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Subject: Formal Complaint – UK Parking Enforcement Ltd (AOS) – Denial of POPLA access and misuse of keeper data via ZZPSDear BPA AOS Compliance Team,Operator: UK Parking Enforcement Ltd (“UKPE”) – BPA AOS memberPCN: [ref] VRM: [reg] Site: Shell, 200 Ilford Lane, IG1 2LWNtK: 11/08/2025 Keeper appeal: 18/08/2025I make a formal complaint that UKPE breached the Private Parking Single Code of Practice (PPSCoP) and AOS rules, and mishandled DVLA keeper data.Denial of POPLA access / unlawful debt escalation– I, as keeper, appealed on 18/08/2025. I did not identify the driver.– UKPE did not accept or reject the appeal. Instead they emailed (09/09/2025) demanding the driver’s details.– The case was then escalated to ZZPS for “debt resolution” without any rejection letter or POPLA code.– In writing (SAR responses dated 31/10/2025 from ZZPS and 05/11/2025 from UKPE) the operator admits no rejection/POPLA was ever issued and the matter went to debt recovery instead.– On 05/11/2025 UKPE confirmed the charge is withdrawn and the case closed.This breaches the PPSCoP requirement that, where an appeal is not accepted, the operator must issue a written rejection with a POPLA verification code, irrespective of whether the keeper has identified the driver. Escalating to debt collection without offering the independent appeal is a serious AOS compliance failure.Misuse of keeper data and controller responsibilityUKPE obtained my data from the DVLA. They then handed the matter to ZZPS and attempted to deny or deflect controller responsibility for the SAR and the appeal outcome, contrary to UK GDPR Articles 12, 15 and 28. Their position was that ZZPS “manages administrative matters” and would “coordinate and fulfil” the SAR. A processor can assist, but UKPE—as controller—must facilitate rights and remains responsible for lawful processing.Passing the case to ZZPS for debt collection while refusing to issue a POPLA code is not fair or lawful processing for the purpose for which DVLA data was obtained (KADOE). It breaches purpose limitation, data minimisation and fairness, and it undermines the AOS framework tied to KADOE use.Requested BPA actionA. Open a compliance investigation into UKPE’s handling of keeper appeals and POPLA access.B. Confirm the BPA’s position that AOS operators who obtain DVLA keeper data remain data controllers and cannot disclaim liability by passing cases to ZZPS or any other agent.C. Require corrective action so keeper appeals are either accepted or rejected with a POPLA code, and prohibit debt escalation until the appeal route is exhausted.D. Confirm what disciplinary or corrective measures the BPA will apply and how recurrence will be monitored.Evidence attached– Keeper appeal (18/08/2025).– UKPE email 09/09/2025 demanding driver details (no rejection/POPLA).– ZZPS SAR bundle (31/10/2025) admitting no rejection/POPLA and debt escalation.– UKPE email (05/11/2025) adopting the SAR and confirming “withdrawn/closed”.Please acknowledge and advise when a full investigation will commence.Yours faithfully,[Your name][Address][Email]
