Free Traffic Legal Advice

Live cases legal advice => Private parking tickets => Topic started by: BB4 on March 01, 2024, 02:41:42 pm

Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: DWMB2 on March 12, 2024, 12:42:59 pm
3 months to send a notice, 60 minutes to cancel it  ;D

Good result!
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: BB4 on March 12, 2024, 12:34:36 pm
Appeals submitted this morning, and PCN's cancelled within an hour!
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: b789 on March 11, 2024, 02:28:02 pm
Nothing has changed. Just send the same appeal as before. Why would it be any different this time around?
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: DWMB2 on March 11, 2024, 01:58:19 pm
For a belt and braces approach, you may wish to add something along the lines of the below onto the end of the appeals:

Even if the car park were relevant land, which is denied, your notice does not comply with the requirements of Paragragh 9 of Schedule 4 of the Protection of Freedoms Act 2012 in order to recover the charge from me as the keeper. For the reasons outlined above, I have no liability for this charge and look forward to your confirmation that no further action will be taken against me. If you choose not to accept this appeal you must issue a POPLA code.
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: BB4 on March 11, 2024, 01:47:55 pm
Here is one redacted copy if it helps, the other two PCN's are identical and for the 6th and 12th December.

Checked and they are also the same as the original PCN's received for dates in November 2023.

[attachment deleted by admin]
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: DWMB2 on March 11, 2024, 01:25:49 pm
Each will need to be appealed separately.

Can you show us the new notices you have received? Their may be additional grounds of appeal apparent in the notice that could beef the appeals up yet further.
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: BB4 on March 11, 2024, 01:12:39 pm
Very interested thread and comments, does feel like would be a breach of GDPR in most other circumstances, however I do not have the inclination or time to sue NCP unfortunately!

More importantly another update - more identical Ntk’s have been received today as originally feared when I started this post  >:( 

NCP have issued 3 new PCN NtK’s for separate dates in December 2023 last week, all on the same day the previous two PCN’s were cancelled! Presumably, this is just the same NCP ‘machine’ churning out the same charges from months ago and they will cancel these PCN’s also?

@b789 in the first instance would you recommend appeal each individually using the same wording?

Extremely irritating and unreasonable and feels like there should be grounds for complaint, wondering as before if/when more NtK's will be sent out.

Thanks for the feedback.
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: DWMB2 on March 07, 2024, 05:21:14 pm
Unless the OP decides he's suing NCP and/or DVLA, any further debate on this in the Flame Pit.
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: b789 on March 07, 2024, 04:12:25 pm
The assumption of keeper = driver is a problem. Of course any assumption that the keeper is also the driver is a problem. It simply isn't allowed in civil law.

It would perhaps be a bit harsh for the DVLA to be culpable for a request. Why shouldn't the DVLA be held to the same standards as everyone else? They charge Ł2.50 for each request. In FY 2021/2022 private parking companies made 8.57 million out of a total of 32.17 million requests. You do the maths.

The DVLA has a responsibility to ensure that any disclosure of personal data is lawful and complies with data protection regulations.  If the operator did not have a legitimate reason for requesting the data, or if they used it inappropriately or unlawfully, they can also be held accountable for the breach.

There are also other areas. Perhaps a vehicle is abandoned on somebody's land. Who knows who abandoned it. It may be the case that my field is relevant land and the request for keeper details so the landowner can try and deal with it is ok. Again, irrelevant. Who is responsible for abandoning a vehicle on your relevant land? The driver, the keeper or the owner? Yes, the owner can be neither the driver or the keeper. Have a look at your V5C and read the words on the front:

(https://i.imgur.com/BMyiauC.jpeg)

Why would the keeper be responsible if they didn't abandon it there?

But if a driver abandons a vehichle in a station car park should the request definitively fail leaving a problem with how to deal with it. Likewise... why is the keeper responsible if they didn't drive the vehicle there and abandoned it?

There are probably many other areas where a landowner has reasonable cause, but no knowledge of driver. Without any valid grounds related to safety, legal obligations, or regulatory compliance, it is impossible to justify the request for vehicle keeper data as having reasonable cause. In such cases, the request should be considered unnecessary and/or unjustified, and so raises concerns about privacy and data protection.

Have a read of the latest KADOE contract and see for yourself:

https://www.dropbox.com/scl/fi/cfaclu7gvydl85znx8w2n/Annex_A_-_KADOE_Fee_Paying_Contract_V4.pdf?rlkey=0ic3ou1xgm0b8pndplqfrydrl&dl=0
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: DWMB2 on March 07, 2024, 03:48:28 pm
I don't have any real idea of how the question gets settled and how broad an answer is obtained.
At any rate I'll suggest that any further discussion of the broader issue might be better placed in the Flame Pit, unless the OP in this case is planning on taking any further action (which, given the charges he had been sent have been cancelled, I'd be surprised if he is).
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: slapdash on March 07, 2024, 03:33:02 pm
The assumption of keeper = driver is a problem.

If it is a breach of GDPR is it the DVLA's the parking companies or both ?

It would perhaps be a bit harsh for the DVLA to be culpable for a request.

There are also other areas. Perhaps a vehicle is abandoned on somebody's land. Who knows who abandoned it. It may be the case that my field is relevant land and the request for keeper details so the landowner can try and deal with it is ok.

But if a driver abandons a vehichle in a station car park should the request definitively fail leaving a problem with how to deal with it.

There are probably many other areas where a landowner has reasonable cause, but no knowledge of driver.

I don't have any real idea of how the question gets settled and how broad an answer is obtained.
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: b789 on March 07, 2024, 02:31:03 pm
It seems to me entirely reasonable to submit a keeper request to DVLA for any vehicle left on my land. The process seems to allow this as reasonable cause. I can fill in a form and do this. The content, however, of invoices sent to keepers for events on non relevant land is a problem.

It would perhaps be a bit odd if the terms of the Kadoe contract prohibited this.

Of course you have a right to request keeper details from the DVLA, as long as you have a valid contract with them and reasonable cause to do this AND your land is not under statutory control. No one is disputing this.

Using the subject data, reasonable cause or not, is the issue when the land is under statutory control. Having provided the subject data to the "customer", what can they then do apart from invite the subject to name the driver or pay the invoice themselves even though there is no requirement to do so.

If the operator has reasonable cause to believe that the driver of a vehicle parked on land (under statutory control) that they manage has entered into a contract with them and is now, allegedly, in breach of that contract, then they should apply an NtD to the vehicle. Only the driver is liable for the alleged breach of contract. The keeper has nothing to do with it... unless they were also the driver but the operator does not know that and cannot just assume or infer that the keeper was also the driver. As there is no obligation for the keeper to either admit to being the driver or to provide the operator with a drivers details, under GDPR, what right does the DVLA have to release the keepers data to a private company?
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: slapdash on March 07, 2024, 02:04:55 pm
It seems to me entirely reasonable to submit a keeper request to DVLA for any vehicle left on my land. The process seems to allow this as reasonable cause. I can fill in a form and do this.

It would perhaps be a bit odd if the terms of the Kadoe contract prohibited this.

The content, however, of invoices sent to keepers for events on non relevant land is a problem.



Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: b789 on March 07, 2024, 01:47:02 pm
We know that KADOE B2(a) cannot be used by the operator if the "reasonable cause" occurred on land under statutory control.

Under B2(b) the DVLA can only provide subject data to their "customer" to enable them to seek recovery from a "driver". It is impossible to recover anything from a driver if the "reasonable cause" was on land under statutory control.

Just by adding in B2(b) "...or is not in a position to pursue the vehicle keeper by utilising conditions in Schedule 4 of the Protection of Freedoms Act 2012" is a contradiction in itself. If they are not in a position to pursue the keeper then why are they giving out the keepers subject data?

The only real remedy is for operators to put NtDs on the windscreen and invite the driver to pay.
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: DWMB2 on March 07, 2024, 01:36:16 pm
I'm not sure I agree that a lack of ability to pursue the keeper under PoFA equates to a lack of reasonable cause to contact the keeper regarding a parking charge, as long as they are not misrepresenting their position re. keeper liability (or lack thereof).
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: b789 on March 07, 2024, 01:23:45 pm
KADOE B2(a) does not allow the DVLA to provide keeper data if the approved operator has reasonable cause or not if the alleged contravention occurred on land under statutory control.

KADOE B2(b) is their get-out clause. However, there can be no justification as the approved operator, operating on land under statutory control, already knows that there can be no reasonable cause to pursue a keeper in the first place. By requesting the keeper data and the DVLA in providing it, without reasonable cause, are breaching the keepers GDPR.
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: slapdash on March 07, 2024, 01:11:49 pm
There is a difference between asserting that a charge is due due to acceptance of a contract and them actually having any viable method of enforcing that.



Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: b789 on March 07, 2024, 12:10:02 pm
Technically, they are breaching KADOE rules by requesting keeper data for alleged contraventions on non relevant land, knowing that they cannot pursue the keeper unless the keeper admits to being the driver.

In other words, the DVLA have breached your GDPR. Good luck trying to get them to admit it though. I know of one case where they are being sued in the county court for this but it has taken time to get this far and has not yet been allocated to a local court. Whatever the outcome, it will have little effect unless it is appealed and subsequently won.
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: DWMB2 on March 07, 2024, 11:56:58 am
NCP are becoming a lot less stubborn than they used to be. Good result and thanks for the update

Quote
Surely accepting these appeals is an admission of the fact of law that NCP are not able to pursue keepers for these NtK's on non-relevant land, and therefore shouldn't be sending out these NtK's or contacting DVLA for the registered keeper's details in the first place?
If you read the notice carefully, they don't actually say that you are liable as the keeper. The fact that they are unable to use the provisions of Schedule 4 of the Protection of Freedoms Act on non-relevant land does not prohibit them from contacting the keeper to send them a charge, it just means they cannot recover the charge from the keeper if he declines to tell them who was driving.
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: BB4 on March 07, 2024, 11:32:06 am
PCN's cancelled! Must admit I was somewhat sceptical, so many thanks @b789 for all the help and guidance.

Worth noting the wording in the reply states that they have accepted my appeal for this contravention only, and not in relation to any PCNs issued in future.

Surely accepting these appeals is an admission of the fact of law that NCP are not able to pursue keepers for these NtK's on non-relevant land, and therefore shouldn't be sending out these NtK's or contacting DVLA for the registered keeper's details in the first place?
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: b789 on March 06, 2024, 01:36:00 pm
If you have received a CCJ and paid it in full within 30 days of judgment, there is no record of it. Why would you have to "declare" it? It is not a criminal matter. It is a simple matter of civil law. Stop overthinking this.

If you are still able to appeal then ignore the complaint to GA. Appeal as the keeper. You can simply use this:

Quote
I am the registered keeper. Your NtK is for an alleged breach of contract on land under statutory control which means that I cannot be liable for the charge as the keeper. NCP have no hope of being successful at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.

NCP cannot hold a registered keeper liable. As a matter of fact and law, NCP (as a longstanding BPA Parking operator) will be well aware that they cannot use the PoFA provisions to hold a keeper liable because Cambridge North Station car park is not 'relevant land'. If Greater Anglia wanted to hold owners or keepers liable under Railway Bylaws, that would be within the landowner's gift and another matter entirely. However, not only is that not pleaded, it is also not legally possible because NCP is not the station owner and your 'parking charge' is not and never attempts to be a penalty. It is created for NCP’s own profit (as opposed to a bylaws penalty that goes to the public purse) and NCP has relied on contract law allegations of breach against the driver only. The registered keeper cannot be presumed to have been the driver nor pursued as such under some twisted interpretation of the law of agency.

Please let us know when this is cancelled.
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: BB4 on March 06, 2024, 01:04:35 pm
Nothing to do with the credit record as such, haven't ever received a CCJ but would have to declare one if I did. Apologies I know next to nothing about (civil) law!

I'm not too late to appeal - today is day 13 since notice was given - as mentioned in my previous post about to do so on the GA website, as NCP suggest for complaints where keepers are "...disputing the validity of this Parking Charge Notice".

So I remove the complaint part, is the wording ok? Do I reference POPLA and are they likely to let them decide and reject my appeal? Want the play the straight bat.
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: b789 on March 06, 2024, 12:31:19 pm
Even if you were to lose a case that went to court, what makes you think that it would have any effect on your credit record? As long as a CCJ is paid within 30 days of judgment there is no record of it.

This is highly unlikely to ever reach a court because there is no way they can identify the driver unless the keeper identifies themself to be the driver. They are not allowed to infer that the keeper was the driver.

How on earth do you think they are going to "prove" that the keeper was also the driver? You are dealing with shysters (Hansard) who are only interested in the easily picked, low-hanging fruit, who pay up without a fight. There are plenty of them around and it is not worth their effort to go chasing anyone who has more than a bit of knowledge about the difference between keeper and driver liability.

Are you too late to appeal? If not, then your message is not a complaint. It is simply an appeal as the keeper pointing out that you are not liable for the charge and they should go chase the driver.
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: BB4 on March 06, 2024, 12:17:11 pm
Hi @b789 – just getting round to submitting via the appeal process, is this enough please? Would very much appreciate thoughts:

“I am the registered keeper, and I am under no obligation to identify the driver. Your Parking Charge Notice to Keeper is for an alleged breach of contract on land that is subject to statutory control, and it is therefore not relevant land for the purposes of the Schedule 4 to the Protection of Freedoms Act 2012 (PoFA) and there can be no keeper liability.

I advise you to consider this correspondence as an official complaint, not an appeal and, as such, requires a response within the required timescale that can be escalated to the BPA if necessary.”


As mentioned in the original post wondering if more NtK’s like this from months ago could exist. Would multiple PCN’s affect the creditor’s desire to try to make a claim here if they feel they can prove who the driver was in court, e.g. balance of probabilities etc?? Given all that you have explained is that even possible? I could not reasonably take the risk of losing a claim in court and receiving a CCJ due to my profession, however unlikely that is to happen.

Thanks again for your advice.
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: b789 on March 01, 2024, 05:41:52 pm
Despite the fact they cannot keep the registered keeper liable, curious to know if objective evidence in the form of an ANPR photo can be used by NCP to pursue the liable party here?
How do you imagine they could do that? Even if I went up to you and took a photo and then went off, how do you think I can identify who you are? There is no magical database against which I or an unregulated private parking company can refer the picture to in order to identify who that is.

NCP is not an "authority" or the police. They cannot forensically use an ANPR picture to try and identify someone. Do not overthink this. ANPR is to be used for what it says on the tin.

Just keep in mind that NCP have no idea who the driver is and they are not allowed to assume. They either know or they don't. Unless the keeper has identified themselves (deliberately or inadvertently) as the driver, they simply don't know. The keeper is under no legal obligation to identify the driver. NCP cannot rely on PoFA to hold the keeper liable. Do you see how they have nowhere else to go with this?

In short, you tell NCP to go chase the driver. If you're feeling ambivalent, wish them luck.

You have what is sometimes referred to as a "golden ticket".
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: b789 on March 01, 2024, 05:33:38 pm
I've posted your redacted NtK here as I do not want to download your stuff.

(https://i.imgur.com/e7ZH9CX.jpeg)
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: BB4 on March 01, 2024, 05:25:30 pm
Thanks for the clarity again!

Having read the other post so interesting to see that they have recognised that error - maybe why the PCN's were cancelled? It's bad enough to receive these PCN's months after the event when it's hard to verify, but completely disgraceful to send out final reminders in error in my opinion!!

Please see the redacted copy of the PCN here, page 2 just has the standard stuff. Despite the fact they cannot keep the registered keeper liable, curious to know if objective evidence in the form of an ANPR photo can be used by NCP to pursue the liable party here?

[attachment deleted by admin]
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: b789 on March 01, 2024, 05:07:12 pm
In which case you appeal them, individually, with what I wrote in the second post.

In the last day or so, NCP issued this "apology" for delays in issuing PCNs"

Quote
National Car Parks Ltd. have identified an issue with the automated despatch of the Parking Charge Notice (PCN) letters with the PCN reference beginning with ‘GA’.  This has resulted in the delay in the despatch of the letters informing customers of the contravention. Parking Charge Notices offer a period where a customer can settle the matter at a discounted rate (14 days from receipt of the letter). The issue has led to a number of letters arriving with the customer with the discounted offer period either already expired or expiring within a few days from receipt of the letter.

NCP would like to apologise for the confusion this has caused. We will ensure that all of our customers who have been impacted are given the opportunity to settle that matter or appeal as they feel appropriate. NCP will be writing to every customer that has had a notification issued over the last 4 weeks. We will be extending the discounted period for 3 weeks as from the date of the new letter.

NCP will be monitoring the situation closely and will be putting additional safe guards in place to rectify this one off issue.

Once again we would like to apologise for the upset that this has caused.

In other words "Were sorry but we're still going to try and screw you over". Of course, as you are here, you know that this can be easily defeated.
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: BB4 on March 01, 2024, 04:50:11 pm
Thanks @b789 !

The PCN's are original NtKs, issued 99 days precisely after the event! So not reminders, hence why I am thinking the other PCN's may have been cancelled

Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: b789 on March 01, 2024, 04:22:53 pm
The above is not an appeal. It is a complaint. You are too late to appeal unless they re-issue the original NtK and restart the clock. Hence the reference to BPC CoP 23.8.

As in the other thread, the complaint still resulted in three PCNs being cancelled.

Just to clarify, are the PCNs you received marked as "Reminders" or are they the original issue NtKs, just a few months after the even? Please show us a suitably redacted copy but with the dates showing.

If they are original NtKs and they reject the appeal you appeal to POPLA where it should be upheld.
Title: Re: Cambridge North NCP Car Park - 2x PCNs
Post by: BB4 on March 01, 2024, 04:05:37 pm
Well noted thanks for the feedback @b789 !

As with the other recent thread on this same topic by CurtLemmington on 22 Feb - in my case given the fact that they correctly issued a non-POPA NTK as per BPA guidelines within 7 months, may I ask what is most likely to happen next in my situation, and what my next steps might be if the appeal using the above wording is rejected?
Title: Re: Cambridge North NCP Car Park - 3x PCN served at the same time.
Post by: DWMB2 on March 01, 2024, 02:53:10 pm
Have split this out. To avoid confusion we operate a "one case, one thread" rule.
Title: Re: Cambridge North NCP Car Park - 3x PCN served at the same time.
Post by: b789 on March 01, 2024, 02:50:47 pm
For the avoidance of doubt, just appeal as the keeper with this, which is all you need:

Quote
I am the registered keeper. Your NtK is for an alleged breach of contract on land that is under statutory control making it impossible to hold the keeper liable. NCP have no hope at POPLA or in court, so you are urged to save us both a complete waste of time and cancel the PCN.

NCP cannot hold a registered keeper liable. As a matter of fact and law, NCP (as a longstanding BPA Parking operator) will be well aware that they cannot use the PoFA provisions because this is not 'relevant land'. If Greater Anglia wanted to hold owners or keepers liable under Railway Byelaws, that would be within the landowner's gift and another matter entirely, but not only is that not pleaded, it is also not legally possible because NCP is not the Station owner and your 'parking charge' is not and never attempts to be a penalty. It is created for NCP’s own profit (as opposed to a byelaws penalty that goes to the public purse) and NCP has relied on contract law allegations of breach against the driver only. The registered keeper cannot be presumed to have been, nor pursued under some twisted interpretation of the law of agency.
Title: Cambridge North NCP Car Park - 2x PCNs
Post by: BB4 on March 01, 2024, 02:41:42 pm
Hi all

Thank you for all the posts on this thread, this has been very helpful! I am a newbie who finds himself in exactly the same situation as @CurtLemington


The driver has parked at Cambridge North station regularly since March last year. On the same day (Feb 20th 2024) I also received two "Parking Charge Notice to Keeper" letters for two separate incidents dating back over 3 months (14th and 16th November 2023). Given how far back they are dated I am worried that there could be more on the way as the registered keeper.

The driver normally pays for parking by the PayByPhone app, and there have been occasions where parking was paid on leaving the carpark, which via the PaybyPhone app may have resulted in an underpayment.

The period of time taken to issue these PCN's seems very unreasonable - should I assume that if I accept liability NCP will most definitely send any additional PCN's they can find to generate as much revenue as possible, as this is a scheme to make money out of those drivers that do accept liability despite this being a non-POFA NTK??

Reading this thread and the successful outcome that was achieved for @CurtLemington , and given my circumstances (I have received initial NTK's, not just final reminders).....please could someone validate that my proposed approach below is best/viable?

1) Do not pay the PCN or disclose the name the driver.
2) Instead appeal/challenge the Parking Charge NTK immediately with the following wording:
"I am the registered keeper, and I appeal as keeper. Your Parking Charge Notice to Keeper is for an alleged breach of contract on land that is under statutory control making it impossible to hold the keeper liable. As a matter of fact and law, NCP (as a longstanding BPA Parking operator) will be well aware that they cannot use the PoFA provisions because this is not 'relevant land'. Should this appeal be rejected, you will be required to provide me with a POPLA code where an appeal by the keeper will be upheld."

Would very much appreciate thoughts on this? Are NCP likely to reject, given there are no other factors involved e.g. the SAR request?

Thanks all!