Dear Driver and Vehicle Licensing Agency,

On 27 September 2022 DLUHC wrote to me in the following terms.

"Our Ref:18048118

Date: 27 September 2022

Dear Mr Baker

Thank you for your email of 24 May, regarding the use of a private parking company
to enforce parking charges by Brighton and Hove City Council. I apologise for the
delay in responding.

I am grateful to you for making us aware of this matter and for sharing the evidence
you have obtained. I hope you will understand that we are unable to provide a legal
interpretation or comment on the circumstances of individual cases. However, I hope
I can assist you by providing some additional information.

Schedule 4 of the Protections of Freedoms Act (POFA) 2012 outlines the framework
which parking on private land can be enforced. Paragraph 3 of Schedule 4 is clearly
designed to apply to private land and to exclude public land by defining "relevant
land" to schedule 4. It states that relevant land means any Iand other than:

"(a) a highway maintainable at the public expense (within the meaning of
section 329(1) of the Highways Act 1980);
(b) a parking place which is provided or controlled by a traffic authority (as
defined by the Road Traffic Regulation Act 1984);
(c) any land (not falling within paragraph (a) or (b)) on which the parking of a
vehicle is subject to statutory control."
For the purposes of sub-paragraph b, Schedule 4 defines a "traffic authority" as the
following:
"(a) the Secretary of State;
(b) the Welsh Ministers;
(c) Transport for London;
(d) the Common Council of the City of London;
(e) the council of a county, county borough, London borough or district;
(f) a parish or community council;
(g) the Council of the lsles of Scilly."

We are in regular contact with the DVLA and have written to them to clarify the position outlined above.

Yours sincerely

[Redacted]"

Pursuant to the Freedom of Information Act 2000, please provide suitably redacted copies of the following in relation to the issue of the DVLA providing OPS (BHCC's contractors) with keeper details that enable it to enforce private parking tickets on public land, pursuant to its contract with BHCC:

1) Correspondence between DVLA and DLUHC
2) Correspondence between DVLA and BHCC
3) Correspondence between DVLA and OPS
4) Correspondence (including any legal advice) between DVLA and any legal advisers it may have consulted concerning this issue
5) Any internal attendance notes/emails/correspondence that may have been generated concerning this issue.

For the avoidance of doubt and for ease of reference, I can confirm I first contacted the DVLA over this issue via email on 24 May 2022.

If you require any clarification concerning this request, please do not hesitate to contact me.

Thank you.

Yours faithfully

Stephen Baker

Dear Driver and Vehicle Licensing Agency,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Driver and Vehicle Licensing Agency's handling of my FOI request 'Correspondence between the DVLA, Department for Levelling Up, Housing & Communities (DLUHC), Brighton and Hove City Council (BHCC) and One Parking Solution Ltd (OPS)'.

I accept the assertions made under S40(2) regarding the redactions of personal details of junior civil servants, i.e. their names within the bodies of emails and any names contained within email addresses.

However, I would ask you to consider reinstating the domain names within email addresses as I do not believe these are properly redacted under S40(2).

Because the domain names have been redacted it has been difficult, and sometimes impossible for me to establish which agencies are the senders and/or recipients of emails. Consequently, I must reserve my right to ask for a further internal review should any clarification by you suggest there are further issues I consider you have not dealt with properly under the FoIA.

In addition, you have referred to redactions made under S41(1) and S42(1) where you have specified the pages where redactions are made. Unfortunately, when I downloaded the document it appears that on a number of occasions the specified page numbers do not coincide with the pages shown on my Adobe Acrobat reader.

Can you please rectify this in order that I may better understand the redactions for which you are claiming exemptions. Again I must reserve my right to ask for a further internal review should any clarification by you suggest there are further issues I consider you have not dealt with properly under the FoIA.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/c...

Yours faithfully,

Stephen Baker

Dear FOI,

On 14 April 2023, in replying to my request for an internal review you wrote, "You should expect to receive a reply to your request by 12 May 2023."

Please explain the delay.

Yours faithfully,

Stephen Baker

Dear FOI,

On 14 April 2023, in replying to my request for an internal review you wrote, "You should expect to receive a reply to your request by 12 May 2023."

On 29 July 2023 I wrote to ask why there had been a delay in dealing with my request for an internal review. On 31 July 2023 you replied "Apologies for the lateness in our reply. Your request his being looked at and a response will be sent shortly."

Today is 30 October 2023. Your contempt for the Freedom of Information Act process is clear. Please deal with my request for an internal review without further delay.

Yours faithfully,

Stephen Baker

Dear FOI,

On 14 April 2023, in replying to my request for an internal review you wrote, "You should expect to receive a reply to your request by 12 May 2023."

On 29 July 2023 I wrote to ask why there had been a delay in dealing with my request for an internal review. On 31 July 2023 you replied "Apologies for the lateness in our reply. Your request his being looked at and a response will be sent shortly."

On 30 October 2023 I wrote again to complain about the delay in conducting the internal review. On 31st October 2023 you replied "Please accept our apologies for the delay in responding. We will endeavour to provide you with a response as soon as possible."

I have spoken to an adviser at the Information Commissioner's Office and they told me that you should provide a time frame for conducting the internal review. Please provide a time frame, failing which I will be writing a complaint to the ICO.

Yours sincerely,

Stephen Baker