Cross-border (ROI) enforcement — CBE Directive non-application post-Brexit
Vehicles registered in the Republic of Ireland are present in NI in large numbers. The EU Cross-Border Enforcement Directive (2015/413) facilitated mutual exchange of keeper data for traffic offences. After Brexit (and DfI's withdrawal from the Eucaris exchange for parking-only data), DfI has limited lawful means to obtain ROI keeper data for civil parking PCNs. ROI-registered vehicles are therefore practically (and arguably legally) unenforceable for DfI civil parking unless the driver is identified.
Legal basis
EU Directive 2015/413 (CBE); Withdrawal Agreement & Northern Ireland Protocol/Windsor Framework; Road Traffic Regulation (NI) Order 1997 Art 80; Data Protection Act 2018 / UK GDPR
How to identify this in your case
ROI-registered vehicle, civil PCN issued by DfI to keeper. Ask DfI to disclose the legal basis and lawful source for obtaining the keeper data.
Sample appeal wording
Dear Sir/Madam, Re: PCN [PCN_NUMBER] — vehicle [VRM] The vehicle is registered in the Republic of Ireland. Following the United Kingdom's withdrawal from the European Union and the limitations of the Windsor Framework, the Cross-Border Enforcement Directive (2015/413) no longer provides a lawful conduit for the Department to obtain ROI keeper data for civil parking enforcement. Please specify (a) the legal basis on which the Department obtained my registered-keeper data from the Driver and Vehicle Computer Services Division (DVCSD) Shannon, (b) the data-sharing agreement under which it was disclosed, and (c) why the use of that data complies with Article 6(1) UK GDPR. In default of a substantive answer the PCN must be cancelled and a data-subject complaint will be made to the Information Commissioner. Yours faithfully, [NAME]
Replace [PARKING DATE], [NtK DATE] etc. with your own dates before sending.
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Scan my ticketSources
- EUR-Lex 32015L0413
- infrastructure-ni.gov.uk
- ico.org.uk