Premier Park PCN to wrong address

Dear Sir/Madam
I have been sent a letter from Debt Recovery Plus (18/10/18) working on your behalf with regards to PCN xxxxxx (originally issued 12/07/18) This is the first correspondence that has been received on this matter at my current address which is
xxxxxx Close
xxxxxxxxx
xxxxxxxxx


I believe that original correspondences were sent to my previous address. The car is a motability car and motability have accepted and apologised for their error in not updating DVLA causing this issue. Would you please rectify the address on your database for the above and delete the old address.
Further more under a subject access request i would like all letters and all made payments that relate to OR are a close match to the vehicle registration number on the day in question and send them to the correct address. I also request that you interrogate the payment data for an initial cash payment at the machine and a phone payment by top-up app on the day and provide these in detail.
After providing the SAR data and erasing and rectifying the addresses, i request that you as Data Protection Officer refer the file back to the appeals team since the incorrect address shows that i was not afforded an opportunity to appeal. Once these data concerns have been addressed this contact should be treated as an allowed late appeal, on the basis that the driver has been using this car park in good faith for 12 months and on the day two payments were made. An occupant of the car is also registered disabled and therefore if a “typo” was made on the machine keypad or phone app or either method failed to register one of the payments for the VRN then this is de minimis so a reasonable adjustment should be made under the Equality Act 2010 and the PCN be cancelled or a POPLA code be provided.
As you are aware there has already been BPA involvement in this matter so i hope we can resolve this fairly

Reply from Premier. What info should I send. Obviously VRN and PCN number (which they already have). I don't hold the V5C as Motability hold it.






(motability are going to email V5 so its just the question of do they require my driving
licence)

*********I have also already filled in a Disclosure Authority and Consent Form for Premier to allow the letters to be accessed by the BPA so why did they release info to them without my ID being confirmed via passport/driving licence********



Dear Mr ,

Subject Access Request

We write in response to your recent Subject Access Request (SAR).

Please be advised that, in order to protect individual’s anonymity and personal data, our systems are designed to be primarily searchable by Parking Charge Notice reference number or Vehicle Registration Mark, rather than by name or address.

As such, it may not be possible to search for all data we hold on you without the following information:

• Parking Charge Notice reference number
• Vehicle Registration Mark

To maintain confidentiality and ensure that we do not disclose any personal data, except to the individual to whom it is applicable, the law allows us to take reasonable steps to establish and confirm your identity before we can provide any information. Please provide us with proof of your identity, in the form of a scanned copy of one of the following:

• Driving License
• Passport
• Council Tax or Utility Bill (not more than 3 months old) showing your name and address

If your SAR relates to either a Parking Charge Notice or Vehicle Registration Mark we also require proof that you are entitled to details for the data in connection with the vehicle in question. This must be provided in the form of a scanned copy of one of the following:

• The ownership details from the V5 Logbook
• Written authorisation from the Registered Keeper named on the V5 Logbook where this is not listed as yourself

Please be advised that we will complete your SAR within 30 days of the above information being provided. Should you be dissatisfied for any reason you are reminded that you have the right to raise a complaint with the ICO, details for which can be found in our Privacy Policy.

Yours Sincerely

DPO Team Assistant
Premier Park Limited
POX Box 624
Exeter
EX1 9JG
Email
Website:

Is it worth sending the below or should I sit tight and wait for LBCC


Dear DPO team assistant
I have received some of the information in response to my SAR. You are required to supply ALL data that is held with regards to my details. The SAR is incomplete. You have provided details of payments associated with the VRN since the 7/7/18 at least 15 times or more. On each occasion Premier Park used ANPR to take time and date stamped images of the VRN entering and leaving the car park. I require these to be sent as they may be used as part of my defence in court. You still have not stated at what time the alleged offence took place but rather state at 17:06 the vehicle was parked in a manner whereby the driver became liable for a parking charge.
You have not provided any correspondences that you had with the BPA where again my details were shared. I require these letters/emails.
It appears from the SAR that you have issued another PCN on 17th August (PCN 7103272). This PCN was forwarded onto debt recovery stage after you were made aware of the keepers correct address. I require both of these PCNs to be regarded as one claim and be subject to a late appeal.
I note that even though you are aware that the V5C document address was not updated due to a third party error (motability) you have still refused to refer it to your appeals team on the basis that the driver or keeper was not afforded the opportunity to appeal. In fact you were sent a SAR request on 9th November requesting that address information be updated yet on the 10th November you forwarded on my details to Debt Recovery Plus showing no intention of putting the case on hold whilst the SAR was processed. This will be brought to the attention of a court as will you wasting court time by not allowing a late appeal
I require you to answer any concerns raised and provide the data requested.


regards