Free Traffic Legal Advice

Your letter just about gives it away that you were the driver so that’s a wasted appeal point. For future reference, never reveal who was driving. As the Keeper, you simply refer to the driver in the third person. No “I did this or that”, only “the driver did this or that”.

In cases where the operator has not fully complied with all the requirements of PoFA, liability for the charge cannot be transferred from the unknown driver to the known keeper. There is no legal obligation for the known keeper to identify the unknown driver to an unregulated private parking company. The Keeper and the driver are two separate legal entities. The Keeper may be both but there is no legal requirement to identify the driver.

As the Keeper, blabbing that you were the driver, inadvertently or otherwise, throws away a perfectly good appeal and defence point.

Anyway, you are where you are and you still have some good appeal and defence points you can use, even if you have identified as the driver.

Have you managed to log into their appeals page as though to appeal or pay and seen the evidential photos they have? Does any evidential photo on the Notice to Keeper (NtK) show the vehicle with a Notice to Driver (NtD) attached to the windscreen?

Before we move on to what you need to do now you must get it into your head that what you have received is not and never was a “fine”. By referring to it as such in your correspondence you are alerting them to the fact that you are low-hanging fruit on the gullible tree, ripe for the picking.

What you have received is simply a speculative invoice from an unregulated private parking operator. I will give you £100 for every occurrence of the word “fine” you can show me in their correspondence.

So, reviewing your case, you parked and paid for a parking session using their P&D machine which does not print a receipt unless requested. You returned to your vehicle and departed within the period of parking you paid for.

You have since received a Parking Charge Notice (PCN) delivered as an NtK which claims that your vehicle had already received a PCN which had been affixed to your vehicle as a Notice to Driver (NtD). However, you are adamant that there was no NtD affixed to the vehicle when you returned and led the car park.

You now realise that you are being scammed by a rogue operator, SIP. Why? Because their operator either took some photos of a notice attached to your vehicle and then removed it or never attached one in the first place. Had you been able to try and appeal (without actually completing it) you should have been able to review any evidential photos they intend to rely on. However, their NtK does not provide any opportunity to appeal.

You also need to ask, why did their attendant believe that your vehicle needed targetting? I suggest that you made a keying error when inputting your VRM into the P&D machine. As you have no receipt to prove otherwise, you cannot refute that suggestion. However, there are ways that they can be made show their logs for a VRM that is almost but not identical to yours, which we will come to.

I hope you are beginning to realise that you are in a scam by a firm of ex-clampers with an intellectual malnourishment that we use against them. However, you must realise that this will be a protracted process but if you follow the advice we give, you wil not be paying a penny to SIP.

As SIP are IPC members, there will be no secondary appeals process that is worth attempting. The most likely outcome is going to be that they eventually issue a debt claim in the county court. This is where you win. If they issue a claim, it is in the hope that, as low-hanging fruit on the gullible tree, you will simply pay up out of ignorance and fear once litigation commences.

So, before I move on to what you need to do now, I need to know whether you are prepared to fight this all the way? It will be a protracted process but one which we are very familiar with and has a greater than 99% probability of being successful.

There is no risk of a CCJ, even if, in the less than 1% chance you are not successful. So no need to worry about anything except to do as we advise, within the deadlines we advise. In the meantime you get on with your life as normal and gain a valuable life lesson on your rights and how to protect against abuse of them by cowboy parking companies.

So, are you prepared to fight this unfair PCN?

OK. As you have not received any NtD and their NtK is flawed as it doesn't comply with the PPSCoP, you need to submit a formal complaint to SIP, which they are bound to also consider as an appeal.

Send the following as a PDF attachment in an email to info@sipcarparks.co.uk and also CC in yourself:

SIP Car Parks (1) Limited
Peter House
Oxford Street
Manchester
M1 5AN

By email to: info@sipcarparks.co.uk

[Date]

FORMAL COMPLAINT

PCN number: [PCN number from the NtK]

Dear Sirs,

This is a formal complaint from the Keeper of vehicle [VRM] and you are required to also treat it as an appeal as per the BPA/IPC Private Parking Code of Practice (PPSCoP) section 11.2.

False Claim That a Notice to Driver (NtD) Was Affixed

The Notice to Keeper (NtK) falsely claims that a Notice to Driver (NtD) was affixed to the vehicle at the time of the alleged contravention. This is patently false. The driver has confirmed that no such notice was found on the vehicle. Given the well-documented practices of unscrupulous operators like yours in this industry, I put it to you that your operative either failed to place an NtD at all or removed it after taking a staged photograph, thereby deliberately denying the driver the opportunity to appeal within the reduced charge period. If you maintain that an NtD was affixed, then I require timestamped, unedited photographs clearly showing the NtD attached to the vehicle, including wide-angle images that confirm both its presence and the vehicle’s surroundings. Failure to provide this evidence will confirm my position that your operative acted dishonestly, further highlighting your company's already dismal conduct.

Deliberate Misrepresentation of Appeal Rights – Unlawful Conduct

Your NtK states that the driver had 21 days to appeal. This is an outright falsehood and a blatant breach of the PPSCoP Section 8.4.1(a), which mandates a minimum of 28 days to appeal. By deliberately misrepresenting the appeal period, you have invalidated the entire PCN, rendering it null and void. More critically, this breach means you have also violated your Keeper At Date Of Event (KADOE) contract with the DVLA. My follow-up complaint to the DVLA will highlight your total disregard for both the DVLA’s requirements and the conditions under which you are permitted to access Keeper data. Your unlawful actions must be thoroughly investigated, and I will be requesting that the DVLA withdraw your access to Keeper data for gross non-compliance with your contractual obligations.

Unlawful Use of My Data – Breach of GDPR

As your processing of Keeper data was unlawful—due to your non-compliance with the PPSCoP and KADOE contract—you are in direct breach of the UK General Data Protection Regulation (GDPR). As you have obtained and used my personal data unlawfully, you are now liable for a claim for compensation under data protection law. I will be reporting this to the Information Commissioner’s Office (ICO). Furthermore, should you attempt to litigate any enforcement action against me based on this unlawful PCN, I will file a Part 21 counterclaim against you for a GDPR breach, seeking damages for your misuse of my personal data. If you want to be so foolish as to take this all the way to court knowing that your position is completely indefensible, then you do so at your own risk. You will not only lose but will be met with a counterclaim that will ensure you suffer financial consequences for your unlawful actions.

PCN Issued for "No Ticket Displayed" in a Ticketless Car Park

If your intellectually malnourished operative believed that no payment had been made against the VRM, then they should have stated exactly that on the PCN. However, your NtK shows that they didn't. Instead, proving their incompetence, they have simply written "No ticket displayed"—which is not a contravention of any terms and conditions. Your own signage explicitly states that no ticket or permit is required to be displayed when payment is made, yet your, so called operative, has issued a charge on that basis.

If the actual issue was that no payment was matched to the VRM, then that should have been clearly stated. The fact that it wasn’t means one of two things: either your operative was too mentally impaired to understand the basic requirements of their job, or this is yet another example of your company’s well known practice of issuing unlawful charges in the hope that the recipient won’t challenge it.

Furthermore, if there was a minor keying error when the driver entered their VRM, it was your responsibility to check your own payment logs before issuing the Notice to Keeper. But, as expected, SIPs incompetence shines through once again. Rather than performing even the most basic level of due diligence, you have instead ploughed ahead with a charge that is demonstrably invalid.

This blatant breach of the PPSCoP proves once again that SIP has failed to comply with the standards required. Section 6.3 of the PPSCoP states:

"6.3. Keying errors

Where the terms and conditions require the driver to supply their vehicle registration mark at an on-site machine, by telephone or online, the parking operator must have and follow a documented policy and procedure to avoid issuing or enforcing a parking charge in respect of accidental keying errors. This should include the adoption of technologies that reduce keying errors."

As the driver has evidence that payment was made, meaning your PCN is not only baseless but also a clear abuse of the DVLA data access you have been granted, I require you to provide suitably redacted copies of your payment logs for this car park for the period of parking, assuming you have a period of parking to refer to, another requirement for PoFA compliance.

No Keeper Liability as Notices are not PoFA Compliant

Without having been able to review the NtD for PoFA compliance, I am confident that it is not and most likely is in breach of paragraph 7(2)(a) and your copy of that NtD which you are now required to provide, will prove my point. As your NtK also does not fully comply with all the requirement of PoFA, you are unable to hold me, Keeper, liable and I will not be providing you, an unregulated private company, the drivers details as I am under no legal obligation to do so.

Failure to Comply with PPSCoP Regarding Payment Deadlines

The NtK states:

"If payment is not received within 28 days beginning with the day after the date of sending this notice, additional admin charges or overdue fees up to the value of £60..."

 This is yet another direct breach of the PPSCoP. Section 8.1.2(e) states that the 28-day period must begin from the date the notice is 'received', not from the day after it is sent. Your NtK is therefore invalid on this basis alone. I now require you to provide evidence of the date the NtK was actually entered into the postal system as required by the PPSCoP section 8.1.2(e) Note 2. The relevant point being:

"parking operators must retain a record of the date of posting of a notice, not simply of that notice having been generated (e.g. the date that any third-party Mail Consolidator actually put it in the postal system.)"

Required Action

To resolve this complaint, I require the following:

1. A copy of the Notice to Driver (NtD) that was allegedly affixed to the vehicle.
2. Full evidential photos of the vehicle showing the alleged contravention, including timestamped images proving the presence of an NtD and unedited metadata proving no tampering.
3. A full payment log, redacted only as necessary for data protection requirements, from the date and time in question that the vehicle was on site, including any transactions that closely match the VRM, to rule out a keying error.
4. An explanation as to why the appeal period was unlawfully restricted to 21 days, contrary to the PPSCoP.
5. An explanation as to why a PCN was issued for "No ticket displayed" when your own signage states there is no requirement to display a ticket.
6. An explanation as to why the NtK states that payment is required within 28 days of sending rather than receipt, in direct contradiction of the PPSCoP.
7. An explanation as to why no checks were made for possible minor keying errors before the NtK was sent.
8. Evidence of the actual date the NtK was entered into the postal system.
9. A clear explanation of who you are pursuing, the driver or the keeper and on what basis

This formal complaint is made in accordance with Section 11.2 of the PPSCoP, which requires operators to treat complaints as appeals if they relate to a parking charge. I expect a substantive response within 14 days.

Should you fail to address this complaint appropriately, I will be taking the following actions:

• Escalating a complaint to the DVLA, highlighting your disregard for the PPSCoP and KADOE contract.
• Reporting you to the ICO for unlawful processing of my personal data in breach of GDPR.
• Filing a Part 21 counterclaim for GDPR breaches if you attempt to pursue any enforcement action.
• Escalating a complaint to the IPC, although given their track record of siding with operators, I have no expectation of genuine scrutiny from them.

You are now on notice that I will not tolerate the misuse of my data for an unlawful charge. Consider this your formal warning.

Yours sincerely,

[Your Name]
Registered Keeper

A month later and just got this In the post

[ Guests cannot view attachments ]

Did they ever respond to the formal complaint? Make a complaint 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 SIP Parking Ltd, an IPC AOS member with DVLA KADOE access, for breaching the BPA/IPC Private Parking Single Code of Practice (PPSCoP) after obtaining my personal data.

While the Operator may have had reasonable cause at the time of their KADOE request, their subsequent misuse of my data—through conduct that contravenes the PPSCoP—renders that use unlawful. The PPSCoP forms an integral part of the DVLA’s governance framework for data access by private parking firms. Continued access is conditional on compliance.

The DVLA, as data controller, is obliged under UK GDPR and the Data Protection Act 2018 to investigate and take enforcement action when data is misused following release. This complaint is not about whether the data was obtained lawfully at the outset, but whether its subsequent use breached the terms under which it was provided.

I have prepared a supporting statement setting out the nature of the breach and the Operator’s actions, and I request a full investigation into this matter. I have attached the supporting document.

Please acknowledge receipt and confirm the reference number for this complaint.

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: SIP Parking Ltd
Date of PCN issue: 07/02/2025
Vehicle registration: [INSERT VRM]

I am submitting this complaint to report a misuse of my personal data by [INSERT PPC NAME], who obtained my keeper details from the DVLA under the KADOE (Keeper At Date Of Event) contract.

Although the parking company may have had reasonable cause to request my data initially, the way they have used that data afterwards amounts to unlawful processing. This is because they have acted in breach of the BPA/IPC Private Parking Single Code of Practice (PPSCoP), which is a mandatory requirement for access to DVLA keeper data. The PPSCoP forms part of the framework that regulates how parking companies must behave once they have received keeper data from the DVLA.

The KADOE contract makes clear that keeper data may only be used to pursue an unpaid parking charge in line with the Code of Practice. If a parking company fails to comply with the PPSCoP after receiving DVLA data, their use of that data becomes unlawful, as they are no longer using it for a permitted purpose.

In this case, SIP Parking Ltd has breached the PPSCoP in the following ways:

• Falsely claimed that a Notice to Driver (NtD) was affixed to the vehicle, when none was present
• Imposed a 21-day appeal window instead of the mandatory 28-day minimum (PPSCoP 8.4.1(a))
• Issued a PCN for “No ticket displayed” despite operating a ticketless system
• Failed to investigate potential keying errors or check payment logs before issuing the NtK (PPSCoP 6.3)
• Attempted to demand payment within 28 days from the date of posting, not the date of receipt, in breach of PPSCoP 8.1.2(e)
• Sent a “Payment Overdue” letter while ignoring a formal complaint submitted on 15 March 2025
• Failed to identify the correct Accredited Trade Association (ATA) in their NtK
• Misused the DVLA data to pursue an invalid and non-PoFA compliant charge without lawful basis

These are not minor or technical breaches. They show a clear disregard for the standards required under the current single Code. As a result, the operator is no longer entitled to use the keeper data they obtained from the DVLA, because the purpose for which it was provided (a fair and lawful pursuit of a charge under the Code) no longer applies.

The DVLA remains the Data Controller for the data it releases under KADOE, and is therefore responsible for ensuring that personal data is not misused by third parties. This includes taking action against AOS operators who breach the conditions under which the data was provided. I am therefore asking the DVLA to investigate this breach and to take appropriate action under the terms of the KADOE contract.

This may include:

• Confirming that a breach has occurred
• Taking enforcement action against the operator
•Suspending or terminating their KADOE access if warranted

I have attached relevant supporting material with this statement. Please confirm receipt and provide a reference for this complaint. I am also happy to provide further information if required.

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

I suggest you also raise a formal complaint about SIP with the IPC, for what's worth. However, keeping a paper trail is always worthwhile. Send this as an email to dpo@theipc.info and CC in yourself:

To: dpo@theipc.info

Subject: Urgent: Formal Complaint – SIP Parking Ltd (IPC AOS Member) and Failure of IPC Complaints Process

Dear Data Protection Officer,

I am writing to submit a formal complaint against your AOS member, SIP Parking Ltd, and to raise a serious concern regarding the IPC’s broken complaints infrastructure.

Both the complaints page (https://theipc.info/complaints) and the contact form (https://theipc.info/contact-us) return a 404 error, making it impossible for members of the public to submit complaints or make legitimate contact. This not only obstructs transparency and accountability, but also raises serious data protection concerns, given the IPC’s role in overseeing operators who obtain and use personal data via DVLA KADOE access.

Please treat the following as a formal complaint regarding SIP Parking Ltd:

Quote

Subject: Formal Complaint – SIP Parking Ltd (IPC AOS Member)

Dear IPC Compliance Team,

Re: Formal Complaint – SIP Parking Ltd (PCN Reference: [INSERT PCN NUMBER])

I am submitting a formal complaint regarding the conduct of SIP Parking Ltd, a member of your Approved Operator Scheme (AOS). The company has committed multiple serious breaches of the BPA/IPC Private Parking Single Code of Practice (PPSCoP) and continues to misuse personal data obtained via its DVLA KADOE access.

A detailed complaint was submitted to SIP on [Date], which they have failed to respond to. Instead, they have issued a further “Payment Overdue” letter dated 11th April, adding a £15 ‘overdue’ fee. This conduct is emblematic of a rogue operator, and I now expect the IPC to take appropriate enforcement action in line with its oversight responsibilities.

For the record, I have already submitted a formal complaint to the DVLA, as the operator’s conduct represents a clear misuse of data in breach of the KADOE contract. The DVLA remains the Data Controller for the personal data it supplies to AOS operators and is now investigating this matter.

SIP Parking Ltd has acted in flagrant violation of multiple sections of the PPSCoP, including but not limited to:

• Section 8.4.1(a): Restricting the appeal period to 21 days (not the required minimum of 28).
• Section 6.3: Failing to carry out basic checks for possible keying errors before pursuing the charge.
• Section 8.1.2(e): Demanding payment within 28 days from posting instead of from receipt of the NtK.
• Section 11.2: Ignoring a formal complaint/appeal submitted by the Keeper.
• PoFA Schedule 4: Issuing a non-compliant NtK and pursuing the Keeper despite lacking lawful basis to do so.
• Misleading Reason for Charge: Issuing a PCN for “No ticket displayed” in a ticketless car park.

In addition, SIP Parking’s Notice to Keeper fails to identify which Accredited Trade Association it belongs to—a further breach of best practice, especially as the Keeper is then directed to appeal within 21 days via the IAS, in breach of PPSCoP rules.

Given the severity of these breaches, I now expect the IPC to launch a formal investigation into SIP Parking Ltd and confirm the steps it will take to bring its member into compliance. I also request that this complaint be added to the operator’s compliance record.

Furthermore, I must emphasise that if the IPC continues to ignore clear and repeated misconduct by its members, it will further erode public confidence in your organisation’s ability to regulate the private parking sector. As the oversight body responsible for ensuring member compliance with the Code, the IPC cannot simply turn a blind eye to behaviour that is demonstrably unlawful and predatory.

Please acknowledge receipt of this complaint and confirm that it will be formally investigated. I am happy to provide supporting documents upon request.

Yours faithfully,

[YOUR FULL NAME]
Registered Keeper
[DATE: 16 April 2025]

Please note that I will be reporting the IPC’s failure to maintain an accessible complaints process to the Information Commissioner’s Office (ICO) as a matter of concern, and I will also be contacting my MP to raise questions about the accountability and transparency of your organisation as a so-called ‘accredited’ trade body.

I expect confirmation of receipt and an explanation of how this complaint will be processed.

Yours sincerely,

[YOUR NAME]
[Your address, if required]

Well, we already knew that the IPC is a corrupt and useless ATA and this boilerplate reply is entirely evasive and does not address your formal complaint at all. It also contradicts their own published materials, which claim that complaints about member conduct can be submitted—yet here, they:


This just reinforces the position that the IPC is failing to meet its obligations as a regulatory body, and their conduct now forms a separate ground for referral to both the:


However, I have just checked the IPC website and it is now possible to register and then log a complaint. However, they have cruelly disabled the ability to copy and paste your complaint into the text box and there is no option to upload a pdf of your complaint which means that it has to be typed out manually with no formatting.

Send the following email to your MP:

Subject: Urgent: Regulatory Failures in Private Parking Industry and Complaint Handling Obstruction by the IPC

Dear [MP’s Name],

I am writing to raise serious concerns about regulatory failures within the private parking industry, specifically regarding SIP Parking Ltd and the International Parking Community (IPC), one of the two Accredited Trade Associations approved by the DVLA to regulate private parking firms.

On 15th March 2025, I submitted a formal complaint to SIP Parking Ltd regarding a parking charge issued in clear breach of the Private Parking Single Code of Practice (PPSCoP). Their conduct includes:

• Falsely claiming that a Notice to Driver was affixed
• Misrepresenting the legal appeal period (offering only 21 days instead of the mandated 28)
• Issuing a charge for “No ticket displayed” in a ticketless car park
• Continuing to pursue payment despite evidence of a valid transaction

I then attempted to escalate my concerns to the IPC, as required. However, both the IPC's complaints page and contact form return a 404 error, making it impossible for the public to lodge a formal complaint. When I emailed their Data Protection Officer, I received a templated reply stating that emails would not be responded to, and I was again directed to the same broken web portal.

This is wholly unacceptable. The IPC appears to have no functioning complaints mechanism, which is deeply troubling given that it oversees companies handling sensitive DVLA-sourced personal data. I have now escalated the matter to both the DVLA and the Information Commissioner’s Office (ICO), but I am also asking for your support in raising this in Parliament.

The private parking sector remains largely unregulated in practice. The DVLA entrusts bodies like the IPC with access to vehicle keeper data, but there is no transparency or accountability when operators behave unlawfully.

While the IPC's complaints system has now been restored, it is functionally unusable for meaningful complaint submission. Complainants are required to register an account, but the text box provided disables copy-and-paste functionality, prevents any formatting, and does not allow uploads. In other words, a complainant must manually type their entire complaint from scratch, unformatted, with no supporting documents. This appears to be a deliberate tactic to frustrate and deter complaints, effectively insulating member firms from oversight.

I would be grateful if you could raise this matter with the relevant Minister or parliamentary committee, and support calls for:

• A formal review of the IPC’s status as an Accredited Trade Association;
• Stronger statutory oversight of private parking firms;
• A fully independent, statutory appeals and complaints body—free from industry influence.

Thank you for your time and support.

Yours sincerely,

[Your Full Name]
[Your Address]
[Your Email]
[Constituency]

The following should be sent to the ICO:

Subject: Complaint Regarding the International Parking Community (IPC) – Obstructed Access to Data Complaint Channels

Dear Information Commissioner,

I am submitting a formal complaint against the International Parking Community (IPC), a DVLA-accredited trade association for private parking operators, on the basis that they are obstructing the public’s ability to raise data protection concerns.

I recently submitted a formal complaint to one of their members, SIP Parking Ltd, for misusing my personal data after obtaining it through the DVLA's KADOE access. SIP Parking issued a non-compliant Notice to Keeper (NtK), misrepresented legal appeal rights, and pursued payment despite evidence of a valid transaction and a formal complaint.

When I attempted to escalate the matter to the IPC, I discovered that their entire complaints system is non-functional:

• Their official complaints portal (https://portal.theipc.info/login/complaints) returns a 404 error
• Their contact form (https://theipc.info/contact-us) also returns a 404 error
• When I emailed their Data Protection Officer at dpo@theipc.info, I received a blanket refusal to respond to any messages sent to that address, with a redirection back to the same broken web pages

While the IPC’s complaints system has recently been restored, it is clearly designed to frustrate rather than facilitate meaningful engagement. It requires full registration including, unnecessarily, date of birth, disables copy-and-paste into the complaint form, allows no formatting, and provides no option to upload supporting documents such as PDFs or images. This obstructive design makes it extremely difficult for individuals to submit coherent or well-evidenced complaints. I believe this is a deliberate attempt to prevent complaints from being submitted or properly reviewed, and that it falls short of data subject rights under UK GDPR, particularly transparency and accessibility.

This is a systemic failure in the IPC’s responsibilities as a regulatory body. The IPC is entrusted with overseeing organisations that handle and process DVLA-sourced personal data, yet they have no functioning mechanism for the public to raise complaints or data protection concerns. This is unacceptable and arguably in breach of UK GDPR Article 38(4), which requires that data subjects can “consult the data protection officer on all issues related to processing of their personal data.”

I am asking the ICO to investigate:

• Whether the IPC is in breach of its data protection obligations by failing to offer a working mechanism for complaint
• Whether their conduct is consistent with their role as a regulatory oversight body trusted with sensitive DVLA data access
• Whether any enforcement action is warranted

I am happy to provide evidence of the broken web pages, the complaint to SIP Parking Ltd, and the full correspondence with the IPC. Please let me know if further details are required.

Yours sincerely,

[Your Full Name]
[Your Email]

The response from DVLA seems promising:

Thank you for your email of 21st April to the DVLA. Just to let you know I will be investigating this matter with the parking company who requested your details, as soon as these investigations are completed I will respond to your complaint.