I would respond to the DVLA with the following...
Dear Mrs N Smith,
Thank you for your email dated 14th January 2026.
I have duly noted its contents.
Unfortunately, the response contained within, bears absolutely no relationship to the complaint which I have actually submitted.
In my step 2 complaint email, I clearly set out the three major points which needed urgently addressing with regard to the correct application of PoFA at the parking location in question - this was clearly the basis of my complaint and was also outlined at length at the step 1 complaint stage.
Your latest email clearly addresses none of those critical issues and as such my complaint continues to be completely unresolved.
More worryingly, your email seemingly 'skips over' my entire complaint in a single generalised sentence without engaging with any of my three key points - clearly, this is not a proper complaints handling process - instead it is an obvious attempt to deliberately avoid investigating the matter correctly - this should not be happening at a step 2 complaints handling process within a Government organisation.
You specify that PoFA came into force on 1st October 2012 and that it made a vehicle keeper liable for unpaid parking charges in situations where the driver was not known to the parking operator - having read PoFA, you must know that this is not true in every circumstance and that each event actually requires a certain amount of examination in order to establish if PoFA can be applied? - There are in fact many requirements to be met before a parking operator can hold the registered keeper liable using the PoFA legal mechanism - inexplicably, your response fails to mention ANY of these specific conditions or requirements.
In your email, instead of engaging with my questions, your statement simply implies that PoFA applies in all circumstances - at no point do you attempt to quantify your statement in order to make it either relevant to my complaint or relevant to the behaviour of the parking operator - you then simply move on to your next point and, in doing so, you immediately steer attention directly AWAY from the nature of the complaint - to be blunt, this is a massive palpable error on your part since it is legally accepted that PoFA does not apply at all car park locations and therefore your blanket statement on PoFA is completely misleading.
In essence, you have failed to ascertain whether PoFA is applicable to this particular car park location - despite my preamble and clearly stated questions, your responses never even addresses this critical question - without considering this point you cannot possibly start to weigh up the complaint in order to ascertain whether the parking operator has breached their code of conduct and therefore breached the KADOE agreement. Neither can you establish whether my personal data has been wrongly supplied, by the DVLA, to a third party unregulated parking operator under a totally false pretence.
This basically presents us with a situation where the obvious errors made in the step 1 complaint handling process have been wholly repeated in the step 2 complaint handling process - namely, that the nature of the complaint is never addressed and that the individual handling the complaint quickly moves the complaint onto issues which were never stated as being part of the complaint - again, a palpable error on the part of the DVLA complaints handling team. This now appears to be a systemic issue within the DVLA complaints handling team as this issue has now occurred at both step 1 and step 2 of the complaints procedure with the step 2 response simply being a re-hash of the wording from the step 1 response.
Given that the errors being made are so blindingly obvious, I would now like the step 2 complaints handling process to be repeated - properly - and this time it would be helpful if the person conducting the investigation would take the time to actually read my step 2 complaint email and address the facts of the case rather than spending their time trying to materially alter the nature of the complaint as to avoid dealing with the core issue - namely; was my data provided to a parking operator who is mis-stating PoFA and therefore wrongly acquiring my personal data before issuing me with a totally non-compliant Ntk which broke numerous rules and regulations which they agreed to be bound by?
Just to give you some idea, and by way of help, (and based on the actual complaint being made) this is how I would personally be responding to the step 2 complaint which I have submitted;
"I have now had time to examine the legal status of the car park location at Fullwell Cross Leisure Centre and I have subsequently established that the land is owned by the London Borough of Redbridge."
"The London Borough of Redbridge is a Council and therefore, legally, constitutes a traffic authority."
"As the car park is Council owned, it represents, in law, an off-street parking place provided by a traffic authority."
"The Council have approached Euro Car Parks to help them manage this location - this appears to be a perfectly legitimate arrangement."
"However, due to the car park being owned by a traffic authority, it is NOT a location where PoFA can be used to invoke keeper liability in the event of a privately issued Parking Charge Notice being issued to an unknown driver."
"In particular, Schedule 4 of PoFA (the ability of a parking operator to move liability from an unknown driver to a registered keeper) applies only to 'relevant land', and Paragraph 3(1)(b) expressly excludes 'a parking place which is provided or controlled by a traffic authority' from being 'relevant land' for the purposes of PoFA.
"It is therefore clear, that the car park at Fullwell Cross Leisure Centre is not 'relevant land' as it is land which is owned by a traffic authority and as such PoFA cannot possibly apply at this particular location."
"From DVLA records, I can see that Euro Car Parks have seemingly accessed registered keeper details for contraventions at Fullwell Cross Leisure Centre despite there being no keeper liability at that site."
"This raises serious issues surrounding 'reasonable cause' (to request keeper details) because there is no keeper liability since PoFA cannot be invoked at this particular location - therefore, there is no legitimate legal pathway for the parking operator to hold the registered keeper liable for any alleged contravention."
"I also note that the PCN issued via a 'Postal Notice to Keeper' (NtK to the complainant) contains a specific wording which states that Euro Car Parks can pursue the registered keeper for the alleged PCN debt using Section 4 of PoFA - such wording on an NtK is EXPRESSLY PROHIBBITED by the operators Code of Conduct in locations where PoFA does not apply."
"It is therefore clear that the parking operator is breaching their Code of Conduct by issuing notices which contain clearly misleading wording relating to both PoFA and keeper liability."
"Any breach of the Code of Conduct is also a breach of the DVLA KADOE Agreement (with the parking operator) since the KADOE Agreement requires the parking operator to expressly agree to comply with the Code of Conduct before accessing Registered Keeper data."
I'm sure you get the picture....
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They may re-examine the matter or they may reject it.
Your case has obviously caused them significant issues and that is why they are refusing to answer specific questions on the PoFA status at Fullwell Cross.
