Author Topic: UK Parking Enforcement PCN Issued After Nearly 6 Months  (Read 5255 times)

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Re: UK Parking Enforcement PCN Issued After Nearly 6 Months
« Reply #15 on: »
Excellent — that email from UK Parking Enforcement is a gift. It’s an outright breach of UK GDPR Article 12(2) and Article 15(1) because they’ve refused to handle your Subject Access Request (SAR) and unlawfully “passed it to ZZPS”.

They are the data controller (the entity that obtained your details from the DVLA), so they cannot sidestep their legal obligations by deflecting to a processor. This is a textbook non-compliance case.

Here’s a formal follow-up you can send to UKPE’s Data Protection Officer — and later use as evidence for the ICO if they fail to comply.

Quote
Subject: Non-compliance with Subject Access Request – Breach of UK GDPR Articles 12 & 15

Dear Data Protection Officer,

On [date], I submitted a valid Subject Access Request under Article 15 UK GDPR and s.45 DPA 2018 regarding PCN [ref], VRM [reg].

Your response of [insert date of their email] stated:

We have passed this to ZZPS to action, as we do not hold data nor the information you are asking for.

That response is wholly inadequate and unlawful. UK Parking Enforcement Ltd is the data controller, having obtained my keeper data from the DVLA under Regulation 27(1)(e) of the Road Vehicles (Registration and Licensing) Regulations 2002. You remain responsible for all processing undertaken on your behalf, including by ZZPS.

Under Article 12(2) you must facilitate the exercise of data-subject rights. Refusing the request or attempting to delegate it to a third party is non-compliance. ZZPS, as your data processor, acts only on your written instructions and has no lawful basis to handle a SAR directly.

Accordingly, you are hereby placed on formal notice that:
1. The statutory one-month period for responding to my SAR continues to run from the original receipt date.
2. You must now conduct the search yourself and provide a full SAR response directly to me within that time limit.
3. Any further attempt to deflect this obligation to ZZPS will be treated as wilful obstruction of my data-subject rights.

If I do not receive a compliant response within the statutory timeframe, I will file a detailed complaint with the Information Commissioner’s Office and reserve all rights to seek damages for breach of data-protection obligations.

Yours faithfully,

[Full Name]
[Address]
[Email]
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Re: UK Parking Enforcement PCN Issued After Nearly 6 Months
« Reply #16 on: »
Hi, 
Would you recommend replying directly to the email they sent, or should I send a new email instead?

Also, should I still use the same email address: info@ukpenforcement.co.uk?

Thanks!




Re: UK Parking Enforcement PCN Issued After Nearly 6 Months
« Reply #17 on: »
Reply to the email they sent it from and CC to the other address and yourself. Please show us the email address they sent it from.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Re: UK Parking Enforcement PCN Issued After Nearly 6 Months
« Reply #18 on: »
There sent it from the same email address which I sent the original email to which is info@ukpenforcement.co.uk

Please see below:


Re: UK Parking Enforcement PCN Issued After Nearly 6 Months
« Reply #19 on: »
Then why are you asking which address you should send the response to????
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Re: UK Parking Enforcement PCN Issued After Nearly 6 Months
« Reply #20 on: »
Apologies for the confusion, I wasn’t sure whether to send it as a new email or reply directly to the one from UKP.

I’ve now sent the email as mentioned above and will keep you all updated if / when I receive a response.

Once again, thank you all for your help and guidance.

Re: UK Parking Enforcement PCN Issued After Nearly 6 Months
« Reply #21 on: »
Hi All,

I've received the email below from ZZPS, where they’ve surprisingly admitted that a POPLA code was not issued.

They’ve also stated that the Parking Charge has now been withdrawn from their system at the request of their client, and no further action is required.

Can we take this to mean the PCN has officially been cancelled?


Re: UK Parking Enforcement PCN Issued After Nearly 6 Months
« Reply #22 on: »
Looks like they've realised they messed up by failing to issue a POPLA code, and have withdrawn on that basis.

Damage limitation, I suspect.

Re: UK Parking Enforcement PCN Issued After Nearly 6 Months
« Reply #23 on: »
Hi All,
I’ve received the below response from the UKP team regarding the Subject Access Request I submitted on 06/10/2025. It’s a bit confusing, as they mentioned I would receive a response from ZZPS, but ZZPS had already contacted me last week confirming that the Parking Charge had been withdrawn from their system.

However, I still haven’t received any official confirmation from UKP themselves confirming whether the Parking Charge has been fully cancelled.

Could you please advise if there’s anything further I need to do?

Best regards, 


Re: UK Parking Enforcement PCN Issued After Nearly 6 Months
« Reply #24 on: »
Their “clarification” doesn’t change anything: UKPE remains the controller, the clock runs from your original SAR date, and you’re entitled to deal with UKPE directly. A processor (ZZZPS) may assist, but UKPE is responsible for the response and its lawfulness.

Respond with the following:

Quote
Subject: Re: SAR – Controller responsibility, deadline and required items – PCN [ref], VRM [reg]

Dear Data Protection Officer,

Thank you for confirming that UK Parking Enforcement Ltd is the data controller and that any processor acts strictly under your instruction. For the avoidance of doubt:
1. The statutory one-month deadline under Article 12(3) UK GDPR runs from my original SAR date [insert date].
2. I will continue to correspond with UKPE as controller. Any response you instruct a processor to compile must be issued on your behalf, with a covering note from UKPE accepting controller responsibility.

Please ensure the SAR bundle includes the personal data and proofs previously requested, specifically:
• A copy of every item of correspondence to/from me (letters, emails) about PCN [ref], including any rejection you allege and any POPLA code;
• Proof of posting/transmission for any such rejection/POPLA (Certificate of Posting or postal/batch manifest; or for email, full SMTP headers and server logs);
• System/audit logs evidencing creation and dispatch of those items (date/time, method, addressee);
• All identifiers you hold for me (name/address/email/phone), their source (including DVLA/KADOE details), and the dates and recipients of any disclosures (including to ZZZPS).

As stated, I rebut any presumption of delivery. Without contemporaneous proof of posting/delivery, you must treat any “rejection” as not served and either cancel or re-issue a rejection to the keeper with a fresh POPLA code.

Finally, my Article 21 objection and Article 18 restriction to debt-collection processing remain in place pending your SAR fulfilment and a lawful conclusion of the appeal process. Please ensure ZZZPS is instructed accordingly.

If a complete response is not provided within the statutory time, I will escalate to the ICO and consider remedies for non-compliance.

Yours faithfully,

[Name]
[Address]
[Email]
[Date]
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain
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Re: UK Parking Enforcement PCN Issued After Nearly 6 Months
« Reply #25 on: »
Hi All,

I’ve received a 19-page PDF report in response to the Subject Access Request. The majority of it contains the original PCN issued, their email correspondence with me requesting driver details, and copies of my communications with them.

I’ve attached the three key pages that are relevant to the SAR for your reference.

On the final page (page 3), towards the bottom, they state: 
"As the Parking Charge has been withdrawn and the case closed, no further processing or enforcement action will take place in respect of this matter."

Can I take this as confirmation that the PCN is now officially cancelled, or should I still expect formal confirmation directly from UK Parking Enforcement?

Thanks, 







Re: UK Parking Enforcement PCN Issued After Nearly 6 Months
« Reply #26 on: »
What response have you had to the email above that I advised you to send to the UKPE DPO? That response is from ZZPS.

Send the following to the UKPE DPO and CC ZZPS and yourself:

Quote
Subject: Formal Data Protection Notice – SAR Non-Compliance and Unlawful Processing

PCN [ref] / VRM [reg]

UK Parking Enforcement Ltd – Data Protection Officer

You used your processor (ZZPS) to issue a partial, inadequate response to my SAR dated [date]. As controller, UK Parking Enforcement Ltd remains responsible under Articles 12 and 15 UK GDPR and s.45 DPA 2018 for issuing a full, lawful response.

Your bundle omits my personal data that I expressly requested:
• Proof of posting/transmission for any alleged rejection/POPLA (certificate of posting or postal/batch manifest; or for email, full SMTP headers and server delivery logs identifying my address).
• System/audit entries that record creation and dispatch to me (date/time, method, addressee).

Provide those items, or confirm in writing that they do not exist, within 7 days.

ZZPS’s pages state the Parking Charge has been “withdrawn and the case closed”. Confirm as controller that PCN [ref] is cancelled (£0 balance), all recovery is permanently withdrawn, and no further processing/sharing for enforcement will occur.

Failure to comply will result in a formal complaint to the DVLA Data Sharing Policy & Compliance Team and the ICO for breach of Articles 12 and 15 UK GDPR.

No further correspondence will be entered into unless it is a complete, compliant disclosure.

[Name]
[Date]

Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Re: UK Parking Enforcement PCN Issued After Nearly 6 Months
« Reply #27 on: »
I’ve not received a direct response from UKPE, only from ZZPS, as shown in the document uploaded above.

In their reply, just before stating that the parking charge has been withdrawn and the case closed, ZZPS acknowledged that because they didn’t receive a response regarding the driver’s details, the matter proceeded to debt resolution without a POPLA code being issued.

I’ve now forwarded your response to UKPE and have also cc’d ZZPS as advised. I’m just a bit concerned as the original SAR was submitted on 06/10/2025, and we’re approaching the one-month mark. 

If there is no response from UKPE by 06/11/2025, would we allow them additional time, or what would be the appropriate next steps?

Thanks,

Re: UK Parking Enforcement PCN Issued After Nearly 6 Months
« Reply #28 on: »
Do not give them extra time.cUnder UK GDPR, they had one month from receipt of your SAR on 06/10/2025. The deadline is 06/11/2025. They can extend by up to two further months only if they told you within that first month that your request is complex and explained why. If they didn’t do that by 06/11/2025, they’re late.

If 06/11/2025 passes with no complete controller response from UKPE (not ZZPS alone), same day, send a final non-compliance notice (short template below). Then file an ICO complaint against UKPE (controller).

Separately, file a DVLA complaint to the Data Sharing Policy & Compliance Team about:
a) escalation to debt recovery without offering POPLA, and
b) mishandling of your data/rights following the KADOE enquiry.

If they respond after 06/11/2025 but it’s incomplete or still issued only by ZZPS, you can still complain to the ICO for late and/or incomplete SAR.

1-paragraph final non-compliance notice (send 07/11/2025 if needed):

Quote
Subject: SAR Non-Compliance – PCN [ref], VRM [reg] (deadline missed)

UK Parking Enforcement Ltd – Data Protection Officer

My SAR was received by you on 06/10/2025. The statutory one-month period expired 06/11/2025 with no complete controller response from UK Parking Enforcement Ltd and no timely extension notification under Article 12(3). You are now in breach of Articles 12 and 15 UK GDPR. Provide the missing items (proof of posting/transmission and the audit/dispatch entries containing my personal data) within 7 days or confirm in writing that they do not exist. Failing that, I will proceed with complaints to the ICO and DVLA Data Sharing Policy & Compliance Team.

Also confirm, as controller, that PCN [ref] is cancelled (£0) and that no further processing/sharing for enforcement will occur.

[Name]

ICO complaint (points to include):

• Controller: UK Parking Enforcement Ltd.
• SAR submitted: 06/10/2025; deadline: 06/11/2025; no valid Article 12(3) extension issued in time.
• Response was compiled/issued by ZZPS; controller failed to adopt it clearly and it is incomplete (missing your personal data within proofs of posting/transmission and dispatch/audit entries).
• Prejudice: escalation to debt recovery occurred while appeal route (POPLA) was not provided; you needed the data to challenge service.
• Remedy sought: compel UKPE to provide the missing personal data and record the breach.
• Attach: your SAR email, proof of receipt, ZZPS bundle, their admissions (no POPLA before debt), your follow-ups, and the non-compliance notice.


DVLA complaint (outline):

• To: DVLA Data Sharing Policy & Compliance Team.
• Grounds: misuse/mishandling after KADOE data access—operator escalated to debt recovery without issuing a POPLA code, then failed to facilitate rights under Article 12; SAR answered by a processor without a complete controller response, missing personal-data proofs of service.
• Ask DVLA to investigate and apply appropriate sanctions/monitoring.

ZZPS's written admission that they went to debt “without a POPLA code being issued” is powerful. Keep that page prominent. It supports both your DVLA complaint and any future challenge if this ever resurfaces.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Re: UK Parking Enforcement PCN Issued After Nearly 6 Months
« Reply #29 on: »
Hi,

I’ve now received confirmation from UKP (see below) that the PCN has been withdrawn and no further enforcement action will be taken.

Thank you very much for all your assistance.