DVLA KADOE Renegotiation 2025 — Keeper Data Challenge

Following the post-Brexit review and the DVLA's KADOE (Keeper at Date of Event) contract renegotiation in 2025, operators must demonstrate strict compliance with KADOE terms to lawfully obtain keeper data. Where an operator's request is outside the Code or the operator has had ATA suspensions, processing may be unlawful under UK GDPR Art 6(1)(f).

Legal basis

UK GDPR (Data Protection Act 2018) Article 6(1)(f); DVLA KADOE Contract Terms 2025; Vidal-Hall v Google [2015] EWCA Civ 311

How to identify this in your case

Operator obtained keeper details from DVLA but is in clear breach of the Code.

Sample appeal wording

Dear [Operator Name], Re: PCN [PCN_NUMBER] — Data Protection Challenge You obtained my keeper details from the DVLA via the KADOE contract. The DVLA's KADOE terms (renegotiated 2025) require all requesting operators to be ATA members in good standing AND compliant with the Single Code 2024. Your conduct breaches the Code in the following respects: [LIST]. Processing my personal data is therefore not supported by a valid legitimate interest under UK GDPR Article 6(1)(f). Under Article 17 UK GDPR I request erasure; under Article 21 I object to further processing. This PCN must be cancelled. Yours faithfully, [Keeper Name]

Replace [PARKING DATE], [NtK DATE] etc. with your own dates before sending.

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Sources

DVLA KADOE Contract 2025
UK GDPR Articles 6(1)(f), 17, 21
Vidal-Hall v Google [2015] EWCA Civ 311