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#Post#: 79467--------------------------------------------------
Re: PCN - Parked in a disabled bay without displaying valid
Disabled badge Grove Farm Retail Park Chadwell Heath. RM6 4B
DIR By: D23
Date: July 3, 2025, 4:11 pm
---------------------------------------------------------
Thank you for the response. I will now do the email and will
follow up the stage 2 with DVLA
to DCB shall i disclose my letter to them so they know who i am
or the reference number that is provided?
thanks
#Post#: 79508--------------------------------------------------
Re: PCN - Parked in a disabled bay without displaying valid
Disabled badge Grove Farm Retail Park Chadwell Heath. RM6 4B
DIR By: b789
Date: July 4, 2025, 4:49 am
---------------------------------------------------------
Obviously you include their reference number in your letter to
DCB Legal, otherwise how would they know who it is from? They
issue hundreds of these a week.
#Post#: 84515--------------------------------------------------
Re: PCN - Parked in a disabled bay without displaying valid
Disabled badge Grove Farm Retail Park Chadwell Heath. RM6 4B
DIR By: D23
Date: August 6, 2025, 4:55 pm
---------------------------------------------------------
Hi all,
I’ve just received DVLA’s Stage 2 reply regarding my complaint
about the release of my data to G24 Ltd. Unfortunately, the
response seems generic and doesn’t address key concerns I
raised.
Here’s what they said in brief:
DVLA insists the data release was lawful and part of a system of
“industry self-regulation.”
They claim once G24 receives my data, they become the data
controller and DVLA has no further responsibility.
They suggest complaints about G24 should go to their trade
association.
They say there’s no evidence of legal breach and refer me to the
ICO if I’m still dissatisfied.
#Post#: 84590--------------------------------------------------
Re: PCN - Parked in a disabled bay without displaying valid
Disabled badge Grove Farm Retail Park Chadwell Heath. RM6 4B
DIR By: b789
Date: August 7, 2025, 8:16 am
---------------------------------------------------------
Respond with the following:
--- Quote ---
> To: DVLA Complaints Team
> Ref: 0410774-B2W3C / DVLA Ref 0400043
>
> Date: [Insert today's date]
>
> Dear Mrs N Smith,
>
> Re: Failure to address Step 2 complaint regarding G24 Ltd –
formal request for escalation to ICA
>
> Thank you for your letter dated 29 July 2025 in response to my
Step 2 complaint. Unfortunately, your response repeats the same
generic assertions made at Step 1 and once again fails to engage
with the substance of the complaint I raised.
>
> To be absolutely clear:
>
> [indent]• I do not dispute that G24 Ltd had reasonable cause
to request keeper data at the time of the original DVLA data
release.
> • My complaint concerns G24 Ltd’s unlawful subsequent use of
that data, in breach of the Private Parking Single Code of
Practice (PPSCoP) and the KADOE contract.
> • Your response completely fails to address the post-access
misuse, despite this being the central issue from the
outset.[/indent]
>
> Summary of Original Complaint (Reiterated for Clarity):
>
> G24 Ltd used my keeper data to pursue a parking charge in
direct breach of the PPSCoP, specifically:
>
> [indent]• Annex F1(c) – I submitted evidence that the vehicle
was broken down and awaiting recovery. G24 continued enforcement
regardless, despite the Code expressly prohibiting enforcement
where a vehicle is immobilised due to mechanical failure.
> • Section 8.3.1 – The NtK misstated the 28-day period for
payment as running from the issue date, not date of receipt,
which is misleading and non-compliant.
> • Failure to address a formal complaint – G24 was given the
opportunity to correct these breaches and failed to do so,
instead escalating matters by sharing my personal data with
third parties (e.g., debt recovery agents) without proper
cause.[/indent]
>
> These are not civil disputes for the courts. They are
compliance and data protection matters governed by the PPSCoP,
the Data Protection Act 2018, and the terms of the KADOE
contract, under which the DVLA remains jointly responsible as
Data Controller.
>
> DVLA Obligations
>
> As you will be aware:
>
> [indent]• The DVLA retains ongoing responsibility for ensuring
that data released under the KADOE contract is not subsequently
misused.
> • The DVLA must investigate post-access misuse where credible
allegations are raised.
> • The DVLA is required to monitor compliance with the PPSCoP
and take proportionate enforcement action when breaches are
identified.[/indent]
>
> Your Step 2 response neither investigates the misuse nor
acknowledges that any breach occurred, despite clear evidence
being provided. It also fails to mention the Independent
Complaints Assessor (ICA) or how to escalate the complaint
further, contrary to the DVLA's own published complaints
process.
>
> Accordingly, I now require the following:
>
> [indent]• A formal acknowledgement that my complaint has been
mishandled and not properly responded to at Step 2.
> • Immediate escalation of this matter to the Independent
Complaints Assessor (ICA), including both:
>
> [indent]• DVLA’s failure to investigate the reported misuse of
my data; and
> • DVLA’s failure to signpost or facilitate escalation to the
ICA at Step 2, as required by its own
procedures.[/indent][/indent]
>
> Please confirm in writing that this matter has now been
referred to the ICA.
>
> Yours sincerely,
>
> [Your full name]
--- End Quote ---
#Post#: 91935--------------------------------------------------
Re: PCN - Parked in a disabled bay without displaying valid
Disabled badge Grove Farm Retail Park Chadwell Heath. RM6 4B
DIR By: D23
Date: September 29, 2025, 5:19 am
---------------------------------------------------------
Here are 2 emails from the INDEPENDENT COMPLAINTS ASSESSOR
INDEPENDENT COMPLAINTS ASSESSOR
Department for Transport
DfT Complaints Team - for the attention of Stephen Shaw
Great Minster House
33 Horseferry Road
London
SW1P 4DR
(By preference, contact should be made by email to:
ica.stephen-shaw@dft.gov.uk or by text or voicemail to 07585
997505. If using standard post, please also alert the ICA by
one of the other means.)
Mr
My reference: 185 (25/26)
By email to: ----------------------@gmail.com
31 August 2025
Dear Mr M
YOUR COMPLAINT AGAINST THE DRIVER AND VEHICLE LICENSING AGENCY
(DVLA)
I write further to your correspondence about the independent
complaint assessor (ICA) review of your complaint. I am the ICA
to whom your case has been referred, and I am formally
acknowledging receipt of your complaint and associated papers
that the DVSA has provided.
I have obviously not yet read or considered the file, but I can
see your complaint concerns the release of your data by the DVLA
to a private parking company.
I have set out our role as ICAs in an annex to this letter. We
are neither civil servants nor employees of the Department for
Transport or the DVLA. We cannot challenge or overturn a
decision made by the DVLA in line with its policies or require
it to change its policies. However, we may assess if it has
administered its policies correctly and acted consistently with
them. The DVLA is in the jurisdiction of the Parliamentary
Ombudsman and we refer where relevant to the Ombudsman’s
Principles in judging whether the DfT or one of its delivery
bodies, including the DVLA, has acted reasonably. We must take
a proportionate approach, weighing carefully the merits of
individual complaints with the operational realities of the
delivery bodies.
We allocate the equivalent of three working days per week to DfT
cases and may not be able to reply immediately to
communications. Our normal time target for reviews is three
months, but I hope to revert to you well within that time.
We prefer email communications as they get to us directly
(terrestrial post is referred on to us by the DfT, adding time
to the process). We will make any adjustment that we can to be
of assistance.
Please tell us if we should adjust our approach to communicate
better with you. If you intend to write to us using Royal Mail
it would be helpful to know in advance so we can ask DfT staff
to be sure to refer correspondence to us as soon as possible.
Good wishes.
Yours sincerely
Stephen Shaw
Independent Complaints Assessor
Encl:  Annex setting out ICA jurisdiction
 
Annex: Summary of ICA role and jurisdiction
The ICAs are independent of the DfT and its delivery bodies and
not civil servants.
They look at whether the DfT or its delivery body handled a
complaint properly and gave a reasonable decision. The
DfT/delivery body will send relevant correspondence and
documents to the ICA within 15 working days of the customer’s
request for ICA review.
If the delivery body and customer both believe referral to the
ICA won’t resolve the complaint, then with the agreement of the
ICA, the ICA doesn’t have to consider it. Instead, the
complainant can ask an MP to refer their case to the
Parliamentary and Health Service Ombudsman (PHSO).
The ICA will aim to review the case within three months of
receipt. They’ll say if they expect it to take longer.
When the ICA has reviewed the case, they’ll tell both sides the
outcome and if they’ve made any recommendations. This ends
their involvement
The ICA can look at complaints about:
•
advice
•
•
The ICA can’t look at:
•
DfT public body policy
•
considered by Parliament
•
the outcome
•
•
•
•
•
example, the clinical decisions of doctors or the judgments of
driving and vehicle examiners.
Also, the ICA can’t usually look at any complaint that:
•
complaints process
•
response2
•
PHSO.
2ND EMAIL BELOW
INDEPENDENT COMPLAINTS ASSESSOR
Department for Transport
DfT Complaints Team - for the attention of Stephen Shaw
Great Minster House
33 Horseferry Road
London
SW1P 4DR
(By preference, contact should be made by email to:
ica.stephen-shaw@dft.gov.uk or by text or voicemail to 07585
997505. If using standard post, please also alert the ICA by
one of the other means.)
Mr
By email to: ---------------------@gmail.com
16 September 2025
Dear Mr M
YOUR COMPLAINT AGAINST THE DRIVER AND VEHICLE LICENSING AGENCY
(DVLA)
I write further to my letter of 31 August regarding the
independent review of your complaint against the DVLA.
As I explained, I am one of the Independent Complaint Assessors
(ICAs) contracted to the Department for Transport, and your case
was allocated for my consideration.
Complaint
You complained that, after the DVLA had released your data to a
private parking company (G24 Ltd), the data was misused. You
argue that the DVLA remains responsible for the use of its data
after its release.
For its part, the DVLA position is that it does not and cannot
‘police’ the activities of private parking companies, beyond
ensuring that they are members of an Accredited Trade
Association (ATA) if they are to receive DVLA data. The Agency
says your grievance is one for the relevant ATA (in this case
the International Parking Community - IPC). In addition, any
concerns you may have about the DVLA’s handling would be a
matter for the Information Commissioner’s Office.
 
Jurisdiction
Before setting out the facts of this case and my views, I should
first explain the nature of the ICA role. The Introduction to
the ICA terms of reference reads as follows:
“The overall aims of the independent complaints assessor (ICA)
process are to:
•
the public as customers or in consequence of the actions,
inactions, or decisions of DfT
•
•
that maladministration has not occurred”
Further paragraphs read:
“Relevant factors for a detailed review are:
•
injustice, loss or hardship
•
it has failed to conduct a proportionate and reasonable
investigation and has failed to apply an appropriate remedy
•
•
learning from the complaint and of promoting consistency and
fairness
“Relevant factors against a detailed review are:
•
administrative failure or mistake
•
•
reference or review through another avenue, for example tribunal
or legal proceedings
•
dispute
•
“Having considered the previous factors, the ICA may decide that
subjecting the complaint to a detailed review would not meet the
overall aims of the ICA review process.”
The protocol to the terms of reference sets out a list of
exclusions to the ICA remit. These include:
•
policy
•
I must emphasise that the ICAs cannot adjudicate on the legality
of the DVLA’s supply of keeper data to private parking
companies. In a parallel case to your own, one of my colleagues
has written as follows:
“Nor is the DVLA an actual or proxy regulator for this sector,
so complaints about the legal footing and procedural basis
behind a PCN [parking charge notice] need to go down the
prescribed appeal route, not to the Agency or us. Complaints
about unlawful data release, you will understand, are for the
ICO [Information Commissioner’s Office] that has fully approved
the DVLA’s practice of releasing keeper data for the
investigation of potential liability under the reasonable cause
provision (in other words, the DVLA does not have to satisfy
itself of the legitimacy of a request before data release). A
complaint to the DVLA that a request for data from a private
parking company was erroneous, meaning that the DVLA should not
have released the data, does not get off the ground.
“Approaching 41,000 drivers are issued with PCNs by private
firms each day, underlining the impossibility of the DVLA
investigating each request individually. We are precluded from
commenting on the content and pursuit of policy by the DVLA. In
my view, a political move in an area of widespread public
concern is required to change the current arrangement.”
Review
The DVLA records show that you applied to register vehicle CY11
UKA in October 2024 and a registration certificate (V5C) was
issued at the end of the month. In December 2024, G24 Ltd made
a request for data in relation to an event on 9 December
involving CY11 UKA. The request was made under the terms of
G24 Ltd’s KADOE (Keeper at date of event) contract with the
DVLA.
On 7 April 2025, you made a complaint to the DVLA in the
following terms:
Your supporting statement included the following:
After listing what you said were breaches of the industry code
of practice, you added:
You also enclosed correspondence between yourself and G24 Ltd.
This shows that you had parked in a disabled bay without
displaying a Blue Badge and that your appeal against the Parking
Charge Notice had been dismissed by the Independent Appeals
Service.
The DVLA replied in largely standard terms at step 1 of its
complaints procedure on 6 May. The Agency suggested that you
might wish to contact the International Parking Community of
which G24 Ltd is a member.
In July, you asked for your complaint to be escalated. You
emphasised that your concern was not with the initial release of
your data but with the subsequent use of it by G24 Ltd which you
described as ‘material breaches’ of the code of conduct that
rendered its usage of the data as unlawful. You added that the
DVLA remained the data controller and must conduct a proper
investigation to be followed by enforcement action that might
include suspension or termination of G24 Ltd’s KADOE contract.
In its further reply on 24 July, the DVLA emphasised that it was
not the regulator of the parking industry (“The Government’s
policy is to operate a system of industry self-regulation") and
therefore it was right to suggest that you took up your concerns
with the IPC. In addition, there was no evidence that G24 Ltd
had breached any statutory provisions or other legal
requirements of the KADOE contract. Moreover, G24 Ltd had
become the data controller from the point that it had received
data from the DVLA.
You were also given details of the Information Commissioner’s
Office (www.ico.org.uk).
Reiterating that the DVLA had ongoing responsibility for the use
of data it had released, you then asked for an ICA review.
While the papers were being prepared, the DVLA wrote once more
on 28 August. This letter provided greater detail on the
Agency’s approach. Unfortunately, it also wrongly suggested
that G24 Ltd was a member of a different ATA (the British
Parking Association) rather than the International Parking
Community.
Further information
Although I know you are very familiar with the legislation, for
the sake of completeness I should quote from Regulation 27 of
The Road Vehicles (Registration and Licensing) Regulations 2002
(
HTML https://www.legislation.gov.uk/uksi/2002/2742/regulation/27)
as
follows:
Disclosure of registration and licensing particulars
27.—(1) The Secretary of State may make any particulars
contained in the register available for use—
...
(e)by any person who can show to the satisfaction of the
Secretary of State that he has reasonable cause for wanting the
particulars to be made available to him.
In June 2022, the Information Commissioner’s Office (ICO)
published an important document entitled The lawful basis for
the processing of vehicle keeper data by the Driver and Vehicle
Licensing Agency (DVLA)
(
HTML https://ico.org.uk/media2/migrated/4020676/dvla-opinion-20220613.pdf).<br
/> Again, it may be helpful to quote from the document. The ICO
found as follows:
“Following consideration of the evidence and legal analysis, the
Commissioner concluded that the DVLA’s correct lawful basis is
public task, not legal obligation. This is because Regulation
27(1)(e) provides the DVLA with a power, rather than a legal
duty, to disclose vehicle keeper information to car park
management companies in these circumstances ...
“It is important to note that in coming to this conclusion, the
Commissioner does not doubt that car park management companies
have reasonable cause to request keeper information from the
DVLA in these circumstances, and that the DVLA is generally
required to provide it. However, Regulation 27(1)(e) creates a
power rather than a duty as there is a discretion for the DVLA
to refuse a request for keeper information in exceptional cases.
For example, if the keeper was on a national security
protection list. This applies even if the requestor has
demonstrated
reasonable cause. Public task is the correct legal basis in
these circumstances, because Regulation 27(1)(e) creates a task
(a power, rather than a legal duty) to be carried out in the
public interest (hence the reasonable cause requirement).
Disclosing vehicle keeper data is necessary for this task.”
(Emphasis added.)
I also note this extract:
“Paragraph 11 of Schedule 4 of POFA [Protection of Freedoms Act
2012] contains an enforceable legal right of the car park
management company to claim the charges from the vehicle keeper.
It is not for the DVLA to determine the validity of claims
against the vehicle keeper. Car park management companies can
use the exception. It would be for a court or parking tribunal
to determine the validity of any claim. It is the
Commissioner’s view is that [sic] the DVLA could refuse an
Article 21(1) objection by the vehicle keeper in these
circumstances.” (Emphasis added.)
As noted above in footnote 2, the Government has recently
initiated a consultation on its plans for a statutory code of
practice for private parking. The Ministerial foreword to the
consultation document includes the following:
“The UK private parking industry plays an important role in
supporting our local economies and high streets. But we
continue to hear reports of poor behaviour by parking operators
that make it difficult for motorists to comply with the terms
and conditions of parking and leave them open to parking charges
and escalating costs. These operators tarnish the reputation of
those in the industry who strive to provide quality parking
facilities and services. That’s bad for motorists, industry and
the economy. And it’s bad for growth. There is considerable
evidence that the public want transparency, and they want to see
parking operators who engage in poor practices held to account.
“Parliament, as long ago as 2019, decided that there should be a
government code of practice for private parking, and there is no
justification for further delay in complying with Parliament’s
direction.
“This government wants to make swift progress to support and
protect motorists, without penalising those private operators
who run their car parks well. The parking industry’s two trade
associations recently published a single industry code of
practice which replaced the two different codes they had. But
more needs to be done to raise standards and to hold parking
operators to account.
“This consultation sets out our proposals for achieving this
through both a new government code of practice aimed at further
driving up standards and a new robust compliance framework for
parking operators that will ensure that motorists have trust in
the system. Whilst we consider these proposals the best way to
raise standards, we remain open minded about what course of
action to take.”
Consideration
Before offering any views, I need to re-emphasise the extent of
my jurisdiction:
•
International Parking Community. This means that I can offer no
views on whether the use of your data by G24 Ltd further to its
release by the DVLA represented, as you allege, a material
breach of the industry code of practice such that its use was
unlawful.
•
authorised to make legal judgments (for example, on the powers
of the DVLA to provide keeper data to parking companies or
others, or whether it ensures sufficient safeguards against
misuse of such data). However, it is worth re-emphasising that
the DVLA is not the regulator of the parking industry. Whether
there should be tighter (or statutory) regulation is a matter
for the political process, and I am sure that you and many
others will have responded to the Government’s consultation
exercise which was recently underway.
That said, it may be helpful if I offer the following comments:
•
Commissioner’s assessment of the legal framework is that parking
companies generally have ‘reasonable cause’ to request
keepership data and the DVLA is not required to first adjudicate
upon the accuracy of the allegations made against a vehicle
keeper before releasing the data requested (“It is not for the
DVLA to determine the validity of claims against the vehicle
keeper”). I accept that you have not challenged this.
•
I am content that the DVLA has no legal or administrative duty
(or, indeed, power) to investigate complaints against private
parking companies. The Agency has therefore correctly referred
you to the International Parking Community.
•
carries out regular audits of those requesting data and requires
parking companies to be a member of an ATA. The Government’s
new consultation exercise endorses this position and as an
administrative complaints assessor I have no authority to
challenge the Government’s statement – even if I thought that
such a challenge was justified. Should you disagree with that
view, I think you might have to take independent legal advice or
pursue your case further with the Information Commissioner’s
Office as the DVLA has suggested.
•
expert in data protection legislation. But my lay view is that
the DVLA is right to say that G24 Ltd became the data controller
of the data it had received from the Agency from the point of
receipt. If you disagree with this analysis, you might again
seek legal advice or approach the Information Commissioner.
•
content with the terms and tone of the DVLA’s two letters at
steps 1 and 2 of its complaints procedure. The contents were
also in line with longstanding DVLA policy in relation to the
release of data from the DVLA registers. However, the step 2
letter was issued outside the DVLA’s time target, and it is
disappointing that this was not acknowledged. In consequence,
no apology was offered. As I have also said, the Agency’s
letter of 28 August also contained a material inaccuracy in
suggesting that G24 Ltd was a member of the British Parking
Association.
•
imposed by G24 Ltd was unsuccessful. It is of course for you to
decide if you will now pay the outstanding debt.
Conclusions
As the Government itself has acknowledged, there is widespread
concern amongst drivers about the practices of some parking
companies and the effectiveness of the current regulatory
arrangements. And given my criticisms in the penultimate bullet
point above, I will record your complaint as having been upheld
in part. However, as far as the substance of the matter is
concerned, I am afraid I cannot assist you or make any formal
recommendations to the DVLA. Like all citizens you have now had
the opportunity of responding in detail to the new proposals put
forward by the Government in its consultation exercise that
continued until 5 September. You also remain at liberty to
contact the IPC or the Information Commissioner.
This letter brings all stages of the Department for Transport
complaints process to a close. However, if you remain
dissatisfied, you also have the right to ask an MP to refer your
complaint to the Parliamentary and Health Service Ombudsman.
(There is a readily downloadable form for this purpose at
www.ombudsman.gov.uk - please note there is a time limit for
making a complaint to the Ombudsman; further information is
available on the PHSO website or call 0345 015 4033.) The
Ombudsman would then consider the extent of any further review
she considered necessary.
I will also send a copy of this letter to the DVLA.
Please do accept my good wishes.
Yours sincerely
Stephen Shaw
Independent Complaints Assessor
#Post#: 91969--------------------------------------------------
Re: PCN - Parked in a disabled bay without displaying valid
Disabled badge Grove Farm Retail Park Chadwell Heath. RM6 4B
DIR By: b789
Date: September 29, 2025, 6:57 am
---------------------------------------------------------
This ICA reply, while courteous, is clearly dismissive and
largely avoids engaging with your central complaint — that DVLA
failed to uphold its post-release obligations as a data
controller under the KADOE contract and UK GDPR, when G24 Ltd
materially misused that data in breach of the PPSCoP.
The ICA's position boils down to three points:
[indent]1. DVLA’s only duty is to confirm ATA membership before
data release.
2. Post-release misuse is not their concern — “take it up with
the IPC”.
3. ICA can’t challenge policy or make legal determinations, even
if malpractice exists.[/indent]
Despite the above, the ICA upheld your complaint in part,
noting:
[indent]• The Step 2 reply was late and failed to acknowledge or
apologise.
• DVLA's further letter (28 August) wrongly identified the ATA
(claiming BPA instead of IPC).[/indent]
Given the limitations of the ICA’s jurisdiction and their
unwillingness to engage with the substance of your complaint,
your next steps should be to respond to the ICA and to also
write to your MP and escalate to the Parliamentary and Health
Service Ombudsman (PHSO).
You can respond to Stephen Shaw, the ICA as follows:
--- Quote ---
> To: Stephen Shaw, Independent Complaints Assessor
> Cc: DVLA Complaints Team
>
> Subject: Response to ICA Review – Reference 185 (25/26)
>
> Date: [Insert today's date]
>
> Dear Mr Shaw,
>
> Thank you for your letter dated 16 September 2025, responding
to my complaint against the DVLA (Reference: 185 (25/26)).
> Regrettably, your response fails to properly address the core
of my complaint, and I must now formally register my
dissatisfaction with the ICA’s handling of this matter.
>
> 1. Mischaracterisation of the Complaint
>
> At no stage did I dispute the lawfulness of DVLA’s initial
release of keeper data under Regulation 27(1)(e). My complaint
explicitly stated that reasonable cause existed at the point of
request. The issue under review was the DVLA’s failure to act
upon post-access misuse of that data by G24 Ltd, in breach of
the Private Parking Single Code of Practice (PPSCoP) and the
KADOE contract.
>
> Your decision fails to engage with this, and instead reverts
to boilerplate reasoning around the DVLA's discretion at the
point of data release — a point which was never in dispute. This
constitutes a fundamental misreading of the complaint and
fatally undermines your review.
>
> 2. Omissions and Factual Errors
>
> Your response omits, or fails to address, the following:
> [indent]• The explicit terms of the KADOE contract, which
confirm that the DVLA remains a joint data controller even after
release and must take enforcement action if a recipient breaches
the terms under which access was granted.
> •The specific PPSCoP breaches by G24 Ltd:
> [indent]• Annex F1(c): Continuing to pursue a charge after I
provided evidence of mechanical breakdown.
> • Section 8.3.1: Misstating the 28-day payment deadline from
issue date rather than date of service.
> • Failure to address a formal complaint: Proceeding to debt
escalation without responding.[/indent]
> • The DVLA’s obligation to investigate such misuse,
particularly where the motorist has already exhausted the ATA’s
appeal process and provides credible evidence of ongoing misuse
of personal data.[/indent]
>
> These are not policy grievances or “commercial disputes” as
described in your letter. They are complaints about
maladministration by a government agency in relation to its
duties under the Data Protection Act 2018, the KADOE contract,
and the DVLA’s own internal governance procedures.
>
> 3. Contradictions and Selective Interpretation
>
> You assert that the DVLA "has no legal or administrative duty"
to investigate post-release misuse of data. This is contradicted
by:
> [indent]• The DVLA’s status as a data controller for all data
supplied under KADOE, including liability for downstream
processing if it becomes aware of misuse.
> • The ICO’s 2022 Opinion, which you partially quote but fail
to interpret accurately. While the DVLA is not required to
adjudicate individual disputes before data release, it does have
a continuing responsibility to monitor use of that data for the
purposes it was released and to take proportionate action when
misuse is identified.
> • Paragraph 2.9 of the KADOE contract, which expressly
prohibits use of DVLA data for purposes other than that for
which it was provided. Where violations are reported, the DVLA
must take investigative and remedial steps.[/indent]
>
> You further suggest the DVLA cannot “police” the private
parking industry. That is not the issue. The question is whether
the DVLA has discharged its obligations in light of clear
evidence that G24 Ltd violated the conditions under which it
received my data. That is a matter of public administration, not
policy.
>
> 4. Process Failings
>
> Even if you had no authority to comment on the data protection
or KADOE aspects, your review still fails to meet the minimum
standards of fair complaint handling:
> [indent]• You did not accurately summarise my complaint,
misstating it as a challenge to DVLA’s data release decision.
> • You failed to acknowledge the evidential material I
submitted.
> • You did not assess whether DVLA’s refusal to investigate
G24’s conduct was a proportionate or reasonable response.
> • You excused factual errors and delay in DVLA correspondence
but provided no meaningful redress or recommendation beyond a
footnote.[/indent]
>
> Your conclusions appear pre-determined and excessively
deferential to DVLA policy rather than properly assessing
whether maladministration occurred. In doing so, you have not
fulfilled the aims set out in the ICA’s own Terms of Reference,
particularly the commitment to “put right any injustice or
unfairness suffered by members of the public in consequence of
the actions, inactions, or decisions of DfT.”
>
> 5. Next Steps
>
> I am therefore escalating this matter further.
> [indent]• I will ask my MP to refer this complaint to the
Parliamentary and Health Service Ombudsman, citing both the
DVLA’s failure to investigate data misuse and the ICA’s failure
to properly consider the complaint.
> • I am also lodging a separate complaint with the Information
Commissioner’s Office, as advised.
> • A copy of this letter will be retained for public record and
shared with relevant accountability groups and public interest
bodies monitoring DVLA data access practices.[/indent]
>
> Yours sincerely,
>
> [Your Full Name]
> [Contact Details]
--- End Quote ---
Email the following to your MP:
--- Quote ---
> Subject: Request for MP Referral to Parliamentary Ombudsman –
DVLA Data Misuse Oversight
>
> Dear [MP’s Name],
>
> I am writing to request that you refer a complaint to the
Parliamentary and Health Service Ombudsman (PHSO) regarding the
Driver and Vehicle Licensing Agency (DVLA) and its failure to
uphold its responsibilities as a data controller under the KADOE
contract.
>
> This complaint has now completed the full DVLA internal
complaints process and has also been considered by the
Independent Complaints Assessor (ICA), who upheld my complaint
in part but declined to investigate the core issues I raised.
The ICA confirmed that this now concludes the Department for
Transport’s complaints process and advised me to approach my MP
for a referral to the Ombudsman.
>
> Summary of complaint
> I do not dispute that G24 Ltd had reasonable cause to request
my keeper data initially. My complaint concerns their subsequent
misuse of that data — a matter for which the DVLA retains shared
data controller responsibility under the terms of the KADOE
contract and UK GDPR.
>
> G24 Ltd materially breached the Private Parking Single Code of
Practice (PPSCoP) by:
> [indent]• Continuing to pursue a parking charge after I
supplied evidence of a vehicle breakdown, in direct breach of
PPSCoP Annex F1(c).
> • Issuing a Notice to Keeper which misstated the payment
deadline, contrary to PPSCoP Section 8.3.1.
> • Failing to address a formal complaint, then sharing my
personal data with third parties, including debt
collectors.[/indent]
>
> These are clear compliance breaches. The DVLA has a duty to
monitor and act on such breaches once reported. Instead, it gave
a template response and denied any responsibility for
post-release misuse, despite remaining the data controller under
KADOE Schedule 2 and the Data Protection Act 2018.
>
> The ICA declined to investigate the substance of these
concerns, stating that they could not challenge Government
policy. However, my complaint was about maladministration and
regulatory failure, not policy. I believe the DVLA has failed in
its public duty to protect personal data and has shielded G24
Ltd from accountability.
>
> I would be grateful if you would consider referring this
matter to the PHSO, so it can be independently investigated.
>
> I can provide a full timeline of correspondence and a copy of
the ICA decision upon request.
>
> Yours sincerely,
>
> [Your Full Name]
> [Your Postal Address]
> [Constituency Postcode]
> [Contact email]
--- End Quote ---
#Post#: 91999--------------------------------------------------
Re: PCN - Parked in a disabled bay without displaying valid
Disabled badge Grove Farm Retail Park Chadwell Heath. RM6 4B
DIR By: D23
Date: September 29, 2025, 8:35 am
---------------------------------------------------------
Hi everyone,
I’ve now received an official County Court Claim Form from the
Civil National Business Centre (Northampton) regarding the G24
parking charge. issued on 12 September 2025. The particulars
state it relates to parking in a disabled bay without displaying
a valid badge. The total amount claimed is £264.92 (including
fees and legal costs).
The website wouldn't allow me to insert any images or documents
not sure why but there isnt a button so I have uploaded them to
google and made the link available to everyone.
please see attachment
HTML https://drive.google.com/drive/folders/1plvqUbJMNqVFCVOOW6qQQeAKM4nzzYYz?usp=sharing
#Post#: 92007--------------------------------------------------
Re: PCN - Parked in a disabled bay without displaying valid
Disabled badge Grove Farm Retail Park Chadwell Heath. RM6 4B
DIR By: b789
Date: September 29, 2025, 9:12 am
---------------------------------------------------------
Please have a look at the back for the actual Claim Form (N1SDT)
and show us who has signed the Statement of Truth (SoT). It used
to be Sarah Ensall as 'Head of Legal' on behalf of DCB Legal. If
it is on the front and you have redacted it, please unredact
that and confirm who has signed it.
The front and back of that single document is all we need to
see.
#Post#: 92008--------------------------------------------------
Re: PCN - Parked in a disabled bay without displaying valid
Disabled badge Grove Farm Retail Park Chadwell Heath. RM6 4B
DIR By: b789
Date: September 29, 2025, 9:15 am
---------------------------------------------------------
With an issue date of 12th September you have until 4pm on
Wednesday 1st October to submit your defence. If you submit an
Acknowledgement of Service (AoS) before then, you would then
have until 4pm on Wednesday 15th October to submit your defence.
You only need to submit an AoS if you need extra time to prepare
your defence. If you want to submit an AoS then follow the
instructions in this linked PDF:
HTML https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0
Until very recently, we never advised using the MCOL to submit a
defence. However, due to recent systemic failures within the
CNBC, we feel that it is safer to now submit a short defence
using MCOL as it is instantly submitted and entered into the
"system". Whilst it will deny the use of some formatting or
inclusion of transcripts etc. these can always be included with
the Witness Statement (WS) later, if it ever progresses that
far.
You will need to copy and paste it into the defence text box on
MCOL. It has been checked to make sure that it will fit into the
122 lines limit.
--- Quote ---
> 1. The Defendant denies the claim in its entirety. The
Defendant asserts that there is no liability to the Claimant and
that no debt is owed. The claim is without merit and does not
adequately disclose any comprehensible cause of action.
>
> 2. There is a lack of precise detail in the Particulars of
Claim (PoC) in respect of the factual and legal allegations made
against the Defendant such that the PoC do not adequately comply
with CPR 16.4.
>
> 3. The Defendant is unable to plead properly to the PoC
because:
>
> (a) The contract referred to is not detailed or attached to
the PoC in accordance with PD 16, para 7.3(1);
>
> (b) The PoC do not state the exact wording of the clause (or
clauses) of the terms and conditions of the contract (or
contracts) which is/are relied on;
>
> (c) The PoC do not adequately set out the reason (or reasons)
why the claimant asserts the defendant has breached the contract
(or contracts);
>
> (d) The PoC do not state with sufficient particularity exactly
where the breach occurred, the exact time when the breach
occurred and how long it is alleged that the vehicle was parked
before the parking charge was allegedly incurred;
>
> (e) The PoC do not state precisely how the sum claimed is
calculated, including the basis for any statutory interest,
damages, or other charges;
>
> (f) The PoC do not state what proportion of the claim is the
parking charge and what proportion is damages;
>
> (g) The PoC do not provide clarity on whether the Defendant is
sued as the driver or the keeper of the vehicle, as the claimant
cannot plead alternative causes of action without specificity.
>
> 4. The Defendant submits that courts have previously struck
out materially similar claims of their own initiative for
failure to adequately comply with CPR 16.4, particularly where
the Particulars of Claim failed to specify the contractual terms
relied upon or explain the alleged breach with sufficient
clarity.
>
> 5. In comparable cases involving modest sums, judges have
found that requiring further case management steps would be
disproportionate and contrary to the overriding objective.
Accordingly, strike-out was deemed appropriate. The Defendant
submits that the same reasoning applies in this case and invites
the court to adopt a similar approach by striking out the claim
due to the Claimant’s failure to adequately comply with CPR
16.4, rather than permitting an amendment. The Defendant
proposes that the following Order be made:
>
> Draft Order:
>
> Of the Court's own initiative and upon reading the particulars
of claim and the defence.
>
> AND the court being of the view that the particulars of claim
do not adequately comply with CPR 16.4(1)(a) because: (a) they
do not set out the exact wording of the clause (or clauses) of
the terms and conditions of the contract which is (or are)
relied on; and (b) they do not adequately set out the reason (or
reasons) why the claimant asserts that the defendant was in
breach of contract.
>
> AND the claimant could have complied with CPR 16.4(1)(a) had
it served separate detailed particulars of claim, as it could
have done pursuant to PD 7C, para 5.2, but chose not to do so.
>
> AND upon the Court determining, having regard to the
overriding objective (CPR 1.1), that it would be
disproportionate to direct further pleadings or to allot any
further share of the Court’s resources to this claim (for
example by ordering further particulars of claim and a further
defence, with consequent case management).
>
> ORDER:
>
> 1. The claim is struck out.
>
> 2. Permission to either party to apply to set aside, vary or
stay this order by application on notice, which must be filed at
this Court not more than 7 days after service of this order,
failing which no such application may be made.
--- End Quote ---
#Post#: 92059--------------------------------------------------
Re: PCN - Parked in a disabled bay without displaying valid
Disabled badge Grove Farm Retail Park Chadwell Heath. RM6 4B
DIR By: D23
Date: September 29, 2025, 12:58 pm
---------------------------------------------------------
HTML https://drive.google.com/drive/folders/1plvqUbJMNqVFCVOOW6qQQeAKM4nzzYYz
I’ve now uploaded the missing sheet as well, which shows Sarah
Ensall.
The only details I’ve removed from the documents are my name and
address – everything else is exactly as received.
This is the first time I’ve had to deal with a County Court
Claim Form, and I’m not sure where to begin with the process.
Could anyone guide me on the right steps to take when filling it
out and responding?
Thanks in advance for any advice.
*****************************************************
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