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#Post#: 72912--------------------------------------------------
Re: Britannia Parking - Overstay - Plinston Retail Park,
Letchworth, Herts
DIR By: jfollows
Date: May 23, 2025, 5:49 am
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I’d not bother with much “evidence”, keep it in reserve in case
you need it later but don’t use it now. You don’t have to prove
anything.
Of course, unless you’re thinking of appealing on a different
basis than the ANPR error, there’s no harm in identifying the
driver.
#Post#: 72915--------------------------------------------------
Re: Britannia Parking - Overstay - Plinston Retail Park,
Letchworth, Herts
DIR By: DWMB2
Date: May 23, 2025, 6:07 am
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--- Quote from: jfollows link ---
>
> Of course, unless you’re thinking of appealing on a different
basis than the ANPR error, there’s no harm in identifying the
driver.
>
--- End Quote ---
Equally, no real benefit either, so I wouldn't.
#Post#: 72953--------------------------------------------------
Re: Britannia Parking - Overstay - Plinston Retail Park,
Letchworth, Herts
DIR By: b789
Date: May 23, 2025, 10:15 am
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I would be more forceful with your appeal. Also, you are
referencing old Code of Practice instead of the current PPSCoP.
You should also make a forma complaint tot he DVLA as they have
obtained your Keeper data unlawfully. Put them on notice.
Your initial appeal will be rejected, no matter what. However,
it is designed to get a POPLA code for your secondary appeal. I
would advise appealing with the following:
--- Quote ---
> I am appealing your Parking Charge Notice (PCN) [Insert PCN
Number] issued as a postal Notice to Keeper (NtK).
>
> You have failed to perform the mandatory manual quality
control checks required under Section 7.3 of the Private Parking
Single Code of Practice (PPSCoP). Note 1 under that section
makes it explicitly clear that such checks are vital for
identifying situations such as “double dipping” and for
correctly assigning orphan ANPR images to separate visits.
>
> Had you fulfilled this requirement, it would have been obvious
that the vehicle in question made two distinct, separate visits.
Your failure to assign the orphan images correctly has resulted
in a completely false allegation of overstaying.
>
> Because of this operational failure, your request to the DVLA
for the registered keeper’s data was made without reasonable
cause, as required by your KADOE contract. The data was obtained
unlawfully. You are therefore on notice that a complaint will be
submitted to the DVLA and escalated as appropriate.
>
> In the meantime, this appeal constitutes a formal notification
that your data processing is also in breach of the UK GDPR. You
had no lawful basis to obtain and continue processing the
keeper’s personal data, and you are hereby instructed to delete
all data relating to this PCN from your systems.
>
> This Parking Charge Notice must be cancelled immediately.
Please confirm cancellation and data erasure in writing.
--- End Quote ---
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 Britannia Parking
Group, a BPA AOS member with DVLA KADOE access, for unlawfully
requesting and misusing my personal data in breach of both the
KADOE contract and the Private Parking Single Code of Practice
(PPSCoP).
>
> This complaint concerns the unlawful initial request for my
data. Britannia Parking failed to carry out the required manual
quality control checks under Section 7.3 of the PPSCoP before
applying to the DVLA for my keeper details. Had they complied
with the Code, they would have identified that this was a
“double dip” scenario involving orphan ANPR images that should
have been assigned to separate visits. This failure meant they
had no reasonable cause to request my data in the first place.
>
> Their non-compliance with the PPSCoP invalidates their access
to DVLA data and puts them in breach of their KADOE contract. I
am attaching a supporting statement setting out the details and
ask that the DVLA investigate this breach, together with their
own responsibilities as the ultimate data controller and confirm
the reference 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: Britannia Parking
> Date of PCN issue: [INSERT DATE]
> Vehicle registration: [INSERT VRM]
>
> I am submitting this complaint to report that Britannia
Parking unlawfully requested and processed my personal data in
breach of the KADOE contract and the Private Parking Single Code
of Practice (PPSCoP), which governs all DVLA data access by AOS
operators.
>
> This complaint is not limited to their post-access conduct.
The initial request for my keeper data was unlawful because
Britannia failed to conduct the mandatory manual quality control
check of their ANPR records, as required under Section 7.3 of
the PPSCoP. Note 1 under this section specifically highlights
the importance of these checks for identifying scenarios such as
“double dipping” — where a vehicle enters and exits a site more
than once but the system fails to match images correctly. The
PPSCoP requires operators to manually assign orphan images
before taking enforcement action.
>
> Had Britannia Parking carried out the required manual quality
control check under Section 7.3 of the PPSCoP, they would have
identified that this was a multi-visit event involving orphan
ANPR images. In other words, they would have had no cause of
action whatsoever and therefore no justification to request my
keeper data from the DVLA.
>
> By failing to conduct this required check, Britannia Parking
submitted a KADOE request without reasonable cause, thereby
unlawfully obtaining my personal data. This is a direct breach
of the KADOE contract and an unlawful intrusion under the UK
General Data Protection Regulation (UK GDPR).
>
> The breach does not stop there. Britannia has continued to
store, use, and process my unlawfully obtained data — including
sending me a PCN and subsequent correspondence. Each act of data
processing constitutes a further breach of the GDPR, compounding
the original misuse.
>
> The DVLA, as the Data Controller for the data it releases
under KADOE, is not a passive party. It has a statutory
obligation under UK GDPR and the Data Protection Act 2018 to
take enforcement action against its contractors who misuse
personal data. Furthermore, because the breach flows from the
DVLA’s own release of data to a non-compliant operator, I expect
the DVLA to self-report this incident to the Information
Commissioner’s Office (ICO) as a controller involved in the
chain of misuse.
>
> I request a full investigation into Britannia Parking’s
unlawful request and misuse of my data, and I expect the DVLA to
take all appropriate action, including sanctions under the KADOE
contract and regulatory reporting to the ICO.
>
> Please confirm receipt and provide a reference for this
complaint. I am happy to provide further evidence if required.
>
> Name: [INSERT YOUR NAME]
> Date: [INSERT DATE]
--- End Quote ---
#Post#: 72978--------------------------------------------------
Re: Britannia Parking - Overstay - Plinston Retail Park,
Letchworth, Herts
DIR By: AJHertsLdn
Date: May 23, 2025, 11:39 am
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Thanks - appeal filed and DVLA complaint made. Hopefully I hear
nothing while I'm on holiday next week.
Regards
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