DIR Return Create A Forum - Home
---------------------------------------------------------
FreeTrafficLegalAdvice
HTML https://ftla.createaforum.com
---------------------------------------------------------
*****************************************************
DIR Return to: Private parking tickets
*****************************************************
#Post#: 60282--------------------------------------------------
Blue Badge parking - failed to authorize Blue Badge
DIR By: Chris_S
Date: March 2, 2025, 4:54 pm
---------------------------------------------------------
Hi,
I have recently received two PCNs for parking at Edmonton Green
shopping centre in Enfield. I was there with my son, who is
disabled. I parked at disabled spot which looked like this:
HTML https://ibb.co/3mF1KsCw.
I have displayed the Blue Badge upon parking.
Few weeks later I received two PCNs which looked pretty much
identical save for the date/duration of the infraction - please
see here:
HTML https://ibb.co/rfRbVq1X.
Turned out there was another sign elsewhere in the parking lot
specifying the conditions for the Blue Badge users, which can be
seen here:
HTML https://ibb.co/zTmDpKM0
I should mention that my son's disability requires my full
attention.
I have responded to both of them as follows:
I arrived at the Edmonton Green Shopping Centre parking lot with
my disabled son and parked in the disabled bay displaying the
Blue Badge. The bay was clearly signposted as per the attached
picture. The signage did not mention any requirements regarding
the Blue Badge parking. Posting additional requirements
elsewhere in the parking area is not sensible as my son requires
assistance and I do not go around the whole parking lot looking
for further instructions. Not to mention the fact that the
requirement of registering the Blue Badge with some office is
onerous and discriminatory to the disabled people, who often
have difficulty moving around.
As per wording on your signage: All Disabled Blue Badge Holders
must clearly display their badge to prevent being issued with a
PCN. We had done so, therefore I request the PCN be cancelled.
I have promptly received two identical responses last week,
please see here:
HTML https://ibb.co/Pf1z5V7
The company in question is G24 Ltd.
What should be my next steps? Appealing to IAS? I find this
"authorization of the Blue Badge" process quite repulsive. I
would have no problem with paying the parking charge had I not
been misled by the signage.
Thank you in advance for any help on this.
Chris
#Post#: 60314--------------------------------------------------
Re: Blue Badge parking - failed to authorize Blue Badge
DIR By: b789
Date: March 3, 2025, 4:20 am
---------------------------------------------------------
Don’t worry. You won’t be paying a penny to these scammers if
you follow our advice. Please show the full Notice to Keeper
(NtK) and the back, redacting only your personal details, the
PCN number and your VRM. Leave all dates and times visible.
It’s too late to rely on PoFA failures as you have inadvertently
admitted to being the driver. However, the signs you showed are
in breach of the BPA/IPC Private Parking Single Code of Practice
(PPSCoP) section 4.1 which states:
[indent]”The parking operator must ensure that at least one sign
containing the terms and conditions for parking can be viewed
without the driver needing to leave the vehicle, in order for
drivers with a disability to be able to make an informed
decision on whether to park at the premises.”[/indent]
The Parking Charge Notices (PCNs) were not issued for not
displaying a blue badge but for not paying the tariff for
parking. The terms signs require blue badge holders to register
their vehicle at a terminal for three hours free parking.
However, you were not aware of this condition of parking because
the operator did not display the terms and conditions in a
position that they could be read without needing to leave the
vehicle. What condition that was visible, you complied with.
Any claim would not stand up in court, which is the most likely
whay his will be defeated. G24 are a vexatious firm of
ex-clampers. We will assist you in defeating this but you will
have to follow the advice we give.
Are you prepared to fight this all the way if necessary?
#Post#: 60445--------------------------------------------------
Re: Blue Badge parking - failed to authorize Blue Badge
DIR By: Chris_S
Date: March 3, 2025, 3:29 pm
---------------------------------------------------------
Dear b789, thank you kindly for your response and offer to help.
Yes, I am prepared to fight it all the way. Please see full
Notices to Keeper here:
First notice:
HTML https://ibb.co/Nqcjm1r
and
HTML https://ibb.co/Jjz7m43V
Second notice:
HTML https://ibb.co/WNbjBhjq
and
HTML https://ibb.co/CpdpKrGh.
Please let me know if you need anything else. Thank you, Chris.
#Post#: 61385--------------------------------------------------
Re: Blue Badge parking - failed to authorize Blue Badge
DIR By: b789
Date: March 8, 2025, 1:32 pm
---------------------------------------------------------
Maybe you didn't reveal the drivers identity if they are
requesting it in their response to your appeal. If so, send the
following as a formal complaint, separately for each PCN, to
G24:
--- Quote ---
> Subject: Formal Complaint Regarding Unlawful Parking Charge &
KADOE Breach
>
> G24 Ltd
> Complaints Department
> PO BOX 3320
> Gerrards Cross
> SL9 8WT.
>
> By email to: info@g24.co.uk
>
> Dear G24 Ltd,
>
> Re: Parking Charge Notice [PCN Reference]
>
> I write in response to your recent correspondence requesting
the driver’s details and to escalate this as a formal complaint
regarding your unlawful issuance of a Parking Charge Notice
(PCN) and your potential breach of the DVLA’s Keeper at Date of
Event (KADOE) contract.
>
> 1. No Contract Was Formed – The Driver Fully Complied with the
Only Visible Terms
>
> Your signage at the disabled bays clearly states:
>
> [indent]"Disabled bays are for disabled badge holders only.
> All Disabled Blue Badge Holders must clearly display their
badge to prevent being issued with a PCN."[/indent]
>
> The driver complied fully with these terms by displaying the
Blue Badge. No other terms were visible, and no requirement to
register the badge or pay a tariff was mentioned on the only
sign at the disabled bays.
>
> Any additional terms—if they exist—were not visible from
within the vehicle and were not in the immediate vicinity of the
disabled bays. The driver could not have agreed to any hidden
terms, making this charge unenforceable.
>
> 2. Breach of the Private Parking Single Code of Practice
(PPSCoP)
>
> Your failure to provide visible terms near the disabled bays
directly contravenes Section 4.1 of the PPSCoP, which states:
>
> [indent]"The parking operator must ensure that at least one
sign containing the terms and conditions for parking can be
viewed without the driver needing to leave the vehicle, in order
for drivers with a disability to be able to make an informed
decision on whether to park at the premises."[/indent]
>
> Since there was no such sign near the disabled bays, you have
failed to comply with the PPSCoP, meaning no enforceable
contract was formed. This also raises concerns about
discriminatory practices against disabled motorists.
>
> 3. No Keeper Liability – Your Notice to Keeper Fails PoFA 2012
>
> Your Notice to Keeper (NtK) was issued too late to comply with
the 14-day limit for delivery as required under Schedule 4,
Paragraph 9(5) of PoFA 2012, meaning you cannot transfer
liability to the registered keeper.
>
> Furthermore, your NtK contains the following unlawful and
misleading statement:
>
> [indent]"If we do not know both the name of the driver and a
current address for service for the driver, we may assume you to
be the driver and you may incur further charges."[/indent]
>
> This is not permitted under PoFA, and any attempt to infer
keeper liability outside of PoFA is misrepresentation of legal
position, which can be considered fraudulent misrepresentation
under the Fraud Act 2006, Section 2.
>
> Since you are not relying on PoFA, you cannot lawfully pursue
the registered keeper. Any further demands directed at me as the
keeper will be reported as harassment.
>
> 4. Misuse of Keeper Data & Breach of the DVLA’s KADOE Contract
>
> Since your signage fails to form a contract, and you cannot
establish liability under PoFA, you had no reasonable cause to
obtain my Keeper data from the DVLA.
>
> The DVLA’s KADOE contract strictly requires that Keeper data
can only be accessed where:
>
> [indent]• A parking charge is lawfully enforceable
> • The operator fully complies with relevant legislation and
the applicable Code of Practice[/indent]
>
> You have failed on both counts. As a result, I am formally
reporting this case to the DVLA and demanding an investigation
into your unlawful data access and potential suspension of your
KADOE access.
>
> I will also be escalating this to the Information
Commissioner’s Office (ICO) for data protection breaches under
UK GDPR.
>
> 5. Required Action from G24 – Formal Complaint
>
> I now require the following within 14 days:
>
> [indent]1. Immediate cancellation of the PCN due to lack of
enforceability.
> 2. Written confirmation that my Keeper data has been erased
and will not be processed further.
> 3. A full response to this formal complaint, including an
explanation of why you obtained my Keeper data without a lawful
basis.[/indent]
>
> Failure to respond adequately will result in further action,
including complaints to:
>
> [indent]• The DVLA – for a full KADOE contract breach
investigation
> • The ICO – for UK GDPR violations
> • My MP – regarding the misuse of DVLA data by private parking
firms[/indent]
>
> 6. Data Protection Warning – Cease & Desist Further Processing
of My Data
>
> Under UK GDPR, you are unlawfully processing my personal data.
You had no legal basis to obtain or retain my information. If
you fail to cancel this charge, I will escalate this as a data
protection breach to the ICO, and you may face enforcement
action.
>
> I expect a substantive response within 14 days. If you fail to
cancel the charge, I will escalate this further.
>
> This is your final warning. If I receive any further demands,
I will take all necessary legal action to hold you accountable.
>
> Yours faithfully,
>
> [Your Name]
> Registered Keeper of Vehicle [Registration Number]
--- End Quote ---
You can also submit a complaint to the DVLA at the same time.
#Post#: 61508--------------------------------------------------
Re: Blue Badge parking - failed to authorize Blue Badge
DIR By: Chris_S
Date: March 9, 2025, 3:58 pm
---------------------------------------------------------
Thank you. I have emailed the letters and will send copies by
email tomorrow. I will let you know what happens next. Kind
Regards, Chris
#Post#: 61532--------------------------------------------------
Re: Blue Badge parking - failed to authorize Blue Badge
DIR By: b789
Date: March 9, 2025, 6:49 pm
---------------------------------------------------------
Make sure you do the DVLA complaint too. That is probably the
one they most fear. If there are enough regular complaints about
their KADOE breaches, the DVLA will be forced to act and they
risk having their access to DVLA data suspended or completely
withdrawn.
#Post#: 64891--------------------------------------------------
Re: Blue Badge parking - failed to authorize Blue Badge
DIR By: Chris_S
Date: March 30, 2025, 2:08 pm
---------------------------------------------------------
Hello again,
I have received the responses from G24. Unsurprisingly, they
have stuck to their guns. Standard reply, not addressing issues
raised in my complaint. Responses to both PCNs are identical,
please see here:
HTML https://ibb.co/HTH89xv1
HTML https://ibb.co/HLR5v17R
HTML https://ibb.co/gbfcGPtH
What should be my next step?
Thank you, Chris
#Post#: 64951--------------------------------------------------
Re: Blue Badge parking - failed to authorize Blue Badge
DIR By: b789
Date: March 31, 2025, 6:51 am
---------------------------------------------------------
I presume that that is G24's response to the formal complaint
letter you were advised to send. Did you make a formal complaint
to the DVLA? If not, I will provide advice on how to do that. It
takes minutes to do online.
As this is likely to escalate to a court claim, which is a good
thing, I propose a few things...
As the core defence will be the fact that no contract was formed
due to the deficient signage and their failure to comply with
section 4.1 of the PPSCoP, as outlined in your formal complaint,
it is not worth pursuing the no Keeper liability angle because
it would become obvious that the Keeper was also the driver in
this instance.
I suggest a formal complaint to the IPC. Not because I expect
them to challenge G24 meaningfully or that you can expect a
reversal of the PCN or any finding in your favour, but because
it establishes a paper trail of reasonable conduct by you.
If G24 escalate this to a court claim, being able to show you
pursued every formal complaint route, including their ATA,
reinforces your reasonableness. It paints G24 as unresponsive
and inflexible, especially when the IPC fail to engage with the
PPSCoP breach or visible signage issue.
A weak, dismissive, or copy-paste response from the IPC (which
is highly likely) can be used as evidence of:
[indent]• Lack of genuine oversight by the ATA
• Lack of meaningful redress in the system for disabled
motorists
• Support for a Parliamentary or DVLA complaint about KADOE
access oversight[/indent]
The breach of Section 4.1 of the PPSCoP is specifically within
IPC’s remit. Even if they brush it off, you’ve now anchored your
complaint to their own Code, and their failure to uphold it
supports a future claim of systemic failure.
So, I suggest the following as your formal complaint to the IPC
by email to complaints@theipc.info and CC in yourself:
--- Quote ---
> To: complaints@theipc.info
>
> Subject: Formal Complaint – G24 Ltd – Failure to Comply with
PPSCoP Section 4.1
>
> Dear Sir/Madam,
>
> I am submitting this formal complaint regarding G24 Ltd and
their handling of Parking Charge Notice [insert PCN reference],
issued in relation to Edmonton Green Shopping Centre, 62 Smythe
Close, London, N9 0TZ.
>
> The complaint concerns G24’s failure to comply with Section
4.1 of the Private Parking Single Code of Practice (PPSCoP).
Specifically, the only signage visible from the disabled bay
stated:
>
> [indent]“Disabled bays are for disabled badge holders only.
All Disabled Blue Badge Holders must clearly display their badge
to prevent being issued with a PCN.”[/indent]
>
> The Blue Badge was correctly displayed at all times. No other
terms were visible from the vehicle. Therefore, even if a
contract could have been formed, the driver complied fully with
all terms actually conveyed, meaning no breach occurred. If
other terms existed elsewhere, they were not visible to the
driver and cannot form part of any alleged agreement.
>
> As I was with my disabled son who requires constant attention,
it is not feasible to leave the vehicle to search for hidden
signs elsewhere in the car park. Section 4.1 of the PPSCoP
requires that at least one sign containing the terms and
conditions must be viewable without the driver needing to leave
the vehicle, particularly for disabled motorists.
>
> G24’s signage setup failed to comply with this requirement,
resulting in a charge issued despite full compliance with the
only visible sign. This is both a breach of the Code and
potentially discriminatory.
>
> I raised these issues clearly in both the initial appeal and a
formal complaint to G24. The operator failed to 'respond
meaningfully' to the formal complaint and did not engage with
the specific points raised. This is a further breach of PPSCoP
Section 11.2, which requires operators to provide a transparent
complaints procedure and to issue a 'meaningful response' to
such complaints, particularly when they concern the handling of
a Parking Charge Notice.
>
> This complaint is submitted for the record and in case G24
escalate the matter to court or debt recovery. While I hold
limited expectations regarding impartial redress, I nonetheless
expect the IPC to demonstrate that it is capable of holding its
members to account, as required under the Private Parking Single
Code of Practice.
> If the IPC is unwilling or unable to ensure that operators
respond meaningfully to formal complaints or comply with
mandatory signage requirements under Section 4.1 of the PPSCoP,
I will be forced to draw adverse inferences about the efficacy
and independence of the IPC's complaints process and may raise
this with the DVLA and other relevant authorities.
>
> Please acknowledge receipt and confirm that this complaint
will be recorded.
>
> Yours faithfully,
>
> [Your Name]
> [Your Address]
> [Vehicle Registration Number]
> [PCN Reference Number]
--- End Quote ---
So, for now, get that off to the IPC. Below is the instruction
on how to make the DVLA complaint:
[indent]• Go to:
HTML https://contact.dvla.gov.uk/complaints
• Select: “Making a complaint or compliment about the Vehicles
service you have received”
• Enter your personal details, contact details, and vehicle
details
• Use the text box to summarise your complaint or insert a
covering note
• You will then be able to upload a file (up to 19.5 MB) — this
can be your full complaint or supporting evidence
That’s it.[/indent]
The DVLA is required to record, investigate and respond to every
complaint about a private parking company. If everyone who
encounters a breach took the time to submit a complaint, we
might finally see the DVLA take meaningful action—whether that
means curtailing or removing KADOE access altogether.
For the text part of the complaint the webform could use the
following:
[indent]I am submitting a formal complaint against G24 Ltd, an
IPC AOS member with DVLA KADOE access, for breaching the BPA/IPC
Private Parking Single Code of Practice (PPSCoP) after obtaining
my personal data.
While G24 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.
Specifically, G24 issued a PCN based on alleged breach of
parking terms that were not visible from the vehicle. They
failed to provide signage in accordance with Section 4.1 of the
PPSCoP, especially critical for disabled motorists, and ignored
a formal complaint which raised this point. A Blue Badge was
properly displayed and the only visible sign had been fully
complied with.
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 attached a supporting statement outlining the breach and
request that this matter be fully investigated. Please
acknowledge receipt and confirm the reference number for this
complaint.[/indent]
Then you could upload the following as a PDF file for the formal
complaint itself:
[indent]SUPPORTING STATEMENT
Complaint to DVLA – Breach of KADOE Contract and BPA/IPC Private
Parking Single Code of Practice (PPSCoP)
Operator name: G24 Ltd
Date of PCN issue: 7th February 2025
Vehicle registration: [INSERT VRM]
I am submitting this complaint to report a misuse of my personal
data by G24 Ltd, who obtained my keeper details from the DVLA
under the KADOE (Keeper At Date Of Event) contract.
Although G24 may have had reasonable cause to request my data
initially, the way they have used that data amounts to unlawful
processing. This is because they have acted in breach of the
Private Parking Single Code of Practice (PPSCoP)—the mandatory
framework which governs their access to DVLA data.
The breaches are as follows:
[indent]1. Failure to Comply with Section 4.1 of the PPSCoP –
Signage Accessibility
G24 failed to provide a sign containing the full terms and
conditions of parking that could be viewed from the vehicle. The
only sign visible in the disabled bay stated:
[indent]“Disabled bays are for disabled badge holders only. All
Disabled Blue Badge Holders must clearly display their badge to
prevent being issued with a PCN.”[/indent]
This sign was complied with in full. No other terms (e.g.
payment requirements or Blue Badge registration) were visible or
available from the vehicle. This directly contravenes PPSCoP
Section 4.1, which requires that:
[indent]“The parking operator must ensure that at least one sign
containing the terms and conditions for parking can be viewed
without the driver needing to leave the vehicle...”[/indent]
2. Discriminatory and Unlawful Conduct Toward Disabled Motorists
The driver was accompanied by a disabled child who required
constant supervision. Expecting a parent in such a situation to
leave the vehicle to hunt for signage is both unreasonable and
discriminatory. G24 failed to make reasonable adjustments,
breaching the spirit of the Equality Act 2010 and the
accessibility obligations embedded within the PPSCoP.
3. Failure to Respond Meaningfully to a Formal Complaint
G24 failed to engage with the substance of a formal written
complaint. The response was generic and ignored the specific
allegations, including the signage breach and the display of a
valid Blue Badge. This contravenes PPSCoP Section 11.2, which
requires operators to provide a transparent complaints procedure
and a meaningful response to complaints relating to PCNs.
4. Misleading Appeals Information – PPSCoP Section 8.1.2(e)
Breach
G24’s Notice to Keeper informs the Keeper that any appeal “must
be made within 28 days of the date of issue” of the NtK. This
directly contradicts Section 8.1.2(e) of the PPSCoP, which
states:
[indent]“The parking operator must ensure that a notice informs
the recipient: that if the recipient appeals within 28 days of
receiving the parking charge, the right to pay at the rate
applicable...”[/indent]
By unlawfully shortening the Keeper’s appeal window, G24 has
misrepresented the appeals process and placed an unfair
restriction on the Keeper’s rights. This breach is not merely
technical — it may cause a recipient to believe they are out of
time when, in fact, the 28-day period has not yet
started.[/indent]
These are not minor breaches. They show a disregard for the
regulatory framework that governs the use of DVLA Keeper data.
Once that data has been obtained, the KADOE contract allows it
to be used only for pursuing charges in full compliance with the
Code of Practice.
G24’s failure to follow the Code renders their continued use of
my data unlawful. I therefore ask the DVLA, as data controller,
to investigate this breach and consider whether enforcement
action — including suspension of KADOE access — is appropriate.
The DVLA is the data controller for keeper data released under
KADOE and is therefore responsible for ensuring that such data
is not misused by operators. I request that the DVLA:
[indent]1. Investigates this complaint in full
2. Confirms whether a breach has occurred
3. Considers appropriate enforcement action, including
suspension or termination of KADOE access if necessary[/indent]
As the DVLA complaints form only permits uploading a single
file, I can provide further evidence upon request should it be
required.
Name: [Insert your name]
Date: [Insert today’s date]
#Post#: 64954--------------------------------------------------
Re: Blue Badge parking - failed to authorize Blue Badge
DIR By: Chris_S
Date: March 31, 2025, 7:21 am
---------------------------------------------------------
Thank you, I really appreciate your help with this problem.
I will submit the complaint to IPC as well as DVLA.
I am actually not a Keeper of the vehicle, my wife is. I was the
driver in both instances though. I am not sure if that makes any
difference at this point?
Kind Regards,
Chris
#Post#: 64956--------------------------------------------------
Re: Blue Badge parking - failed to authorize Blue Badge
DIR By: DWMB2
Date: March 31, 2025, 7:34 am
---------------------------------------------------------
Yes, potentially. In your opening post you said that you had
received PCNs. Was it actually your wife who received them?
*****************************************************
Page 1 of 4
DIR Next Page