Free Traffic Legal Advice

Dear ParkingEye Privacy Team,

Further to my email of earlier today, I must make clear that your reply does not resolve my complaint, which concerns your decision to disclose the content of my appeal to the DVLA, not whether you were entitled to respond to their inquiry generally.

You have not explained:

• What lawful basis under Article 6 of UK GDPR you relied on to disclose narrative content from my appeal;
• Why that disclosure was necessary or proportionate for the DVLA’s oversight role under the KADOE agreement;
• How the DVLA’s request for general information (e.g., whether an appeal was made) justified quoting or paraphrasing statements that I made in confidence during an appeal process.

The DVLA is not a party to the dispute and has no adjudicative function. While they may audit process compliance under the KADOE agreement, that does not relieve you of your duties as data controller to comply with the principles of purpose limitation and data minimisation under Articles 5(1)(b) and (c) of the UK GDPR.

Unless you can provide a lawful basis and justification for disclosing that specific information, I will escalate it to the Information Commissioner’s Office (ICO).

Please treat this as a continuation of my formal complaint and provide a full response within 14 days.

Yours sincerely,

[***]

Subject: Supplementary to Existing Complaint – Failure to Respond to Appeal

Dear ParkingEye Privacy Team,

This is a supplementary item to my existing complaint concerning the misuse of my personal data and the unlawful disclosure of appeal content to the DVLA.

I now additionally note that more than 56 days have passed since I submitted my appeal on 19 February 2025, and ParkingEye has not provided a substantive response. The only correspondence received was a demand for the driver’s identity on 5 March, which ignored the actual content of the appeal and failed to address any of the grounds I raised.

This delay breaches:

• Clause 8.4 of the Private Parking Single Code of Practice (PPSCoP), which requires a written response to an appeal within 28 days;
• Clause 11.4 of the PPSCoP, which applies the same 28-day standard to complaints;
• And the eight-week maximum response time reflected in guidance issued by the Financial Ombudsman Service, Ombudsman Services, and general consumer redress frameworks, including the British Standard for complaints handling (BS ISO 10002). These standards collectively establish 28 days as the normal expectation for responding to appeals or complaints and 56 days (8 weeks) as the upper limit before the matter may be escalated.

This procedural failure will also be noted in any complaint escalated to the Information Commissioner’s Office and the British Parking Association.

Yours sincerely,

[Your Name]
[Date]