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       #Post#: 67090--------------------------------------------------
       Kelly's Storage Lu2 9LF PCN – Not the Driver – Urgent Advice
       Needed Please
   DIR By: S Patel
       Date: April 14, 2025, 12:44 pm
       ---------------------------------------------------------
       Hi everyone,
       I would really appreciate some help and advice regarding a PCN
       I’ve received.
       The charge relates to an incident on 06/08/2024 at Kelly’s
       Storage. However, I was not the driver of the vehicle on that
       day – I had just landed at Luton Airport and was being picked
       up.
       The first letter I received was dated
  HTML 02/01/2025,[img]http://
  HTML https://i.imgur.com/Vb6GjbT.jpeg[/img]
       which is almost five months after the parking incident. I
       appealed this initial letter and provided evidence, including my
       boarding pass, to confirm I wasn’t the driver. I’ve attached
       images of what I sent in my appeal.
  HTML https://i.imgur.com/Vb6GjbT.jpeg
       The appeal was unfortunately rejected, and I missed the deadline
       to respond further.
  HTML [img]http://
  HTML https://i.imgur.com/iPWiIat.jpeg[/img]
  HTML https://i.imgur.com/iPWiIat.jpeg
       Since then, I’ve received two more letters, bringing the total
       to four. The most recent one (Letter 4) is especially concerning
       and I’m worried this might escalate to court proceedings.
  HTML [img]http://
  HTML https://i.imgur.com/aRhXzwd.jpeg[/img]
  HTML [img]http://
  HTML https://i.imgur.com/aZrJp7W.jpeg[/img]
  HTML https://i.imgur.com/aRhXzwd.jpeg
  HTML https://i.imgur.com/aZrJp7W.jpeg
       Could anyone please advise:
       How should I respond to the latest letter?
       Should I name the actual driver (if known)?
       Do I have any grounds to challenge this further?
       Or should I just pay the charge to avoid court action?
       I’ve attached all relevant letters and evidence below for
       context.
       Thanks so much in advance for any help you can give.
       #Post#: 67095--------------------------------------------------
       Re: Kelly's Storage Lu2 9LF PCN – Not the Driver – Urgent Advice
       Needed Please
   DIR By: jfollows
       Date: April 14, 2025, 1:08 pm
       ---------------------------------------------------------
       See also
  HTML https://www.ftla.uk/private-parking-tickets/universal-parking-enforcement-pcn-parking-on-a-no-parking-area-kellys-storage-lu/msg54791/#msg54791
       Please post the appeal you sent, I don’t see it.
       The claim is laughable and, especially if you don’t identify the
       driver, won’t come to anything.
       #Post#: 67097--------------------------------------------------
       Re: Kelly's Storage Lu2 9LF PCN – Not the Driver – Urgent Advice
       Needed Please
   DIR By: jfollows
       Date: April 14, 2025, 1:11 pm
       ---------------------------------------------------------
       You don’t need to do much apart from telling them to get lost,
       and they can’t hold you - the registered keeper - liable for
       anything here. However wait for a better suggested response. The
       other thread I refer you to suggests an IAS appeal mainly
       because the PCN is egregiously bad and even the biased IAS would
       be stretched not to dismiss it.
       Don’t be frightened of court, the reason this is mentioned is
       purely to frighten you into paying.
       #Post#: 67099--------------------------------------------------
       Re: Kelly's Storage Lu2 9LF PCN – Not the Driver – Urgent Advice
       Needed Please
   DIR By: S Patel
       Date: April 14, 2025, 1:34 pm
       ---------------------------------------------------------
       Thank you for your quick response, I really appreciate the help,
       please see below the appeal I sent
       Dear Appeals Team,
       I am writing to formally appeal the Parking Charge Notice
       referenced above.
       I respectfully contest this charge on the following grounds:
       1. I Was Not the Driver
       At the time of the alleged contravention on 06/08/2024, I was
       not driving the vehicle. I was returning to the UK from abroad,
       having arrived at Luton Airport on a delayed flight. I enclose
       my boarding pass and flight itinerary which clearly show I was
       in transit and could not have been the driver.
       The vehicle was being used by another party who collected me
       from the airport. I was not in control of the vehicle at any
       point during the time in question.
       2. Keeper Liability Does Not Apply
       Your Notice to Keeper is dated 02/01/2025, which is nearly five
       months after the alleged parking event. Under Paragraph 9(4)(b)
       of Schedule 4 of the Protection of Freedoms Act 2012 (POFA), a
       Notice to Keeper must be served within 14 days of the incident
       for keeper liability to apply. As this time limit was not met,
       you cannot lawfully pursue me as the keeper.
       3. No Legal Obligation to Name the Driver
       There is no legal requirement under POFA or UK civil law for a
       keeper to identify the driver. I have met my obligations by
       informing you that I was not driving and have provided evidence
       of the same.
       4. Request for Cancellation
       Given that:
       •
       •
       of the notice,
       •
       unreasonable and without legal merit,
       I respectfully request that this Parking Charge Notice be
       cancelled immediately.
       If you reject this appeal, I request that you:
       •
       •
       or video footage),
       •
       the Independent Appeals Service (IAS).
       #Post#: 67101--------------------------------------------------
       Re: Kelly's Storage Lu2 9LF PCN – Not the Driver – Urgent Advice
       Needed Please
   DIR By: jfollows
       Date: April 14, 2025, 1:58 pm
       ---------------------------------------------------------
       Personally I’d appeal to the IAS but simplify it by removing
       everything after the first sentence in your section (1), you
       state you weren’t the driver and leave it at that. You don’t
       have to prove anything to these scoundrels. But as you will.
       You seem to have a handle on the process.
       If the IAS don’t uphold your appeal, you let them take you to
       court if they want to. They probably won’t and you’ll get
       assistance here with the process which will see the case dropped
       or laughed out of court. I think they’re not so stupid as to go
       this far, they’re playing the numbers game by mentioning court
       and “CCJ” in the knowledge that lots of gullible people just pay
       up.
       #Post#: 67168--------------------------------------------------
       Re: Kelly's Storage Lu2 9LF PCN – Not the Driver – Urgent Advice
       Needed Please
   DIR By: b789
       Date: April 15, 2025, 5:32 am
       ---------------------------------------------------------
       You can safely ignore everything unless you receive a Letter of
       Claim (LoC). The debt recovery letters, which you must ignore,
       are designed to get the low-hanging fruit on the gullible tree
       to pay up out of ignorance and fear.
       As already advised earlier, they have no idea who the driver is
       and you are under no legal obligation to identify the driver to
       an unregulated firm of ex-clampers. There is no way they can
       hold the Keeper liable for the charge and so leave them alone to
       get on with their charade of trying to scare you into paying
       into their scam.
       If they ever try and issue a court claim, they will be on a
       hiding to nothing. Let them waste their money. You won't be
       paying a penny to these scammers is you follow the advice here.
       #Post#: 67171--------------------------------------------------
       Re: Kelly's Storage Lu2 9LF PCN – Not the Driver – Urgent Advice
       Needed Please
   DIR By: b789
       Date: April 15, 2025, 5:42 am
       ---------------------------------------------------------
       What you can and should do, is make a formal complaint against
       this rogue operator 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 Universal Parking
       Enforcement Ltd, an IPC Accredited Operator Scheme (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—by
       pursuing keeper liability without complying with the statutory
       requirements under the Protection of Freedoms Act 2012
       (PoFA)—renders their processing 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 the initial data access, but rather the misuse that
       followed.
       >
       > I have uploaded a supporting statement outlining the breaches
       committed by the operator and I request that the DVLA
       investigates and confirms a breach of the KADOE contract and
       PPSCoP.
       >
       > 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: Universal Parking Enforcement Ltd
       > Date of PCN issue: 02/01/2025
       > Vehicle registration: [INSERT VRM]
       >
       > I am submitting this complaint to report a misuse of my
       personal data by Universal Parking Enforcement Ltd, who obtained
       my keeper details from the DVLA under the KADOE (Keeper At Date
       Of Event) contract.
       >
       > Although the company may have had reasonable cause to request
       my data, their subsequent use of it was unlawful due to breaches
       of the governing Code of Practice (PPSCoP), which forms a
       mandatory condition of KADOE access. The KADOE contract only
       permits use of DVLA keeper data for the fair pursuit of unpaid
       parking charges in accordance with the Code.
       >
       > In this case, the operator has breached the Code and misused
       my data in the following ways:
       >
       > [indent]• Unlawful pursuit of keeper liability: The Notice to
       Keeper was issued on 02/01/2025, nearly five months after the
       alleged incident on 06/08/2024. Under PoFA Schedule 4, Paragraph
       9(4)(b), keeper liability can only apply if the notice is
       delivered within 14 days of the parking event. As this was not
       done, the operator had no lawful basis to pursue me as the
       registered keeper.
       > • Failure to respect statutory limits on data use: Despite
       being informed that I was not the driver and presented with
       evidence of this (including my flight itinerary and boarding
       pass showing I was abroad at the time), the operator continued
       to pursue me without any legal basis under PoFA. They also
       refused to acknowledge that I am under no legal obligation to
       identify the driver.[/indent]
       >
       > These breaches are not minor. They represent a fundamental
       misuse of DVLA keeper data and a disregard for the conditions
       attached to its release. By acting outside the boundaries set by
       PoFA and the PPSCoP, Universal Parking Enforcement Ltd lost the
       lawful basis for continued processing of my personal data.
       >
       > The DVLA remains the data controller for all data disclosed
       under KADOE and is therefore responsible for ensuring that this
       data is not misused. I respectfully request that DVLA
       investigate this complaint and confirm whether Universal Parking
       Enforcement Ltd has breached the terms of their KADOE contract.
       >
       > I ask the DVLA to consider the following actions:
       >
       > This may include:
       >
       > [indent]• A formal finding of breach
       > • Enforcement action as appropriate
       > • Suspension or revocation of KADOE access if
       warranted[/indent]
       >
       > Supporting documents, including my original appeal and
       evidence proving I was not the driver, have been uploaded with
       this statement.
       >
       > Name: [INSERT YOUR NAME]
       > Date: [INSERT DATE]
       --- End Quote ---
       #Post#: 67256--------------------------------------------------
       Re: Kelly's Storage Lu2 9LF PCN – Not the Driver – Urgent Advice
       Needed Please
   DIR By: S Patel
       Date: April 15, 2025, 12:46 pm
       ---------------------------------------------------------
       Thank you both for all the advice I will keep you updated on
       what happens next.
       Many Thanks
       #Post#: 67272--------------------------------------------------
       Re: Kelly's Storage Lu2 9LF PCN – Not the Driver – Urgent Advice
       Needed Please
   DIR By: Sander333
       Date: April 15, 2025, 2:26 pm
       ---------------------------------------------------------
       The advice you have been provided with is of the highest
       quality.
       For what it is worth I would not recommend any appeal to IAS a
       total waste of time and effort if you win an appeal with them
       buy a lottery ticket you will be on a winner.
       #Post#: 67288--------------------------------------------------
       Re: Kelly's Storage Lu2 9LF PCN – Not the Driver – Urgent Advice
       Needed Please
   DIR By: H C Andersen
       Date: April 15, 2025, 4:25 pm
       ---------------------------------------------------------
       I don't understand the references to 'appealing to the IAS'.
       That ship sailed weeks ago IMO.
       OP, pl just confirm and add the key procedural facts:
       Parking event which gave rise to the parking charge: 6 August
       2024;
       Date of issue of NTK: 2 Jan. 2025.
       Your appeal to them dated: ????
       Their reply to you dated: ????
       Deadline for appealing to IAS: 'within 21 days of the [unknown]
       date of their reply' -see above.
       Also: was a notice(to driver) left on the vehicle on 6 August,
       or was the first communication the Notice to Keeper dated 2 Jan.
       2025?
       I think you'll find that this is a simple procedural issue, all
       we need is facts.
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