GXS Limited - not purchasing a valid Parking Session

New here so apologies if missing information. The driver arrived at Dover Harbour House Car Park at 08.44 (and 8 seconds). A Ringo ticket was paid for at 08.47, expiring 09.47. The driver left the car park at 09.54 (and 36 seconds).

NTK and Ringo receipt attached. Is there sufficient grounds to appeal on the 10 minute grace period applying from 09.47? ANPR evidence records a total time from entry to exit of car park of 1 hour, 10 mins and 36 secs. On first look online the 10 minute grace period appeared pretty strong, but read contradictory information elsewhere so would appreciate thoughts or any other grounds for appeal based on the NTK. I live 150 miles from the car park and can't see the exact Ts and Cs on street view, annoyingly.

I am having difficulty in accessing images especially rings one.You will also need to post rear of PCN. In general terms if you park and pay for one hour after accepting the T&C then you have a 10 minute grace period. If in this instance the total is 1hr 10 minutes then a PCN should not be issued. You appeal as the RK do not mention who was driving.

I was able to access the images.

I would appeal to the operator strictly as vehicle keeper since their notice is not POFA complaint.

Quote (in your appeal) from the CMA open letter shown below.

https://assets.publishing.service.gov.uk/media/6a5784276d6d5c7e2845ca02/open_letter.pdf

It is clear that this operator is hoping that you haven't seen the letter which highlights such underhand behaviour from parking operators.

Paragraph 22 is the kicker - this states;

We have also seen evidence that suggests that where consumers decide, within the consideration period, to park, operators are treating the parking period as having commenced at the moment the consumer drove into the car park, rather than at the point they decided to park. In consequence, consumers may not enjoy the full period of parking that they should be entitled to.

In your appeal you should draw their attention to the fact that 'time on site' is not legally regarded as the total time parked and, that in this case, it appears that the driver pulled into the car park, found a space and paid quickly. The time paid for (along with the grace period) was more than enough to cover the time the driver was parked for.

Point out that you have noted that their behaviour is demonstrably contrary to the directions given in the CMA letter since it is obvious that they are calculating the period of parking strictly using the ANPR 'time on site' and are deliberately ignoring the actual purchase time of the paid parking in order that they can issue their speculative invoice / PCN.

Follow that with wording like, "I will be more than happy to report this behaviour to the CMA if this PCN is not promptly cancelled."

In theory, they should uphold this appeal.

Thanks, appreciate your help.