June 2018 - start of the new PPC and DVLA fightback (GDPR related)

The_Slithy_Tove

abedegno wrote: »

Not sure why they want my insurance details.

Not surprising they want some evidence that you are the data subject. But surely if you have the V5C, that's enough. And if you are not the person on the V5C, as long as they use the name and address on that form, they are surely communicating with the RK (assuming no recent change in keeper).

They can go swivel regarding insurance. After all, the insurance certificate doesn't give the address (mine doesn't anyway). Named drivers proves nothing at all - it's possible for people not named to be driving the car. And it would then be giving them personal data that they do not need to have or keep.

abedegno

KeithP wrote: »

They are asking for insurance details that demonstrate that you were not only the RK at the date of Issue of the V5c, but continued to be the RK throughout the period that you are requesting data for. Looks like that might almost be reasonable.

I cannot understand their interest in 'named drivers' though.
Just because there are named drivers on any insurance policy does not mean that the registration number of the RK's vehicle becomes personal date of those named drivers. That is ridiculous.

Ahh, yes in that context a current insurance document should be enough to prove that I am currently the RK.

I don't get the named driver bit either, the VRM is an identifier which related to the RK as the data subject only.

The_Slithy_Tove

Thinking about it more, the request for drivers (via insurance) is even more ridiculous and just a fishing exercise.

This will ... identify whether either vehicle is linked to any other named drivers and if other named drivers are identified, written confirmation from those individuals to confirm that they are content to allow data to be released to you.

No matter who was driving, the RK will have received any NtKs, as that's how PE work. And in the past (and present, no doubt), PE don't give a jot about the privacy of the driver when they send out an NtK to the keeper when the car has overstayed in a doctor's surgery.

abedegno

I've replied to them, providing driving license, section 5 of V5 and latest insurance docs that show I am the current keeper of the vehicle.

I've questioned the need for a named driver's consent - the VRM is an identifier that identifies the registered keep as the data subject, unless ParkingEye gets information from insurers they shouldn't have anything else.

The also omitted to answer my supplementary questions, instead directing me to their privacy policy. I have reminded them of this fact and that the privacy policy does not contain the answers.

Fergie76

abedegno wrote: »

I've replied to them, providing driving license, section 5 of V5 and latest insurance docs that show I am the current keeper of the vehicle.

I've questioned the need for a named driver's consent - the VRM is an identifier that identifies the registered keep as the data subject, unless ParkingEye gets information from insurers they shouldn't have anything else.

The also omitted to answer my supplementary questions, instead directing me to their privacy policy. I have reminded them of this fact and that the privacy policy does not contain the answers.

I am really confused about the insurance document bit. An insurance document doesn't prove RK. Previously we have had a Motability car in my wife's name, therefore she was RK, Motability were owners and I was driver (and sole name on insurance). Wife doesn't drive so would never have insurance in her name. So how would she prove RK, as DVLA are requesting?

KeithP

Fergie76 wrote: »

So how would she prove RK, as DVLA are requesting?

It's not DVLA requesting this - they already know who the RK is at any, and every, moment it time.

It is ParkingEye trying to dream up excuses why they don't have to comply with a Subject Access Request.

Coupon-mad

Seems like a fishing exercise worthy of a complaint to the ICO in its own right.

What gives PE to right to ask to see your insurance document, at all?

What gives PE the right to see the name (private data) of named drivers?

How bl00dy dare they? It is crystal clear this is data they will then use for another purpose, to use against a keeper in court by saying, ''look he voluntarily gave us his insurance policy and he is the only driver...''

IMHO, parking firms need their food chain ending, and shoving in jail with the lowlifes of Society.

Fergie76

KeithP wrote: »

It's not DVLA requesting this - they already know who the RK is at any, and every, moment it time.

It is ParkingEye trying to dream up excuses why they don't have to comply with a Subject Access Request.

Ah ok, thanks. I misread the initial post saying it was from PE. Thought s/he was still talking about DVLA, although point still stands.

abedegno

I'll play their little game - fortunately an insurance schedule is easily mocked up - with an Ivana Tinkle and Al Coholic as named drivers...

Coupon-mad

Too right.

And report them to the ICO for this, they cannot harvest insurance policies then use that ''ID'' data for other reasons, to help them sue people.