Sar response · Checkmate The Matrix

Sar response

Hi, looking for some advice. I send by email Sar request to dcbl and receive response. What my next move? Will be grateful for your advice

DCBL act solely on client instruction in the recovery of an outstanding debt. You were afforded the opportunity to appeal the charge, transfer liability or make payment when the original documents were issued. DCBL do not get involved with any disputes you may have with the client.

When parking on private land, the contractual terms of the site are set out on the signs. You are entering a contract, and agreeing to the terms by parking, and staying on the site. Parking in breach of the terms as stipulated on the signage means that you are then breaking the terms of the contract.

A parking company does not require the driver's permission to transfer their data to a debt recovery company, especially if the driver has violated the terms of parking and the company has a legitimate reason for pursuing the debt. However, they must comply with data protection laws, such as the UK General Data Protection Regulation (GDPR), which requires that any data transfer is done lawfully and transparently.

In accordance with the British Parking Association (BPA) Code of Practice, where the Parking Charge Notice (PCN) becomes overdue and before Court proceedings have commenced, a reasonable sum may be added for the debt recovery fees. The correct recovery fees have been added and will not be removed.

DCBL have an obligation to the client to complete our debt resolution process, once this has been exhausted, your case will then be returned to the client, who may choose to refer to a County Court to obtain a judgment against you. This is a decision that can only be made by the client, as DCBL do not instigate legal proceedings against the motorist.

As we act on client instruction a contractual agreement between DCBL and yourself is not applicable.

Further to your Subject Access Request (SAR), please find all personal identifiable data DCBL hold on file for you. Please note, the remit of a SAR is limited to the company to which it has been directed. The information provided by DCBL will only be the information held by ourselves directly at the time of your request. If you require information/data or correspondence relating to a third party, you will need to contact them directly.

By submitting a SAR request, you are entitled to the following information:

A copy of your personal identifiable information that we hold.
Information about what personal data is being processed.
Details of the source of that data.

Your data was transferred to DCBL by the instructing Client, who are the Data Controller in the matter. Your data is processed based on "legitimate interest” which is detailed in Article 6 of GDPR. The personal data supplied by our Client is done so using a SFTP (Security File Transfer Protocol). This data is used to create individual cases and once this has been completed, the data is no longer available other than on our case management systems. DCBL does not store personal information for any longer than is necessary for its defined purpose.

Due diligence checks in the form of address validation were actioned by DCBL to identify your current address. This was to ensure DCBL documentation was issued to the correct recipient at their most recent address. All tracing reference agencies instructed by DCBL only process data in accordance with instructions from DCBL and comply fully with DCBL's privacy notice, contract agreement, the data protection laws, and any other appropriate confidentiality and security measures. For further information regarding our policy on personal data, please refer to the Data Protection Policy & Privacy Notice page on DCBL’s website.

Under the terms of the EU General Data Protection Regulation, it is a legal right for you to access any personal information that DCBL may hold about you. However, under the regulation we are not required by law to supply supplementary information regarding the company’s data mapping processes since this contains confidential information in relation to how we collect, store, process and transfer a variety of personal data as part of our business operations.

DCBL do not currently utilise automated decision-making functions within its business. A Data Protection Impact Assessment (DPIA) would be carried out before any Automated Processing (including profiling) activities were to be undertaken.

DCBL are instructed by the Client Smart Parking (UK) Limited regarding the following unpaid debt which relates to a Parking Charge.

Parking Charge Date: 19/05/2020

Parking Charge Reference: TC57648323

Vehicle Registration: RK03XEV

Parking Charge Location: Lincoln Central Train Station (short Stay)

Reason: Insufficient Paid Time

Evidence in relation to the Parking Charge has been attached for your reference. Any email correspondence you will already have due to being either the sender or recipient of the correspondence.

There is no requirement to provide internal notes or documentation. We are required to disclose personal identifiable data related to the individual, but internal notes that do not pertain to the your personal identifiable data, or that contain sensitive internal information may be withheld.

The personal identifiable data we hold relating to yourself is as follows:

Name: Mr Darius Jarmolavicius

Primary Address: 60 Newfield Road, Sleaford, Lincolnshire, NG34 7AY (Provided by Trace)

Additional Address: 18 Jubilee Grove, Sleaford, Lincolnshire, NG34 8BD (Provided by Client)

Our data is held and processed on our cloud-based CRM system which meets the requirements of PCI DSS v4.0 and complies with ISO27001:2022 standards. DCBL hold ISO27001 certification and have done since 2017. Details of our data retention can be found within our Privacy Policy which can be found on the website.

As the above information does not fall within the remit of a SAR, there is no requirement to provide it.

DCBL are regulated by the Financial Conduct Authority and our Trading License number is 702566. The FCA's Consumer Credit Sourcebook (CONC) applies to all credit-related regulated activities, including consumer loans, credit cards, consumer hire, credit broking, and debt-related services. As such, a Parking charge does not fall under any of these categories and therefore, it is not relevant to the case.

DCBL have noted your requested for a LIA (Legitimate Interest Assessment) and DPIA (Data Protection Impact Assessment). This information does not fall within the remit of a SAR, there is no requirement to provide it.

This is the extent of the personal data held and this correspondence concludes your SAR.

Kind regards,

Donna Kelly

Compliance Associate

Direct Collection Bailiffs Ltd

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