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       #Post#: 69477--------------------------------------------------
       Re: UKPS PCN for leased car at Wing Yip Cricklewood London
   DIR By: dfwtolhr
       Date: April 30, 2025, 5:06 pm
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > The best way to prove that you didn't receive these documents
       is to prove that they weren't in the creditor's possession...to
       do which you get a statement from VWFS.... by writing and asking
       them.
       >
       --- End Quote ---
       H C Anderson. What exactly am I asking SEAT here, what documents
       they sent to UKPS?
       #Post#: 69478--------------------------------------------------
       Re: UKPS PCN for leased car at Wing Yip Cricklewood London
   DIR By: dfwtolhr
       Date: April 30, 2025, 5:09 pm
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > Does the email you received with the appeal rejection show or
       indicate that there were any attachments to it? If it can be
       used as evidence of the lying behaviour of UKPS, then it should
       be sent as additional evidence to a Step 2 complaint to the
       DVLA. Don't send the Step 2 complaint if you can show that the
       email you received shows or failed to show that there were any
       attachments, as I would have to amend the wording slightly.
       >
       > To send the Step 2 complaint, you go through the same steps as
       for there initial complaint except that the web address is:
       >
       >
  HTML https://contact.dvla.gov.uk/head-of-complaints
       >
       > [quote]Subject: Step 2 Escalation – Misuse of Personal Data
       and Deliberate Misrepresentation by UK Parking Solutions Ltd
       (UKPS)
       >
       > Dear DVLA Head of Complaints,
       >
       > I am writing to escalate my complaint regarding the misuse of
       my personal data by UK Parking Solutions Ltd (UKPS) to Step 2 of
       your complaints process.
       >
       > This matter concerns not just technical breaches, but
       deliberate misrepresentation by a DVLA-approved KADOE user,
       acting in direct violation of the BPA/IPC Private Parking Single
       Code of Practice (PPSCoP) and the terms of the KADOE contract.
       >
       > Background
       >
       > As clarified in your Step 1 response, my data was not released
       to UKPS by the DVLA directly, but was passed to them via a
       Transfer of Liability by the vehicle’s registered keeper,
       Volkswagen Financial Services UK Ltd.
       >
       > However, UKPS is a KADOE account holder, and the conditions of
       use attached to KADOE data access apply regardless of how the
       data was obtained. The purpose of the KADOE contract is to
       ensure that AOS members process personal data lawfully,
       proportionately, and in full compliance with the PPSCoP —
       including when pursuing charges via hirer liability under
       Schedule 4 to the Protection of Freedoms Act 2012 (PoFA).
       >
       > Substance of the Complaint – Deliberate False Representation
       >
       > UKPS issued a Notice to Hirer (NtH) which falsely states that
       it encloses all four documents required under Paragraph 13(2) of
       PoFA. In reality, none of these documents were enclosed. This
       was not an accidental omission — the covering page explicitly
       asserts that the documents are included, which makes this a
       deliberate misrepresentation.
       >
       > This was not an isolated incident. UKPS has now repeated the
       false claim in their written response to my appeal. They stated
       that the Transfer of Liability was “attached,” when in fact
       nothing was enclosed. This is consistent with the earlier Notice
       to Hirer, which similarly claimed that four PoFA-mandated
       documents were included — when they were not. The repeated
       nature of these omissions, accompanied by false assertions that
       the documents were provided, demonstrates deliberate
       misrepresentation and unlawful data processing, not
       administrative error. This is a clear abuse of DVLA-sourced
       personal data, and one that warrants regulatory action.
       >
       > The effect of this is that UKPS is:
       >
       > [indent]• Asserting that the statutory requirements of PoFA
       have been met (when they haven’t);
       > • Knowingly processing personal data on a false legal basis;
       > • Misleading the recipient about their liability in order to
       extract payment.[/indent]
       >
       > This goes far beyond mere sloppiness. It is a calculated and
       mendacious act designed to fabricate the appearance of PoFA
       compliance and shift liability unlawfully.
       >
       > If the DVLA accepts such conduct at face value, then it is
       allowing the integrity of the vehicle register to be undermined
       by rogue operators. The PPSCoP and KADOE contract become
       meaningless if operators can simply lie about their compliance
       and continue to access and process personal data without
       oversight or consequence.
       >
       > Recommendation
       >
       > Perhaps it is time the DVLA stops assuming that operators are
       acting in good faith and starts investigating whether they are,
       in fact, lying. I strongly suggest that the DVLA conduct a sting
       operation — for example, by hiring a vehicle and deliberately
       breaching a term in a car park operated by UKPS. The resulting
       NtH is likely to contain the same false assertion that the
       required documents are enclosed, when in reality they will not
       be. This would serve as hard proof that the breach is systemic
       and deliberate, not accidental.
       >
       > Request
       >
       > I am therefore asking the DVLA to:
       >
       > [indent]• Investigate whether UKPS’s actions amount to a
       breach of the KADOE contract and PPSCoP;
       > • Determine whether the deliberate false assertion of PoFA
       compliance invalidates the legal basis for processing my
       personal data;
       > • Consider enforcement action including suspension or
       termination of KADOE access if breaches are established;
       > • Acknowledge that “self-certification” by operators is wholly
       inadequate when clear evidence exists of falsified statutory
       compliance.[/indent]
       >
       > Please confirm receipt of this escalation and provide a Step 2
       complaint reference. I am happy to provide copies of the NtH and
       supporting evidence again if required.
       >
       > Yours faithfully,
       >
       > [Your Full Name]
       > [Original DVLA Complaint Date / Reference Number]
       --- End Quote ---
       [/quote]
       So the email contained none of the 4 required documents, and the
       posted version only had the transfer of liability enclosed...
       #Post#: 69521--------------------------------------------------
       Re: UKPS PCN for leased car at Wing Yip Cricklewood London
   DIR By: b789
       Date: May 1, 2025, 5:22 am
       ---------------------------------------------------------
       SO send the Step 2 escalation to the DVLA.
       #Post#: 71487--------------------------------------------------
       Re: UKPS PCN for leased car at Wing Yip Cricklewood London
   DIR By: dfwtolhr
       Date: May 14, 2025, 10:17 am
       ---------------------------------------------------------
       Correspondence from ukps
       [attachment deleted by admin]
       #Post#: 71528--------------------------------------------------
       Re: UKPS PCN for leased car at Wing Yip Cricklewood London
   DIR By: jfollows
       Date: May 14, 2025, 1:20 pm
       ---------------------------------------------------------
       “Reasonable Clause criteria”
       Related to Santa Claus perhaps.
       And “criterion” is the singular.
       Given their inability to write proper English, I’m not sure I
       think much of their competence.
       Sorry, doesn’t really help, I’m just moaning!
       #Post#: 76381--------------------------------------------------
       Re: UKPS PCN for leased car at Wing Yip Cricklewood London
   DIR By: dfwtolhr
       Date: June 13, 2025, 8:58 am
       ---------------------------------------------------------
       Response from dvla complaint
       [attachment deleted by admin]
       #Post#: 76382--------------------------------------------------
       Re: UKPS PCN for leased car at Wing Yip Cricklewood London
   DIR By: dfwtolhr
       Date: June 13, 2025, 8:59 am
       ---------------------------------------------------------
       First half
       [attachment deleted by admin]
       #Post#: 76395--------------------------------------------------
       Re: UKPS PCN for leased car at Wing Yip Cricklewood London
   DIR By: b789
       Date: June 13, 2025, 10:15 am
       ---------------------------------------------------------
       So, you escalate to the Independent Complaints Assessor (ICA) by
       emailing with the following to ICA@dvla.gov.uk and CC yourself:
       --- Quote ---
       > Subject: ICA complaint – misuse of keeper data by UKPS – DVLA
       handling failure [0404017-Y3Z3B]
       >
       > Dear Independent Complaints Assessor,
       >
       > I am escalating my complaint because the DVLA’s Step 2 reply
       (dated 9th June 2025) did not address the core issue: UK Parking
       Solutions Ltd (UKPS) misused my keeper data after obtaining it
       from the DVLA under the KADOE scheme.
       >
       > The following four points highlight the DVLA's failures:
       >
       > 1. DVLA position:
       >
       > [indent]“Reasonable cause” is judged only at the point of
       request.[/indent]
       >
       > Why the response is inadequate:
       >
       > [indent]The KADOE contract is explicit that keeper data may be
       used solely “for the purpose of enforcement in accordance with
       the prevailing Code of Practice”. Once UKPS breached PPSCoP
       8.1.1(d), their use of the data ceased to be lawful—even if the
       original request was valid.[/indent]
       >
       > 2. DVLA position:
       >
       > [indent]PoFA compliance is “not required”.[/indent]
       >
       > Why the response is inadequate:
       >
       > [indent]Nobody argued it was. The complaint is that UKPS
       invoked PoFA in wording but failed to meet para 9(2)(f).
       Misrepresentation is data misuse. This point has been avoided
       altogether.[/indent]
       >
       > 3. DVLA position:
       >
       > [indent]“We do not arbitrate civil disputes.”[/indent]
       >
       > Why the response is inadequate:
       >
       > [indent]I was not asking the DVLA to settle a parking
       dispute—only to enforce its own contract and data-protection
       duties when misuse is shown to have occurred, as it has in this
       instance. [/indent]
       >
       > 4. DVLA position:
       >
       > [indent]Cites the ICO Opinion (Jun 2022) to justify
       disclosure.[/indent]
       >
       > Why the response is inadequate:
       >
       > [indent]The 'Opinion' expressly states that operators must
       comply with the Code. It does not excuse post-disclosure misuse
       which was the cause for the complaint in the first
       place.[/indent]
       >
       > Because the DVLA failed to engage with these four points, it
       failed to apply its own policies or consider enforcement action
       against UKPS. I therefore ask the ICA to review the DVLA’s
       handling of my complaint and recommend that the case is
       re-opened and referred to DVLA Enforcement & Compliance.
       >
       > I attach:
       >
       > [indent]• my original Step 1 and Step 2 submissions;
       > • the DVLA Step 2 response;
       > • a copy of the UKPS Notice to Keeper showing the PoFA 9(2)(f)
       omission.[/indent]
       >
       > Thank you for your consideration.
       >
       > Yours sincerely,
       >
       > [Your name]
       > [Date]
       --- End Quote ---
       #Post#: 77773--------------------------------------------------
       Re: UKPS PCN for leased car at Wing Yip Cricklewood London
   DIR By: dfwtolhr
       Date: June 23, 2025, 12:13 pm
       ---------------------------------------------------------
       Trace debt recovery letter
       [attachment deleted by admin]
       #Post#: 77830--------------------------------------------------
       Re: UKPS PCN for leased car at Wing Yip Cricklewood London
   DIR By: b789
       Date: June 24, 2025, 2:41 am
       ---------------------------------------------------------
       You can safely ignore any debt recovery letters and we don't
       need to know about them. Debt collectors 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.
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