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#Post#: 65818--------------------------------------------------
Parking charge- Not Parked Wholly Within Bay
DIR By: ugoben
Date: April 6, 2025, 12:08 am
---------------------------------------------------------
I parked yesterday but unfortunately could not wholly park
within parking bay due to an column structure which prevented
drivers door from opening after parking.
* Unfortunately this was the only space available.
* If I parked within bay, I would not be able to open door.
* this was the only space and I was not obstruction any car
within area.
* The enforcement officer knew there was a column preventing me
from parking properly but suprisingly, ommitted pictures showing
obstruction, which makes me wonder if this was done on purpose.
I kindly need advice on how to approach h this situation.Do you
suggest I pay fine or is there any way around this?
Draft letter - Whee do I send this to, please?
Any ammendment would be very helpful.
=======================
I am writing to challenge the issuance of Penalty Charge Notice
[PCN number] issued on [date] at [location].
I acknowledge that my vehicle was not wholly within the marked
bay. However, I would like to explain that this was due to an
unavoidable physical obstruction — a fixed column structure
located adjacent to the bay — which prevented me from opening
the driver’s door had I parked fully within the bay lines.
At the time of parking:
* This was the only available space in the area.
* Parking fully within the bay would have made it impossible to
safely exit the vehicle, and I had no other practical parking
alternative.
* I made every effort to park responsibly and was not causing
any obstruction to other vehicles or to the general flow of
traffic.
I am particularly concerned that the enforcement officer's
photographic evidence omits the presence of this fixed
obstruction, which was a key factor in the circumstances. I
believe this omission presents an incomplete and potentially
misleading account of the situation.
I have attached photographs taken afterward that clearly show
the column and its proximity to the bay. These demonstrate that
the obstruction would have physically prevented the opening of
my driver’s door had I parked fully within the bay markings.
Given the exceptional circumstances, the absence of obstruction
to others, and the practical limitations I faced, I kindly
request that you exercise discretion and cancel the penalty
notice.
===================
[attachment deleted by admin]
#Post#: 65960--------------------------------------------------
Re: Parking charge- Not Parked Wholly Within Bay
DIR By: b789
Date: April 7, 2025, 8:57 am
---------------------------------------------------------
Do nothing for the time being. You certainly DO NOT admit any
liability with silly things like "I acknowledge that my vehicle
was not wholly within the marked bay."
Do not imagine for a second that you are dealing with a comp[any
that has any customer service ethos. These are ex-clamper thugs
and have only one aim, to fleece you out of your money. No
appeal whatsoever is going to succeed, especially with an IPC
member.
Can you get a phot of the signs at the location. I especially
need to see the small print on the signs and whether they ar sin
the name of Premier Parking Enforcement Ltd or Premier Parking
Logistics Ltd.
For now, put this date in your diary... Friday 2nd May. On that
date and not before or after, you send the following appeal by
email to info@premierparkingenforcementltd.com and also CC in
yourself:
--- Quote ---
> There is no legal obligation on the known keeper (the
recipient of the Notice to Keeper (NtK)) to reveal the identity
of the unknown driver and no inference or assumptions can be
made.
>
> The NtK is not compliant with all the requirements of PoFA
which means that if the unknown driver is not identified, they
cannot transfer liability for the charge from the unknown driver
to the known keeper.
>
> Use the following as your appeal. No need to embellish or
remove anything from it:
>
> [quote]I am the keeper of the vehicle and I dispute your
'parking charge'. I deny any liability or contractual agreement
and I will be making a complaint about your predatory conduct to
your client landowner.
>
> As your Notice to Driver (NtD) does not fully comply with ALL
the requirements of PoFA 2012, you are unable to hold the keeper
of the vehicle liable for the charge. Partial or even
substantial compliance is not sufficient. There will be no
admission as to who was driving and no inference or assumptions
can be drawn. PPE has relied on contract law allegations of
breach against the driver only.
>
> The registered keeper cannot be presumed or inferred to have
been the driver, nor pursued under some twisted interpretation
of the law of agency. Your NtD can only hold the driver liable.
PPE have no hope should you try to escalate this matter, so you
are urged to save us both a complete waste of time and cancel
the PCN.
--- End Quote ---
[/quote]
You then wait and see what the response is.
#Post#: 65999--------------------------------------------------
Re: Parking charge- Not Parked Wholly Within Bay
DIR By: ugoben
Date: April 7, 2025, 12:12 pm
---------------------------------------------------------
Thanks for the guide.
I have provided the site signage.
[attachment deleted by admin]
#Post#: 70765--------------------------------------------------
Re: Parking charge- Not Parked Wholly Within Bay
DIR By: ugoben
Date: May 10, 2025, 4:52 am
---------------------------------------------------------
Good morning,
Following advice to send above email on 2nd May, I got a
response after sending above mail as advised. Email reads below-
'This is not the Appeal process please follow the steps on your
PCN for the appeal web address to appeal.'
I will appreiate any advice before this gets out of hand. Also,
I got a payment reminder (100£ since I have missed the initial
window).
[attachment deleted by admin]
#Post#: 70791--------------------------------------------------
Re: Parking charge- Not Parked Wholly Within Bay
DIR By: b789
Date: May 10, 2025, 9:29 am
---------------------------------------------------------
What do you mean by “get out of hand”?
There is no way this could ever “get out of hand”. PPE have now
started digging a hole for themselves by breaching the KADOE
contract with the DVLA by requesting your data after you already
provided them with your name and address as the Registered
Keeper.
The “Reminder Notice” is the Notice to Keeper (NtK) which is not
PoFA compliant. They don’t know who the driver is and they
cannot hold the Keeper liable. That doesn’t mean that they will
not try and blag their way through the process, in the hope that
you are low-hanging fruit on the gullible tree who will simply
pay up out of ignorance and fear.
For now, you need to 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 Premier Parking
Enforcement Ltd, an IPC AOS member with DVLA KADOE access, for
unlawfully obtaining my personal data when no reasonable cause
existed to do so.
>
> This is not a complaint about misuse after data release — it
concerns the fact that there was no lawful basis for the data
request in the first place. The parking company was already in
possession of both the name and a serviceable address for the
registered keeper before making their KADOE request.
>
> A formal appeal was submitted on 2 May 2025, naming the keeper
and providing a full postal address. The operator responded to
this email and deliberately refused to engage with it, clearly
intending to fabricate a justification for accessing DVLA data
they already held. This is a breach of the DVLA’s KADOE contract
and a misuse of personal data under UK GDPR.
>
> I have attached a supporting statement and evidence showing
that the keeper’s data was provided before any DVLA access.
Please investigate this breach and confirm the outcome,
including the exact date Premier Parking Enforcement Ltd
accessed my data and what action will be taken in response.
--- End Quote ---
Then you could upload the following as a PDF file for the formal
complaint itself:
--- Quote ---
> SUPPORTING STATEMENT
>
> Complaint to DVLA – Unlawful Request for Keeper Data
>
> Operator name: Premier Parking Enforcement Ltd
> Date of PCN issue: 5 April 2025
> Vehicle registration: KP68 DLF
>
> I am submitting this complaint to report that Premier Parking
Enforcement Ltd unlawfully obtained my keeper data from the DVLA
under the KADOE (Keeper At Date Of Event) contract. In this
case, the parking company already knew the name and address of
the registered keeper before making the data request. There was
no legal basis for them to access the DVLA database.
>
> The KADOE contract only permits a request where the parking
operator does not already hold “the full name and serviceable
address of the registered keeper or the driver.” That condition
was not satisfied.
>
> On 2 May 2025, I submitted a formal appeal to PPE by email,
clearly identifying myself as the registered keeper and
providing my full name and a valid UK postal address for
service. PPE replied to that email, proving that they received
and read it. However, they deliberately refused to treat it as
an appeal and instead told me to use their online portal, which
is irrelevant and contrary to PoFA 2012 and data protection
principles.
>
> Despite being in possession of the keeper’s name and address,
PPE then unlawfully accessed DVLA data — an action that was not
justified by any reasonable cause and was clearly designed to
give the appearance of compliance with PoFA and to maintain
pressure on the registered keeper by invoking DVLA authority.
>
> It should also be noted that neither the Notice to Driver
issued on 5 April 2025 nor the subsequent postal notice dated 5
May 2025 are compliant with the requirements of Schedule 4 of
the Protection of Freedoms Act 2012 (PoFA). The postal notice
purports to act as a Notice to Keeper and appears to rely on
PoFA to assert keeper liability, but it fails to comply with key
statutory requirements. Specifically:
>
> [indent]• The notice fails to specify the “period of parking,”
instead giving only a single timestamp, which breaches paragraph
9(2)(a);
> • There is no invitation for the keeper to either pay the
charge or provide the name and address of the driver, contrary
to paragraph 9(2)(e)(i).
>
> These are not trivial omissions — they are statutory
requirements. PPE is relying on PoFA to claim keeper liability
despite failing to meet the minimum conditions required by law.
This reinforces that their use of my DVLA data was not only
unlawful in timing, but is now also being used to pursue a claim
that has no lawful foundation.
>
> This is not a case of misusing data after access. The access
itself was unlawful. By refusing to accept a validly submitted
appeal and pretending the keeper was unknown, PPE have
deliberately circumvented the rules of the KADOE contract and
misused personal data held by the DVLA.
>
> I am requesting that the DVLA:
>
> [indent]• Confirms the date and time PPE accessed my data
> • Acknowledges that the data was obtained without reasonable
cause
> • Investigates the breach fully and records this misuse
> • Considers suspension or termination of PPE’s KADOE access if
appropriate[/indent]
>
> Attached are copies of:
>
> [indent]• The email appeal sent on 2 May 2025
> • PPE’s dismissive response
> • The ‘Reminder Notice’ subsequently issued[/indent]
>
> These show beyond any doubt that PPE had my data before they
contacted the DVLA and that they are subsequently using that
data unlawfully.
>
> Name: [INSERT YOUR NAME]
> Date: [INSERT TODAY’S DATE]
--- End Quote ---
#Post#: 72162--------------------------------------------------
Re: Parking charge- Not Parked Wholly Within Bay
DIR By: ugoben
Date: May 19, 2025, 7:06 am
---------------------------------------------------------
Hello,
Thank you for your response. I got a response from DVLA saying
the parking firm requested for info. on the 5th. See attahed. It
looks like DVLA supports their action.
I will appreciate your further guidance, please.
Thank you.
[attachment deleted by admin]
#Post#: 72206--------------------------------------------------
Re: Parking charge- Not Parked Wholly Within Bay
DIR By: b789
Date: May 19, 2025, 10:23 am
---------------------------------------------------------
You can noe escalate the complaint to Step 2. The response you
have received is the standard fob-off. The procedure for the
step 2 complaint is exactly the same as the Step 1 except that
the link to the complaint for is now yo 'Head of Complaints':
HTML https://contact.dvla.gov.uk/head-of-complaints
Here’s how to make a DVLA Step 2 complaint:
[indent]• Go to:
HTML https://contact.dvla.gov.uk/head-of-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 Step 2 escalation complaint following the
unsatisfactory response received from Carly Williams on 19 May
2025 (Reference: 0403600).
>
> This is not a complaint about the interpretation of PoFA or
about whether an operator can pursue a charge outside PoFA. My
complaint concerns the unlawful access of my personal data by
Premier Parking Enforcement Ltd, despite the fact that they were
already in possession of both the full name and serviceable
address of the keeper.
>
> DVLA's own KADOE contract prohibits data release in such
circumstances, and the justification offered at Step 1
misrepresents the issue entirely. I have attached a supporting
statement, which includes full documentation showing that the
data was accessed after the keeper’s details had already been
supplied directly to the operator in writing.
>
> Please escalate this matter for review by the Head of
Complaints and provide a written response and case reference.
--- End Quote ---
Then you could upload the following as a PDF file for the formal
complaint itself:
--- Quote ---
> SUPPORTING STATEMENT
>
> DVLA Step 2 Complaint – Unlawful Keeper Data Access
>
> Operator name: Premier Parking Enforcement Ltd
> Date of PCN issue: 5 April 2025
> DVLA Case Reference: 0403600
> Vehicle registration: KP68 DLF
>
> This is a Step 2 escalation following an unsatisfactory
response from Carly Williams dated 19 May 2025.
>
> This complaint is not about the Protection of Freedoms Act
(PoFA) or whether the operator can pursue a charge through other
means. It is about the unlawful access of DVLA keeper data when
no such access was justified, as the operator was already in
possession of the keeper’s name and address prior to their KADOE
request.
>
> The Step 1 response ignores this entirely and instead focuses
on PoFA, which is irrelevant to the point at hand. The key facts
are as follows:
>
> [indent]• On 2 May 2025, I submitted a written appeal to
Premier Parking Enforcement Ltd via email. That appeal clearly
identified me as the registered keeper and provided a valid UK
service address.
> • PPE responded to that email, acknowledging receipt and
refusing to engage because I did not use their website portal —
which has no legal standing and is not required for a valid
appeal.
> • On 5 May 2025, Premier Parking Enforcement Ltd made a
request to the DVLA for keeper data.[/indent]
>
> At the time of their request, they already had the keeper’s
name and address, and therefore did not have reasonable cause to
access DVLA data. This is a direct breach of the KADOE contract,
which states:
>
> [indent]“The Customer shall not request Keeper details… where
it already holds the name and address of the Registered Keeper
or Driver.”[/indent]
>
> DVLA’s duty as data controller includes ensuring that the
legal basis for access is met. The operator deliberately ignored
the appeal to manufacture a false justification for accessing
DVLA data. That access was unlawful.
>
> In addition, the operator is now attempting to rely on
Schedule 4 of PoFA 2012 to assert keeper liability, despite
issuing a non-compliant Notice to Keeper that fails to meet the
statutory requirements, including:
>
> [indent]• No “period of parking” stated, contrary to paragraph
9(2)(a);
> • No invitation to pay or provide driver details, contrary to
paragraph 9(2)(e).[/indent]
>
> While the PoFA non-compliance is not the basis of this
complaint, it adds further weight to the fact that DVLA-supplied
data is being misused to pursue a claim based on legal
provisions that do not apply.
>
> This is a serious breach. I am therefore requesting that DVLA:
>
> [indent]• Escalates this matter to the Head of Complaints;
> • Acknowledges that a breach of the KADOE contract occurred;
> • Confirms what enforcement action will be taken against
PPE.[/indent]
>
> I have attached the original Step 1 complaint, PPE’s response,
my 2 May email, and the subsequent “Reminder Notice” issued by
the operator.
>
>
> Name: [INSERT YOUR NAME]
> Date: [INSERT DATE]
--- End Quote ---
#Post#: 76063--------------------------------------------------
Re: Parking charge- Not Parked Wholly Within Bay
DIR By: ugoben
Date: June 11, 2025, 12:47 pm
---------------------------------------------------------
Greetings,
Really grateful for your guidance and help. I got an update from
DVLA.
Kindly find attached letter. It looks like I need to appeal to
the independent compliants assessor.
Your guidance is really appreciated.
Thank you!
[attachment deleted by admin]
#Post#: 76083--------------------------------------------------
Re: Parking charge- Not Parked Wholly Within Bay
DIR By: b789
Date: June 11, 2025, 3:13 pm
---------------------------------------------------------
As expected, it is another standard fob-off and does not address
the actual complaint.
Your complaint was that Premier Parking Enforcement Ltd (PPEL)
unlawfully requested your keeper data even though they already
had your name and address from your email sent on 2 May 2025.
The DVLA has ignored this and simply repeated their usual
generic statements about “reasonable cause” and PoFA, which are
not relevant. The key issue is that under the KADOE contract,
the operator must not request data if they already have the
keeper’s details. The DVLA has avoided addressing this.
The next step is to escalate the complaint to the Independent
Complaints Assessor (ICA). You are now entitled to do this
because both Step 1 and Step 2 have been completed.
To escalate to the ICA:
[indent]• Go to the ICA website:
HTML https://www.independentcomplaintsassessor.org.uk/how-to-complain
• You can fill in the online complaint form or send an email to
complaints@independentcomplaintsassessor.org.uk
• You should attach your original complaint, the DVLA’s Step 1
and Step 2 responses, and any evidence (your email of 2 May, the
Reminder Notice, etc.)[/indent]
Here is a suggested text you can use in the complaint form or
email:
--- Quote ---
> I am escalating this complaint to the Independent Complaints
Assessor following unsatisfactory responses from the DVLA at
both Step 1 and Step 2 of their complaints process. The DVLA
reference number is 0404670.
>
> My complaint is about an unlawful KADOE data request made by
Premier Parking Enforcement Ltd on 5 May 2025 in relation to
vehicle registration KP68DLF. On 2 May 2025, I had already sent
an email to the operator identifying myself as the registered
keeper and providing my full name and UK serviceable address.
The operator acknowledged this email. The KADOE contract clearly
states that a request must not be made if the name and address
of the keeper or driver is already held. This condition was not
met.
>
> The DVLA’s responses at Step 1 and Step 2 failed to address
this and instead gave general explanations about “reasonable
cause” and PoFA, which do not apply here. This shows that they
did not properly investigate or apply the terms of their own
KADOE contract. They have not responded to the actual substance
of my complaint.
>
> I am asking the ICA to review how the DVLA handled this
complaint, including their failure to follow their own rules and
their refusal to acknowledge a clear data breach.
--- End Quote ---
#Post#: 79067--------------------------------------------------
Re: Parking charge- Not Parked Wholly Within Bay
DIR By: ugoben
Date: July 1, 2025, 7:52 am
---------------------------------------------------------
Hi,
Thank you for your guidance.
Please, is there an alternative way to contact the independent
assessors? Neither the site nor the email address has been
accessible for over two weeks. Could it be from my device, or is
it a general challenge?
Also, I got a letter from Gladstones Solicitors—a debt recovery
firm regarding this ticket asking to pay approximately £300.
Should I ignore it?
Kind regards,
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