Respond to MET with the following:
Subject: Formal Response – PCN AB22730675 (Vehicle: [Reg])
Dear MET Parking Services,
I write further to your letter dated 25th March 2025, and feel compelled to respond, if only to express how profoundly ludicrous your position has become.
Your allegation — that the “vehicle was left in McDonald's car park while the occupants left McDonald's premises” — deserves to be addressed plainly. Are you seriously suggesting that any occupant of a vehicle, regardless of whether they were the driver, is bound to remain hostage on the site under threat of penalty if they dare to step beyond some unmarked, undefined boundary? Is this an exercise in parking enforcement, or Cold War border control?
Even setting aside the fact that you’ve provided no evidence whatsoever to support this allegation (no surveillance footage, no timestamped observation, no indication of who supposedly “left”), the notion itself is unworkable. You offer no definition of what constitutes the “McDonald’s premises.” Is it the restaurant’s interior? The doorway? A few feet beyond the car? The car park perimeter? Where precisely is this invisible tripwire — and more to the point, how is any vehicle occupant meant to be warned about it before crossing it?
Your signage — assuming it even mentions this alleged rule at all — is not addressed to “occupants,” nor is it placed in a manner that would notify passengers, children, or any person other than the driver. Yet you appear to be claiming that the moment anyone exits the premises, the driver somehow breaches a contractual term. This is not only absurd, it is legally unsustainable and blatantly unenforceable.
To compound this, your Notice to Hirer is not compliant with Schedule 4 of the Protection of Freedoms Act 2012 (PoFA). It lacks:
• The original Notice to Keeper;
• A copy of the hire agreement;
• A statement of liability from the hire company;
• And the mandatory wording under Paragraph 14(5).
Instead, you leap straight to the stupid conclusion that the hirer is “liable”, a position which has no foundation in law. Your subsequent fishing expedition for the driver’s details is noted, but irrelevant. The hirer has already stated they were not the driver, and they are under no obligation to assist you in filling the gaping evidential holes in your case.
In summary, this Parking Charge is legally and factually hopeless. You may now:
• Cancel it in full, or
• Provide a POPLA code, so your fiction can be dealt with accordingly after you waste your money on the fee.
You are reminded that you will also be required to provide evidence to prove you have complied with PoFA paragraph 14(2). You will also be required to evidence that you have also complied with PoFA paragraph 14(5), which I already know that you haven't.
If you insist on persisting with this farce, given your ongoing misrepresentations of liability and your attempt to enforce a term that would be laughed out of any courtroom, I will be making a formal DVLA complaint about your dismal failures which amount to a breach of the KADOE contract.
You are now on notice.
Yours sincerely,
[Your Name]
You should also make a formal DVLA complaint anyway (even if only warning it in the response). Here’s how to make a DVLA complaint:
• Go to:
https://contact.dvla.gov.uk/complaints• Select: “Making a complaint or compliment about the
Vehicles service you have received”
• Enter your personal details, contact details, and vehicle details
• Use the text box to summarise your complaint or insert a covering note
• You will then be able to upload a file (up to 19.5 MB) — this can be your full complaint or supporting evidence
That’s it.
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 MET Parking Services Ltd, a BPA 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 to obtain the Registered Keeper’s details from the DVLA, they subsequently misused that data by pursuing me, the Hirer, in a manner that breached the PPSCoP and the conditions of lawful data use. The PPSCoP forms a binding part of the DVLA’s governance framework for third-party access to vehicle data. Continued access is conditional on full adherence.
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: MET Parking Services Ltd
Date of of "event": 28th November 2024
Date of NtH issue: 27th February 2025
Vehicle registration: OV73EMF
I am submitting this complaint to report a misuse of my personal data by MET Parking Services Ltd (MET), 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.
I am submitting this complaint in my capacity as the Hirer of the above vehicle. The private parking company MET obtained details of the vehicle's Registered Keeper from the DVLA via the KADOE scheme and has used that information to issue a Notice to Hirer to me.
Although the Operator may claim to have had reasonable cause to access the Registered Keeper’s data, this is highly questionable given the absence of any factual basis for the alleged contravention. The claim that “vehicle occupants left the premises” is both unprovable and legally meaningless. Only the driver could ever be liable under contract law or the Protection of Freedoms Act 2012 (PoFA), and the Operator has neither identified the driver nor produced any evidence showing who allegedly left the site, when, or how this breached any visible term. The concept of pursuing a charge based on the movements of unnamed “occupants” — individuals who are not party to any alleged contract — does not amount to reasonable cause. No clear signage defines the premises’ boundary or warns occupants that crossing an invisible line would give rise to liability. In the absence of a genuine contravention or reasonable grounds to suspect one, the Operator’s request for vehicle data under the KADOE scheme was unjustified from the outset.
Furthermore, even if the initial request were valid (which is disputed), the Operator’s subsequent use of the data breached the BPA/IPC Private Parking Single Code of Practice (PPSCoP), which forms part of the mandatory governance framework for data access. As such, their processing of my personal data is unlawful.
The KADOE contract makes it clear that vehicle data may only be used for the fair and lawful pursuit of parking charges, in accordance with the Code. Where an operator breaches that Code, continued use of the data becomes unlawful.
In this case, [INSERT PPC NAME] has breached the Code in the following ways:
– Issued a Notice to Hirer without enclosing copies of the required documents under PoFA Schedule 4 Para 14
– Misrepresented the legal position by falsely asserting liability
– Failed to provide evidence of the alleged contravention
– Pursued a parking charge based on vague or unprovable allegations, such as “occupants leaving the premises”
– Ignored or bypassed the protections afforded to hirers under PoFA
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]
