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  • FIRST POST
    • Coupon-mad
    • By Coupon-mad 31st May 18, 7:17 PM
    • 72,324Posts
    • 84,638Thanks
    Coupon-mad
    June 2018 - start of the new PPC and DVLA fightback (GDPR related)
    • #1
    • 31st May 18, 7:17 PM
    June 2018 - start of the new PPC and DVLA fightback (GDPR related) 31st May 18 at 7:17 PM
    Let's allocate June as a month for:

    - SARs to all PPCs in every case we reply on, every time, whatever stage! ALWAYS.

    and

    - Everyone to write or email the DVLA (EVERYONE HERE, NEW AND OLD) telling them that you've read Section 14 of the new DPA "Automated decision-making authorised by law: safeguards" which provides that:-

    (a) the DVLA as controller has to notify the data subject, (RK) when they have made a decision to release their data via KADOE.
    (b) the RK has a right to request the DVLA to reconsider their decision.

    And as the DVLA has stated that it is not making any data decisions by automation only, you want a permanent note attached to your V5 data to say that you do not consent to your data being sold to any private parking company under any circumstances, and now (from 25th May onwards) formally opt out because of previous harassment by the industry and the fact that the DVLA is clearly using automation alone to sell on data with insufficient checks and balances and with NO method to notify data subjects, which fails the applicable law.*

    https://forums.moneysavingexpert.com/showthread.php?p=74347065#post74347065

    https://forums.moneysavingexpert.com/showthread.php?t=5817804

    Thanks to Castle and BTailor in the threads above.





    * If EVERY POSTER did that in June, it would cause the DVLA a headache even just to respond.


    I will link this to the NEWBIES thread...
    Last edited by Coupon-mad; 31-05-2018 at 7:22 PM.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT UNLESS IN SCOTLAND OR NI
    TWO Clicks needed Look up, top of the page:
    Main site>>Forums>Household & Travel>Motoring>Parking Tickets Fines & Parking - read the NEWBIES THREAD
Page 1
    • Coupon-mad
    • By Coupon-mad 31st May 18, 7:23 PM
    • 72,324 Posts
    • 84,638 Thanks
    Coupon-mad
    • #2
    • 31st May 18, 7:23 PM
    • #2
    • 31st May 18, 7:23 PM
    Need a template SAR here, suggestions please. I haven't written any yet...

    Also suggestions on this thread for a standard DVLA template and which email address to use.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT UNLESS IN SCOTLAND OR NI
    TWO Clicks needed Look up, top of the page:
    Main site>>Forums>Household & Travel>Motoring>Parking Tickets Fines & Parking - read the NEWBIES THREAD
    • AltheHibby
    • By AltheHibby 31st May 18, 9:06 PM
    • 701 Posts
    • 804 Thanks
    AltheHibby
    • #3
    • 31st May 18, 9:06 PM
    • #3
    • 31st May 18, 9:06 PM
    https://www.itgovernance.co.uk/blog/how-to-write-a-gdpr-compliant-data-subject-access-request-procedure/

    Don't know if the example at the link will help you?

    When you do come up with your template Me and Mrs Al will send ours to DVLA and keep you updated when we get their responses.
    • abedegno
    • By abedegno 31st May 18, 9:21 PM
    • 140 Posts
    • 223 Thanks
    abedegno
    • #4
    • 31st May 18, 9:21 PM
    • #4
    • 31st May 18, 9:21 PM
    Need a template SAR here, suggestions please. I haven't written any yet...

    Also suggestions on this thread for a standard DVLA template and which email address to use.
    Originally posted by Coupon-mad
    I used this:
    Dear Sir/Madam:

    I am writing to you in your capacity as data protection officer for your company - Company Name. I have reason to believe you hold personal data on myself as a vehicle I own and am the registered keeper for visits car parking sites managed by your company. It should be noted that contrary to article 13 of GDPR legislation no privacy information was provided to myself, the data subject, at the time of collection. I am therefore compelled into making this request for access to personal data pursuant to Article 15 of the General Data Protection Regulation.

    The vehicle in question is a Vehicle Model with VRM: VRM.

    I have attached the V5 document to prove I am the registered keeper. Should you require further documentation necessary to verify my identity please contact me.

    I would like you to be aware at the outset, that I anticipate a reply to my request within one month as required under Article 12, failing which I will be forwarding my inquiry with a letter of complaint to the Information Commissioners Office (ICO).

    Please advise as to the following:
    1. Please confirm to me whether or not my personal data is being processed. If it is, please provide me with the categories of personal data you have about me in your files and databases.
      1. In particular, please tell me what you know about me in your information systems, whether or not contained in databases, and including e-mail, documents on your networks, or voice or other media that you may store.
      2. Additionally, please advise me in which countries my personal data is stored, or accessible from. In case you make use of cloud services to store or process my data, please include the countries in which the servers are located where my data are or were (in the past 12 months) stored.
      3. Please provide me with a copy of, or access to, my personal data that you have or are processing.
    2. Please provide me with a detailed accounting of the specific uses and lawful basis that you have made, are making or will be making of my personal data.
    3. Please provide a list of all third parties with whom you have (or may have) shared my personal data.
      1. If you cannot identify with certainty the specific third parties to whom you have disclosed my personal data, please provide a list of third parties to whom you may have disclosed my personal data.
      2. Please also identify which jurisdictions that you have identified in 1-1 above that these third parties with whom you have or may have shared my personal data, from which these third parties have stored or can access my personal data. Please also provide insight in the legal grounds for transferring my personal data to these jurisdictions. Where you have done so, or are doing so, on the basis of appropriate safeguards, please provide a copy.
      3. Additionally, I would like to know what safeguards have been put in place in relation to these third parties that you have identified in relation to the transfer of my personal data.
    4. Please advise how long you store my personal data, and if retention is based upon the category of personal data, please identify how long each category is retained.
    5. If you are additionally collecting personal data about me from any source other than me, please provide me with all information about their source, as referred to in Article 14 of the GDPR.
    6. If you are making automated decisions about me, including profiling, whether or not on the basis of Article 22 of the GDPR, please provide me with information concerning the basis for the logic in making such automated decisions, and the significance and consequences of such processing.


    Yours Sincerely,

    Name

    I've started collecting the relevant data protection email addresses:
    ParkingEye: privacy@parkingeye.co.uk
    Excel Parking Services: dataprotection@excelparking.co.uk
    VCS: dataprotection@vehiclecontrol.co.uk
    • beamerguy
    • By beamerguy 1st Jun 18, 10:36 AM
    • 11,253 Posts
    • 15,186 Thanks
    beamerguy
    • #5
    • 1st Jun 18, 10:36 AM
    • #5
    • 1st Jun 18, 10:36 AM
    I agree .... not only those on this forum and newbies
    should OPT-OUT from the DVLA for private parking companies
    BUT ....... they should tell all their friends and family to do
    the same

    This clause is interesting .....

    "(b) the RK has a right to request the DVLA to reconsider their decision.

    If the DVLA will not reconsider, it can only be assumed that
    they then approve of motorists being harassed

    How would they answer that ???
    RBS - MNBA - CAPITAL ONE - LLOYDS

    DISGUSTING BEHAVIOUR
    • markrg1965
    • By markrg1965 1st Jun 18, 10:43 AM
    • 27 Posts
    • 22 Thanks
    markrg1965
    • #6
    • 1st Jun 18, 10:43 AM
    • #6
    • 1st Jun 18, 10:43 AM
    Sending my letter to DVLA today and have done a SAR to CPM, happy days.
    • DW190
    • By DW190 1st Jun 18, 10:48 AM
    • 79 Posts
    • 105 Thanks
    DW190
    • #7
    • 1st Jun 18, 10:48 AM
    • #7
    • 1st Jun 18, 10:48 AM
    Possibly this could be made a "STICKY" to keep it in view all the time for a while.
    • beamerguy
    • By beamerguy 1st Jun 18, 10:56 AM
    • 11,253 Posts
    • 15,186 Thanks
    beamerguy
    • #8
    • 1st Jun 18, 10:56 AM
    • #8
    • 1st Jun 18, 10:56 AM
    Possibly this could be made a "STICKY" to keep it in view all the time for a while.
    Originally posted by DW190
    That will be good if MSE allow it
    RBS - MNBA - CAPITAL ONE - LLOYDS

    DISGUSTING BEHAVIOUR
    • Coupon-mad
    • By Coupon-mad 1st Jun 18, 11:13 AM
    • 72,324 Posts
    • 84,638 Thanks
    Coupon-mad
    • #9
    • 1st Jun 18, 11:13 AM
    • #9
    • 1st Jun 18, 11:13 AM
    They won't allow any more stickies so I will mention it in the already crowded NEWBIES thread.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT UNLESS IN SCOTLAND OR NI
    TWO Clicks needed Look up, top of the page:
    Main site>>Forums>Household & Travel>Motoring>Parking Tickets Fines & Parking - read the NEWBIES THREAD
    • Hot Bring
    • By Hot Bring 1st Jun 18, 11:14 AM
    • 1,515 Posts
    • 2,628 Thanks
    Hot Bring
    My favourite muckers .... G24 :

    dataprotection@G24.co.uk

    But don't hold your breath .... their email server appears to be down at the moment

    And Athena ANPR : dpo@athena-parking.com
    Last edited by Hot Bring; 01-06-2018 at 11:59 AM.
    "The darkest places in hell are reserved for those who maintain their neutrality in times of moral crisis." - Dante Alighieri
    • Loadsofchildren123
    • By Loadsofchildren123 1st Jun 18, 11:14 AM
    • 2,452 Posts
    • 4,147 Thanks
    Loadsofchildren123
    I used this:
    Dear Sir/Madam:

    I am writing to you in your capacity as data protection officer for your company - Company Name. I have reason to believe you hold personal data on myself as a vehicle I own and am the registered keeper for visits car parking sites managed by your company. I think it needs to be said here how they collect that data - eg "Such data is collected by your ANPR camera systems". It should be noted that contrary to article 13 of GDPR legislation no privacy information was provided to myself, the data subject, at the time of collection. I am therefore compelled into making this request for access to personal data pursuant to Article 15 of the General Data Protection Regulation which, as you will be aware, came into force on 25 May 2018.

    The vehicle in question is a Vehicle Model with VRM: VRM.

    I have attached the V5 document to prove I am the registered keeper. Should you require further documentation necessary to verify my identity please contact me. [is it sensible to request specifically that once they have read the V5 they securely dispose of it and do not retain it? Otherwise you're giving them your data aren't you? - eg "You do not have my consent to retain this document, please dispose of it securely once you have read it"]

    I would like you to be aware at the outset, that I anticipate a reply to my request within one month as required under Article 12, failing which I will be forwarding my inquiry with a letter of complaint to the Information Commissioners Office (ICO).

    Please advise as to the following:
    1. Please confirm to me whether or not my personal data is being processed. If it is, please provide me with the categories of personal data you have about me in your files and databases.
      1. In particular, please tell me what you know about me in your information systems, whether or not contained in databases, and including e-mail, documents on your networks, or voice or other media that you may store.
      2. Additionally, please advise me in which countries my personal data is stored, or accessible from. In case you make use of cloud services to store or process my data, please include the countries in which the servers are located where my data are or were (in the past 12 months) stored.
      3. Please provide me with a copy of, or access to, my personal data that you have or are processing.
    2. Please provide me with a detailed accounting of the specific uses and lawful basis that you have made, are making or will be making of my personal data.
    3. Please provide a list of all third parties with whom you have (or may have) shared my personal data.
      1. If you cannot identify with certainty the specific third parties to whom you have disclosed my personal data, please provide a list of third parties to whom you may have disclosed my personal data.
      2. Please also identify which jurisdictions that you have identified in 1-1 above that these third parties with whom you have or may have shared my personal data, from which these third parties have stored or can access my personal data. Please also provide insight in the legal grounds for transferring my personal data to these jurisdictions. Where you have done so, or are doing so, on the basis of appropriate safeguards, please provide a copy.
      3. Additionally, I would like to know what safeguards have been put in place in relation to these third parties that you have identified in relation to the transfer of my personal data.
    4. Please advise how long you store my personal data, and if retention is based upon the category of personal data, please identify how long each category is retained.
    5. If you are additionally collecting personal data about me from any source other than me, please provide me with all information about their source, as referred to in Article 14 of the GDPR.
    6. If you are making automated decisions about me, including profiling, whether or not on the basis of Article 22 of the GDPR, please provide me with information concerning the basis for the logic in making such automated decisions, and the significance and consequences of such processing.


    Yours Sincerely,

    Name

    I've started collecting the relevant data protection email addresses:
    ParkingEye: privacy@parkingeye.co.uk
    Excel Parking Services: dataprotection@excelparking.co.uk
    VCS: dataprotection@vehiclecontrol.co.uk
    Originally posted by abedegno
    Love this letter. Just a couple of suggestions in case it's linked as a template in the Newbies thread or elsewhere.
    Although a practising Solicitor, my posts here are NOT legal advice, but are personal opinion based on limited facts provided anonymously by forum users. I accept no liability for the accuracy of any such posts and users are advised that, if they wish to obtain formal legal advice specific to their case, they must seek instruct and pay a solicitor.
    • Coupon-mad
    • By Coupon-mad 1st Jun 18, 11:16 AM
    • 72,324 Posts
    • 84,638 Thanks
    Coupon-mad
    [is it sensible to request specifically that once they have read the V5 they securely dispose of it and do not retain it? Otherwise you're giving them your data aren't you? - eg "You do not have my consent to retain this document, please dispose of it securely once you have read it"]
    Definitely. Any more suggestions gratefully received.

    Anyone recall the best complain email to use for the DVLA? Need to bombard it.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT UNLESS IN SCOTLAND OR NI
    TWO Clicks needed Look up, top of the page:
    Main site>>Forums>Household & Travel>Motoring>Parking Tickets Fines & Parking - read the NEWBIES THREAD
    • Umkomaas
    • By Umkomaas 1st Jun 18, 12:06 PM
    • 23,435 Posts
    • 37,369 Thanks
    Umkomaas
    (a) the DVLA as controller has to notify the data subject, (RK) when they have made a decision to release their data via KADOE.
    (b) the RK has a right to request the DVLA to reconsider their decision.
    Given that the majority of KADOE data requests are made via electronic access, and once made, your data flies out of the DVLA into the clutches of the PPC faster than the proverbial off a shovel, any notification to you will be, by definition, retrospective, and should you request that DVLA reconsider their decision (who wouldn't), you're already into the PPC sausage machine and the proud owner of a NtK.

    How's all that going to work?
    Please note, we are not a legal, residential or credit advice forum, rather one that helps motorists fight private parking charges, primarily at the 'front-end' of the process.
    Give a man a fish, and you feed him for a day;
    show him how to catch fish, and you feed him for a lifetime.
    • BTailor
    • By BTailor 1st Jun 18, 12:06 PM
    • 23 Posts
    • 13 Thanks
    BTailor
    [QUOTE=Coupon-mad;74353873]Definitely. Any more suggestions gratefully received.

    I would say "retain or process this document's data" as the rules apply separately to each way it is handled/stored.

    Which email address are people sending to when addressing the DVLA please?
    • Umkomaas
    • By Umkomaas 1st Jun 18, 12:09 PM
    • 23,435 Posts
    • 37,369 Thanks
    Umkomaas
    Which email address are people sending to when addressing the DVLA please?
    I think we're trying to determine that now.

    It's important to get the correct email address, to avoid a scattergun distribution of emails to inappropriate sections, which will could result in further time-consuming stonewalling replies from the DVLA.
    Please note, we are not a legal, residential or credit advice forum, rather one that helps motorists fight private parking charges, primarily at the 'front-end' of the process.
    Give a man a fish, and you feed him for a day;
    show him how to catch fish, and you feed him for a lifetime.
    • DW190
    • By DW190 1st Jun 18, 3:10 PM
    • 79 Posts
    • 105 Thanks
    DW190
    I think we're trying to determine that now.

    It's important to get the correct email address, to avoid a scattergun distribution of emails to inappropriate sections, which will could result in further time-consuming stonewalling replies from the DVLA.
    Originally posted by Umkomaas
    The "Subject Access Request" address is :

    SubjectAccess.Requests@dvla.gsi.gov.uk

    I think the correct place to complain would be to the Data Controller at the DVLA.

    Unfortunately. The register of data controllers on the ICO website is being updated:

    We are currently updating the public register. We will publish the register early next week.
    • ladaowner55
    • By ladaowner55 1st Jun 18, 4:07 PM
    • 52 Posts
    • 23 Thanks
    ladaowner55
    Let's allocate June as a month for:


    - Everyone to write or email the DVLA (EVERYONE HERE, NEW AND OLD) telling them that you've read Section 14 of the new DPA "Automated decision-making authorised by law: safeguards" which provides that:-

    (a) the DVLA as controller has to notify the data subject, (RK) when they have made a decision to release their data via KADOE.
    (b) the RK has a right to request the DVLA to reconsider their decision.

    Originally posted by Coupon-mad
    Who is RK ???
    • ladaowner55
    • By ladaowner55 1st Jun 18, 4:08 PM
    • 52 Posts
    • 23 Thanks
    ladaowner55
    Given that the majority of KADOE data requests are made via electronic access, and once made, your data flies out of the DVLA into the clutches of the PPC faster than the proverbial off a shovel, any notification to you will be, by definition, retrospective, and should you request that DVLA reconsider their decision (who wouldn't), you're already into the PPC sausage machine and the proud owner of a NtK.

    How's all that going to work?
    Originally posted by Umkomaas
    Surely DVLA will be at fault then for releasing your name/address. 750 compo claim.
    • Hot Bring
    • By Hot Bring 1st Jun 18, 4:21 PM
    • 1,515 Posts
    • 2,628 Thanks
    Hot Bring
    Who is RK ???
    Originally posted by ladaowner55
    Registered Keeper
    "The darkest places in hell are reserved for those who maintain their neutrality in times of moral crisis." - Dante Alighieri
    • beamerguy
    • By beamerguy 1st Jun 18, 4:25 PM
    • 11,253 Posts
    • 15,186 Thanks
    beamerguy
    Surely DVLA will be at fault then for releasing your name/address. 750 compo claim.
    Originally posted by ladaowner55
    Won't work like that, that was the old data protection act.
    This one is far more serious for providers of data.

    GDPR is a EU directive and the ICO would find it very
    difficult to change it to favour the DVLA.

    If they did, the next explosion will be the cry of SCAM

    Would the ICO fine the DVLA ? Of course not, they both
    sleep in the governments bed
    Last edited by beamerguy; 01-06-2018 at 4:30 PM.
    RBS - MNBA - CAPITAL ONE - LLOYDS

    DISGUSTING BEHAVIOUR
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