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#Post#: 68762--------------------------------------------------
Re: ACE Security Services CN – Not Displaying a Valid Permit –
The Pelhams 1, Wimbledon, SW19 1NY
DIR By: b789
Date: April 26, 2025, 5:30 am
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Here’s how to make a DVLA complaint which you should also submit
immediately:
[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 Ace Security
Services, an IPC AOS member with DVLA KADOE access, for
breaching the Private Parking Single Code of Practice (PPSCoP)
after obtaining my personal data.
>
> While the Operator 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.
>
> 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 prepared a supporting statement setting out the nature
of the breaches and the Operator’s actions, and I request a full
investigation into this matter. I have attached the supporting
document.
>
> Please acknowledge receipt and confirm the 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: Ace Security Services
> Date of PCN issue: 13 March 2025
> Vehicle registration: DF14KYP
>
> I am submitting this complaint to report a misuse of my
personal data by Ace Security Services, who obtained my keeper
details from the DVLA under the KADOE (Keeper At Date Of Event)
contract.
>
> Although the parking company may have had reasonable cause to
request my data initially, the way they have used that data
afterwards amounts to unlawful processing. This is because they
have acted in breach of the Private Parking Single Code of
Practice (PPSCoP), which forms a mandatory requirement for
access to DVLA keeper data. The PPSCoP is part of the governance
framework that regulates how parking companies must behave once
they have received keeper data from the DVLA.
>
> The KADOE contract makes clear that keeper data may only be
used to pursue an unpaid parking charge in full compliance with
the Code of Practice. If a parking company fails to comply with
the PPSCoP after receiving DVLA data, their use of that data
becomes unlawful, as they are no longer using it for a permitted
purpose.
>
> In this case, Ace Security Services has breached the PPSCoP in
the following ways:
>
> [indent]• They issued a Charge Notice without recording or
specifying any "period of parking," in breach of the
requirements of both PoFA Schedule 4 and the PPSCoP. Instead,
they relied on a single observation time and a time of issue one
minute later. This fails to evidence that the vehicle remained
beyond the mandatory minimum "consideration period" required
under the PPSCoP, during which no contract can be formed.
> • They pursued a parking charge where there was no evidence
that any contract had been formed, contrary to the requirements
of the PPSCoP.
> • They issued a Notice to Keeper containing incorrect
information about the 28-day statutory period under PoFA,
misrepresenting the Keeper’s legal rights.
> [indent]This is wrong. PoFA Schedule 4 paragraph 8(2)(f)
requires the warning to state that the relevant period is "28
days beginning with the day AFTER" the day on which the notice
is given (deemed two working days after posting).
> By incorrectly wording the 28-day period, Ace Security
Services misrepresented the Keeper’s statutory rights, created
confusion over the legal timescale for payment and liability,
and failed to comply with the strict mandatory conditions of
PoFA required to transfer liability from the driver to the
Keeper.
> Strict adherence to PoFA wording is required. Failure to meet
these conditions invalidates any lawful basis for pursuing the
Keeper.[/indent]
> • They used the Keeper’s data for enforcement purposes despite
having failed to comply with the conditions under which they are
permitted to pursue keeper liability.
> • They therefore used my personal data for a purpose not
permitted by the KADOE contract or UK data protection
law.[/indent]
>
> These are not minor or technical breaches. They show a clear
disregard for the standards required under the current single
Code. As a result, the operator is no longer entitled to use the
keeper data they obtained from the DVLA, because the purpose for
which it was provided (a fair and lawful pursuit of a charge
under the Code) no longer applies.
>
> The DVLA remains the Data Controller for the data it releases
under KADOE, and is therefore responsible for ensuring that
personal data is not misused by third parties. This includes
taking action against AOS operators who breach the conditions
under which the data was provided. I am therefore asking the
DVLA to investigate this breach and to take appropriate action
under the terms of the KADOE contract.
>
> This may include:
>
> [indent]• Confirming that a breach has occurred
> • Taking enforcement action against the operator
> •Suspending or terminating their KADOE access if
warranted[/indent]
>
> I have attached relevant supporting material with this
statement. Please confirm receipt and provide a reference for
this complaint. I am also happy to provide further information
if required.
>
> Name: [INSERT YOUR NAME]
> Date: [INSERT DATE]
--- End Quote ---
#Post#: 68947--------------------------------------------------
Re: ACE Security Services CN – Not Displaying a Valid Permit –
The Pelhams 1, Wimbledon, SW19 1NY
DIR By: tobesb
Date: April 27, 2025, 4:42 pm
---------------------------------------------------------
Dear b789,
thank you for your help. I've emailed ACE Security Services.
I've also sent the complaint to the DVLA.
HTML https://i.ibb.co/kVLJ1Sg7/Screenshot-2025-04-27-at-22-37-40.png
I'll let you all know how we get on.
Best wishes,
Toby
#Post#: 70621--------------------------------------------------
Re: ACE Security Services CN – Not Displaying a Valid Permit –
The Pelhams 1, Wimbledon, SW19 1NY
DIR By: tobesb
Date: May 9, 2025, 3:44 am
---------------------------------------------------------
Update:
HTML https://i.ibb.co/YFfCCqcr/Screenshot-2025-05-09-at-09-38-42.png
#Post#: 71440--------------------------------------------------
Re: ACE Security Services CN – Not Displaying a Valid Permit –
The Pelhams 1, Wimbledon, SW19 1NY
DIR By: tobesb
Date: May 14, 2025, 6:02 am
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DVLA's reply to the complaint:
HTML https://i.ibb.co/VWcFwJZh/14525-DVLAACEreply1.png
HTML https://i.ibb.co/5XwrQSFd/14525-DVLAACEreply2.png
#Post#: 71475--------------------------------------------------
Re: ACE Security Services CN – Not Displaying a Valid Permit –
The Pelhams 1, Wimbledon, SW19 1NY
DIR By: b789
Date: May 14, 2025, 9:44 am
---------------------------------------------------------
This is the standard Step 1 fob-off, which:
[indent]• Avoids addressing any specific PoFA or PPSCoP breach,
• Falls back on the “reasonable cause” at time of request
excuse, and
• Repeats that the DVLA “cannot determine liability” — which is
irrelevant to your complaint.[/indent]
They did not engage with your actual complaint, which was not
about whether there was reasonable cause at the time of the
request, but whether the subsequent use of your data breached
the KADOE contract and UK GDPR after receipt.
Their statement that:
[indent]"Pace Recovery & Storage Ltd confirmed the Charge Notice
was issued… due [to] parking… without a valid permit…"[/indent]
completely ignores that the Notice to Driver and Notice to
Keeper were PoFA non-compliant, and that no evidence of contract
formation exists.
They incorrectly rely on “no appeal received” as justification.
But you intended to appeal within the 28 days but didn’t, you
later provided your full Keeper details voluntarily and they
then obtained them from DVLA after already being in possession
of them, and they pursued Keeper liability without complying
with PoFA or the PPSCoP.
DVLA’s refusal to “determine liability” is irrelevant. You are
not asking them to do that — you are asking them to determine
whether data was misused once obtained in breach of the KADOE
contract and/or PPSCoP.
The DVLA is still the Data Controller and is responsible for
ensuring its data is used lawfully after disclosure. You have
provided evidence that the operator:
[indent]• Breached PoFA by failing to specify a “period of
parking,”
• Breached PoFA by misstating the 28-day liability warning,
• Breached the PPSCoP by issuing a charge where no contract
could have been formed,
• Breached the KADOE contract by using your data for an
illegitimate purpose once it was clear no recovery could
lawfully be made from the Keeper.[/indent]
The Step 2 complaints procedure is exactly the same as the first
step but the link is to "Head of Complaints" here:
HTML https://contact.dvla.gov.uk/head-of-complaints
Use the following as the content for the webform:
--- Quote ---
> This is a Step 2 escalation regarding a complaint already
submitted and acknowledged under DVLA reference 0401979.
>
> Your Step 1 response dated 14 May 2025 fails to address the
actual basis of my complaint. You have wrongly assumed that my
concern was about the initial request for data (reasonable
cause), when in fact the issue is with the subsequent misuse of
that data in breach of the KADOE contract, the Private Parking
Single Code of Practice (PPSCoP), and UK GDPR.
>
> The parking operator, Ace Security Services (trading as Pace
Recovery & Storage Ltd), used my DVLA data to pursue a parking
charge in circumstances where:
>
> - No valid “period of parking” was recorded (PoFA breach),
> - No evidence of any contract being formed exists (PPSCoP
breach),
> - The NtK misstates the 28-day period under PoFA (Schedule 4,
para 8(2)(f)),
> - Therefore, the use of my data for enforcement purposes was
illegitimate.
>
> The DVLA remains the data controller and is responsible for
ensuring that third parties with KADOE access do not misuse that
data once obtained. My complaint is about post-access misuse,
not the initial request. I am now requesting a formal internal
review at Step 2.
>
> A revised supporting statement is attached. Please escalate
this matter accordingly and confirm the new reference number.
--- End Quote ---
You save the following as a PDF file and upload it as before:
--- Quote ---
> SUPPORTING STATEMENT – STEP 2 COMPLAINT
>
> Misuse of DVLA Data by Ace Security Services (Pace Recovery &
Storage Ltd)
>
> DVLA Ref: 0401979
> Vehicle: DF14KYP
> Date of CN: 13 March 2025
>
> This is a formal Step 2 escalation following the DVLA’s
response dated 14 May 2025. That response did not address the
substance of my original complaint and failed to distinguish
between a complaint about initial data access and a complaint
about subsequent misuse.
>
> What the DVLA got wrong:
>
> Your Step 1 response focused entirely on whether the operator
had “reasonable cause” at the time of requesting data. This was
never in dispute. My complaint is about how the data was used
after it was obtained — which falls under your obligations as
Data Controller under the KADOE contract and UK GDPR.
>
> Summary of misuse and code breaches:
>
> Ace Security Services obtained my data and then:
>
> [indent]• Issued a Notice to Keeper without specifying a
“period of parking”, as required by Schedule 4, paragraph
8(2)(a) of PoFA. The NtD and NtK only referenced a single
timestamp, not a duration.
> • Failed to evidence that the vehicle remained in situ beyond
the consideration period (as required by the PPSCoP). Therefore,
there is no basis to claim a contract was formed.
> • Issued a Notice to Keeper that misstates the 28-day warning
under PoFA. It said: "28 days from the date given," instead of:
"28 days beginning with the day AFTER the day on which the
notice is given" (per paragraph 8(2)(f)).
> • Pursued Keeper liability despite failing to comply with PoFA
— invalidating their legal basis to do so and rendering the use
of my DVLA data unlawful.[/indent]
>
> Why this breaches the KADOE contract and UK GDPR:
>
> The KADOE contract explicitly states that keeper data must
only be used to pursue a parking charge in full compliance with
the applicable Code of Practice.
>
> Ace Security Services has not done so. By breaching PoFA and
the PPSCoP, their use of my data falls outside the “permitted
purpose” for which it was provided — making it a misuse of
personal data under both the KADOE contract and data protection
law.
>
> Action requested:
>
> I am now formally requesting that the DVLA:
>
> [indent]• Conduct a proper internal review of this complaint,
> • Confirm that a breach of the KADOE contract has occurred,
> • Take enforcement action against Ace Security Services / Pace
Recovery & Storage Ltd,
> • Provide me with a new reference number and outcome in
writing.[/indent]
>
> The DVLA remains the data controller and is duty-bound to act
when personal data it provides is misused. You cannot lawfully
ignore a complaint about post-access abuse simply because the
initial request may have had “reasonable cause.”
>
> Please confirm that this has been escalated to Step 2 and
provide an appropriate response. I am also willing to provide
additional material if required.
>
> Name: [INSERT YOUR NAME]
> Date: [INSERT DATE]
--- End Quote ---
#Post#: 77608--------------------------------------------------
Re: ACE Security Services CN – Not Displaying a Valid Permit –
The Pelhams 1, Wimbledon, SW19 1NY
DIR By: tobesb
Date: June 22, 2025, 3:19 pm
---------------------------------------------------------
Done. Will wait for a reply regarding the DVLA.
Re: ACE, they've moved it onto the debt recovery firm bwlegal.
Would you mind helping me please regarding what I should say to
these... people.
Kind regards,
Tobes
HTML https://i.ibb.co/fdc4qfyJ/bwlegal1.jpg
HTML https://i.ibb.co/kVXZ6nJG/bwlegal2.jpg
#Post#: 77616--------------------------------------------------
Re: ACE Security Services CN – Not Displaying a Valid Permit –
The Pelhams 1, Wimbledon, SW19 1NY
DIR By: DWMB2
Date: June 22, 2025, 4:16 pm
---------------------------------------------------------
You'd be wise not to upload documents with your full name and
home address visible...
#Post#: 77618--------------------------------------------------
Re: ACE Security Services CN – Not Displaying a Valid Permit –
The Pelhams 1, Wimbledon, SW19 1NY
DIR By: tobesb
Date: June 22, 2025, 4:21 pm
---------------------------------------------------------
Thank you. Updated. Shouldn't be doing this tired.
#Post#: 77634--------------------------------------------------
Re: ACE Security Services CN – Not Displaying a Valid Permit –
The Pelhams 1, Wimbledon, SW19 1NY
DIR By: b789
Date: June 23, 2025, 1:51 am
---------------------------------------------------------
Unless BW Legal send you a Letter of Claim (LoC), they are
acting in the capacity of a debt collector. As for all debt
collectors, you can safely ignore them as they are powerless to
do anything except to try and persuade the low-hanging fruit. on
the gullible tree to pay up out of ignorance and fear.
COme back when they send an LoC.
#Post#: 87618--------------------------------------------------
Re: ACE Security Services CN – Not Displaying a Valid Permit –
The Pelhams 1, Wimbledon, SW19 1NY
DIR By: tobesb
Date: August 28, 2025, 4:31 pm
---------------------------------------------------------
Good evening ,
BW Legal have now come back with a Letter of Claim. Please would
you help me regarding what I should do?
Kind regards,
Tobes
HTML https://i.ibb.co/HTPkWhDN/bwlegal1.png
HTML https://i.ibb.co/LDJgKSPy/bwlegal2.png
HTML https://i.ibb.co/TBms1ryC/bwlegal3.png
HTML https://i.ibb.co/cSfwBr6d/bwlegal4.png
And these are the other documents that were in the envelope:
HTML https://i.ibb.co/ymTF3SSy/bwlegal5.png
HTML https://i.ibb.co/Y77ZjNmT/bwlegal6.png
HTML https://i.ibb.co/4gwF7BPK/bwlegal7.png
HTML https://i.ibb.co/NgjrML8C/bwlegal8.png
HTML https://i.ibb.co/CpD0fyqv/bwlegal9.png
HTML https://i.ibb.co/4Zn4nZHc/bwlegal9b.png
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