It seems to me entirely reasonable to submit a keeper request to DVLA for any vehicle left on my land. The process seems to allow this as reasonable cause. I can fill in a form and do this. The content, however, of invoices sent to keepers for events on non relevant land is a problem.
It would perhaps be a bit odd if the terms of the Kadoe contract prohibited this.
Of course you have a right to request keeper details from the DVLA, as long as you have a valid contract with them and reasonable cause to do this
AND your land is
not under statutory control. No one is disputing this.
Using the subject data, reasonable cause or not, is the issue when the land is under statutory control. Having provided the subject data to the "customer", what can they then do apart from invite the subject to name the driver or pay the invoice themselves even though there is no requirement to do so.
If the operator has reasonable cause to believe that the
driver of a vehicle parked on land (under statutory control) that they manage has entered into a contract with them and is now, allegedly, in breach of that contract, then they should apply an NtD to the vehicle. Only the
driver is liable for the alleged breach of contract. The
keeper has nothing to do with it... unless they were also the
driver but the operator does not know that and cannot just
assume or
infer that the
keeper was also the
driver. As there is no obligation for the
keeper to either admit to being the
driver or to provide the operator with a
drivers details, under GDPR, what right does the DVLA have to release the
keepers data to a private company?
