Free Traffic Legal Advice

Hello and many thanks in advance,

My situation is as follows:

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I recently visited the property I was renting last year to check for post and found the 7th 'Urgent Reminder' from Debt Recovery Plus dated 01/04/2025 informing me of a parking charge dated 27/12/2024.

I am the keeper of the car and unfortunately I had neglected to update the DVLA with my new address (now updated), and the landlord didn't inform me of any previous post and instead marked as return to sender and put in a post box. This presumably included the original Notice to Keeper.

The PCN is from Initial Parking Ltd (a BPA member), for not paying for parking at St Mary's Church car park in Betws y Coed car park. 
The driver didn't pay because the ticket machine was broken and there was no other means to pay. The driver has no evidence of this however. A thread relating to a PCN from the same car park earlier the same month is a useful reference, with PCN images: St Marys Church - 14/12/2024

From this I gather that the 'Notice to Keeper (NtK) is not fully compliant with ALL the requirements of PoFA to be able to hold the Keeper liable if the drivers identity is not revealed. There is no legal obligation on the Keeper to identify the driver to an unregulated private parking company.'

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I've read enough to know I should ignore the debt recovery letter but I'm unclear of the next steps.


I expect one worthwhile action is to complain to the legal department of the Church in Wales who are the charity that run St Mary's and are presumably the landowner.

As well as this should I request a Data Rectification Notice (DRN) to Initial Parking and then when the notice is received appeal to them within 28 days, arguing that the NtK is not PoFA-compliant and that no Keeper liability can arise? Advised here.

Or is this not appropriate and should I go straight for a formal complaint? As advised here.

As I understand the next step would be an appeal via POPLA but hopefully this can be avoided.

Could you please advice me on the best course of action?

Wonderful, thank you!

I'll use the template for the DRN you posted here, to which I'll add a specific request for a copy of the NtK and instruct them to the update of the record with the new address and erase the old address.

I'll post again when the NtK is received. 

You should respond to the DPO at Initial Parking and remind him/her/it that it is their responsibility as the data controller to get their lackey debt collector to update their recored, not yours. Email the DPO with the following:

Subject: Data Accuracy and Third-Party Rectification Obligations under UK GDPR

Dear [Initial Parking DPO's Name],

Following your confirmation that my personal data has now been updated in your records, I note with concern your suggestion that I should independently contact the debt recovery company to rectify the same data.

To be clear, it was Initial Parking Limited who disclosed my personal data to this third party. Under Article 19 of the UK GDPR, where personal data has been disclosed to recipients, the controller is obligated to communicate any rectification of personal data to each recipient, unless this proves impossible or involves disproportionate effort. No such justification has been provided.

It is therefore your legal responsibility—not mine—to ensure that your agent updates their records accordingly. Should you fail to do so, I will have no hesitation in escalating this matter to the Information Commissioner’s Office, citing your failure to comply with your obligations as a data controller under the UK GDPR.

I expect written confirmation that you have instructed your agent to update their records without delay.

Yours sincerely,

[Your Full Name]

Nothing to do for now. You can safely ignore all debt recovery letters, Debt collectors are powerless to do anything except to try and persuade the low-hanging fruit on the gullible tree to pay up out of ignorance and fear.

Come back when you receive a letter of Claim (LoC)