The Notice to Keeper (NtK) is not PoFA compliant with paragraph 9(2)(a) because there is no period of parking stated. No initial appeal is going to be successful, but you have to go through the motions.
Under these facts, I’d run this as a single continuous parking event with an ambiguous/onerous “daily renewal” requirement that was not clearly incorporated into any contract. Two NtKs for one unmoved vehicle is, on its face, duplicate ticketing.
Duplicate charging: The vehicle did not move from Saturday 2 August to Monday 4 August. Any “permit issue” is one continuing state; issuing more than one charge for the same continuous stay is an attempt at double recovery and is unreasonable.
Contract terms not incorporated: The alleged “renew daily” rule must be on the signage in clear, prominent terms at the point of contract. Verbal instructions by a separate security firm cannot add to, vary or replace the written terms.
Ambiguity: “Expired/discontinued permit” is unclear. If overnight is “included” (as stated verbally), the operator must show what the permit covered (times/dates) and how/when it purportedly expired mid-stay. Any ambiguity is construed against the drafter.
Signage/prominence (CRA 2015): A requirement to collect a fresh permit every calendar day for an unmoved vehicle is an onerous/unusual term that must be prominent and transparent. If it wasn’t, it is not binding and/or is unfair.
Keeper liability not admitted: The keeper does not identify the driver and requires strict proof of full PoFA 2012 compliance, including a specified period of parking (not merely photos of moments in time) and all mandatory wording.
Mitigation and reliance: A permit was obtained on arrival and displayed (your photos show it). If the operator’s system later “discontinued” that permit the burden is on them to prove that this was communicated on the signs and applicable to this stay.
Evidence to demand from the operator:
• Full-frame photographs of all signage in situ at the material time, including any term about “daily renewal”, the exact renewal cut-off time, and any definition of “overnight included”.
• The permit scheme rules in force for visitors/temporary permits on those dates (not a generic template).
• The permit audit log/whitelist for your VRM showing issue time/date, validity window, and any “discontinued” status change.
• All photos for each NtK, with time/date stamps, and the operative’s notes.
• Landowner authority/contract showing the operator is allowed to issue charges and pursue them.
I suggest that you appeal, only as the Keeper with the following for each PCN, only swapping the PCN reference numbers in each appeal:
Subject: Parking Charge [REF A] – Duplicate and Unfounded Charge (separate appeal also lodged for [REF B])
I am the registered keeper. Liability is denied.
This appeal concerns PCN [REF A]. A separate, materially identical appeal has been lodged under PCN [REF B]. The vehicle was parked in the same residential bay from Saturday 2 August to Monday 4 August and did not move. A temporary permit was obtained from on-site security on arrival and was displayed (as your photos show). Security advised that overnight was included. Any requirement to renew a permit daily must be clearly set out on the signage and incorporated into any parking contract. Verbal remarks by a separate security company cannot impose terms not present on the signs.
You have issued two Notices to Keeper (NtK) for the very same continuous stay, alleging “parked displaying an expired/discontinued permit”. That amounts to duplicate charging. If you contend that a fresh liability arises on each calendar day regardless of movement, you are put to strict proof that this onerous term was prominently stated on the signs at the material time, including the precise renewal cut-off time.
“Expired/discontinued permit” is ambiguous. Provide the permit scheme rules in force, the permit audit log for VRM [VRM] (issue time/date, validity window and any “discontinued” status), and copies of all photographs and operative notes for both PCNs. Also provide full-frame images of all signage as displayed then, and your landowner authority.
As keeper I do not identify the driver. You must prove full compliance with Schedule 4 of the Protection of Freedoms Act 2012 for PCN [REF A], including a specified period of parking and all mandatory wording and deadlines. Failing that, there is no keeper liability.
Given the above, PCN [REF A] must be cancelled. If you reject this appeal, you must provide a separate POPLA verification code for PCN [REF A] and your complete evidence pack.
Treat this as a formal complaint as well as an appeal.
Yours faithfully,
[Keeper’s name]
You should also make a formal complaint to the DVLA as they have breached the KADOE contract by making two separate data requests for the same single parking event. You should also attach a SAR form which you can download from here:
DVLA Subject Access Request form.
Subject: Complaint – Duplicate DVLA enquiries for a single parking event by UKPC (VRM [ABC1234]; PCNs [REF A] & [REF B])
Dear DVLA Data Sharing Compliance Team,
I am the registered keeper of vehicle [VRM: ABC1234]. I am raising a formal complaint about UK Parking Control Ltd (UKPC) making two separate enquiries to DVLA for my keeper data in relation to what was, in substance, one continuous parking event.
Event summary
• Location: [Residential complex/address]
• Continuous stay: Saturday 2 August 2025 to Monday 4 August 2025 (vehicle unmoved in the same bay)
• UKPC issued two NtKs alleging “Parked displaying an expired/discontinued permit”:
• PCN [REF A] (date of event shown: [DD/MM/YYYY])
• PCN [REF B] (date of event shown: [DD/MM/YYYY])
A temporary visitor permit was obtained from on-site security on arrival and displayed. Any “daily renewal” requirement is not incorporated by signage.
Why this is a DVLA/KADOE issue
Each KADOE enquiry must have its own reasonable cause, tied to a specific date/event. Here, both NtKs arise from the same unmoved stay. There was no new, distinct event to justify a second DVLA disclosure. A repeat enquiry for the same substantive event appears to be requesting keeper data without reasonable cause, contrary to the KADOE contract.
In parallel, making a duplicate enquiry for the same event also raises UK GDPR concerns (data minimisation and the “necessity” limb of legitimate interests).
What I am asking DVLA to do
1. Investigate UKPC’s enquiries for my VRM around these dates and confirm:
• the dates/times of each enquiry and the “date of event” declared by UKPC;
• whether DVLA considers the second enquiry to lack reasonable cause given a single continuous stay.
2. Record and address any breach/misuse, including compliance action and referral to UKPC’s Accredited Trade Association.
3. Require remediation, including ceasing processing for the duplicate PCN and deletion of any personal data obtained via the second, unnecessary enquiry.
4. Provide a written outcome to this complaint.
Attachments
• Copy NtK for [REF A].
• Copy NtK for [REF B].
• Brief timeline statement confirming the vehicle remained unmoved from 2–4 August 2025 and that a permit was obtained on arrival.
• (For information) My DVLA Subject Access Request form is enclosed separately to obtain the enquiry log; however, this email constitutes a complaint and requests a compliance investigation irrespective of the SAR.
Please confirm receipt and advise the reference for this complaint. I look forward to your investigation outcome.
Yours faithfully,
[Full name]
[Postal address]
[Email] | [Telephone]
Registered keeper: [VRM ABC1234]
Operator: UK Parking Control Ltd (UKPC)
