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#Post#: 102680--------------------------------------------------
Re: Euro car park - Fullwell cross Leisure centre.
By: DWMB2 Date: December 16, 2025, 10:56 am
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Then try and find some alternative email address via which to
reach the relevant team. Respectfully, given the driver works
for the council they are probably better placed to find out/tell
you how to contact the council than we are...
#Post#: 102681--------------------------------------------------
Re: Euro car park - Fullwell cross Leisure centre.
By: Brenda_R2 Date: December 16, 2025, 11:11 am
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I sent a blank email to parking.services@redbridge.gov.uk with
the subject line "Test".
It bounced back with
Your message to parking.services@redbridge.gov.uk couldn't be
delivered.
parking.services wasn't found at redbridge.gov.uk.
More Info for Email Admins
Status code 554 5.4.14
Typically this error occurs because the recipient email address
doesn't exist at the destination domain.
Are they providing duff email addresses for service?
#Post#: 102771--------------------------------------------------
Re: Euro car park - Fullwell cross Leisure centre.
By: b789 Date: December 16, 2025, 7:35 pm
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They must publish a contact email address for their DPO, so
check their privacy statement for those details and send to the
DPO explaining that the email is served and for them to pass it
to the relevant department.
It’s not our job to do everything for you. Please use some
initiative and get it to the relevant department.
#Post#: 103807--------------------------------------------------
Re: Euro car park - Fullwell cross Leisure centre.
By: Hashim Date: December 26, 2025, 4:29 am
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Seasons Greetings.
DVLA replied:
HTML https://ibb.co/93mLmK1q
waiting on the others..
Hashim
#Post#: 103821--------------------------------------------------
Re: Euro car park - Fullwell cross Leisure centre.
By: b789 Date: December 26, 2025, 11:33 am
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This DVLA response does not properly address the complaint and
amounts to a fob-off.
Your complaint was not about whether a PCN exists, whether Euro
Car Parks are BPA members, or whether a vehicle was parked. It
was about whether DVLA lawfully released keeper data where the
operator is asserting PoFA keeper liability on land that is
excluded from PoFA by statute.
The response completely fails to engage with PoFA Schedule 4
paragraph 3. There is no consideration at all of whether the
land is “relevant land”. There is no consideration of whether
the parking place is provided or controlled by a traffic
authority. There is no analysis of council ownership, traffic
authority status, or off-street parking provision. Those are
mandatory considerations, because PoFA can only apply on
relevant land.
Instead, DVLA rely on generic statements about “reasonable
cause” and simply repeat what Euro Car Parks have told them.
That is not an assessment. DVLA are required to make their own
lawful decision before releasing personal data. Accepting the
operator’s assertion at face value is not sufficient,
particularly where Parliament has expressly excluded local
authority parking from Schedule 4.
Reasonable cause cannot exist where the stated cause relied upon
by the operator is legally unavailable. Euro Car Parks are
asserting statutory keeper liability under PoFA. PoFA does not
apply to a parking place provided by a traffic authority. Once
that statutory exclusion applies, the foundation for keeper
liability collapses and DVLA data cannot lawfully be released
for that purpose.
The response also mischaracterises DVLA’s role. While DVLA do
not regulate parking companies generally, they do regulate their
own disclosure of personal data under Regulation 27. That duty
cannot be delegated to the BPA, to the operator, or avoided by
saying DVLA do not regulate parking enforcement. This complaint
concerns DVLA’s own statutory decision-making, not the parking
company’s business model.
The response therefore demonstrates a failure to take into
account relevant considerations, reliance on irrelevant
considerations, and a failure to apply the correct legal test.
That is maladministration.
The correct next step is a Step 2 DVLA complaint stating clearly
that DVLA have failed to consider PoFA Schedule 4 paragraph
3(1)(b), failed to determine whether the land is relevant land,
and have unlawfully relied on operator assertions rather than
applying the statute. If DVLA maintain this position at Step 2,
the matter should be escalated to the Independent Complaints
Assessor and, in parallel, to the Information Commissioner’s
Office on the basis that DVLA disclosed personal data without
properly assessing lawfulness.
I advise you to submit the following Step 2 complaint in
response:
[quote]Subject: Step 2 complaint – failure to consider PoFA
Schedule 4 paragraph 3 and unlawful release of keeper data
Dear Mrs Boucher,
This is a Step 2 escalation of my complaint concerning the
DVLA’s release of registered keeper data to Euro Car Parks Ltd.
I am dissatisfied with the Step 1 response dated 22 December
2025, which fails to address the substance of the complaint and
amounts to a fob-off.
My complaint was not about whether a Parking Charge Notice was
issued, whether Euro Car Parks are members of an Accredited
Trade Association, or whether a vehicle was parked. It was about
whether DVLA lawfully released keeper data in circumstances
where the operator is asserting keeper liability under Schedule
4 of the Protection of Freedoms Act 2012 on land where that
statute is expressly excluded.
The Step 1 response does not address PoFA Schedule 4 paragraph 3
at all. There is no consideration of whether the land is
“relevant land”. There is no consideration of whether the
parking place is provided or controlled by a traffic authority.
There is no analysis of council ownership, traffic authority
status, or off-street parking provision. These are mandatory
considerations because keeper liability under PoFA can arise
only on relevant land.
Instead, the response relies on generic statements about
“reasonable cause” and simply repeats assertions made by Euro
Car Parks. That is not a lawful assessment. DVLA are required to
make their own independent decision before releasing personal
data. Accepting an operator’s assertions at face value, without
applying the statutory exclusions enacted by Parliament, is a
failure of that duty.
Reasonable cause cannot exist where the cause relied upon is
legally unavailable. Euro Car Parks are asserting statutory
keeper liability under PoFA. PoFA does not apply to a parking
place provided by a traffic authority. Once paragraph 3(1)(b)
applies, the statutory foundation for keeper liability falls
away and DVLA data cannot lawfully be released for that purpose.
The Step 1 response also mischaracterises DVLA’s role by stating
that DVLA do not regulate parking companies. That is irrelevant.
This complaint concerns DVLA’s own statutory decision-making
under Regulation 27 of the Road Vehicles (Registration and
Licensing) Regulations 2002 and DVLA’s obligations as a data
controller. Those obligations cannot be delegated to the
operator or the BPA.
The Step 1 response therefore demonstrates a failure to consider
relevant matters, reliance on irrelevant matters, and a failure
to apply the correct legal test. That amounts to
maladministration.
I request that this Step 2 review addresses the following points
directly and substantively:
1. Whether the land in question is a parking place provided or
controlled by a traffic authority for the purposes of PoFA
Schedule 4 paragraph 3(1)(b).
2. Whether PoFA keeper liability is legally capable of applying
at that location.
3. On what lawful basis DVLA considered “reasonable cause” to
exist for the release of keeper data where PoFA is statutorily
excluded.
4. Why these matters were not considered at Step 1.
If the Step 2 response again fails to engage with the statutory
exclusion in PoFA Schedule 4 paragraph 3, or simply repeats
generic statements without applying the law, I will escalate the
matter without further notice to the Independent Complaints
Assessor as a case of maladministration. I will also refer the
matter to the Information Commissioner’s Office in relation to
unlawful disclosure of personal data, and to my Member of
Parliament with a view to further escalation to the
Parliamentary and Health Service Ombudsman.
I expect a substantive Step 2 response that directly addresses
the legal issues raised.
Yours sincerely,
[name][/quote]
#Post#: 105092--------------------------------------------------
Re: Euro car park - Fullwell cross Leisure centre.
By: Hashim Date: January 8, 2026, 9:29 am
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Dear b789
Step 2 was sent as instructed. Waiting for a response.
Also received a response from the Euro parks stating that they
will NOT cancel the PCN. See below:
HTML https://ibb.co/RkvfcwJ6
what's next.....
Thanks
Hashim
#Post#: 106118--------------------------------------------------
Re: Euro car park - Fullwell cross Leisure centre.
By: Hashim Date: January 16, 2026, 1:54 am
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Good morning
Also received a response from DVLA...
HTML https://ibb.co/LdXy6r3H
what's next please.......
Hashim
#Post#: 106120--------------------------------------------------
Re: Euro car park - Fullwell cross Leisure centre.
By: InterCity125 Date: January 16, 2026, 2:04 am
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Once again the DVLA have deliberately ducked the key issue - the
correct application PoFA does not get one single mention in
their response.
#Post#: 106252--------------------------------------------------
Re: Euro car park - Fullwell cross Leisure centre.
By: InterCity125 Date: January 17, 2026, 3:34 am
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I would respond to the DVLA with the following...
[font=Georgia]Dear Mrs N Smith,
Thank you for your email dated 14th January 2026.
I have duly noted its contents.
Unfortunately, the response contained within, bears absolutely
no relationship to the complaint which I have actually
submitted.
In my step 2 complaint email, I clearly set out the three major
points which needed urgently addressing with regard to the
correct application of PoFA at the parking location in question
- this was clearly the basis of my complaint and was also
outlined at length at the step 1 complaint stage.
Your latest email clearly addresses none of those critical
issues and as such my complaint continues to be completely
unresolved.
More worryingly, your email seemingly 'skips over' my entire
complaint in a single generalised sentence without engaging with
any of my three key points - clearly, this is not a proper
complaints handling process - instead it is an obvious attempt
to deliberately avoid investigating the matter correctly - this
should not be happening at a step 2 complaints handling process
within a Government organisation.
You specify that PoFA came into force on 1st October 2012 and
that it made a vehicle keeper liable for unpaid parking charges
in situations where the driver was not known to the parking
operator - having read PoFA, you must know that this is not true
in every circumstance and that each event actually requires a
certain amount of examination in order to establish if PoFA can
be applied? - There are in fact many requirements to be met
before a parking operator can hold the registered keeper liable
using the PoFA legal mechanism - inexplicably, your response
fails to mention ANY of these specific conditions or
requirements.
In your email, instead of engaging with my questions, your
statement simply implies that PoFA applies in all circumstances
- at no point do you attempt to quantify your statement in order
to make it either relevant to my complaint or relevant to the
behaviour of the parking operator - you then simply move on to
your next point and, in doing so, you immediately steer
attention directly AWAY from the nature of the complaint - to be
blunt, this is a massive palpable error on your part since it is
legally accepted that PoFA does not apply at all car park
locations and therefore your blanket statement on PoFA is
completely misleading.
In essence, you have failed to ascertain whether PoFA is
applicable to this particular car park location - despite my
preamble and clearly stated questions, your responses never even
addresses this critical question - without considering this
point you cannot possibly start to weigh up the complaint in
order to ascertain whether the parking operator has breached
their code of conduct and therefore breached the KADOE
agreement. Neither can you establish whether my personal data
has been wrongly supplied, by the DVLA, to a third party
unregulated parking operator under a totally false pretence.
This basically presents us with a situation where the obvious
errors made in the step 1 complaint handling process have been
wholly repeated in the step 2 complaint handling process -
namely, that the nature of the complaint is never addressed and
that the individual handling the complaint quickly moves the
complaint onto issues which were never stated as being part of
the complaint - again, a palpable error on the part of the DVLA
complaints handling team. This now appears to be a systemic
issue within the DVLA complaints handling team as this issue has
now occurred at both step 1 and step 2 of the complaints
procedure with the step 2 response simply being a re-hash of the
wording from the step 1 response.
Given that the errors being made are so blindingly obvious, I
would now like the step 2 complaints handling process to be
repeated - properly - and this time it would be helpful if the
person conducting the investigation would take the time to
actually read my step 2 complaint email and address the facts of
the case rather than spending their time trying to materially
alter the nature of the complaint as to avoid dealing with the
core issue - namely; was my data provided to a parking operator
who is mis-stating PoFA and therefore wrongly acquiring my
personal data before issuing me with a totally non-compliant Ntk
which broke numerous rules and regulations which they agreed to
be bound by?
Just to give you some idea, and by way of help, (and based on
the actual complaint being made) this is how I would personally
be responding to the step 2 complaint which I have submitted;
"I have now had time to examine the legal status of the car park
location at Fullwell Cross Leisure Centre and I have
subsequently established that the land is owned by the London
Borough of Redbridge."
"The London Borough of Redbridge is a Council and therefore,
legally, constitutes a traffic authority."
"As the car park is Council owned, it represents, in law, an
off-street parking place provided by a traffic authority."
"The Council have approached Euro Car Parks to help them manage
this location - this appears to be a perfectly legitimate
arrangement."
"However, due to the car park being owned by a traffic
authority, it is NOT a location where PoFA can be used to invoke
keeper liability in the event of a privately issued Parking
Charge Notice being issued to an unknown driver."
"In particular, Schedule 4 of PoFA (the ability of a parking
operator to move liability from an unknown driver to a
registered keeper) applies only to 'relevant land', and
Paragraph 3(1)(b) expressly excludes 'a parking place which is
provided or controlled by a traffic authority' from being
'relevant land' for the purposes of PoFA.
"It is therefore clear, that the car park at Fullwell Cross
Leisure Centre is not 'relevant land' as it is land which is
owned by a traffic authority and as such PoFA cannot possibly
apply at this particular location."
"From DVLA records, I can see that Euro Car Parks have seemingly
accessed registered keeper details for contraventions at
Fullwell Cross Leisure Centre despite there being no keeper
liability at that site."
"This raises serious issues surrounding 'reasonable cause' (to
request keeper details) because there is no keeper liability
since PoFA cannot be invoked at this particular location -
therefore, there is no legitimate legal pathway for the parking
operator to hold the registered keeper liable for any alleged
contravention."
"I also note that the PCN issued via a 'Postal Notice to Keeper'
(NtK to the complainant) contains a specific wording which
states that Euro Car Parks can pursue the registered keeper for
the alleged PCN debt using Section 4 of PoFA - such wording on
an NtK is EXPRESSLY PROHIBBITED by the operators Code of Conduct
in locations where PoFA does not apply."
"It is therefore clear that the parking operator is breaching
their Code of Conduct by issuing notices which contain clearly
misleading wording relating to both PoFA and keeper liability."
"Any breach of the Code of Conduct is also a breach of the DVLA
KADOE Agreement (with the parking operator) since the KADOE
Agreement requires the parking operator to expressly agree to
comply with the Code of Conduct before accessing Registered
Keeper data."
I'm sure you get the picture....[/font]
----------------------------------------------------------------
-
They may re-examine the matter or they may reject it.
Your case has obviously caused them significant issues and that
is why they are refusing to answer specific questions on the
PoFA status at Fullwell Cross.
#Post#: 106255--------------------------------------------------
Re: Euro car park - Fullwell cross Leisure centre.
By: DWMB2 Date: January 17, 2026, 4:09 am
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I'm not sure I would suggest to DVLA what their own response
wording should be, but I think the wording about their failure
to properly consider is great.
If you've reached the end of the DVLA process, you can refer it
to an Independent Complaints Assessor. They won't "relitigate"
the issue, but will look at whether DVLA's handling was
sufficient.
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