Driver and Vehicle Licensing Agency
Data Sharing Strategy & Compliance
Strategy, Policy and Communications Directorate
Longview Road
Morriston
Swansea
SA6 7JL
Your Email:
x@xxxxxxxxxxx.xx.xx
My Email:
@dvla.gsi.gov.uk
One Parking Ltd (trading as Capital 2 Coast)
Website:
www.gov.uk/browse/driving
95 Arundel Road
Worthing
Date:
23 March 2018
West Sussex
BN13 3EU
Dear
,
DISCLOSURE OF DVLA DATA FOR DEBT ASSIGNMENT
DVLA is aware that One Parking Ltd has passed on DVLA vehicle keeper data to MIL
Collections Ltd in the past. This was done as part of the assignment or selling of unpaid
private parking charges by your company to MIL Collections Ltd who then became the legal
owner of the alleged debts.
The term used in this context to describe this activity is “debt assignment”. This is different to
sub-contracted debt collection, where the debt collection company acts on behalf of the private
parking company.
I must advise that the DVLA does not allow vehicle keeper data originating from its records to
be provided by One Parking Ltd (or any other private parking company) to MIL Collections Ltd
or any other third party for this purpose.
The issue has required careful consideration, taking into account the clear differences
between debt assignment and the more usual arrangements where debt collection companies
act under contract to recover unpaid parking charges on behalf of the parking company. The
need to demonstrate sufficient accountability and control over the use of vehicle keeper
information for this purpose has been a factor in the Agency’s consideration.
The terms & conditions applying to requests for vehicle keeper data from DVLA contained on
the V888/3 form and in the KADOE contract were drafted some time ago, when the debt
assignment model for private parking was not known to the Agency.
However, the Agency’s view is that these terms & conditions did not, and were not intended to,
provide for the disclosure of DVLA data to third parties as part of a debt assignment
arrangement. One Parking Ltd should have formally requested written permission directly
from DVLA before passing any DVLA vehicle keeper data to MIL Collections Ltd.
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That said, following the extensive work and research to understand the debt assignment
model DVLA accepts that minor amendments to the terms & conditions would be helpful. This
will remove the scope for any doubt over their correct interpretation in this matter.
DVLA will issue updated V888/3 forms in due course. For the avoidance of any doubt in the
meantime, the Agency considers disclosure of data obtained from DVLA to third parties as
part of a debt assignment arrangement as a breach of the terms and conditions for requesting
vehicle keeper data from DVLA, which could result in suspension.
DVLA will conduct a full audit of One Parking Ltd’s compliance with this and all terms &
conditions for receiving DVLA data. DVLA’s Data Sharing Strategy & Compliance Team will
contact you in due course to make arrangements for this audit, which will take place at your
offices.
Please be warned that any compliance issues found at that audit could result in immediate
suspension from being able to request vehicle keeper data from DVLA and termination of the
service.
DVLA will also be working closely with both Accredited Trade Associations for the private
parking industry to ensure DVLA’s position on debt assignment is understood and complied
with.
Please acknowledge receipt of this letter immediately.
Please contact me as soon as possible if you have any questions or would like to discuss
anything.
Yours sincerely,
[sent unsigned via email]
Data Sharing Strategy & Compliance
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