Free Traffic Legal Advice

It would help if you showed us a proper phot of the Notice to Keeper (NtK). Only redact your personal details, the PCN number and the VRM of the vehicle. Leave everything else showing, especially ALL dates and times.

Classic case of a double-dip where the operator has not performed the necessary manual quality control checks of the ANPR images. They will have two "orphan images" which will show the first exit time and the second entry time.

Because of this failure to comply with the necessary checks, they have unlawfully obtained your DVLA data. If they'd done their job properly, they would have had no reasonable cause to request your data. As such, they have also breached your GDPR but requesting it and also by subsequently using it.

This warrants a DVLA complaint, as they are the data controller. I will tell you how to do that after the suggested appeal.

You appeal only as the Keeper with the following:

I am the registered keeper of the vehicle and am writing to formally appeal the Parking Charge Notice issued in relation to an alleged continuous stay at Purley Cross Retail Park on 19 June 2025. Your allegation is based on ANPR images that incorrectly suggest a single stay from 07:01 to 18:16. In fact, the vehicle made two separate visits that day — one in the early morning and another later in the afternoon.

Your Notice is based on ANPR images purporting to show a single continuous stay from 07:01 to 18:16, which is factually incorrect. The vehicle made two separate visits to the site — one in the early morning and another later that day. Your system failed to record the first exit and second entry, thereby conflating two distinct visits into one — a well-known ANPR failure known as “double dipping.”

Such errors are typically caused by your system's failure to reconcile "orphan images" — unpaired entries or exits — which should have been identified during the mandatory manual quality control check required by Section 7.3(d) of the Private Parking Single Code of Practice (Version 1.1, 17 February 2025). That section states:

“Photographic evidence must not be used by a parking operator as the basis for issuing a parking charge unless: images generated by ANPR or CCTV have been subject to a manual quality control check, including the accuracy of the timestamp and the risk of keying errors.”

And Note 1 explicitly refers to:

“...issues such as ‘double dipping’, where image camera systems might have failed to accurately record each instance when a vehicle enters and leaves controlled land...”

Your failure to detect this pattern, especially over an alleged stay of 8 hours and 15 minutes, demonstrates that no such check was carried out, and no due diligence was applied. You had no reasonable cause to request my personal data from the DVLA, and your continued processing of that data — despite clear evidence of a system error — constitutes a breach of Article 5(1)(a), (b), and (f) of the UK GDPR, which require data to be processed lawfully, fairly, and for a specified, legitimate purpose. I won't even start on the KADOE contract breach.

Irrespective of the outcome of this appeal, I am reporting Premier Park Ltd to the DVLA for unlawfully obtaining my keeper data. A further complaint to the Information Commissioner’s Office is being prepared, and I reserve the right to pursue damages under Article 82 UK GDPR for this data misuse.

This appeal is submitted solely by the registered keeper. No admission is made as to the identity of the driver, and no such information will be provided.

You are formally invited to cancel this PCN immediately. Should you choose not to, you must provide a full explanation of how your ANPR system complied with Section 7.3(d) of the PPSCoP, including evidence of the manual quality control check and reconciliation of orphan images.

Report them to the DVLA as without any reasonable cause to request your data, they have breached your GDPR and you can, if you want, sue them for compensation under the Data Protection Act. 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 Premier Park Ltd, an IPC AOS member with KADOE access, for unlawfully requesting my personal data from the DVLA. This was a breach of both the KADOE contract and the Private Parking Single Code of Practice (PPSCoP).

The operator failed to carry out the mandatory manual quality control check required under Section 7.3(d) of the PPSCoP. Had they done so, they would have identified orphan ANPR images and realised that no contravention had occurred. The PCN should never have been issued, and my data should never have been requested.

Because the operator failed to comply with the PPSCoP at the point of data request, they had no reasonable cause. The request was unlawful from the outset. This is not a case of misuse after the fact — the breach occurred the moment the DVLA released my data in response to an invalid, unlawful request.

As the data controller, the DVLA is directly responsible for this unlawful release. You must not release personal data to third parties who are in breach of the Code. I do not expect to be fobbed off with the usual “reasonable cause” excuse. There was none. The operator’s failure to comply with the PPSCoP Section 7.3(d) invalidates the request entirely.

The DVLA must now:

- Acknowledge that the release of my data was unlawful;
- Take enforcement action against Premier Park Ltd for breaching the KADOE contract;
- Report itself to the Information Commissioner’s Office for unlawfully releasing my personal data.

I have attached a supporting statement and request a full investigation. Please confirm receipt and provide a reference number.

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: Premier Park Ltd
Date of PCN Issue: [INSERT DATE]
Vehicle Registration: [INSERT VRM]

This is a formal complaint regarding the unlawful release of my personal data by the DVLA to Premier Park Ltd under the KADOE contract.

Premier Park Ltd requested my keeper data in connection with an alleged parking contravention at Purley Cross Retail Park. Their request was based on ANPR images that appeared to show a continuous stay. In fact, the vehicle made two separate visits. This is a known ANPR failure referred to as “double dipping,” caused by the system failing to capture either an entry or exit — resulting in orphan images.

Section 7.3(d) of the Private Parking Single Code of Practice (PPSCoP, Version 1.1, 17 February 2025) states:

“Photographic evidence must not be used by a parking operator as the basis for issuing a parking charge unless: images generated by ANPR or CCTV have been subject to a manual quality control check, including the accuracy of the timestamp and the risk of keying errors.”

Note 1 under this section explicitly refers to:

“...issues such as ‘double dipping’, where image camera systems might have failed to accurately record each instance when a vehicle enters and leaves controlled land...”

Premier Park Ltd failed to carry out this mandatory check. Had they done so, they would have identified the orphan images and realised that no contravention had occurred. There was therefore no reasonable cause to request my DVLA data and the PCN should never have been issued.

Because the operator failed to comply with the PPSCoP at the point of data request, they had no reasonable cause. The request was unlawful from the outset. This is not a matter of how the data was used after it was obtained — the breach occurred the moment the DVLA released it in response to a request that should never have been made.

The DVLA, as the data controller, is responsible for ensuring that personal data is only released where lawful grounds exist. In this case, the DVLA released my data to a company that was in breach of the Code at the time of the request. That makes the release itself unlawful.

The DVLA must now:

• Acknowledge that the release of my data was unlawful;
• Take enforcement action against Premier Park Ltd for breaching the KADOE contract;
• Report itself to the Information Commissioner’s Office for unlawfully releasing my personal data.

I will be submitting my own complaint to the ICO and expect this matter to be cross-referenced with the DVLA’s own self-report. This is a serious breach of data protection law. The DVLA cannot continue to release personal data to operators who fail to meet the basic standards required under the Code. I expect a full investigation and a formal response confirming the outcome. Please also confirm the reference number for this complaint.

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

Huge apologies for not coming back to the forum to update sooner.

I followed exactly as you advised (i.e. I made the appeal first then the complaint to DVLA maybe a week or so later).  Two days after submitting the complaint to DVLA the PCN appeal was successful. The only thing I didn’t do was to submit a complaint to the ICO.

Thank you very much for your professional and detailed response.