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top photo says 21:32:46 and bottom photo says 21:42:50.

Would it be the keeper/driver or both that would need to go to the court case?

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The keeper unless you identify the driver (doing so would mean PCM pursue them instead) - doing this would reduce the number of defence arguments to be made, as they couldn't use the arguments around keeper liability, but there would still seem to be a defence there.

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top photo says 21:32:46 and bottom photo says 21:42:50.

They are both 21:32, as far as I can see, suggesting they were taken just 4 seconds apart.

If you log onto the PCM online portal, are any other photos available? If so, what time stamps do these show?

There is persuasive case law on this point - if the only photos they have are taken 4 seconds apart, then as b789 says they have not stated the period of parking (required for keeper liability), but further, more basically, their evidence would not seem to show that any alleged contract has been breached if they only have 2 photos taken 4 seconds apart.

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Would it be the keeper/driver or both that would need to go to the court case?

Quote

The keeper unless you identify the driver (doing so would mean PCM pursue them instead) - doing this would reduce the number of defence arguments to be made, as they couldn't use the arguments around keeper liability, but there would still seem to be a defence there.

Even
than

Also, gather evidence:

• Take a photo of any “30 minutes free parking” sign to show UKCPM’s own signage contradicts their claim;
• Speak to the caretaker, as planned, to confirm the history and intended use of the drop-off bays.

You have every right to challenge this. Your lease comes first, and neither UKCPM nor Hyde can rewrite it without following proper legal procedures.

OP, let's clear up some issues pl:

Is the Notice to Keeper addressed to you by name;
** The 'Penalty charge notice' is addressed to me at my home next to the 'loading/unloading bay' in the photo which the driver parked in.

It refers to 'your vehicle', not one belonging to a third party, the 'driver'. Pl explain;
** What do you mean by third party?
Yes, I am the registered keeper/owner and I let the driver use it as they help me with various things.

Was the car displaying a permit?
** No it doesn't have a permit as it isn't parked on the estate.

I am submitting a formal complaint against UK Car Park Management Ltd (UKCPM), a IPC AOS member with DVLA KADOE access, for breaching the 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.

SUPPORTING STATEMENT

Complaint to DVLA – Breach of KADOE Contract and PPSCoP

Operator name: UK Car Park Management Ltd (UKCPM)
Date of PCN issue: 6 April 2025
Vehicle registration: [INSERT VRM]

I am submitting this complaint to report a misuse of my personal data by UKCPM, 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 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, UKCPM has breached the PPSCoP in the following ways:

• The Notice to Keeper (NtK) fails to specify a required period of parking, in breach of Schedule 4, Paragraph 9(2)(a) of the Protection of Freedoms Act 2012. The evidence available shows only that the car was present for approximately 32 seconds, which is not sufficient to establish any contract was formed or breached.
• The PCN and subsequent Final Warning Letter issued by UKCPM contain inconsistent timestamps, raising concerns about the accuracy and integrity of the data used to justify the charge. This misrepresentation further undermines the lawfulness of the data use.
• At the time of the incident, the on-site signage was contradictory and unclear. Hyde Housing displayed a notice stating 30 minutes was allowed for loading/unloading, whereas UKCPM now claim the limit is 15 minutes. The signs were recently changed following a complaint to the estate caretaker, who confirmed UKCPM’s own signage had previously allowed 30 minutes. The driver was using the marked “drop off” zone outside a resident’s home for its intended purpose, under existing estate rules.
• The resident’s tenancy agreement contains no clause that authorises UKCPM to enforce parking, nor any requirement to display a permit or comply with a 15-minute restriction. This means any alleged contract imposed by UKCPM signage is legally baseless, and any charge based on such signage is unjustified.

These are not minor breaches. They show a disregard for the PPSCoP and the governing principles that must be followed when processing keeper data. UKCPM has demonstrated poor compliance and misused the data they obtained from the DVLA.
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. I therefore ask the DVLA to investigate and take appropriate action against UKCPM.

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]