil procedure rules.
• Persisted with correspondence employing idiotic excuses and legally baseless arguments, demonstrating either severe intellectual malnourishment or a total, unembellished ignorance of the governing legal framework.

Britannia Parking's actions are not minor or technical breaches. They show a clear, knowing disregard for the standards required under the current Code and their obligations as a data user.

As a result, they are no longer entitled to use the keeper data obtained from the DVLA, because the purpose for which it was provided — fair, lawful pursuit of a parking charge in accordance with the Code — no longer applies.

The DVLA, as the data controller, is responsible for ensuring that personal data released to third parties is not misused. I therefore request that the DVLA fully investigate this breach and take appropriate action under the KADOE contract.

This may include:

• Confirming that a breach has occurred
• Taking enforcement action against the operator
• Suspending or terminating their KADOE access if warranted

I have attached supporting material including Britannia Parking's own correspondence, which illustrates the extent of their misconduct. I am happy to provide any further information if required.

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