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What evidence do you have to show anything?

READ THIS FIRST - Private Parking Charges Forum guide

We need to see the original Notice to Hirer (NtH) that you received in your name, the copy of the original Notice to Keeper (NtK) sent to the lease company, exactly what you put in your appeal (not a summary) and we need to see the letter you received from ECP that you say is trying to "reinstate" the PCN against you.

At any point, has the drivers identity been given to ECP? Unless you, the Hirer have told them, they have no idea who the driver is.

Apologies for being slow to upload info. 

I don't have the original PCN letter (Notice to Hirer) to hand, though I will post when I locate it.  As you will see from the appeal letter, though, they failed to provide any of the other information they are required to give me (notice to hire company, statement from the hire company, copy hire agreements, statement of liability etc).  It was just a PCN letter. 

Attached are:

1. The letter of appeal against the PCN, using some fairly standard recommended language.  Sent January for a letter received in December. 
2. The rejection of appeal letter from ECP, with the cancellation language at the bottom of Page 1.  Note no POPLA code offered, and most of the questions I raised were not addressed. There is some wording here about POFA but it isn't relevant to the points raised in my letter and they couldn't invoke keeper liability
3. The recent letter stating there had been an administrative error. 

As I locate any other paperwork I will forward on.

No admission has been made concerning the driver.

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It would help to see the NtH but you can simply respond with a formal complaint sent to dpo@eurocarparks.com and CC info@eurocarparks.com and yourself:

Subject: Formal Complaint – Improper Handling of Appeal and Reversal of Cancelled PCN

Dear Sir/Madam,

Parking Charge Notice: [Insert PCN number]
Date of Issue: 04/11/2024
Location: Sainsbury’s – Sury Basin

This is a formal complaint regarding your mishandling of the above Parking Charge Notice and your abysmal standard of case management throughout.

Your letter dated 24/01/2025 clearly and unequivocally stated that the Parking Charge Notice “The Parking Charge Notice has been cancelled on this occasion...”, This representation was definitive. There was no ambiguity. It brought the matter to a close. I accepted that outcome on its face and rightly considered the issue resolved.

Despite this, you have now sent further correspondence dated 15/04/2025 demanding payment, asserting that the cancellation was an “administrative error”. This is wholly unacceptable and procedurally illegitimate. There is no provision in contract law, POFA 2012, or under the BPA/IPC Private Parking Single Code of Practice (PPSCoP) that permits a parking operator to reinstate a cancelled charge on a whim or due to internal incompetence.

Worse still, your original rejection letter failed to provide a POPLA code despite also stating that the appeal had been rejected. If you had truly intended to reject the appeal rather than cancel the charge, you were required to issue a POPLA code and allow the standard 28-day ADR window. You did not. That failure alone is a breach of the PPSCoP and strips you of any pretence that you followed proper procedure.

You cannot now reverse a decision you previously conveyed as final. You cannot retrospectively issue threats of debt collection on a charge you yourself cancelled. And you most certainly cannot continue to process personal data for enforcement purposes on a voided PCN.

You are now unlawfully processing the Hirer’s personal data.

Your letter dated 24/01/2025 confirmed that the Parking Charge Notice had been cancelled. That outcome removes any lawful basis for continued processing under Article 6(1) of the UK GDPR. Your subsequent letter dated 15/04/2025, demanding payment and threatening further action, makes clear that you are still actively processing the Hirer’s personal data for enforcement purposes.

This is now a breach of:

• Article 5(1)(b) – purpose limitation: data must not be processed in a manner incompatible with the purpose it was collected for; and
• Article 5(1)(c) – data minimisation: data must be adequate, relevant, and limited to what is necessary for the stated purpose.

There is now no outstanding debt and no lawful enforcement process in play. You must therefore immediately cease processing the Hirer's personal data, delete it where retention is no longer legally justified, and confirm this in writing.

If you do not do so, I will escalate this matter to the Information Commissioner’s Office and will supply all correspondence to support the complaint.

For the avoidance of doubt, a formal complaint has been submitted to the DVLA regarding Euro Car Parks' conduct in this matter. Your continued pursuit of a cancelled charge, your failure to issue a POPLA code, and your ongoing processing of the Hirer’s data all constitute clear breaches of the Private Parking Single Code of Practice (PPSCoP).

As you are fully aware, any breach of the PPSCoP is also a breach of your KADOE contract. Accordingly, I have requested that the DVLA investigate your conduct and consider applying formal sanctions, including the suspension or permanent removal of your access to DVLA data.

Your conduct has been wholly incompetent and procedurally indefensible. I require written confirmation within 7 days that the PCN remains cancelled and closed, and that no further action will be taken. Should you fail to provide that confirmation, I will escalate this matter to the British Parking Association and request an investigation into your non-compliance with the Private Parking Single Code of Practice.

Yours faithfully,

[Your Name]

You also submit a formal complaint to the DVLA about the conduct of ECP as they are in breach of their KADOE contract.

Here’s how to make a DVLA complaint:


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 Euro Car Parks Ltd, a BPA AOS operator with KADOE access.

This complaint does not relate to the original DVLA data request, but rather to subsequent breaches of the Private Parking Single Code of Practice (PPSCoP) — which forms a binding condition of the KADOE contract.

I have attached a supporting statement detailing the breaches and explaining why they amount to a breach of the KADOE terms.

Please confirm receipt and provide a 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 PPSCoP

Operator Name: Euro Car Parks Ltd
Date of PCN Issue: 04/11/2024
Vehicle Registration: [INSERT VRM]

I am submitting this complaint to report serious misconduct by Euro Car Parks Ltd, a BPA AOS member with active KADOE access. This complaint concerns their ongoing breach of the Private Parking Single Code of Practice (PPSCoP), which forms a mandatory condition of their KADOE contract.

To be clear, I do not dispute that Euro Car Parks may have had reasonable cause to obtain keeper data from the DVLA at the time of the original request. However, this complaint relates to their conduct after obtaining that data, which has since fallen demonstrably below the standards required of a KADOE user.

All operators with DVLA data access are contractually bound to comply with the PPSCoP throughout their enforcement processes. In this case, Euro Car Parks has breached that Code in the following ways:

• They issued a written response on 24/01/2025 explicitly stating that the Parking Charge Notice had been cancelled. This representation was clear, final, and unqualified.
• Despite that cancellation, they later issued a letter dated 15/04/2025, attempting to reinstate and pursue payment for the same cancelled charge, describing their earlier statement as an "administrative error".
• Their original response also rejected the appeal but failed to provide a POPLA code, denying access to independent ADR, in clear violation of the PPSCoP.
• Euro Car Parks is continuing enforcement activity using data received under Paragraphs 13 and 14 of the Protection of Freedoms Act 2012, derived from the original DVLA keeper data. That entire chain of processing has now become tainted by the operator’s non-compliance with the Code.

These are serious and material breaches of the PPSCoP. Because their ongoing use of personal data — whether from the Keeper or passed lawfully to them from the Keeper — arises from an enforcement process initiated with DVLA-supplied data, Euro Car Parks’ conduct now falls outside the permitted purpose defined under their KADOE contract.

The DVLA remains the Data Controller for data released under KADOE and is responsible for ensuring that operators uphold the standards to which they are contractually bound. The terms of the KADOE contract are clear: a breach of the Code is a breach of contract.

I therefore request that the DVLA investigate this matter in full and take appropriate enforcement action, which may include:

• Confirming that a breach has occurred
• Taking enforcement action against Euro Car Parks
• Suspending or terminating their KADOE access if warranted

I have retained all relevant correspondence and am happy to provide further information if required.

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

Have you posted the notice you received from them?

As regards 'Had a ECP ticket back end of last year.  They’ve contacted me as Keeper (the car is a lease vehicle).' there's no such thing.

If anything, they contacted you as 'Hirer'.

'Hirer' is not a synonym for 'keeper'. It's 'hirer' and hirers can be held liable just as keepers can.

Personally, I don't think their slip would be fatal considering that within the same letter they notified you:

That payment was still due and how to pay;
You had a right to appeal to POPLA;
In general, the action they would take if you did not.

Anyway, the POPLA option is out so they can either take legal action* or not.

The ball's in their court.....and will be for up to 6 years.

* Against the driver or the registered keeper(depending upon their situation) or you as hirer, if they're stupid enough given their failure to comply with PoFA.

My error.  You’re right, it was a notice to Hirer.  I was confusing myself.  But nonetheless, as I understand it they made multiple procedural failings that prevent them from establishing Hirer liability. 

But the key point is that, whatever the merits or otherwise of the hirer liability, they clearly cancelled the PCN in their January letter, and are now trying to reinstate it.  I thought that’s not right or fair, and will write to them now in the strong terms suggested by b789. 

I'm somewhere between the two on this. I don't think one can definitively say the charge was 'clearly' cancelled, as the only reference to it being cancelled is in a letter that also says that the appeal has been rejected, and that payment or a POPLA appeal are now due. Contractual disputes don't work as some sort of game where whoever makes an error first automatically loses. However, the parking company's error in this case has materially disadvantaged the OP, by at best creating much ambiguity, and at worst leading the appellant to believe the matter was closed, such that they declined to submit a POPLA appeal.

With that in mind I agree with b789's approach of going in hard on the complaints route.

If it were to get to court, I think additional arguments than just "they said it was cancelled" might be needed, but, more likely, it would be discontinued anyway, this being Euro Car Parks and DCB Legal after all...

A small point of clarification (that is important, as it will potentially need to be reflected in the suggested complaint wording) - there are repeated claims that no POPLA code was provided. The rejection letter that has been uploaded to this thread does appear to contain one:



If/when we get to escalated complaints, explicit reference to S69 of the CRA as described above would seem wise.

Thanks HC, and noted.  Let’s see what their next step is if any.  I am taking b789’s route of a preemptive complaint and complaint to DVLA, anyway.  But I take the point that the fact they sent me a letter cancelling their claim doesn’t mean it’s game over. 

I will post the original Notice to Hirer here when I lay my hands on it.  However, it does seem to me that they are short of a party to sue, if it comes to that. 

They don’t know who the driver is. 

They have contacted the RK, who’s given them details of the Hirer.  The RK is off the hook, so ECP would now hope to place liability with the Hirer.  But as I understand it, there are quite a few actions they need to take to establish the Hirer as liable, and they have not failed to do several within the prescribed timeframe - most notably they have not provided the documents required under POFA. 

So their hope now must be to establish who the driver was or try to con a Court that the driver must have been the Hirer.  There are several people who could have been the driver so it’s a high bar for them to clear. 

I had overlooked the point about POPLA verification codes - it seems to be placed carefully so it’s easily missed, as several of us did - and there is nothing else in the letter to reference it. I wouldn’t want to rely on POPLA though.