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       #Post#: 82966--------------------------------------------------
       Re: SABA, railway property, Penalty Notice to OWNER
   DIR By: martin_t
       Date: July 27, 2025, 9:54 am
       ---------------------------------------------------------
       Indeed.
       Maybe saba would like to consult the freely available 'Register
       of Vehicle Owners'. Do you have contact details for such a thing
       ;D
       #Post#: 84667--------------------------------------------------
       Re: SABA, railway property, Penalty Notice to OWNER
   DIR By: martin_t
       Date: August 7, 2025, 2:53 pm
       ---------------------------------------------------------
       I received the standard response from DVLA a couple of days ago.
       So, just for the record:
  HTML [img]http://
  HTML https://i.imgur.com/OxcfwMa.png[/img]
  HTML [img]http://
  HTML https://i.imgur.com/Ugo7DsH.png[/img]
       Or this (as the above doesn't seem to work - despite following
       the instructions)
  HTML https://imgur.com/a/zWkzp7T
       DVLA level 2 response now?
       #Post#: 84729--------------------------------------------------
       Re: SABA, railway property, Penalty Notice to OWNER
   DIR By: b789
       Date: August 8, 2025, 5:45 am
       ---------------------------------------------------------
       Usual DVLA fob-off. Send the following email to
       dvla.complaints@dvla.gov.uk and CC
       kadoeservice.support@dvla.gov.uk and yourself:
       --- Quote ---
       > Subject: Step 2 Escalation – Misuse of DVLA Data by SABA UK
       Ltd – Reference 0413745
       >
       > Dear Data Assurance Team,
       >
       > DVLA Reference: 0413745
       > Date of DVLA Step 1 Response: 5 August 2025
       >
       > I am writing to formally escalate my complaint to Step 2 of
       the DVLA complaints process, following the unsatisfactory
       response I received at Step 1.
       >
       > My original complaint, dated 31 July 2025, concerned the
       misuse of DVLA-supplied vehicle keeper data by SABA Park
       Services UK Ltd, a British Parking Association (BPA) member
       operating under the Approved Operator Scheme (AOS). The penalty
       notice issued by SABA relates to an alleged breach of Railway
       Byelaw 14 and falsely asserts that, in addition to criminal
       prosecution, “legal action may be taken via the Civil Procedure
       in the County Court”.
       >
       > This is factually and legally incorrect. A breach of Railway
       Byelaw 14 is a summary-only criminal offence, enforceable
       exclusively via prosecution in the Magistrates’ Court. There is
       no legal basis for recovery via civil litigation or the Civil
       Procedure Rules. The claim that a civil court route is available
       is not only misleading — it is a fiction invented to coerce
       payment.
       >
       > The Step 1 response entirely failed to engage with the
       substance of this complaint. The following issues remain
       unresolved:
       >
       > [indent]1. Failure to assess whether the use of DVLA data
       breaches the KADOE contract
       >
       > The use of keeper data to send misleading notices falsely
       implying civil recovery is not authorised under Regulation
       27(1)(e) of the Road Vehicles (Registration and Licensing)
       Regulations 2002 or under the KADOE contract. The data was
       supplied for a specific lawful purpose, not to facilitate
       misrepresentation of enforcement options.
       >
       > 2. Failure to respond to the question of lawfulness
       >
       > I asked whether the DVLA accepts that keeper data is being
       used by SABA in connection with an enforcement route that is not
       legally available. The response merely reiterated standard
       policy on “reasonable cause,” ATA membership, and the BPA’s
       role, without addressing whether this particular usage is
       lawful, accurate, or contractually compliant.
       >
       > 3. Failure to confirm referral to compliance/enforcement team
       >
       > I explicitly requested that the matter be referred to the
       DVLA’s compliance and enforcement team for investigation under
       the KADOE contract. The Step 1 response does not confirm whether
       any such referral was made.
       >
       > 4. Failure to consider data misuse under UK GDPR and section
       171 of the Data Protection Act 2018
       >
       > If keeper data is used for a purpose that was not lawful, fair
       or transparent, or used in a misleading and coercive manner,
       this may constitute a breach of data protection law. This aspect
       was entirely overlooked.[/indent]
       >
       > The DVLA's reliance on BPA membership as a safeguard is
       insufficient in this context. BPA membership cannot legitimise
       the misuse of personal data or override the statutory framework
       governing criminal offences. Moreover, the BPA is not a
       statutory regulator and does not have legal authority to
       determine the lawfulness of enforcement methods.
       >
       > In summary, I am not seeking DVLA arbitration in a contractual
       dispute. I am raising concerns about the systematic misuse of
       DVLA-supplied data, which:
       >
       > [indent]• misrepresents the legal status of a penalty notice,
       > • threatens enforcement methods not permitted under law, and
       > • thereby breaches the DVLA's own KADOE contract and possibly
       the UK GDPR.[/indent]
       >
       > I expect DVLA, as the data controller, to assess whether
       SABA's practices are compatible with the stated purposes for
       which the data was released, and to confirm whether the matter
       has been referred to its internal compliance or enforcement
       function.
       >
       > Please treat this as a formal Step 2 complaint. I would
       appreciate confirmation of receipt and a timeline for your
       review.
       >
       > Yours faithfully,
       >
       > [Full name]
       >
       > [Address or other identifying details, if needed to match the
       case]
       > [Optional: Attach the SABA notice again for reference]
       --- End Quote ---
       #Post#: 91655--------------------------------------------------
       Re: SABA, railway property, Penalty Notice to OWNER
   DIR By: martin_t
       Date: September 26, 2025, 10:22 am
       ---------------------------------------------------------
       An update...
       DVLA Step 2 Escalation was emailed on 12/8/25. No response so
       far. Shocked! Shall I poke them?
       First ZZPS money demand with menaces received on 22/8/25
       Second ZZPS money demand with menaces seemingly posted on
       8/9/25. Due to holidays from 8th to 23rd Sept, received on
       23/9/25
  HTML https://i.imgur.com/mNz0gSp.jpeg
       #Post#: 91658--------------------------------------------------
       Re: SABA, railway property, Penalty Notice to OWNER
   DIR By: b789
       Date: September 26, 2025, 10:46 am
       ---------------------------------------------------------
       You should prompt the DVLA for a response to your step 2
       complaint.
       When you receive the letter from GCTT, their supposed
       "enforcement agents", have a look at the small print on the
       bottom of the letter if you want a laugh!
       I think Deborah just hands the file to Tim (nice but dim)
       sitting next to her.
       If it was me and I had the time, I'd be responding to these
       cretins and winding them up no end. Not because I have to but I
       enjoy the sport.
       #Post#: 91660--------------------------------------------------
       Re: SABA, railway property, Penalty Notice to OWNER
   DIR By: martin_t
       Date: September 26, 2025, 10:50 am
       ---------------------------------------------------------
       Deborah has such a lovely signature, so I'm sure she's a great
       person. Shame about Tim though. I wonder if his signature is,
       er, a bit faded...
       #Post#: 91661--------------------------------------------------
       Re: SABA, railway property, Penalty Notice to OWNER
   DIR By: DWMB2
       Date: September 26, 2025, 10:52 am
       ---------------------------------------------------------
       The "We are surprised that this matter remains unresolved" line
       always makes me laugh - ZZPS are debt collectors, every single
       case sent their way is unresolved.
       #Post#: 91662--------------------------------------------------
       Re: SABA, railway property, Penalty Notice to OWNER
   DIR By: martin_t
       Date: September 26, 2025, 10:54 am
       ---------------------------------------------------------
       Yeah, and on reflection, I've changed my mind about Deborah.
       She's too passive-aggressive for me.
       #Post#: 92348--------------------------------------------------
       Re: SABA, railway property, Penalty Notice to OWNER
   DIR By: martin_t
       Date: October 1, 2025, 9:02 am
       ---------------------------------------------------------
       Ooohhhh...
  HTML https://i.ibb.co/Swgg1mKq/Enforcement-1.jpg
       I followed your instructions and had a giggle.
       I'm curious about how you'd wind them up! I'm sure it would be
       at least as amusing as GCCT's footer.
       I've also sent the following to DVLA:
       "Dear Data Assurance Team,
       I have yet to receive a response to my previous email (dated
       12/8/25) escalating my complaint to Step 2 of the DVLA
       complaints process.
       Six weeks plus without any response appears unfortunate.
       However, if you consider that this is not unacceptable I would
       appreciate some indication of the timeframe to respond that you
       aim to achieve.
       Yours faithfully,"
       I fear some of the lovely Deborah's passive-aggressive-ness has
       rubbed off onto me   :-X  ;D
       #Post#: 92417--------------------------------------------------
       Re: SABA, railway property, Penalty Notice to OWNER
   DIR By: b789
       Date: October 1, 2025, 1:47 pm
       ---------------------------------------------------------
       Consider that letter as free hamster bedding if you shred it
       finely enough.
       Think about it... "transfer to solicitors". What does that mean?
       Are they really going to try and sue a county court claim under
       civil contract law for a Penalty Notice issued under statutory
       railway byelaws which is a criminal matter which can only be
       heard in a magistrate's court?
       Just sit back and enjoy the farce that is unfolding.
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