Private operator had no lawful basis to get your keeper details (NVDF / GDPR)
In Ireland the National Vehicle and Driver File (the register of who owns a vehicle) is locked down by statute — Finance Act 1993 s.60(3) + SI 287/2015 set an exhaustive, closed list of who may receive keeper data, and a private parking operator is NOT on it, so it has no NVDF gateway to your details. This does not automatically defeat the debt (they might identify you lawfully another way — a permit relationship, the hirer, the landowner, a prior disclosure, or a legitimate-interests basis under GDPR Art 6). The argument is to PUT THE OPERATOR TO PROOF: require them to show the specific lawful basis on which they obtained and processed your data, because the closed NVDF gateway means they cannot simply have looked you up.
Legal basis
Finance Act 1993, s.60(3) (access to NVDF records confined to prescribed office-holders and 'such other persons as may be prescribed'); S.I. No. 287/2015 National Vehicle and Driver File (Access) (No. 2) Regulations 2015, Schedule (exhaustive list of prescribed persons/purposes — no private parking operator listed); GDPR Article 6(1) / Data Protection Act 2018 (processing without a lawful basis).
How to identify this in your case
The notice is from a PRIVATE company (not a council/Garda FCN), it is on private land, and it is addressed to the registered keeper by name/address (proving they pulled keeper data). Ask the operator to state, in writing, the exact S.I. 287/2015 Schedule reference number under which it accessed the NVDF; a private car-park operator has none.
Sample appeal wording
formal
Replace [PARKING DATE], [NtK DATE] etc. with your own dates before sending.
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