Free Traffic Legal Advice

Are you saying that you were not at the location for the duration they claim? If so, this is what is known as a "double dip" where the first exit and the second entry ANPR photos have been "orphaned".

However, there's also a possibility that the signs say that there's a minimum time before you can return. You will need to get some photos of the signs and show us.

A "double dip" is a failure by the operator to perform the necessary quality control checks on the ANPR images, which is a breach of the PPSCoP section 7.3(d) and therefore also means that the operator has breached their KADOE contract.

For now, show us some photos with the terms of parking on them. If it is a case of a "double dip", this sits best dealt with by a formal complaint rather than an appeal. Also, it warrants a DVLA complaint as the operator will have breached the KADOE contract and obtained your Keeper data unlawfully.

The sign is the basis of the contract, and you parked for less than the 3 hour maximum stated on the sign. The sign says nothing about not returning, so that is not a condition they can impose.

Have you already sent an appeal? In what capacity did you send it? Keeper, Driver or both?

Your "receipts" do not evidence anything that will assist you except to expose you as the driver. Those receipts do not evidence that the vehicle did not remain on the property.

You have been advised on what to say and that there has been no breach of contract by the driver. However, GroupNexus t/a CP Plus Ltd have breached the PPSCoP section 7.3(d) and therefore requested and obtained your DVLA data unlawfully, which merits a formal complaint about CP Plus to the DVLA.

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 CP Plus Ltd trading as Group Nexus, a BPA AOS operator with DVLA KADOE access. This operator unlawfully accessed my data on 30 April 2025 in breach of Section 7.3(d) of the Private Parking Single Code of Practice (PPSCoP) and therefore, the KADOE contract.

The breach occurred at the point they requested my data. The Operator failed to carry out a manual quality control check of ANPR images, as required by PPSCoP Clause 7.3(d).

Note 1 to Clause 7.3 highlights that this check is "particularly important for detecting 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.” This is precisely what occurred here. The Operator has failed to search for orphan images from two separate visits which would have confirmed that there was no single stay and therefore they had no reasonable cause to obtain my keeper data.

This was a misuse of my personal data at the point of acquisition, not merely in its processing after the fact. A full supporting statement is attached. Please confirm receipt and provide a complaint 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: CP Plus Ltd trading as Group Nexus
Date of PCN issue: 30 April 2025
Vehicle Registration: [INSERT VRM]

This is a formal complaint regarding an unlawful request for my keeper data made by CP Plus Ltd under the DVLA’s KADOE (Keeper At Date Of Event) contract. The operator did not have reasonable cause to obtain my personal data because the Parking Charge Notice (PCN) issued was based on fundamentally flawed ANPR evidence and a clear breach of Section 7.3 of the Private Parking Single Code of Practice (PPSCoP).

The nature of the breach

The PCN alleges that the vehicle remained on site at Ashford Retail Park from 09:19 to 12:37 on 30 April 2025, constituting a parking period of 3 hours 17 minutes. However, this is not supported by a complete ANPR event log. The images relied upon show only a first entry and second exit, with no corresponding data for a first exit or second entry. This is a known failure mode referred to in the PPSCoP as “double dipping.”

CP Plus Ltd breached Clause 7.3(d) of the Private Parking Single Code of Practice, which mandates that:

“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 to Clause 7.3 makes clear:

“The manual quality control check for remote ANPR and CCTV systems is particularly important for detecting 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...”

Had CP Plus conducted the required manual quality control check, they would have identified orphan images — i.e. unpaired ANPR timestamps not yet assigned to any valid event. This is precisely what the PPSCoP requires operators to review before issuing any PCN based on ANPR data.

By failing to carry out this check, CP Plus wrongly assumed a continuous stay where none could reasonably be inferred. No contravention was evidenced, and therefore no reasonable cause existed to request my keeper data. The breach occurred at the point of data access, not afterwards.

This conduct is in clear breach of the KADOE contract, which only permits access to DVLA data for the purpose of pursuing a charge issued in full compliance with the relevant Code of Practice.

Requested action

This is a serious breach of the DVLA’s data governance regime. As the Data Controller, the DVLA is responsible for ensuring that personal data is not accessed or used unlawfully by private parking operators.

I request that the DVLA:

• Confirm that a breach has occurred
• Investigate CP Plus Ltd’s data access request
• Take appropriate enforcement action, including suspension or termination of KADOE access if warranted

Please confirm receipt and provide a reference number for this complaint. I am willing to provide any further information if required.

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

You'll need to make that link to Google Drive public. At the moment it only lets you request access.

You have not confirmed whether this is a "double dip" case. You suggested, but have not confirmed that the driver possibly made two separate visits between 09:19 and 12:37 that day.

Please confirm if we are dealing with a "double dip" or simply a single visit with an overstay.

I can't find anywhere in this thread, what you (or whoever appealed) put in the initial appeal. Was it appealed as the Keeper, the driver or both?

The response you've received and your posts suggest that something was sent to GroupNexus as a representation, but without knowing exactly what was sent, it is very difficult for us to advise on the exact response you should be sending in response to this:

Dear Sir/Madam,

Thank you for your correspondence relating to your Parking Charge.

The representations stated in your correspondence have been noted and considered. Please forward to us the full name and address of the driver at the time this charge was incurred so that we can update our records accordingly.

We are placing this Charge on hold for 14 days from the date of this email to allow you to provide the details requested.

Yours faithfully,

CP Plus Ltd

All we can derive from that is that whoever made the representation, probably did so as the Keeper and now they are phishing for the drivers details, which should not be provided, under any circumstances.