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#Post#: 90347--------------------------------------------------
Re: CPM PARKING PCN X3 - NOT DISPLAYING A VALID PERMIT - TOPMAST
POINT, BARKANTINE ESTATE
DIR By: msrr204
Date: September 17, 2025, 5:26 am
---------------------------------------------------------
Hi guys,
Sorry for the delayed response. I can confirm that BW Legal or
Gladstones, however a few months ago when I got the letters I
did contact CPM to see if they can withdraw the PCNs. I did not
explicitly mention that I was the driver and spoke in a general
sense.
For context where I parked:
HTML https://imgur.com/a/lLXFN61
I must make clear when I parked the car there, there was NO road
markings. Nowhere did it state it was estate parking and it is a
side road that is directly off a road where I normally park. At
the time there was no single or double yellow lines and nor were
there any parking spot bays. In the image it shows 'estate
parking' on the floor painted but this must have happened
recently as it was not there months ago when I parked. The
private land sign is further down this side road on a pillar and
so it is very easy to miss and not clear at all.
I did not move my car from that parking spot that I left it and
it was only there for 2 days before I moved it again. I was
issued 2 PCNs (I have a total of 3) on the same day for the same
spot which I find baffling. Topmast point I am not sure where
they got that location from as it was always on the same spot. I
hope this information helps and I'll wait a little before
sending that email once you guys have seen this. If there is any
other details that you may think is relevant please let me know.
Thank you very much.
#Post#: 90349--------------------------------------------------
Re: CPM PARKING PCN X3 - NOT DISPLAYING A VALID PERMIT - TOPMAST
POINT, BARKANTINE ESTATE
DIR By: msrr204
Date: September 17, 2025, 5:31 am
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--- Quote from: WhoLetTheScamsOut link ---
>
> OP have you checked the entrance sign to that location? iirc
it’s not even a CPM entrance sign at the time the PCN was
issued. It’s an entrance sign from a complete different operator
>
--- End Quote ---
When I turned in the road there was 0 obvious indications
immediately that it was a private road or anything like that. I
assumed as it was safe to park since there was 0 road markings
anywhere. Only when a couple weeks passed by did I receive 3
separate letters from CPM which states 2 dates of contravention.
#Post#: 90351--------------------------------------------------
Re: CPM PARKING PCN X3 - NOT DISPLAYING A VALID PERMIT - TOPMAST
POINT, BARKANTINE ESTATE
DIR By: DWMB2
Date: September 17, 2025, 5:33 am
---------------------------------------------------------
Can you share a Google Maps street view link?
#Post#: 90359--------------------------------------------------
Re: CPM PARKING PCN X3 - NOT DISPLAYING A VALID PERMIT - TOPMAST
POINT, BARKANTINE ESTATE
DIR By: msrr204
Date: September 17, 2025, 6:02 am
---------------------------------------------------------
Here is a google maps street link:
HTML https://maps.app.goo.gl/Ft8i8BJsJVEaRkjZ6
The long straight road is also 'Stafford Street' and the side
bit (where I parked and has now been updated to show estate
parking on Google maps) is also called 'Stafford Street'. My car
was behind the 'Hiya' car and like I mentioned before had 0 road
markings previously. So all of the new markings must have been
in recent times.
I hope this helps. Thank you
#Post#: 90361--------------------------------------------------
Re: CPM PARKING PCN X3 - NOT DISPLAYING A VALID PERMIT - TOPMAST
POINT, BARKANTINE ESTATE
DIR By: DWMB2
Date: September 17, 2025, 6:17 am
---------------------------------------------------------
Those Google Street View images were taken between 2022 and
September 2024, so the markings visible on Google would have
been there when your vehicle was parked (albeit rather faded!),
but I think this is a distraction. What matters is the CPM
signage (or lack thereof), which is frankly rubbish to
nonexistant.
#Post#: 90375--------------------------------------------------
Re: CPM PARKING PCN X3 - NOT DISPLAYING A VALID PERMIT - TOPMAST
POINT, BARKANTINE ESTATE
DIR By: b789
Date: September 17, 2025, 8:09 am
---------------------------------------------------------
The entrance view in GSV is from September 2024 and whilst the
entrance sign is a winning point because it is not suitable for
its purpose, the road markings are all there.
--- Quote from: msrr204 link ---
>
> My car was behind the 'Hiya' car and like I mentioned before
had 0 road markings previously. So all of the new markings must
have been in recent times.
>
--- End Quote ---
The GSV images from May 2022 and September 2024 all show
markings. There is nowhere to park "behind the Hiya car". Where
the Hiya car and the Audi in the GSV images is, are bot bays
marked with a 'V', most likely indicating visitor bays.
There are markings and I doubt you would be able to convince
anyone that there were none at the time your vehicle was parked
there.
What needs clarifying, is the fact that you say the two PCNs
issued on 19/11/2024 for:
[indent]1. Topmast Point, Barkantine Estate at 07:24
2. The Quarterdeck, Barkantine Estate at 15:15[/indent]
were a single parking event and the car never moved at all that
day. If so, that introduces even more breaches of the PPSCoP by
the operator.
#Post#: 90453--------------------------------------------------
Re: CPM PARKING PCN X3 - NOT DISPLAYING A VALID PERMIT - TOPMAST
POINT, BARKANTINE ESTATE
DIR By: msrr204
Date: September 17, 2025, 5:22 pm
---------------------------------------------------------
I can confirm that on the 19th my car did not move that day so
it adds more frustration why I got 2 for the mind. Also I called
CPM and asked them for the images which they said they could not
provide.
#Post#: 90475--------------------------------------------------
Re: CPM PARKING PCN X3 - NOT DISPLAYING A VALID PERMIT - TOPMAST
POINT, BARKANTINE ESTATE
DIR By: b789
Date: September 18, 2025, 4:46 am
---------------------------------------------------------
Good to know that they have said that they cannot provide the
evidential photos for the alleged contravention on 19/11/2024.
As this is a single parking event, if the vehicle never moved on
19/11/2024, issuing two PCNs on the same day for the same
stationary presence is, in substance, a duplication of the same
alleged breach. A private parking charge is a liquidated sum for
breach of a single contractual term at a given time/place. Where
there is one continuous breach, the correct construction is one
cause of action, not multiple rolling causes every time an
operative wanders past.
Re-ticketing without any intervening windscreen notice (so the
motorist remains unaware) is predatory. Even operators’ own
practices and the PPSCoP expect fairness and reasonableness
around multiple charges for the same event. Courts regularly
view serial ticketing of a single event as unreasonable.
They must have made two DVLA requests for your data and have
breached your GDPR and you will be able to sue them for
compensation under the Data Protection Act. Never, EVER phone
these scammers. EVERYTHING must be in writing, preferably by
email.
The first thing you must do immediately is SAR the DVLA. Use
this form MIS1065 'DVLA subject access request (SAR)'
HTML https://assets.publishing.service.gov.uk/media/62692f63d3bf7f0e7d5b3dc6/make-a-subject-access-request-to-dvla-form-mis1065_270422.pdf<br
/>and complete sections 1 and 3 and email it to
subjectaccess.requests@dvla.gov.uk.
At the same time send the following DVLA complaint to
kadoeservice.support@dvla.gov.uk and CC yourself:
--- Quote ---
>
>
> I am the registered keeper of VRM [ABC123]. I make a formal
complaint that DVLA released my keeper data more than once to UK
Car Park Management Ltd (UK-CPM) or its agents in relation to a
single continuous parking event at the Barkantine Estate in
November 2024.
>
> Background
> The vehicle did not move at any time on 19/11/2024. UK-CPM
issued two Notices to Keeper for that same continuous stationary
presence, using different sub-labels for the same estate: (1)
“Topmast Point, Barkantine Estate” timed 07:24; and (2) “The
Quarterdeck, Barkantine Estate” timed 15:15. A further PCN was
issued for 20/11/2024. When asked for evidential photographs for
19/11/2024, UK-CPM stated they could not provide them. I believe
DVLA disclosed my data more than once for the same continuous
event.
>
> Basis of complaint
> Regulation 27 of the Road Vehicles (Registration and
Licensing) Regulations 2002 permits disclosure only where there
is reasonable cause. The KADOE contract requires requests to be
accurate, necessary and proportionate, prohibits duplicate or
speculative enquiries, and limits use of data to the specific
incident for which it was requested. Using different sub-labels
within the same managed estate (Barkantine Estate) for a single
continuous stationary presence does not create a fresh
reasonable cause to obtain keeper data again.
>
> Industry Code breach
> The Private Parking Single Code of Practice (v1.1, 17 February
2025) at section 8.3 states:
>
> [indent]“Parking operators must ensure that they only issue
Parking Charges in accordance with their advertised terms on any
site. Such terms shall not entitle any operator to issue more
than one parking charge in the same calendar day for the same
parking event.”[/indent]
>
> UK-CPM issued two PCNs on 19/11/2024 for the same continuous
stationary presence. This is inconsistent with §8.3 and
indicates that any second KADOE enquiry relating to that same
event lacked reasonable cause.
>
> Remedies sought
>
> [indent]1. Please consider this apparent PPSCoP §8.3 breach
when assessing reasonable cause and KADOE compliance, and liaise
with the relevant AOS (BPA/IPC) as appropriate alongside DVLA’s
own KADOE sanctions process.
>
> 2. Investigate all KADOE enquiries made for VRM [ABC123]
between 01/11/2024 and 31/12/2024. Identify each enquiry that
relates to Barkantine Estate on 19/11/2024 and determine whether
multiple releases were made for the same continuous stationary
presence, irrespective of any different sub-labels used.
>
> 3. For each relevant enquiry, provide the date and time, DVLA
reference, the requesting entity’s legal name, the reason code
and any free-text location or reason supplied (including any
mention of “Topmast Point” or “The Quarterdeck”), and the
incident date and time cited by the requester.
>
> 4. Explain the legal and contractual basis on which DVLA
authorised multiple releases for one continuous event, or
confirm that the duplicate disclosure(s) were non-compliant with
Regulation 27 and KADOE requirements.
>
> 5. Confirm what compliance action DVLA will take under the
KADOE regime (for example warning, sanction points or
suspension) for any non-compliant duplicate enquiry.
>
> 6. Direct the operator and any agents or solicitors to erase
personal data obtained via any duplicate or unlawful request and
require written confirmation of erasure to me.[/indent]
>
> Please acknowledge receipt and provide a written outcome and
complaint reference within 20 working days. I ask that all
records relevant to these enquiries and this complaint are
preserved pending conclusion.
>
> Yours faithfully,
>
> [Full name]
>
> [Postal address]
> [Email address]
> [Telephone]
--- End Quote ---
You can attach copies of the NtKs to the email.
Also, you send the following email to the UK-CPM DPO at
dpo@uk-cpm.com and CC both complaints@uk-cpm.com and yourself:
--- Quote ---
> Subject: Formal complaint and Letter Before Claim. Ref: PCN 1.
[PCN number1] & PCN 2 [PCN number2]
>
> Dear Sirs,
>
> I am the registered keeper of VRM [ABC123]. This is a formal
complaint addressed to the Data Protection Officer. It concerns
UK Car Park Management Ltd’s processing of my personal data in
relation to two PCNs issued on 19/11/2024 for a single
continuous parking event at Barkantine Estate. The vehicle did
not move at any point on 19/11/2024. Nonetheless, you issued two
PCNs for the same stationary presence using different sub-labels
within the same managed estate: “Topmast Point, Barkantine
Estate” timed 07:24 and “The Quarterdeck, Barkantine Estate”
timed 15:15. When asked for evidential photographs for that
date, your company stated it could not provide them.
>
> You appear to have obtained or caused the obtaining of my
keeper data from DVLA more than once for the same continuous
event. Re-accessing or re-processing keeper data for a
duplicated charge lacks reasonable cause and is not necessary or
proportionate. Your conduct breaches the Private Parking Single
Code of Practice section 8.3 (no more than one parking charge in
the same calendar day for the same parking event) and infringes
UK GDPR and the Data Protection Act 2018, specifically Article
5(1)(a) (lawfulness, fairness, transparency), Article 5(1)(c)
(data minimisation/necessity) and Article 6(1) (absence of a
lawful basis for duplicate processing for the same event). It
also constitutes unfair and excessive processing by onward
disclosure to agents.
>
> I require the following remedies and actions:
>
> [indent]1. Cancel the duplicate PCN for 19/11/2024. Confirm
that both 19/11/2024 notices arose from one continuous parking
event and that all enforcement activity relating to any
duplicate is ceased.
> 2. Apply Article 18 UK GDPR restriction to all records linked
to the 19/11/2024 duplicate. Segregate that record from active
workflows and cease processing and dissemination for the
duplicate purpose. Preserve (do not delete) all data and logs
for regulatory/litigation duties.
> 3. Under Article 16, rectify your records to reflect a single
continuous event and notify all recipients of the rectification;
confirm the duplicate PCN reference has been cancelled.
> 4. Acknowledge my Article 21 objection to any further
processing for the duplicate purpose.
> 5. Identify each DVLA KADOE enquiry you or your agents made
for the 19/11/2024 event (date/time, requester identity, reason
code/free-text location, incident date/time) and list all third
parties to whom you disclosed my data.
> 6. Pay compensation for distress caused by duplicate
processing and multiple PCNs for one event (Article 82 UK GDPR;
s.168 DPA 2018). I reserve quantum to be assessed; invite your
proposals.
> 7. Confirm measures to prevent recurrence, including controls
to avoid multiple PCNs for one event and duplicate DVLA
requests.[/indent]
>
> Please acknowledge this complaint within 14 days and provide a
full written response within 28 days. Treat this as a letter of
claim for the purposes of pre-action protocols applicable to
data protection claims. Pending resolution, require your agents
including BW Legal and any debt recovery firms to cease
processing and to place their files on hold. Preserve all
records relevant to this complaint, including DVLA request logs,
internal notes, patrol notes, images, site plans, and
correspondence. I reserve all rights.
>
> Yours faithfully,
>
> [Full name]
--- End Quote ---
And, for the time being, send the following email to BW Legal at
SAR@bwlegal.co.uk and also CC enquiries@bwlegal.co.uk and
yourself:
--- Quote ---
> Subject: Data processing objection and restriction – Your ref:
[BW Legal reference number]
>
> Dear Sirs,
>
> I am the registered keeper of VRM [ABC123]. There will be no
identification of the driver.
>
> Your debt recovery “final warning” dated 28/08/2025 refers to
two PCNs dated 19/11/2024. Those two notices concern one
continuous stationary presence at Barkantine Estate; the vehicle
did not move. You are processing my personal data for both PCNs
using data supplied by your client.
>
> Your client had no reasonable cause to obtain or reuse my
keeper data more than once for the same event (Regulation 27;
KADOE). Duplicate PCNs for the same day/event also breach PPSCoP
8.3. Any onward disclosure to you for the duplicate purpose
lacks a lawful basis (Articles 5(1)(a), 5(1)(c), 6(1) UK GDPR).
As an independent controller you are jointly and severally
liable with your client for unlawful processing and the distress
caused (Article 82; s.168 DPA 2018).
>
> Accordingly:
>
> [indent]1. Record my Article 21 objection and apply Article 18
restriction to all processing relating to the duplicate
19/11/2024 PCN. Segregate that record from active workflows and
cease processing and dissemination for the duplicate purpose. 2.
Preserve all data and logs for disclosure.
> 3. Confirm within 7 days the lawful basis you rely upon for
processing in relation to each of the two 19/11/2024 PCNs and
identify the precise data source for each.
> 4. Confirm your file is on hold for the 19/11/2024 event
pending resolution of my complaints to your client and the DVLA.
All rights reserved.[/indent]
>
> Yours faithfully,
>
> [Full name]
> [Postal address]
> [Email]
--- End Quote ---
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