DVLA complaints about PPCs abysmally low. Why?

LDast

I recently submitted a Freedom of Information (FoI) request to the DVLA to find out how many complaints they’ve received about private parking companies—particularly those we frequently see breaching the PPSCoP and PoFA. It’s often said that the DVLA won’t “bite the hand that feeds it”, and we regularly hear complaints about how they dismiss or deflect legitimate concerns.

Well, the numbers returned in the FoI response show exactly why that is. Consider this: over 40,000 private parking charge notices (PCNs) are issued daily. That’s more than 14 million PCNs a year. The number of cases we deal with here and over on FTLA is only a tiny fraction of that total.

So how many complaints about these PCNs—specifically for breaches of the PPSCoP or PoFA, both of which would invalidate the operator’s KADOE contract—were made to the DVLA? According to the FoI response, just 690 complaints were received between 6 March 2023 and 5 March 2025.

No wonder the DVLA doesn’t think there’s a problem. As far as they can tell, there isn’t one. 690 complaints over two years equates to a “problem” with just 0.002% of all PCNs issued. That’s because the vast majority of people either don’t know they can complain, or they don’t think it will make a difference.

But every issue we see here or on FTLA involves a breach of the PPSCoP or PoFA in some form. And any such breach is also a breach of the KADOE contract between the PPC and the DVLA. Once a breach occurs, the parking company is no longer using keeper data for a lawful purpose. That is unlawful data use—but does the DVLA care? Clearly not, because they’re not even aware. The low number of complaints makes the problem appear insignificant.

This is why every OP who comes here or to FTLA for help should be encouraged to submit a formal complaint to the DVLA about the parking company involved. It only takes a few minutes, even though the DVLA has made the process more convoluted than necessary.

Here’s how to do it:

1. Go to: https://contact.dvla.gov.uk/complaints

2. Select: “Making a complaint or compliment about the Vehicles service you have received”

3. Enter your personal details, contact details, and vehicle details

4. Use the text box to summarise your complaint or insert a covering note

5. You will then be able to upload a file (up to 19.5 MB) — this can be your full complaint or supporting evidence

That’s it.

The DVLA is required to record, investigate and respond to every complaint about a private parking company. If everyone who encounters a breach took the time to submit a complaint, we might finally see the DVLA take meaningful action—whether that means curtailing or removing KADOE access altogether.

It’s not difficult to create and reuse a template complaint that highlights the issue. The more people who raise it, the harder it becomes for the DVLA to ignore it.

The webform could use the following:

I am submitting a formal complaint against [INSERT PPC NAME], an [INSERT IPC or BPA] AOS member with DVLA KADOE access, for breaching the BPA/IPC Private Parking Single Code of Practice (PPSCoP) after obtaining my personal data.

While the Operator may have had reasonable cause at the time of their KADOE request, their subsequent misuse of my data—through conduct that contravenes the PPSCoP—renders that use unlawful. The PPSCoP forms an integral part of the DVLA’s governance framework for data access by private parking firms. Continued access is conditional on compliance.

The DVLA, as data controller, is obliged under UK GDPR and the Data Protection Act 2018 to investigate and take enforcement action when data is misused following release. This complaint is not about whether the data was obtained lawfully at the outset, but whether its subsequent use breached the terms under which it was provided.

I have prepared a supporting statement setting out the nature of the breach and the Operator’s actions, and I request a full investigation into this matter. I have attached the supporting document.

Please acknowledge receipt and confirm the reference number for this complaint.

Then a template for the formal complaint itself:

SUPPORTING STATEMENT
Complaint to DVLA – Breach of KADOE Contract and PPSCoP

Operator name: [INSERT PPC NAME]

Date of PCN issue: [INSERT DATE]

Vehicle registration: [INSERT VRM]

I am submitting this complaint to report a misuse of my personal data by [INSERT PPC NAME], who obtained my keeper details from the DVLA under the KADOE (Keeper At Date Of Event) contract.

Although the parking company may have had reasonable cause to request my data initially, the way they have used that data afterwards amounts to unlawful processing. This is because they have acted in breach of the BPA/IPC Private Parking Single Code of Practice (PPSCoP), which is a mandatory requirement for access to DVLA keeper data. The PPSCoP forms part of the framework that regulates how parking companies must behave once they have received keeper data from the DVLA.

The KADOE contract makes clear that keeper data may only be used to pursue an unpaid parking charge in line with the Code of Practice. If a parking company fails to comply with the PPSCoP after receiving DVLA data, their use of that data becomes unlawful, as they are no longer using it for a permitted purpose.

In this case, [INSERT PPC NAME] has breached the PPSCoP in the following ways:

[INSERT A SHORT SUMMARY OF THE BREACH(ES), e.g. failure to follow grace periods, misleading notices, refusal to engage with a complaint, pursuing a charge despite having evidence of disability or mitigation, etc.]

These are not minor or technical breaches. They show a clear disregard for the standards required under the current single Code. As a result, the operator is no longer entitled to use the keeper data they obtained from the DVLA, because the purpose for which it was provided (a fair and lawful pursuit of a charge under the Code) no longer applies.

The DVLA remains the Data Controller for the data it releases under KADOE, and is therefore responsible for ensuring that personal data is not misused by third parties. This includes taking action against AOS operators who breach the conditions under which the data was provided. I am therefore asking the DVLA to investigate this breach and to take appropriate action under the terms of the KADOE contract.

This may include:

• Confirming that a breach has occurred

• Taking enforcement action against the operator

• Suspending or terminating their KADOE access if warranted

I have attached relevant supporting material with this statement. Please confirm receipt and provide a reference for this complaint. I am also happy to provide further information if required.

Name: [INSERT YOUR NAME]
Date: [INSERT DATE]

This is just a suggested template and I am open to suggestions and changes.

Here is the FoI data of the pathetic number of DVLA complaints against PPCs:

https://drive.google.com/file/d/1OlDnTFvVOasqtXBtmsrygBN5_OvwF4aD/view?usp=sharing

LoneStarState

I'm in full support of this and good template.  Complaining to the DVLA creates a paper trail for repeat offenders, enables us to provide stats to MPs (and for aware journalists to also dig) on the market failure of this industry and will better enable questions of the DVLA when they deflect from genuine misuse of the KADOE system (which is rampant without a doubt).

Should probably be recommended for every time a genuine resident receives one in flat car parks etc where leases hold primacy.

Something I've also never read on these forums......has anyone sued the DVLA for proven release of data where no reasonable cause is present (other than the trotted out "member of ATA means they have reasonable cause")?  It seems there's a possible avenue here but am not a lawyer.  I was aware there was the Keller Lenkner Group Claim some time back but no idea of how that progressed.

I'll admit I should have complained to the DVLA in the past where there was blatant dishonesty from a PPC (deliberate angled and deliberately misfocussed photos to hide permit present on dash while also stating a completely different location).  I guess it's a case of stepping up now.  Pending some more info to come out from the current ticket I am fighting on behalf of a relative, the DVLA will 100% be receiving a complaint as there have been a number of code breaches.

Coupon-mad

I think the lady with the unpronounceable username @zhonguonuren sued the DVLA. She posted about it.

DullGreyGuy

LDast said:
No wonder the DVLA doesn’t think there’s a problem. As far as they can tell, there isn’t one. 690 complaints over two years equates to a “problem” with just 0.002% of all PCNs issued. That’s because the vast majority of people either don’t know they can complain, or they don’t think it will make a difference.

What was the total number of complaints in total during that period?

Was there any form of categorisation or segmentation of the other complaints?

Comparing it to PCNs issued doesnt seem the most logical to me at least, would have thought a decent proportion of people just pay up and so no DVLA request is ever made

Most companies in the first instance will look at the volume of complaints they get and target the largest numbers... its only later when you start looking as the rate of complaints where a department may decide that though they only get 10 complaints a year given they only do this thing 9 times a year it needs looking at -v- the thing that gets 100 complaints a year but is done 1m times per year. 

Coupon-mad

Are they even counting the complaints where the DVLA merely fobs people off to the ATAs?

Kaizen2024

It is not mandatory to comply with POFA (see 4(6) of POFA), nor is it mandatory to cancel a charge based on alleged mitigation (only consider it); therefore, there is no breach of KADOE for such cases.

Blindside6

LDast said:

I recently submitted a Freedom of Information (FoI) request to the DVLA to find out how many complaints they’ve received about private parking companies—particularly those we frequently see breaching the PPSCoP and PoFA. It’s often said that the DVLA won’t “bite the hand that feeds it”, and we regularly hear complaints about how they dismiss or deflect legitimate concerns.

Well, the numbers returned in the FoI response show exactly why that is. Consider this: over 40,000 private parking charge notices (PCNs) are issued daily. That’s more than 14 million PCNs a year. The number of cases we deal with here and over on FTLA is only a tiny fraction of that total.

So how many complaints about these PCNs—specifically for breaches of the PPSCoP or PoFA, both of which would invalidate the operator’s KADOE contract—were made to the DVLA? According to the FoI response, just 690 complaints were received between 6 March 2023 and 5 March 2025.

No wonder the DVLA doesn’t think there’s a problem. As far as they can tell, there isn’t one. 690 complaints over two years equates to a “problem” with just 0.002% of all PCNs issued. That’s because the vast majority of people either don’t know they can complain, or they don’t think it will make a difference.

But every issue we see here or on FTLA involves a breach of the PPSCoP or PoFA in some form. And any such breach is also a breach of the KADOE contract between the PPC and the DVLA. Once a breach occurs, the parking company is no longer using keeper data for a lawful purpose. That is unlawful data use—but does the DVLA care? Clearly not, because they’re not even aware. The low number of complaints makes the problem appear insignificant.

This is why every OP who comes here or to FTLA for help should be encouraged to submit a formal complaint to the DVLA about the parking company involved. It only takes a few minutes, even though the DVLA has made the process more convoluted than necessary.

Here’s how to do it:

1. Go to: https://contact.dvla.gov.uk/complaints

2. Select: “Making a complaint or compliment about the Vehicles service you have received”

3. Enter your personal details, contact details, and vehicle details

4. Use the text box to summarise your complaint or insert a covering note

5. You will then be able to upload a file (up to 19.5 MB) — this can be your full complaint or supporting evidence

That’s it.

The DVLA is required to record, investigate and respond to every complaint about a private parking company. If everyone who encounters a breach took the time to submit a complaint, we might finally see the DVLA take meaningful action—whether that means curtailing or removing KADOE access altogether.

It’s not difficult to create and reuse a template complaint that highlights the issue. The more people who raise it, the harder it becomes for the DVLA to ignore it.

The webform could use the following:

I am submitting a formal complaint against [INSERT PPC NAME], an [INSERT IPC or BPA] AOS member with DVLA KADOE access, for breaching the BPA/IPC Private Parking Single Code of Practice (PPSCoP) after obtaining my personal data.

While the Operator may have had reasonable cause at the time of their KADOE request, their subsequent misuse of my data—through conduct that contravenes the PPSCoP—renders that use unlawful. The PPSCoP forms an integral part of the DVLA’s governance framework for data access by private parking firms. Continued access is conditional on compliance.

The DVLA, as data controller, is obliged under UK GDPR and the Data Protection Act 2018 to investigate and take enforcement action when data is misused following release. This complaint is not about whether the data was obtained lawfully at the outset, but whether its subsequent use breached the terms under which it was provided.

I have prepared a supporting statement setting out the nature of the breach and the Operator’s actions, and I request a full investigation into this matter. I have attached the supporting document.

Please acknowledge receipt and confirm the reference number for this complaint.

Then a template for the formal complaint itself:

SUPPORTING STATEMENT
Complaint to DVLA – Breach of KADOE Contract and PPSCoP

Operator name: [INSERT PPC NAME]

Date of PCN issue: [INSERT DATE]

Vehicle registration: [INSERT VRM]

I am submitting this complaint to report a misuse of my personal data by [INSERT PPC NAME], who obtained my keeper details from the DVLA under the KADOE (Keeper At Date Of Event) contract.

Although the parking company may have had reasonable cause to request my data initially, the way they have used that data afterwards amounts to unlawful processing. This is because they have acted in breach of the BPA/IPC Private Parking Single Code of Practice (PPSCoP), which is a mandatory requirement for access to DVLA keeper data. The PPSCoP forms part of the framework that regulates how parking companies must behave once they have received keeper data from the DVLA.

The KADOE contract makes clear that keeper data may only be used to pursue an unpaid parking charge in line with the Code of Practice. If a parking company fails to comply with the PPSCoP after receiving DVLA data, their use of that data becomes unlawful, as they are no longer using it for a permitted purpose.

In this case, [INSERT PPC NAME] has breached the PPSCoP in the following ways:

[INSERT A SHORT SUMMARY OF THE BREACH(ES), e.g. failure to follow grace periods, misleading notices, refusal to engage with a complaint, pursuing a charge despite having evidence of disability or mitigation, etc.]

These are not minor or technical breaches. They show a clear disregard for the standards required under the current single Code. As a result, the operator is no longer entitled to use the keeper data they obtained from the DVLA, because the purpose for which it was provided (a fair and lawful pursuit of a charge under the Code) no longer applies.

The DVLA remains the Data Controller for the data it releases under KADOE, and is therefore responsible for ensuring that personal data is not misused by third parties. This includes taking action against AOS operators who breach the conditions under which the data was provided. I am therefore asking the DVLA to investigate this breach and to take appropriate action under the terms of the KADOE contract.

This may include:

• Confirming that a breach has occurred

• Taking enforcement action against the operator

• Suspending or terminating their KADOE access if warranted

I have attached relevant supporting material with this statement. Please confirm receipt and provide a reference for this complaint. I am also happy to provide further information if required.

Name: [INSERT YOUR NAME]
Date: [INSERT DATE]

This is just a suggested template and I am open to suggestions and changes.

Here is the FoI data of the pathetic number of DVLA complaints against PPCs:

https://drive.google.com/file/d/1OlDnTFvVOasqtXBtmsrygBN5_OvwF4aD/view?usp=sharing

Two highly creditable drafts. Very well done. Worth joining this forum just to see these. 

LDast

All you can gather from the FoI data is the number of formal complaints made to the DVLA about the listed PPCs. We have no idea what those complaints were about except they referred to the PPC.

Any breach of the PPSCoP is a therefore a KADOE breach. Almost every single NtK issued contains misstatements about the deadline for payment or appeal. In almost every operators NtK you will see reference to payment and appeal deadlines referring to 28 days from the date of the notice rather than from the date of receipt as per PPSCoP section 8.1.2(e).

No one said that a complaint about requiring an NtK to comply with PoFA. However, there are plenty of cases where PoFA compliance is claimed and declared when it is not as per PPSCoP section 8.1.1(d), such as MET Parking NtKs issued at Stansted and Gatwick airports. There a loads of other reasons that the PPCs are in breach of the PPSCoP.

It is the breach of the PPSCoP that renders the KADOE contract breached and therefore the unlawful behaviour occurs after the DVLA request is made under the reasonable cause criteria. Once the KADOE contract is broken by something the PPC has done after receiving the Keepers DVLA data, they are then using that data unlawfully and the complaint to the DVLA requires them to investigate and respond.

The DVLA knows how many Keeper data requests are made by each operator. We know that there are well over 40,000 private PCNs issued on average per day. I simply conservatively extrapolated that with only 690 formal complaints about PPC operators over 2 years and the number of PCNs issued per year, the ratio of complaints to the number of PCNs issued is embarrassingly low.

pinkelephant12

This is a really useful thread.  Thank you.

When a complaint is made to DVLA, DVLA emails the PPC and the PPC replies with their  ‘explanation’ of what went wrong.  It’s really important that everyone asks to see the PPC’s full response.  In my case, DVLA gave me ‘edited highlights’ but when I later saw the PPC’s full response, I discovered that the PPC had told DVLA a pack of lies and I could prove it.  If this information had been available to me during the complaints process, I could have made a much stronger complaint.

It’s also important to pursue all stages of the complaints process, not just the first stage, if you get an unsatisfactory response.

1. Complaints Team

2. Head of complaints

3. Independent Complaints Assessors for the DfT

The Assessors’ reports show they are ineffectual, but at least complaints that get to this stage are publicly reported.  Again, the number of complaints about the release of Keeper details at this stage is miniscule and doesn’t reflect the true problem.

https://www.gov.uk/government/publications/dft-independent-complaints-assessor-report-for-2023-to-2024

Blindside6

LDast said:

All you can gather from the FoI data is the number of formal complaints made to the DVLA about the listed PPCs. We have no idea what those complaints were about except they referred to the PPC.

Any breach of the PPSCoP is a therefore a KADOE breach. Almost every single NtK issued contains misstatements about the deadline for payment or appeal. In almost every operators NtK you will see reference to payment and appeal deadlines referring to 28 days from the date of the notice rather than from the date of receipt as per PPSCoP section 8.1.2(e).

No one said that a complaint about requiring an NtK to comply with PoFA. However, there are plenty of cases where PoFA compliance is claimed and declared when it is not as per PPSCoP section 8.1.1(d), such as MET Parking NtKs issued at Stansted and Gatwick airports. There a loads of other reasons that the PPCs are in breach of the PPSCoP.

It is the breach of the PPSCoP that renders the KADOE contract breached and therefore the unlawful behaviour occurs after the DVLA request is made under the reasonable cause criteria. Once the KADOE contract is broken by something the PPC has done after receiving the Keepers DVLA data, they are then using that data unlawfully and the complaint to the DVLA requires them to investigate and respond.

The DVLA knows how many Keeper data requests are made by each operator. We know that there are well over 40,000 private PCNs issued on average per day. I simply conservatively extrapolated that with only 690 formal complaints about PPC operators over 2 years and the number of PCNs issued per year, the ratio of complaints to the number of PCNs issued is embarrassingly low.

I've gone a stage further with DVLA, with this FOIA request sent in earlier this evening:

Dear Driver and Vehicle Licensing Agency,

When finalising information request 'FOIR 12229', the DVLA helpfully provided a table showing the number of complaints received, within a specified time period, broken down by private parking company.

The table, again helpfully, carried this short narrative at its head:

"This provides information relating to 690 complaints received about private parking companies between 6 March 2023 and 5 March 2025 by parking company. Information relating to the parking company is not captured in all complaints."

Under the Freedom of Information Act, could you please disclose:
1. The number of those 690 complaints, made between 6th March, 2023 and 5th March, 2025 that are (i) under investigation (ii) upheld (iii) dismissed. Analysed by private each parking company.

For example: Euro Car Parks: 'complaints received 46; under investigation 16; upheld 15; dismissed 15.'

2. The number of complaints received where parking company information is not captured.

Yours faithfully,

[redacted]

With not a trace of self-regard, I'm an experienced information rights practitioner and this is the first step of what will, probably, be three or four requests to get to where I think we want to be (I know what's coming next; they don't, of course).

Will keep the forum posted.

Blindside6

pinkelephant12 said:

This is a really useful thread.  Thank you.

When a complaint is made to DVLA, DVLA emails the PPC and the PPC replies with their  ‘explanation’ of what went wrong.  It’s really important that everyone asks to see the PPC’s full response.  In my case, DVLA gave me ‘edited highlights’ but when I later saw the PPC’s full response, I discovered that the PPC had told DVLA a pack of lies and I could prove it.  If this information had been available to me during the complaints process, I could have made a much stronger complaint.

It’s also important to pursue all stages of the complaints process, not just the first stage, if you get an unsatisfactory response.

1. Complaints Team

2. Head of complaints

3. Independent Complaints Assessors for the DfT

The Assessors’ reports show they are ineffectual, but at least complaints that get to this stage are publicly reported.  Again, the number of complaints about the release of Keeper details at this stage is miniscule and doesn’t reflect the true problem.

https://www.gov.uk/government/publications/dft-independent-complaints-assessor-report-for-2023-to-2024

You've added very considerably to the utility of this thread. Thank you.