Do not contact TRACE. They are not a party to any contract and cannot resolve disputes. Write back to Alliance, to their complaints email address, confirming this is both a formal complaint and a Data Subject Access Request (DSAR). State you will not provide photo ID by email; they can verify identity using data they already hold (their ref, your VRM, name, and address) and the enclosed copy of the TRACE letter. Under UK GDPR any ID request must be necessary and proportionate; here it is not.
Require them to place the case on hold, recall it from the debt collector, and respond within one calendar month for the DSAR and within a reasonable time for the complaint. Ask for specific evidence: a copy of the original NtK, proof of posting (e.g. batch manifest, mailroom logs, postage receipts), the exact address used, the DVLA KADOE lookup date, all outbound letters or emails since 22/04/2022, ANPR images and logs, payment machine audit where relevant, and a full account activity/history explaining why this was sent to a DRA now.
Reiterate that you are the registered keeper, you do not identify the driver, and if an NtK was not served within PoFA deadlines, there is no keeper liability. Instruct them to stop debt collection while the complaint and DSAR are live and to correspond in writing only.
If they refuse to hold the case, insist on intrusive ID, or fail to respond, escalate to the BPA and make a brief report to the ICO about disproportionate ID demands or failure to comply with a DSAR.
Template to send to Alliance (email and ideally post; keep proof of sending):
Subject: Formal Complaint and Data Subject Access Request – Ref 386323 (Date of charge: 22/04/2022)
Dear Sir/Madam,
FORMAL COMPLAINT
I received a letter from TRACE Debt Recovery referencing your client reference 386323 (date of charge 22 April 2022). I have never received a Notice to Keeper for this matter at any time.
Please treat this as a formal complaint. I require you to:
• Confirm whether you contend that a Notice to Keeper was issued in 2022 and, if so, to which full postal address and on what date(s).
• Explain why this account has been escalated to a debt collector when the NtK was not received and the matter is disputed.
• Place the case on hold and instruct your agent to cease contact while you investigate and respond.
For the avoidance of doubt, I am the registered keeper. I do not identify the driver. If an NtK was not served in full compliance with Schedule 4 of the Protection of Freedoms Act 2012 within the statutory deadlines, you cannot hold the keeper liable.
Data Subject Access Request (UK GDPR and Data Protection Act 2018)
Separately, I exercise my right of access. Please provide, within one calendar month:
1. A copy of the original NtK and all subsequent correspondence you say was sent in 2022 and thereafter.
2. Proof of posting for each letter (for example batch or postage manifest and mailroom logs) and the exact address used.
3. The DVLA KADOE enquiry date, the data returned by DVLA, and any subsequent address checks or updates including source, date, and result.
4. All photographs, ANPR logs showing entry and exit timestamps, back-office notes, call logs, payment or VRM audit records, and full system event history for reference 386323.
5. Your current privacy notice and the data retention policy that applied in April 2022.
Identity verification
You already hold sufficient identifiers to verify me: my name as registered keeper, vehicle registration [insert VRM], my postal address, and your reference 386323. I attach a redacted copy of the TRACE letter showing the same details. Under Article 12(6) UK GDPR, any request for additional ID must be necessary and proportionate. Emailing photo ID is neither necessary nor proportionate here and introduces avoidable security risk. Please proceed without it.
Conduct while complaint and DSAR are live
Please place the account on hold and recall the matter from debt collection pending your complaint reply and DSAR fulfilment. Confirm in writing that no adverse processing will occur and no further fees will be added while the dispute is outstanding.
If you decline to treat this as a complaint, demand excessive ID, fail to hold the case, or fail to respond to my DSAR within one calendar month, I will escalate to the BPA and the ICO.
Yours faithfully,
[Name]
Registered Keeper of [VRM]
[Postal address]
Attachment: redacted copy of TRACE letter showing ref 386323 and my address
