Parking notices possibly sent to old address / Local Car Park Management

LCee5500

Hi. I recently submitted a SAR to the DVLA, to establish if any third-party organisations had requested the registered keeper's details for my vehicle, after realising I'd forgotten to update the address several years ago when moving. An annoying oversight - I've since updated the address with the DVLA!

Today I received the information requested and can see that OKS Empire Limited, trading as Local Car Park Management, previously requested the registered keeper's details twice in 2021, for 'breach of terms and conditions of a private car park'. 

I’ve concluded this was in a car park where I was living at the time.

I’ve not received any correspondence for the two alleged breaches, as I assume they would have been posted to my old address. I also have no idea if LCPM has taken this any further and enlisted a collector, as again, anything would have been posted to my former address.

LCPM is a tricky one to understand. On Companies House, neither OKS Empire Limited nor any of its listed people appear to be currently connected to LCPM. 

I read the privacy policy on LCPM's website and after finding the company number, did another search. Again, LCPM appears to have no link to OKS Empire Limited and the listed people are all different. It also shows that LCPM, at least in its current iteration, was incorporated in 2022 - a year after the alleged breaches!

I called the number on their website (also featured on the car park signage) and the person who answered said the business was sold several years ago and they’ve not updated the signage/website. Rather odd?

Their privacy policy also ists two DPOs - one of whom is active as an officer for LCPM on Companies House. The other is listed as an officer for OKS Empire Limited. I can only assume they were maybe involved before the business was sold. Again, seems odd?

All in all, I’m pretty worried and not sure what I should do now. I’ve read the newbies thread, as well as several others, and am unsure how to navigate this best. Especially as I've got no correspondence and am only aware of this thanks to the SAR with the DVLA. Given how much time has passed, the potential risk of a surprise CCJ popping up in the future and ruining my credit score is stressing me out. 

So, my questions are:

1) Should I submit a SAR to the DPO of LCPM and ask them for any data they have stored related to my vehicle? In particular, any previous correspondence that may have been posted to my previous address about the two alleged breaches?

2) Should I email a rectification notice to the DPO of LCPM telling them my current address and instruct them to erase the old data / my previous address?

3) Within the rectification notice, should I instruct that they inform all and any of their agents and sub-contractors of my new data/address? I assume this would be important if any documents were possibly posted to me by a collector in the future?

4) Is it too late to contact my old landlord and see if there’s anything they can do about this? Assuming they own the car park itself. It’s been a few years, so not sure if this is even an option I can explore?

There are only a few other threads about LCPM on here - they appear to be a bit of a mystery - potentially even a sole trader at one point?! I can see they’ve gotten Gladstones involved at least once: https://forums.moneysavingexpert.com/discussion/6158713/gladstone-s-solicitors-local-car-park-management/p1 - something I’m very eager to avoid myself. 

Thanks in advance for any advice or guidance given - this forum is so useful! 

Coupon-mad

Welcome!  Quick answers:

1.  Yes

2.  Yes
 
3.  Yes

4.  I would try it but not be too concerned as the above 3 things are more important to put your mind at rest.  And we doubt this little firm has issued a claim.

LCee5500

Coupon-mad said:

Welcome!  Quick answers:

1.  Yes

2.  Yes
 
3.  Yes

4.  I would try it but not be too concerned as the above 3 things are more important to put your mind at rest.  And we doubt this little firm has issued a claim.

Thanks for replying to my post.

I've been working on this, using the forums as a reference point, and think I've gotten everything ready to email the PPC...

I've included my draft SAR and data rectifcation notices below - would really appreciate any pointers if I've given too much/not enough info. Cautious of giving too much info or doing something wrong! 

I also have a few questions: 

1) Should I send the SAR first, or the Data Rectification? Not sure it matters what order they are sent?

2) For the Data Rectification, do I need to provide them with anything for reference/as proof as to who I am? Same evidence as the SAR? Or just my VRN?

2) Due to a mistake made by the DVLA, my name was previously mispelt on V5C. This has now been corrected and I've got evidence of my original doc, name change request and current doc. Should I include photographic evidence of this, plus a redacted bank statement as standard, so the PPC has enough proof I am who I say I am? Should I request that they erase the incorrect spelling of my name and update, or is this not necessary?

SAR:
My present address
XX/XX/XXXX
PPC Name
Dear Sir or Madam

Subject access request (Data Protection Act 2018 / General Data Protection Regulations (GDPR)

My Correct Address:  XXXXX XXXXX XXXXX  
My Previous Address:  XXXXX XXXXX XXXXX
Please supply the data about me that I am entitled to under data protection law relating to myself.
Please provide all information relating to the alleged PCNs, for my vehicle with the VRN: XXXXXX
Reference: xxxxxxxxx | Dated: xx/xx/xxxx
Reference: xxxxxxxxx | Dated: xx/xx/xxxx

Please provide, as a minimum: ALL photos taken. ALL letters/emails sent and received. All data held, all evidence that you wish to rely on, and a full copy of the PCN, NTK. A list of all PCNs outstanding against this VRN. I will take this opportunity to remind you that any claim must be for all PCNs, not several separate claims.

Please note, that due to an administrative mistake, my name as the Registered Keeper was previously misspelt as ‘name’ rather than ‘name’. I have since requested a change of name with the DVLA and the Registered Keeper details have been updated accordingly. Please find attached evidence of this change of name request, as well as evidence of both my old and current, up-to-date V5C document and a redacted bank statement.

It may be helpful for you to know that data protection law requires you to respond to a request for data within one calendar month. If you need advice on dealing with this request, the Information Commissioner’s Office can assist you. Its website is ico.org.uk or it can be contacted on 0303 123 1113.

Yours faithfully,
My Name



Data Rectification:
My present address
XX/XX/XXXX
PPC Name
Dear Sir or Madam

Data Rectification Notice 

I am writing to instruct that you update my personal information on file with your company. 

My Correct Address for service:  XXXXX XXXXX XXXXX  
My Previous Address:  XXXXX XXXXX XXXXX

I request that you update your records with my correct address for service as detailed above and ERASE all other address data that you hold for me, and inform any and all of your agents and sub-contractors to do the same.

Please note, that due to an administrative mistake, my name as the Registered Keeper was previously misspelt as ‘name’ rather than ‘name’. I have since requested a change of name with the DVLA and the Registered Keeper details have been updated accordingly. Please find attached evidence of this change of name request, as well as evidence of both my old and current, up-to-date V5C document and a redacted bank statement.

Yours faithfully,
My name

Le_Kirk

I would send the Data Rectification Notice as a matter of urgency, you don't want letters going to the wrong address.  In the NEWBIES you will find we do not recommend a SAR until later in the process until after a court claim and you see the POC on it.

LCee5500

Le_Kirk said:

I would send the Data Rectification Notice as a matter of urgency, you don't want letters going to the wrong address.  In the NEWBIES you will find we do not recommend a SAR until later in the process until after a court claim and you see the POC on it.

Okay, I’ll get that emailed to them. 

Should I add something like ‘please note, I am the registered keeper of the vehicle with VRN xxxxx’ to the data rectification notice, so they have reference as to who I am? If not I’m unsure how they’d connect that I am the person they have on their records and be able to update accordingly / notify third party agents?

I’m curious as to why it’s not recommended to send a SAR? As it stands I’ve got no evidence of the PCNs other than the two requests made to the DVLA - would it not be useful to have the full details of these?

Le_Kirk

You are, of course issuing the Data Rectification Notice as the Registered Keeper; you will need to supply proof of who you are and where you reside - maybe a copy of the V5C (with your correct address on it) and a copy of the PCN with your VRM on it.  The reason for not submitting a SAR until after you've seen the POC on the claim form is so that you can claim that you don't know what the PPC are and what you are defending against.  Read some other threads particularly the @hharry100 thread and search CEL v Chan.

LCee5500

Le_Kirk said:

You are, of course issuing the Data Rectification Notice as the Registered Keeper; you will need to supply proof of who you are and where you reside - maybe a copy of the V5C (with your correct address on it) and a copy of the PCN with your VRM on it.  The reason for not submitting a SAR until after you've seen the POC on the claim form is so that you can claim that you don't know what the PPC are and what you are defending against.  Read some other threads particularly the @hharry100 thread and search CEL v Chan.

Ok, good to know. I’ll add something to the subject / email along the lines of ‘Data Rectification Notice - from the Registered Keeper of vehicle VRN XXXXX’ 

I don’t have the PCN numbers - assume both got sent to my old address several years back. All I have is two reference numbers that I got from my SAR to the DVLA - which may be the PCNs potentially. Shall I include them? 

With a data rectification notice do they have to respond / acknowledge it? Or should I add in something asking for confirm of receipt? 

Once I’ve emailed this over, I’m considering contacting my old landlord to see if they can them cancelled. Is this worthy pursuing seen as it’s been several years?

Thanks for the reading suggestions - I’ll get stuck in! 

Coupon-mad

Always see if a landlord/landowner can cancel rogue PCNs.

Mikeh2001

LCee5500 said:

Le_Kirk said:

You are, of course issuing the Data Rectification Notice as the Registered Keeper; you will need to supply proof of who you are and where you reside - maybe a copy of the V5C (with your correct address on it) and a copy of the PCN with your VRM on it.  The reason for not submitting a SAR until after you've seen the POC on the claim form is so that you can claim that you don't know what the PPC are and what you are defending against.  Read some other threads particularly the @hharry100 thread and search CEL v Chan.

Ok, good to know. I’ll add something to the subject / email along the lines of ‘Data Rectification Notice - from the Registered Keeper of vehicle VRN XXXXX’ 

I don’t have the PCN numbers - assume both got sent to my old address several years back. All I have is two reference numbers that I got from my SAR to the DVLA - which may be the PCNs potentially. Shall I include them? 

With a data rectification notice do they have to respond / acknowledge it? Or should I add in something asking for confirm of receipt? 

Once I’ve emailed this over, I’m considering contacting my old landlord to see if they can them cancelled. Is this worthy pursuing seen as it’s been several years?

Thanks for the reading suggestions - I’ll get stuck in! 

See link below in terms of what to expect from the rectification notice.  They have one month to respond.

https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/individual-rights/right-to-rectification/

LCee5500

Apologies for reviving an old thread.

I realised today that in my panic over this situation at the time, I forgot to email the data rectification. I’m embarrassed to have made such a stupid oversight. 

As such, I want to get this sent ASAP - I just want to check that the data rectification notice I’ve drafted below is suitable.

Also, I have two questions:

Do I need to include my old address for reference?

I previously had to ask the DVLA to update my name as they misspelt it. Should I mention this in my data rectification notice and include proof of my change of name with the DVLA?

I’m cautious that LCPM will refuse to rectify my data as requested if they have a different spelling of my name on their system. 

Below is the data rectification notice I’ve written - just want to be certain I’ve included all necessary information.

My present address
XX/XX/XXXX
PPC Name

Dear Sir or Madam

Data Rectification Notice 

As the Registered Keeper of vehicle VRN XXXX XXX, I am writing to instruct that you update my personal information on file with your company. 

My Correct Address for service:

XXXXX XXXXX XXXXX  

I request that you update your records with my correct address for service, as detailed above, and ERASE all other address data that you hold for me, and inform any and all of your agents and sub-contractors to do the same.

Please note, that due to an administrative mistake, my name as the Registered Keeper was previously misspelt as ‘name’ rather than ‘name’. I have since requested a change of name with the DVLA and the Registered Keeper details have been updated accordingly. Please find attached evidence of this change of name request, as well as evidence of both my old and current, up-to-date V5C document and a redacted bank statement.

Yours faithfully,

My name

 

Coupon-mad

Yes, prove everything.

Have you checked that a claim form hasn't already arrived at the old address?

Maybe not possible to check? LCPM aren't known for litigation anyway.