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       #Post#: 64090--------------------------------------------------
       Re: APCOA - No Valid Payment - Railway Byelaws Bedford Station
   DIR By: G6PRK
       Date: March 25, 2025, 10:42 am
       ---------------------------------------------------------
       Amazing, thank you [member=26]b789[/member]. Complaint response
       sent.
       On the MP letter, I assume it should be the MP for my
       constituency rather than the one where the Railway Station is?
       Any advantage to sending to both?
       #Post#: 64113--------------------------------------------------
       Re: APCOA - No Valid Payment - Railway Byelaws Bedford Station
   DIR By: b789
       Date: March 25, 2025, 1:13 pm
       ---------------------------------------------------------
       Yes. It is always your own MP. They can, if necessary contact
       the MP for the constituency elsewhere.
       #Post#: 64116--------------------------------------------------
       Re: APCOA - No Valid Payment - Railway Byelaws Bedford Station
   DIR By: DWMB2
       Date: March 25, 2025, 1:19 pm
       ---------------------------------------------------------
       When contacting your MP, alongside your name I would also
       include your address.
       In the past when I've contacted my MP, one of their staff has
       got back to me to ask what my address is before passing the
       message onto the MP, to make sure that I'm a constituent of
       theirs.
       #Post#: 64117--------------------------------------------------
       Re: APCOA - No Valid Payment - Railway Byelaws Bedford Station
   DIR By: b789
       Date: March 25, 2025, 1:24 pm
       ---------------------------------------------------------
       Yes, they need the address to confirm that you are one of their
       constituents.
       #Post#: 65679--------------------------------------------------
       Re: APCOA - No Valid Payment - Railway Byelaws Bedford Station
   DIR By: G6PRK
       Date: April 4, 2025, 1:03 pm
       ---------------------------------------------------------
       I've received nothing following my reply to their useless
       response to my complaint. Their complaints policy states 28 days
       to respond fully to a complaint, or if it will be longer,
       they'll let me know, which they haven't surprise surprise. As
       such I'm going to reply again, pointing that out.
       [member=26]b789[/member] / anyone else with a view - is there
       any escalatory language you would suggest in that reply?
       Additionally, I wonder given there is a data protection element,
       and somewhat just for fun, if it might be with a SAR at this
       stage? Any thoughts on that / any suggested wording? It's been a
       few years since I've done one.
       #Post#: 65711--------------------------------------------------
       Re: APCOA - No Valid Payment - Railway Byelaws Bedford Station
   DIR By: b789
       Date: April 5, 2025, 2:28 am
       ---------------------------------------------------------
       Yes, a follow-up is appropriate. Given their failure to provide
       a full response within the 28-day timeframe as required under
       their own complaints policy—and by Section 11.4 of the Private
       Parking Sector Single Code of Practice (PPSCoP)—you are well
       within your rights to write again, formally registering their
       non-compliance and warning of your intent to escalate.
       Given the data handling issues raised—including inconsistency in
       identifying the liable party, failure to provide clarity on
       lawful processing grounds, and the suggestion that personal data
       may have been shared improperly—a Subject Access Request (SAR)
       under the UK GDPR would be appropriate at this point.
       Here is a suggested response regarding the failure to address
       the formal complaint:
       --- Quote ---
       > Subject: Failure to Respond to Formal Complaint – Final
       Reminder Prior to Escalation
       >
       > Dear [Complaints Handler / APCOA Complaints Department],
       >
       > I am writing to express my deep dissatisfaction with your
       continued failure to properly address the formal complaint
       submitted on [insert date]. Your email of 22 March 2025—while
       acknowledging cancellation of the spurious “Penalty Notice”—did
       not even attempt to provide a full and substantive response to
       the serious matters raised.
       >
       > I remind you once again that your obligations are clear. As
       per Section 11.4 of the BPA/IPC Private Parking Sector Single
       Code of Practice (PPSCoP):
       >
       > [indent]“A full response to a complaint must be provided by
       the parking operator within 28 days of its receipt unless
       exceptional circumstances apply, in which case the complainant
       must be kept informed by the operator.”[/indent]
       >
       > No such full response has been received, and no justification
       has been offered for this delay. In the absence of any
       reasonable explanation, your failure to comply with both your
       own policy and the industry Code of Practice amounts to a
       flagrant disregard for accountability and transparency.
       >
       > To be absolutely clear: this matter is not closed. You are
       under a continuing obligation to provide a detailed and
       point-by-point reply to the concerns I raised. Your attempt to
       offer a generic, dismissive response while hoping the issue
       would disappear has been noted and will not be accepted.
       >
       > I will now allow a further 7 days for you to issue a complete
       and substantive response addressing all of the following:
       >
       > [indent]• The basis on which you purport to issue “Penalty
       Notices” that imply criminal liability, despite being a private
       contractor with no statutory authority.
       > • The misuse of Byelaw 14 to pursue civil enforcement outside
       the scope of prosecution under Byelaw 24(1).
       > • The misleading reference to criminal sanctions and statutory
       enforcement powers in your correspondence.
       > • Your misuse and misinterpretation of DVLA keeper data in an
       attempt to establish liability.
       > • The contradictory and inconsistent statements made by your
       staff regarding the nature of the alleged contravention, the
       liable party, and the appeals process.
       > • The failure of your customer service agents to engage with
       basic queries or offer any clarity to the recipient of your
       demands.
       > • The apparent mishandling of personal data, including
       comments suggesting that information disclosed to me "shouldn’t
       have been," which raises significant concerns over your internal
       data governance and staff training.
       > • The lack of clarity on what alleged contravention occurred,
       and why no coherent explanation has ever been given.[/indent]
       >
       > If a full response is not received within 7 days, I will
       escalate this matter formally to the British Parking
       Association, the DVLA, and, where applicable, to the Information
       Commissioner's Office. I also reserve the right to report the
       matter to the police on the basis that your use of intimidating
       and misleading documents may constitute an offence under Section
       2 of the Fraud Act 2006.
       >
       > Let there be no doubt: this is not a matter that will simply
       be allowed to lapse. You are now on notice to comply with your
       obligations in full.
       >
       > Yours sincerely,
       >
       > [Your Name]
       > [Your Address]
       > [Reference number, if applicable]
       --- End Quote ---
       Here is the suggested format of a SAR which you email as a PDF
       attachment to the DPO and CC in yourself. Their details will be
       in the privacy policy on their website:
       --- Quote ---
       > Dear Sir/Madam,
       >
       > RE: SUBJECT ACCESS REQUEST
       >
       > I write to make a formal Subject Access Request in respect of
       my personal information. I am entitled to make this request
       under data protection laws. The request is made in accordance
       with section 45 of the Data Protection Act 2018 and Article 15
       of the retained EU General Data Protection Regulation 2016/679
       (UK GDPR). You can identify my records using the information
       which is listed below.
       >
       > For clarity, this request is directed to APCOA Parking (UK)
       Ltd and all affiliated companies and data controllers within the
       APCOA group, including but not limited to:
       >
       > [indent]– APCOA Parking (UK) Ltd
       > – APCOA Parking Holdings (UK) Ltd
       > – APCOA Facilities Management (UK) Ltd
       > – APCOA Parking Services Ltd
       > – APCOA Parking Group GmbH (as the parent company)
       > – Any other UK or EEA-based subsidiaries, affiliates, or
       contractors acting as data processors or controllers on behalf
       of the APCOA group[/indent]
       >
       > Requester (data subject) information
       >
       > (a) Full name:
       > (b) Address:
       > (c) Email address:
       > (d) Telephone number:
       > (e) PCN number:
       > (f) VRM:
       >
       > Requested information
       >
       > [indent](a) Copies of my personal data
       >
       > I request that I am provided with full copies of all personal
       data relating to me which is held by the APCOA group as outlined
       above. I would prefer to receive an electronic copy of the
       requested information.
       >
       > (b) Purpose of the processing
       >
       > Please confirm within your response the purpose(s) for which
       my personal data was collected and processed by any part of the
       APCOA group.
       >
       > (c) Categories of the data
       >
       > Please confirm which categories of my personal data have been
       collected or processed by any APCOA group company.
       >
       > (d) Sharing of the data
       >
       > Please confirm which recipients (including any third parties)
       my personal data has been or may be disclosed to. This includes
       disclosure to debt collection agencies, solicitors, or
       international entities. Please also confirm whether any data has
       been transferred outside the UK and, if so, the applicable
       safeguards in place.
       >
       > (e) Storage of the data
       >
       > Please provide the applicable data retention periods, or if no
       specific period is available, the criteria used to determine
       such periods.
       >
       > (f) Source of the data
       >
       > Please confirm the original source(s) of the data held about
       me.
       >
       > (g) Details about automated decision-making
       >
       > Please advise whether any automated decision-making has taken
       place using my data and provide full details of the logic
       involved and potential effects of such decisions.
       >
       > (h) Existence of my rights
       >
       > Please confirm my rights in respect of this data, including
       the rights to rectification, erasure, restriction, and objection
       to processing.[/indent]
       >
       > Responding to my request
       >
       > The above contains all necessary information in order for you
       to process my request and any delay by yourselves will not
       absolve you from providing me with the information within one
       calendar month of the date above as this is being sent to you as
       an attachment by email.
       >
       > I believe that the information which has been requested should
       be readily available to you.
       >
       > This request should not therefore fall within the legal
       definition of an excessive or manifestly unfounded request and
       should not attract any processing fee.
       >
       > I would be grateful for your assistance in processing my
       request within the required one month period of your receipt.
       >
       > Yours faithfully,
       >
       > [Your Full Name]
       --- End Quote ---
       #Post#: 65912--------------------------------------------------
       Re: APCOA - No Valid Payment - Railway Byelaws Bedford Station
   DIR By: G6PRK
       Date: April 7, 2025, 5:24 am
       ---------------------------------------------------------
       Thanks for that [member=26]b789[/member].
       Within about 20 minutes of sending the follow up this morning I
       got a response to my previous email:
       --- Quote ---
       > Dear [Name],
       >
       > We are currently reviewing the points raised in your complaint
       and a full response will be issued to your complaint in due
       course.
       >
       > Thank you for your patience during this time
       >
       > Kind regards,
       > [Name]
       > Complaints Handler
       > APCOA
       --- End Quote ---
       Good old 'due course'.
       #Post#: 69369--------------------------------------------------
       Re: APCOA - No Valid Payment - Railway Byelaws Bedford Station
   DIR By: G6PRK
       Date: April 30, 2025, 8:03 am
       ---------------------------------------------------------
       [member=26]b789[/member] two updates I'd appreciate your
       thoughts on...
       1. They've finally responded to my complaint (on Saturday) with
       [I]some[/I] level of depth. Where would you suggest I go from
       here? The PNs are all cancelled so I don't have anything to gain
       in that regard, but keen to keep pressing them on their
       inadequacies.
       --- Quote ---
       > Thank you for your patience whilst this has been investigated.
       >
       > • Why are you, an unregulated private parking company, issuing
       fake “Penalty Notices” designed to mislead motorists into
       believing you possess statutory or criminal enforcement powers
       which you clearly do not?
       >
       > APCOA operate under and are regulated by the British Parking
       Association (BPA) and agree to adhere to the sector single code
       of practice.
       >
       > We can confirm that this Penalty Notice is issued as a civil
       matter. The penalty notice system is an established mechanism
       designed to address breaches of the railway byelaws in a way
       that is proportionate and fair. These notices are not intended
       to suggest criminal intent or prosecution at the outset but to
       offer the opportunity to resolve matters without escalation.
       Should the recipient fail to engage or resolve the matter,
       criminal enforcement under Byelaw 14(1) may be pursued.
       >
       >
       > • Why are you attempting to rely on Railway Byelaws to justify
       civil enforcement of minor parking indiscretions, despite
       knowing full well that such matters do not fall within the scope
       of criminal prosecution under Byelaw 24(1)?
       > •Additionally, your use of the term “Penalty Notice”, coupled
       with the implied criminal consequences, is highly misleading.
       You are not a prosecuting authority, and your notice cannot be
       lawfully construed as anything more than a speculative civil
       invoice. Its presentation—suggesting legal obligation and
       criminal liability—appears to constitute a breach of Section 2
       of the Fraud Act 2006, namely:
       >
       > “False representation made dishonestly and with intent to make
       a gain or cause loss.”
       >
       >
       > In other words, this was an attempt at extortion by deception.
       >
       > The term “Penalty Notice” is used because the breach of
       railway byelaws, such as unauthorised parking, constitutes a
       potential statutory offence. This is entirely different from a
       private parking charge, as our notices pertain to statutory
       enforcement of the byelaws, which may involve criminal liability
       in some cases. The presentation of the notice reflects the legal
       process in place, and it has been reviewed and approved to
       ensure compliance with the applicable legal standards.
       >
       >
       > • Why are you directing recipients to a private appeals
       process in circumstances where you are claiming a statutory
       breach? Appeals panels have no jurisdiction over alleged
       criminal offences.
       >
       > It is important to clarify that while the alleged breach may
       indeed involve a potential criminal offence under the railway
       byelaws, the appeals process we reference is an administrative
       review mechanism designed to ensure that the matter is properly
       investigated, and the correct party is held accountable.
       > In accordance with the enforcement procedures under Byelaw 14
       of the Railway Byelaws, the appeals process is a non-judicial
       review that allows recipients to challenge the validity of the
       charge based on the circumstances surrounding the alleged
       breach. This process provides an opportunity for the train
       operating company or relevant authority to review whether the
       penalty notice was appropriately issued, and for any mitigating
       factors to be considered.
       > It is important to note that this appeals process does not
       alter or replace the statutory provisions under the byelaws. If
       the matter proceeds beyond the appeals stage, it may be referred
       for criminal prosecution if deemed necessary. The appeals
       process, therefore, acts as a preliminary step in ensuring that
       no unfair or incorrect penalties are applied, rather than
       replacing or overstepping the jurisdiction of the criminal
       justice system.
       > Any decision made by POPLA is only binding on the car park
       operator and therefore the use of this independent appeals
       service benefits the consumer/motorist.
       >
       >
       > • Why are you asserting that you have a legal basis to infer
       vehicle ownership from DVLA registered keeper data, when this is
       explicitly contradicted by the front page of the V5C and by DVLA
       guidance?
       > • Why are your communications inconsistent as to who you
       believe is liable—at times addressing the keeper, at other times
       the driver or “owner”—with no coherent explanation?
       >
       > Our access to DVLA data is governed by the Keeper at Date of
       Event (KADOE) contract, which permits APCOA to request the
       registered keeper’s details for the purpose of enforcing parking
       terms and conditions or pursuing relevant offences.
       >
       > While the V5C document does indicate that being the registered
       keeper is not proof of ownership in itself, there is a legal
       presumption that the registered keeper is the owner of the
       vehicle unless evidence to the contrary is provided. This is
       reflected in the Vehicle Excise and Registration Act 1994, which
       defines an “owner” as the person by whom the vehicle is kept. In
       the case of a registered vehicle, this is presumed to be the
       person in whose name the vehicle is registered.
       >
       > Accordingly, when investigating a breach of the railway
       byelaws, and in the absence of any information suggesting
       otherwise, it is both reasonable and appropriate for us to
       correspond with the registered keeper as the presumed owner of
       the vehicle. Under contract law, only the driver can be liable
       as they are present when the parking contract is both offered
       and accepted. However, under the Railway Byelaws, it is made
       clear that the owner is the liable party.
       >
       >
       > • Why are your communications inconsistent as to what
       contravention is even alleged to have taken place?
       >
       > The Penalty Notice clearly states that the Penalty Notice was
       issued for the offence of "Use of private car park without
       making a valid payment". Whilst payment was made for the parking
       session, the payment is deemed as invalid as the incorrect
       tariff was paid.
       >
       > The ANPR systems captured the vehicle entering Bedford Station
       car park at 07:31:29 meaning that the full one day tariff of
       £11.30 was due, however, as payment was only made at 13:08:38
       the incorrect tariff of £4.60 was paid due to the off peak
       tariff being activated at 10:00am.
       >
       >
       > • What failing occurred that allowed your customer service
       team to ignore straightforward questions from a customer
       attempting to resolve the matter?
       > • Why do different members of your staff have conflicting
       views on what information it is appropriate to disclose to a
       customer?
       >
       > The chat transcripts have been reviewed by APCOA management
       and has been found to be below the high standards that APCOA
       work to. As a result, an internal investigation has been
       conducted and a conclusion is that the fails were due to
       insufficient training of the customer service agents who handled
       your queries. The agents involved have now been given the
       required additional training.
       >
       > Whilst we’re unable to comment on internal processes and their
       outcomes, rest assured the level of customer service given to
       all customers, and the conduct of all APCOA staff is a top
       priority and as such, we are treating this matter extremely
       seriously.
       >
       >
       > APCOA would like to take this opportunity to thank you for
       bringing this to our attention and also offer our sincere
       apologies for the less than satisfactory level of customer
       service that you received on this occasion.
       >
       >
       >
       > • Given I was told that information was disclosed to me which
       "shouldn’t have been", what assurances can you provide that my
       personal data—and that of your other customers—is being handled
       lawfully and securely?
       > • On what lawful basis under the UK GDPR are you processing
       and storing my personal data?
       >
       > We can confirm that your personal data has been redacted from
       the below cases:
       >
       >
       > Please see below links to both APCOA's privacy policy and data
       protection policy which outline how APCOA handles your personal
       data.
       >
       > APCOA Privacy Policy -
  HTML https://www.apcoa.co.uk/privacy-policy/
       > APCOA Data Protection Policy -
  HTML https://www.apcoa.co.uk/index.php?id=6296
       >
       > If you have any concerns or queries relating to how APCOA have
       handled your details, you can contact our Data Protection Office
       via email on DPO@apcoa.com
       >
       > Kind regards,
       > Complaints Handler
       > APCOA
       --- End Quote ---
       2. They have just today, 27 days after submitting my SAR,
       responded as follows. They are asking me to fill a form (which I
       won't do) and demanding V5C and ID. The V5C seems completely
       unneccesary, and suggesting the 30 days starts from this point
       seems completely unreasonable.
       --- Quote ---
       > Good Afternoon,
       >
       > Thank you for your email to the Data Protection Office at
       APCOA Parking (UK).
       >
       > Please complete the attached form and return in order that we
       can provide the requested information.
       >
       > Please be advised that you are not obliged to complete this
       form to make a request, but it’s helpful for us to know what
       you’re looking for so we can respond fully and promptly.
       Although the completion of this form is not a requirement, proof
       of identification is still required. The timescale for
       responding to your request will start when we receive this.
       >
       > Yours Sincerely,
       >
       --- End Quote ---
       #Post#: 69374--------------------------------------------------
       Re: APCOA - No Valid Payment - Railway Byelaws Bedford Station
   DIR By: b789
       Date: April 30, 2025, 8:41 am
       ---------------------------------------------------------
       Did you send the email to your MP?
       That response to your complaint to APCOA is damning for them:
       [indent]• They explicitly call it a "Penalty Notice", while also
       admitting it is “a civil matter.” That contradicts the statutory
       basis implied by the term.
       • They claim criminal prosecution is only a possibility if
       people “fail to engage”—a pressure tactic with no legal
       substance if they never intend to prosecute.
       • They state they are enforcing private contractual terms—not
       statutory offences—but do so under the guise of Byelaw 14
       enforcement.
       • They collect and retain revenue for themselves or the
       landowner, not the Treasury, proving these are not legitimate
       statutory penalties.[/indent]
       This completely undermines any claim that these are lawful
       statutory fines. As I stated, fraud by false representation
       under Section 2 of the Fraud Act 2006 is arguably engaged, and
       DVLA data was clearly accessed and processed under a false
       pretext.
       For now, make a formal complaint to the DVLA.
       Here’s how to make a 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:
       --- Quote ---
       > I am submitting a formal complaint against APCOA Parking (UK)
       Ltd, a BPA AOS member with DVLA KADOE access, for breaching the
       Private Parking Sector Single Code of Practice (PPSCoP) and
       misusing my personal data obtained from the DVLA.
       >
       > While APCOA may have had reasonable cause to request my data
       initially, they subsequently used it to issue a document titled
       “Penalty Notice” that falsely implied criminal liability and
       statutory enforcement under railway byelaws. However, in
       response to a formal complaint, APCOA have now explicitly
       admitted that their notices are in fact civil in nature, and
       that they are relying on private contract law to justify
       enforcement and collection.
       >
       > This is a damning admission that they accessed DVLA data on
       the false premise of pursuing a statutory offence, only to
       repackage the enforcement as a civil matter once challenged.
       This is a clear breach of the KADOE contract and the PPSCoP,
       both of which prohibit misleading conduct and misuse of DVLA
       data.
       >
       > The DVLA, as data controller, is responsible for ensuring that
       personal data is not misused following its release under KADOE.
       This complaint is not about the initial access to my data, but
       rather the subsequent unlawful use of it once it became clear
       that the operator had no legal basis to pursue a penalty under
       the statutory regime.
       >
       > I have attached a supporting statement and request a full
       investigation. Please confirm receipt and provide a reference
       number for this complaint.
       --- End Quote ---
       Then you could upload the following as a PDF file for the formal
       complaint itself:
       --- Quote ---
       > SUPPORTING STATEMENT
       >
       > Complaint to DVLA – Breach of KADOE Contract and PPSCoP
       >
       > Operator name: APCOA Parking (UK) Ltd
       > Date of Penalty Notice issue: [INSERT DATE]
       > Vehicle registration: [INSERT VRM]
       >
       > I am submitting this complaint to report a misuse of my
       personal data by APCOA Parking (UK) Ltd, who obtained my keeper
       details from the DVLA under the KADOE (Keeper At Date Of Event)
       contract.
       >
       > While APCOA may have had reasonable cause to request my data
       initially, they subsequently used it to issue a document styled
       as a “Penalty Notice” for an alleged breach of Railway Byelaws.
       The notice mimicked the form and language of a statutory
       penalty, implied criminal liability, and threatened escalation
       under Byelaw 14(1).
       >
       > However, in a formal written complaint response dated [INSERT
       DATE], APCOA made the following admissions:
       >
       > [indent]• The “Penalty Notice” is not a statutory enforcement
       measure, but a civil matter based on private contract law.
       > • Enforcement is pursued under contract law and not through
       the railway byelaw criminal framework.
       > • Revenue from the notice is retained by APCOA or the
       landowner—not remitted to the public purse—confirming it is not
       a fine issued by a prosecuting authority.[/indent]
       >
       > These admissions expose a clear deception: keeper data
       obtained under the pretext of enforcing statutory railway
       offences was instead used to pursue what APCOA now claims is a
       private contractual matter. This amounts to a misuse of personal
       data, a breach of the Private Parking Sector Single Code of
       Practice (PPSCoP), and a violation of the terms of the KADOE
       contract.
       >
       > More seriously, this conduct raises significant concerns under
       the Fraud Act 2006, specifically Section 2 – false
       representation. APCOA knowingly represented a private civil
       charge as a statutory “Penalty Notice” in order to induce
       payment from a motorist under threat of criminal consequences.
       This is not a minor procedural failing or mere miscommunication;
       it is arguably a criminal offence, and it must be treated as
       such.
       >
       > As the Data Controller, the DVLA bears direct responsibility
       for ensuring that personal data it supplies under KADOE is:
       >
       > [indent]• Used lawfully and fairly
       > • Not processed for misleading or deceptive purposes
       > • Not used in ways that facilitate or support criminal
       conduct[/indent]
       >
       > These responsibilities cannot be delegated or brushed aside.
       Where there is evidence that a KADOE recipient has used personal
       data in a manner that may constitute a criminal offence, the
       DVLA must act—whether by initiating proceedings under the KADOE
       contract, reporting the matter to enforcement agencies, or
       revoking access to its data systems.
       >
       > I request that the DVLA take the following actions:
       >
       > [indent]• Investigate APCOA’s conduct in this case
       > • Determine whether a breach of the KADOE contract and PPSCoP
       has occurred
       > • Refer the matter to the appropriate enforcement authority or
       police, given the potential criminality under the Fraud Act
       > • Suspend or terminate APCOA’s KADOE access if
       warranted[/indent]
       >
       > The attached correspondence from APCOA constitutes direct
       evidence of misrepresentation and unlawful processing. I trust
       the DVLA will treat this complaint with the seriousness and
       urgency that such conduct demands.
       >
       > Name: [INSERT YOUR NAME]
       > Date: [INSERT DATE]
       --- End Quote ---
       Attachments to Upload with the DVLA Complaint:
       [indent]1. This PDF supporting statement
       2. The APCOA complaint response email/letter (as proof of
       admission)
       3.The original PN issued by APCOA
       #Post#: 69376--------------------------------------------------
       Re: APCOA - No Valid Payment - Railway Byelaws Bedford Station
   DIR By: b789
       Date: April 30, 2025, 8:47 am
       ---------------------------------------------------------
       Regarding the SAR, a copy of the V5C is perfectly OK to use as
       verification of ID. However, if you do not want to provide a
       copy of that, I suggest you respond to the DPO with the
       following:
       --- Quote ---
       > Subject: Re: Subject Access Request – Reminder of Legal
       Obligations
       >
       > Dear Data Protection Officer,
       >
       > Thank you for your response dated [INSERT DATE].
       >
       > While I appreciate the need for identity verification, I must
       remind you that this request was submitted in my capacity as the
       Keeper, and I have already corresponded with APCOA on this
       matter using the same name and address you originally obtained
       from the DVLA.
       >
       > As such, you already have sufficient information to verify my
       identity. If you require confirmation, a copy of that prior
       correspondence can be provided to satisfy any reasonable
       verification requirement. However, requesting a V5C document is
       disproportionate in this context and not justified under Article
       12(6) of the UK GDPR.
       >
       > You are therefore reminded that:
       >
       > [indent]• I submitted a valid Subject Access Request on
       [INSERT DATE].
       > • The 30-day statutory period began on that date, not from
       when you receive additional documents you arbitrarily demand.
       > • Your continued delay in responding may amount to a breach of
       the UK GDPR.[/indent]
       >
       > I expect the SAR to be processed without further obstruction.
       If no response is provided within the statutory timeframe, I
       will refer the matter to the Information Commissioner’s Office
       without further notice.
       >
       > Yours sincerely,
       >
       > [Your Name]
       --- End Quote ---
       *****************************************************
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