Premier Parking Solutions

Fruitcake

Kpros said:

Fruitcake said:

Did you expressly say that you were seeking debt advice when you instructed them to put the case on hold?

Hello, yes, this was the email.

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Dear sirs,

Re: XXXXXXX /XXXX XXX

Please be advised that I am seeking debt advice, however I deny any debt.

The case must be placed on hold for no less than 30 days under the PAP for debt claims 2017.

I have sent your client a Subject Access Request (SAR).

Yours sincerely

XXXXXX XXXXXXXX

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 I hope this is sufficient? 

Perfect.

Kpros

Hi all,

I have received this response from PPS

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Good morning,

We understand that you are requesting a Subject Access Request (SAR).

The General Data Protection Regulations (GDPR) came into play on 25th May 2018 and replaced the Data Protection Act 1998 (DPA).

GDPR gives certain rights to Data Subjects (DS) in accessing personal data that is about them or where they are identified.

It also places obligations on Data Controllers (DC) in relation to the security of the personal data that we hold not to divulge this personal data to individuals or organisations that should not normally have access to it.

We therefore need you to confirm your identity by providing us with two pieces of documentary evidence. We don’t need to see original documents (a clear photocopy or photograph of the document will suffice) and it is advisable to redact (blank out) any financial information that may be contained in the document.

Some examples of documents we can use to verify your identity can be found below:

Driving License

Passport

Utility Bill

Council Tax Bill

Mortgage or Rent document

Bank Statement (or other financial statement)

HMRC document

When we receive your identity documents, we will then collate any personal data we hold on you and will endeavour to provide it to you within the prescribed timeframe of one calendar month.

We won’t retain these documents and will delete or securely destroy them once your identity has been verified.

You can send a copy of your ID (not the original) via post or by email to dpo@pps.uk.com

You might find this link from the Information Commissioners Office (ICO) website helpful in relation to your rights and our obligations regarding complying with a SAR under GDPR.

https://ico.org.uk/your-data-matters/your-right-of-access/

We look forward to hearing from you accordingly. Alternatively, if the ID information requested is not provided your SAR file will be closed.

Please also provide a PCN reference or vehicle registration details

Kind regards

Premier Parking Solutions Ltd

Tel: 0845 862 1034

Fax: 0845 862 1035

Web: www.pps.uk.com

Registered in England & Wales No. 06659134

Registered Office: PO Box 471, Newton Abbot, Devon TQ12 9FX

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I stuck to the advice in the thread, and I have read the thread regarding what I.D. to send and what not to send, but just wanted to make sure as they reference the fact that I have used the old data protection act etc.

Thanks again

Le_Kirk

You don't need (in fact shouldn't) send photo ID; do they have a database of photos of everybody in the UK against which to compare your photo?  If they continue to waste your time, report them to the ICO.

Fruitcake

You do need to provide proof of your identity if you haven't already done so. A copy of the V5C should be enough. However, if they are playing billy suggers, and since you want to know what data they hold about you, then it won't hurt to send two forms of redacted ID.

Do report them to the ICO if they are being unreasonable.

Kpros

Thank you both.

I have not replied yet.

What would be a good response to this email? I obviously want to give them as little information as possible!

Thanks as ever 

Le_Kirk

Kpros said:

Thank you both.

I have not replied yet.

What would be a good response to this email? I obviously want to give them as little information as possible!

Thanks as ever 

Photo ID is not required, you have a scan/copy of my V5C, you wrote to me at my address, which is the same as that on the V5C, by way of further proof of my address, I attach a scan of a recent *utility bill/council tax bill.  Further prevarication on your part will result in you being reported to the ICO.

*Cross out which does not apply or add something else.

Fruitcake

In any case, waiting for proof of ID does not stop the clock. The ICO website states this so the PPC should still provide you with copies of your data that they hold within 30 days.

B789

Kpros said:

Thank you both.

I have not replied yet.

What would be a good response to this email? I obviously want to give them as little information as possible!

Thanks as ever 

Do you REALLY need advice on how to respond to that request?

Dear PPS DPO,

Attached please find copies of two documents, redacted of all information except my name and address. I now expect you to provide me with the information I have requested in my SAR dated dd/mm/yyy. For reference, the PCN No: 123456789 and the VRM: AB12CDE.

Yours faithfully,

@Kpros

Kpros

Thank you so much for the support. I have now sent them a further redacted form of identification showing my address and the date only.

Kpros

Hello again

I have had the SAR back from PPS. The debt recovery firm BW Legal have not come back to me.

They have not included any information relating to the original appeal, or any other information requested, just my redacted identification. Should I be requesting this? I'm also not entirely sure on what I must do next.

Here is their email, a copy and paste job of course.

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Dear Mr xxxxxxx,

Many thanks for the previous email and the ID provided, which I have now deleted.  

Premier Parking Solutions (PPS) confirms that it holds and processes personal data about you for the purposes of the recovery of unpaid parking charge notices.

You will find enclosed, your SAR containing copies of the documents that we hold relating to you as the data subject. 

You will see that the PCN was issued for no trace of payment.

This charge progressed to our legal and debt recovery partners who you must now deal with. They will also provide any non-personal data you have requested in your SAR.  

Below is the link to our GDPR information page which sets out our GDPR policies and procedures www.pps.uk.com then go to the FAQs where you will see our GDPR section. 

It may be worthwhile looking at the following guidance from the Information Commissioners Office (ICO) website. The following links relate to your rights when making a SAR and our obligations when a SAR is made to us: https://ico.org.uk/your-data-matters/your-right-of-access/

https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-of-access/

If you are not satisfied with our response to you or believe that we have not provided all the personal data that we hold relating to you can raise a concern with the ICO by using this link: https://ico.org.uk/make-a-complaint/your-personal-information-concerns/

However, it may be worthwhile contacting the ICO helpline on 0303 123 1113 prior to making a formal complaint and they will advise you further.

Should you wish to discuss matters in relation to payment of a PCN, please contact BW Legal direct.  

It may be helpful if I explain the process of what occurs when a parking infraction takes place.

In simple terms, a vehicle enters a private car park and breaches the terms and conditions in relation to parking and a Parking Charge Notice (PCN) is issued to the vehicle or by post to the registered keeper of the vehicle giving the opportunity for the PCN to be paid. In order to obtain the keeper details, we have to have reasonable cause in order to obtain the keeper details from the DVLA.

We write to the keeper of the vehicle and if these letters are ignored, we pass the details of the infraction and the keeper details to BW Legal. These organisations will then also write to the vehicle keeper and may also have dialogue via the telephone or email with the data subject and this may generate more personal data about the individual being held.

It is a commonly held mistake that a data controller requires the consent of an individual when holding and processing personal data and it may be helpful for me to point out the following guidance from the Information Commissioners Office (ICO) relating to the lawful basis for processing personal data under the General Data Protection Regulations (GDPR) which came into force on the 25th May 2018: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/

BW Legal and ourselves along with the other entities you named rely upon Legitimate Interests as our lawful basis for processing and you can read more in relation to this from the following link from the ICO website: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/legitimate-interests/

To see more about security and GDPR please see this link from the ICO website: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/security/

Kind regards,

DPO