Community Charge / Electoral Roll Not Valid for Keeper Tracing in Scotland
Some private parking operators attempt to use electoral roll or other databases to identify and trace vehicle keepers in Scotland when DVLA enquiries are not possible or have failed. In Scotland, use of personal data from such sources for debt collection purposes without proper legal basis breaches UK GDPR and the Data Protection Act 2018. Any charge notice based on keeper identification through improper data sources is tainted and challengeable.
Legal basis
UK GDPR Article 6 (lawful basis); Data Protection Act 2018; Representation of the People Act 1983 (restrictions on electoral roll use)
How to identify this in your case
You receive a parking charge notice as keeper but you know the operator could not have obtained your details from DVLA (e.g. their trade association membership lapsed or they are not DVLA-accredited). The address used may not match DVLA records. Ask them how they obtained your data.
Sample appeal wording
I am writing regarding parking charge notice [reference] and to make a formal Subject Access Request under UK GDPR Article 15 / Data Protection Act 2018 s.45. Please provide: 1. All personal data you hold relating to me 2. The source from which you obtained my personal data 3. The lawful basis under UK GDPR Article 6 for processing my data 4. Confirmation of whether you made a DVLA keeper enquiry and on what date I have reason to believe my personal data was not obtained through a legitimate DVLA enquiry. If this is the case, you have processed my data without a lawful basis, breaching UK GDPR. Any charge notice founded on unlawfully obtained data is unenforceable, and I will report this breach to the ICO. I require a response within 30 days. This notice is disputed in its entirety.
Replace [PARKING DATE], [NtK DATE] etc. with your own dates before sending.
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Scan my ticketSources
- UK GDPR Article 6
- Data Protection Act 2018
- Representation of the People Act 1983