Free Traffic Legal Advice

Live cases legal advice => Private parking tickets => Topic started by: bebu on August 20, 2024, 11:36:45 am

Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: DWMB2 on October 21, 2024, 06:27:41 pm
Wait until you get a response from Smart then try again, attaching a copy of said response.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: b789 on October 21, 2024, 06:11:33 pm
It's the standard fob off template from the BPA.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on October 21, 2024, 06:04:15 pm
I got a response from bpa today. I think they misunderstood my complaint. However. I still have the pending complain with smart parking. So I guess I will wait for their response


Thank you for your enquiry.
Our Role
Our role as an Accredited Trade Association is to investigate alleged breaches of our Code of Practice where evidence can be supplied and our members internal complaints policy has been exhausted. We are unable to become involved in individual Parking Charge disputes.

Appealing the Parking Charge
I note that you have appealed to the operator and the independent appeals service, POPLA, who have both rejected your appeals which means you have exhausted the appeals process. As POPLA is an independent appeals service, we are unable to become involved and we cannot compel them to overturn a decision.

Next Steps
If you believe that there has been a breach of our Code of Practice you must first submit your complaint directly to the operator using their internal complaints process which can be found here - https://www.smartparking.com/uk/uk-complaints-policy

If you believe the alleged breach of the Code of Practice has not been addressed in your complaint outcome, we require a copy of this and supporting evidence before becoming further involved.

Kind regards

Xxxx xxxxx
British Parking Association
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on October 16, 2024, 11:37:54 am
Kindly ignore that,

no need for the email, I just got an email to say the 2nd POPLA appeal has been withdrawn.

Winnnnnnnnnnnnnnnnnnnnnnnnnnning


They are now on the backfoot

So I will wait for the complaint and update as time goes on, many many thanks
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on October 16, 2024, 11:34:27 am
Points noted.

About timescales, I just want to ensure the cancel the 2nd pending appeal with the email reminder. If thats ok ?

thanks
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: b789 on October 16, 2024, 11:12:46 am
Please don't ever sign off complaints or anything that is serious with "kind regards". Only ever sign off with Yours faithfully (if you don't know the person you are corresponding with) or Yours sincerely (if you know the person or at least their name).

Before you send anything about the formal complaint you sent, check the timescale for. response on their complaints policy. If no response has been received within that timescale, go straight into a formal complaint to the BPA.

If you need assistance formatting a suitable complaint, let me know.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on October 16, 2024, 11:08:25 am
I still advise you to follow up with the formal complaint to Smart and then with the BPA. That cancellation is not a response to the formal complaint I suggested you send to them. Be insistent. They are on the back foot now and we also need to see what sanctions the BPA will impose on this rogue operator.

Oh without doubt, I definitely will. This is mypending draft

Hello

I lodged a complaint about the issue to your company, I would appreciate a response to my complaint. 

As I would like to further escalate my complaint to the ICO, who demand that I first complaint to the operator first.

I also have a pending POPLA appeal on a 2nd ticket from your company and I would appreciate that cancelled asap

Kind regards
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: b789 on October 16, 2024, 10:56:57 am
I still advise you to follow up with the formal complaint to Smart and then with the BPA. That cancellation is not a response to the formal complaint I suggested you send to them. Be insistent. They are on the back foot now and we also need to see what sanctions the BPA will impose on this rogue operator.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: DWMB2 on October 16, 2024, 10:54:08 am
Thanks for the update - good result that at least the original parking charge is now cancelled!
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on October 16, 2024, 10:50:45 am
Good morning everyone,
I got this correspondence from DAFT parking today.

I have a pending complaint lodged still with DVLA and BPA. However, ICO said to report first to the operator before lodging further complaints


Good Morning,

Thank you for your email.

In relation to the parking charge notice TC82751969, we have investigated and we can see this has happened due to an admin error, therefore the parking charge notice has been cancelled, no further action is required.

Kind Regards
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on October 10, 2024, 12:44:20 pm
I got this response from the DVLA, will keep everyone updated. I also have complained to others as advised above.

Kind regards


Thank you for your email of 8th October to the DVLA. Just to let you know I will be investigating this matter with the parking company who requested your details, as soon as these investigations are completed I will respond to your complaint.

 

Kind Regards

 

Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: DWMB2 on October 08, 2024, 02:26:50 pm
I'd leave things like that out personally. Part of their method of operation is to grind people down so that they give up and pay - don't let them think they're succeeding.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on October 08, 2024, 02:01:49 pm
Here is a suggested complaint to (not so) Smart:

Quote
Subject: Formal Complaint Regarding Handling of POPLA Appeal [Case Reference]

Dear Sir/Madam,

Vehicle Registration Number: [YOUR VEHICLE REGISTRATION]
Parking Charge Reference: [PCN REFERENCE]
POPLA Appeal Reference: [POPLA REFERENCE]

I am writing to formally inform you of my complaint regarding the handling of my POPLA appeal. Given your demonstrated incompetence and unprofessionalism, I am not seeking an investigation but merely informing you of the reasons for this complaint and the actions I have already taken.

Key Issues:

1. GDPR Breach: Your submission in response to my POPLA appeal contained personal details from another motorist’s appeal, referencing breastfeeding and shopping with a 6-month-old child—information that is entirely irrelevant to my case, as I am male and do not have a 6-month-old child. This constitutes a gross breach of Article 5(1)(f) of the UK GDPR, and such a careless error only highlights your incompetence and unlawful handling of personal data.

2. Tampered and Outdated Evidence: Your submission also included signage evidence from 2017, with suspicious metadata showing the “creation” date as November 2017 and the “modified” date as May 2017. This, coupled with the fact that Google Street View from March 2023 confirms that the signage no longer exists, shows that you have submitted outdated and misleading evidence to POPLA.

Escalation Already Initiated: As a result of these serious failings, I have already escalated a formal complaint to the DVLA regarding your violations of the KADOE contract. Additionally, I will be escalating this matter to the British Parking Association (BPA) and the Information Commissioner’s Office (ICO) irrespective of your response. Your repeated failures in this case demonstrate a clear lack of professionalism and competence that needs to be addressed by regulatory authorities.

Next Steps: While I doubt you will cancel the Parking Charge Notice (PCN) at this stage, as the appeal has already been submitted to POPLA (a fee you have already wasted), I want to make it clear that your position is indefensible. Should you wish to withdraw your POPLA submission, it is already too late to save yourselves from the consequences of your own incompetence. You are now being held to account by your own errors.

I trust this matter will be duly noted on your side.

Yours faithfully,

[Your Full Name]

[Your Address]
[Your Email Address]
[Date]

I have lodge complaints to all organisations above and in my DAFT PARKING COMPLAINT. I added this to your draft


Bear in mind, you have caused me and mine a lot of pain, time wasted, discomfort and mental torture. Not to add all the legal avenues/advice I have wasted hours pursing in other to remediate the issue.

This time lost is irecoverable and costly to me



Once again, many many thanks for your kind words and helpful advise

E
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on October 07, 2024, 01:30:57 pm
Here is a suggested initial complaint to the DVLA to start the ball rolling:

Quote
Subject: Breach of KADOE Contract by Smart Parking Ltd

Dear Sir/Madam,

Vehicle Registration Number: [YOUR VEHICLE REGISTRATION]
Parking Charge Reference: [PCN REFERENCE]
POPLA Appeal Reference: [POPLA REFERENCE]

I am writing to formally lodge a complaint against Smart Parking Ltd for their blatant breaches of the KADOE contract, which governs their access to vehicle keeper data through the DVLA. This complaint is supported by attached evidence, which clearly demonstrates the operator's incompetence, unprofessional behavior, and unlawful conduct. I am aware that this is not an isolated incident, as other motorists have raised similar concerns about Smart Parking’s misuse of personal data. Given the financial relationship between the DVLA and operators like Smart Parking, I am concerned that this complaint may be deflected to protect your income stream. However, I expect the DVLA to address this issue transparently and fully investigate these breaches.

Key Issues:

1. GDPR Breach: In their response to my POPLA appeal, Smart Parking embedded another motorist’s POPLA appeal within mine, including personal details completely irrelevant to my case. This breach includes references to breastfeeding and shopping with a 6-month-old child—information that obviously has nothing to do with me, as I am male and have no such child. This careless inclusion of another individual’s personal data not only violates Article 5(1)(f) of the UK GDPR but also demonstrates Smart Parking's incompetence and lack of professionalism. By acting unlawfully and irresponsibly in this manner, they have clearly violated the standards of conduct required under the KADOE contract.

2. Tampered and Outdated Evidence: Additionally, Smart Parking submitted signage evidence from 2017, which contains tampered metadata, showing the “creation” date as November 2017, while the “modified” date is May 2017. Further to this, Google Street View from March 2023 confirms that the signage in their submission no longer exists. This is a clear attempt to mislead by submitting tampered and outdated evidence, which further demonstrates their lack of professionalism and their failure to comply with the KADOE contract’s requirements for accurate and lawful conduct.

Escalation to BPA, ICO, and MP Involvement: In addition to this complaint, I have escalated the matter to the British Parking Association (BPA) and the Information Commissioner’s Office (ICO). Evidence of these blatant breaches of the KADOE contract, GDPR, and BPA Code of Practice will also be submitted to these bodies. Furthermore, I will be raising these concerns with my Member of Parliament, asking them to bring this matter to the attention of the relevant government ministers. This is a serious issue that warrants ministerial oversight to ensure that the DVLA is fulfilling its obligations to protect the public’s personal data.

Action Requested: I request that the DVLA conduct a formal investigation into Smart Parking’s conduct and provide me with a detailed response, including the specific sanctions or actions the DVLA intends to take regarding these violations. I expect the DVLA to address these issues appropriately, rather than deflecting the complaint to protect its income stream from this lucrative operator. Given Smart Parking’s breaches of the KADOE contract, I believe that their access to sensitive vehicle keeper data should be reconsidered.

Please find attached the relevant evidence to support my complaint, including the tampered and outdated evidence provided by Smart Parking and the GDPR breach in which personal data from another motorist’s appeal was embedded in mine. I trust that this matter will be handled with the seriousness it deserves.

I look forward to your response, including a full explanation of the actions you will take.

Yours faithfully,

[Your Full Name]

[Your Address]
[Your Email Address]
[Date]: [PCN REFERENCE]
POPLA Appeal Reference: [POPLA REFERENCE]

You guys are far too kind. Words arent enough to say A HUGE THANK YOU
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: b789 on October 07, 2024, 01:28:57 pm
Here is a suggested complaint to (not so) Smart:

Quote
Subject: Formal Complaint Regarding Handling of POPLA Appeal [Case Reference]

Dear Sir/Madam,

Vehicle Registration Number: [YOUR VEHICLE REGISTRATION]
Parking Charge Reference: [PCN REFERENCE]
POPLA Appeal Reference: [POPLA REFERENCE]

I am writing to formally inform you of my complaint regarding the handling of my POPLA appeal. Given your demonstrated incompetence and unprofessionalism, I am not seeking an investigation but merely informing you of the reasons for this complaint and the actions I have already taken.

Key Issues:

1. GDPR Breach: Your submission in response to my POPLA appeal contained personal details from another motorist’s appeal, referencing breastfeeding and shopping with a 6-month-old child—information that is entirely irrelevant to my case, as I am male and do not have a 6-month-old child. This constitutes a gross breach of Article 5(1)(f) of the UK GDPR, and such a careless error only highlights your incompetence and unlawful handling of personal data.

2. Tampered and Outdated Evidence: Your submission also included signage evidence from 2017, with suspicious metadata showing the “creation” date as November 2017 and the “modified” date as May 2017. This, coupled with the fact that Google Street View from March 2023 confirms that the signage no longer exists, shows that you have submitted outdated and misleading evidence to POPLA.

Escalation Already Initiated: As a result of these serious failings, I have already escalated a formal complaint to the DVLA regarding your violations of the KADOE contract. Additionally, I will be escalating this matter to the British Parking Association (BPA) and the Information Commissioner’s Office (ICO) irrespective of your response. Your repeated failures in this case demonstrate a clear lack of professionalism and competence that needs to be addressed by regulatory authorities.

Next Steps: While I doubt you will cancel the Parking Charge Notice (PCN) at this stage, as the appeal has already been submitted to POPLA (a fee you have already wasted), I want to make it clear that your position is indefensible. Should you wish to withdraw your POPLA submission, it is already too late to save yourselves from the consequences of your own incompetence. You are now being held to account by your own errors.

I trust this matter will be duly noted on your side.

Yours faithfully,

[Your Full Name]

[Your Address]
[Your Email Address]
[Date]
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: b789 on October 07, 2024, 01:16:43 pm
Here is a suggested initial complaint to the DVLA to start the ball rolling:

Quote
Subject: Breach of KADOE Contract by Smart Parking Ltd

Dear Sir/Madam,

Vehicle Registration Number: [YOUR VEHICLE REGISTRATION]
Parking Charge Reference: [PCN REFERENCE]
POPLA Appeal Reference: [POPLA REFERENCE]

I am writing to formally lodge a complaint against Smart Parking Ltd for their blatant breaches of the KADOE contract, which governs their access to vehicle keeper data through the DVLA. This complaint is supported by attached evidence, which clearly demonstrates the operator's incompetence, unprofessional behavior, and unlawful conduct. I am aware that this is not an isolated incident, as other motorists have raised similar concerns about Smart Parking’s misuse of personal data. Given the financial relationship between the DVLA and operators like Smart Parking, I am concerned that this complaint may be deflected to protect your income stream. However, I expect the DVLA to address this issue transparently and fully investigate these breaches.

Key Issues:

1. GDPR Breach: In their response to my POPLA appeal, Smart Parking embedded another motorist’s POPLA appeal within mine, including personal details completely irrelevant to my case. This breach includes references to breastfeeding and shopping with a 6-month-old child—information that obviously has nothing to do with me, as I am male and have no such child. This careless inclusion of another individual’s personal data not only violates Article 5(1)(f) of the UK GDPR but also demonstrates Smart Parking's incompetence and lack of professionalism. By acting unlawfully and irresponsibly in this manner, they have clearly violated the standards of conduct required under the KADOE contract.

2. Tampered and Outdated Evidence: Additionally, Smart Parking submitted signage evidence from 2017, which contains tampered metadata, showing the “creation” date as November 2017, while the “modified” date is May 2017. Further to this, Google Street View from March 2023 confirms that the signage in their submission no longer exists. This is a clear attempt to mislead by submitting tampered and outdated evidence, which further demonstrates their lack of professionalism and their failure to comply with the KADOE contract’s requirements for accurate and lawful conduct.

Escalation to BPA, ICO, and MP Involvement: In addition to this complaint, I have escalated the matter to the British Parking Association (BPA) and the Information Commissioner’s Office (ICO). Evidence of these blatant breaches of the KADOE contract, GDPR, and BPA Code of Practice will also be submitted to these bodies. Furthermore, I will be raising these concerns with my Member of Parliament, asking them to bring this matter to the attention of the relevant government ministers. This is a serious issue that warrants ministerial oversight to ensure that the DVLA is fulfilling its obligations to protect the public’s personal data.

Action Requested: I request that the DVLA conduct a formal investigation into Smart Parking’s conduct and provide me with a detailed response, including the specific sanctions or actions the DVLA intends to take regarding these violations. I expect the DVLA to address these issues appropriately, rather than deflecting the complaint to protect its income stream from this lucrative operator. Given Smart Parking’s breaches of the KADOE contract, I believe that their access to sensitive vehicle keeper data should be reconsidered.

Please find attached the relevant evidence to support my complaint, including the tampered and outdated evidence provided by Smart Parking and the GDPR breach in which personal data from another motorist’s appeal was embedded in mine. I trust that this matter will be handled with the seriousness it deserves.

I look forward to your response, including a full explanation of the actions you will take.

Yours faithfully,

[Your Full Name]

[Your Address]
[Your Email Address]
[Date]: [PCN REFERENCE]
POPLA Appeal Reference: [POPLA REFERENCE]
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: DWMB2 on October 07, 2024, 01:01:50 pm
How do I go about these complaints ?

BPA usually insist you complain directly to the member first - frankly this might be interesting to do simply to see how Smart claim they are going to resolve the issue in regards to the other person's data.

And can I demand compensation ?
You can demand it, but it's probably unlikely to be forthcoming. A bigger GDPR breach has seemingly been committed against whoever's appeal they're confusing yours with. It does raise the question of whether or not your data has been similarly mis-shared, but getting evidence of that might prove tricky.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on October 07, 2024, 12:50:02 pm
I dont think I have laughed so much on a monday.  :)  :D  ;D

I think these forum, should have a "BUY ME A COFFEE" section, to say thank you to everyone for such kind assistance.

It needs a DVLA complaint, a BPA complaint and an ICO complaint.

How do I go about these complaints ? And can I demand compensation ?

I changed the wording slightly to

Smart Parking has entirely failed to address the substantive points raised in my original appeal to POPLA, which were critical in challenging the validity of the Parking Charge Notice (PCN). Instead of responding to these points, they have chosen to submit irrelevant, incorrect, and tampered evidence, which includes an astonishing GDPR breach. In their submission, Smart Parking seems to believe I went shopping with a 6-month-old son and spent the time breastfeeding. Allow me to clarify:

I am male, and I do not breastfeed

I have a 16-year-old daughter (who lives two hours away in another city, close to London and has never been to Hull, where the incidence happened). This level of incompetence would be laughable if it weren’t so utterly unprofessional and unlawful.

I see my "ONLY CHILD" regularly, (e.g. last saturday the 5th) But she stopped breastfeeding over 15 years ago
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: b789 on October 07, 2024, 12:15:33 pm
It needs a DVLA complaint, a BPA complaint and an ICO complaint.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: DWMB2 on October 07, 2024, 12:10:02 pm
I do not breastfeed my 16-year-old daughter
There's a line I never thought I'd read on a parking forum.

That response looks good - given the sheer level of incompetence on show, once the POPLA appeal is concluded, I'd recommend following up on the DVLA complaints mentioned in the proposed response.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: b789 on October 07, 2024, 12:04:46 pm
As any reply to the operators evidence can only be pasted into the response box on the POPLA website and is limited to 20,000 charachters, you should respond with this:

Quote
Initial Summary – Operator’s Complete Failure to Address My Appeal Points

Smart Parking has entirely failed to address the substantive points raised in my original appeal to POPLA, which were critical in challenging the validity of the Parking Charge Notice (PCN). Instead of responding to these points, they have chosen to submit irrelevant, incorrect, and tampered evidence, which includes an astonishing GDPR breach. In their submission, Smart Parking seems to believe I went shopping with a 6-month-old son and spent the time breastfeeding. Allow me to clarify: I am male, and I do not breastfeed my 16-year-old daughter (who lives two hours away in another city). This level of incompetence would be laughable if it weren’t so utterly unprofessional and unlawful.

It is hard to imagine a more vexatious attempt to extort money from me than this submission, which fails to meet the basic standards required by the BPA Code of Practice. Smart Parking’s blatant disregard for accuracy and their gross mishandling of personal data—pulling someone else’s appeal details into my case—demonstrates nothing short of contempt for the POPLA process and data protection laws.

Given that Smart Parking has not even attempted to engage with or rebut the actual arguments in my appeal, I assert that their evidence is incomplete, unreliable, and fails to meet the required standards of an Accredited Operator Scheme (AOS) member. Their incompetence and this ridiculous submission should result in the immediate cancellation of the PCN.

1. GDPR Breach and Incompetence

Smart Parking’s submission is not only factually incorrect but also includes irrelevant personal details from another individual's appeal, which is a gross breach of GDPR. The mention of breastfeeding and shopping with a 6-month-old child is not only irrelevant to my case but constitutes a serious breach of Article 5(1)(f) of the UK GDPR, which requires that personal data be processed in a manner that ensures its security and confidentiality.

This level of incompetence violates several sections of the BPA Code of Practice, including:

Section 23.1(c): Operators must comply with all relevant legislation, including the Data Protection Act (UK GDPR). Including another person's personal data in my case demonstrates a total disregard for data protection laws.

Section 23.1(a): Operators must act professionally and treat motorists fairly. The inclusion of someone else's details in my appeal shows a fundamental failure in professionalism.

Such a breach of both GDPR and the BPA Code of Practice makes Smart Parking’s evidence fundamentally unreliable and calls into question their fitness as an AOS member. Their mishandling of this case should result in the invalidation of the PCN.

2. Lack of Evidence Regarding Standing

The operator has provided no evidence that they have the right to issue parking charges at this location. While POPLA has, in the past, made the assumption that operators must have a contract simply because signage is present, this is not legally sufficient proof of authority to operate.

The presence of signage does not constitute evidence that the operator has the landowner's authorisation to issue parking charges or pursue these charges through enforcement. It is critical to understand that any party wishing to impose charges on private land must provide strict proof of their legal standing to do so. This requires more than assumptions or generalisations—it requires an unredacted, valid, and up-to-date contract with the landowner.

The BPA Code of Practice clearly states under Section 7.2 that operators must ensure they have written authorisation from the landowner, and this must be produced if challenged. The contract should clearly define:

• The land on which the operator may operate, with boundaries clearly specified.

• Any restrictions on hours of operation or parking control.

• Whether the operator is authorised to issue Parking Charge Notices in their own name or merely as an agent of the landowner.

• Whether any exemptions exist, such as for genuine customers or residents.

The contract must also set out the specific authority the operator has to enforce parking terms and the exact amount they are authorised to charge. It is not acceptable for the operator to simply assert that they have authority without producing this document.

In this case, Smart Parking has failed to provide any such contract, and their omission is telling. I challenge POPLA to recognise that without strict proof of an active and valid contract, the operator has no legal standing to enforce parking charges at this site. Any decision based on an assumption that the operator has a contract without seeing actual evidence would be fundamentally flawed and unjust.

Only an unredacted, up-to-date contract between the operator and the landowner that complies with BPA Code of Practice Section 7.3 should be accepted as valid proof. This is a minimum legal requirement, and failure to produce this document undermines the operator's entire case. It is not enough to assume that signage equals authorisation; strict proof is needed to validate the operator’s standing.

3. Operator’s Competence, Integrity, and Failure to Comply with the BPA Code of Practice

Smart Parking’s submission exhibits a profound lack of competence and professionalism, which directly contravenes the standards laid out in the BPA Code of Practice (CoP). Their handling of this appeal is indicative of a broader failure to comply with the BPA CoP in several key areas, which should seriously call into question their ability to operate as an Accredited Operator Scheme (AOS) member.

BPA CoP Section 2.4 clearly requires that operators must maintain high standards of professional conduct. Smart Parking’s submission, which contains inaccurate, irrelevant, and tampered evidence, shows they have failed to adhere to even the most basic professional standards. The use of evidence from an entirely unrelated appeal, containing personal details from another motorist, is not only grossly unprofessional but represents an utter disregard for data protection laws and the BPA’s own requirements for fair and transparent conduct.

BPA CoP Section 23.1(a) obliges operators to act professionally and fairly when dealing with motorists. Smart Parking’s failure to respond to the points raised in my appeal and their inclusion of another individual’s personal data demonstrates a clear breach of this obligation. Their handling of the evidence is sloppy at best and a deliberate attempt to mislead at worst.

BPA CoP Section 23.1(c) also mandates that operators must comply with all relevant legislation, including the UK GDPR and the Protection of Freedoms Act (PoFA). The inclusion of personal details from another case in my appeal submission constitutes a serious breach of Article 5(1)(f) of the UK GDPR, which requires data to be processed in a manner that ensures appropriate security. This is not a minor oversight but a significant failure in data management, which I will be reporting to the Information Commissioner’s Office (ICO) for investigation.

Further to this, I will also be reporting Smart Parking to the DVLA for serious breaches of the KADOE contract, which governs their access to driver data. Their gross mishandling of personal data in this case is indicative of a systemic failure to meet the conditions required under the KADOE contract, and I will be raising this issue with the DVLA as part of my complaint.

It is important to note that, while POPLA may not consider external reports as part of their assessment, the operator’s gross failure to meet both the legal requirements under GDPR and the BPA CoP standards should not be ignored when assessing their competence and reliability. These breaches demonstrate that the operator lacks the professionalism, competence, and integrity necessary to issue and enforce Parking Charge Notices.

For these reasons, and given the operator’s complete failure to adhere to the BPA Code of Practice, the PCN must be cancelled. Smart Parking's conduct, from their mishandling of personal data to their submission of outdated and tampered evidence, shows that they are not fit to operate in accordance with the standards required of an AOS member.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on October 07, 2024, 11:26:14 am
Where are the photos you took when you went back to the site? The links to them do not work anymore. However, the GCV view from March 2022 show that any signs they claim were there in 2017, were not actually there anymore.

Also, the signs they have shown show that they were "created" in November 2017 but "modified" in May 2017. If that is not evidence of tampering, I don't know what else is.

I cant attach them on here, as it says the storage is full. So I have uploaded them to my dropbox account here


https://www.dropbox.com/scl/fo/xtruxsvfak8fv1sbr6krv/AKommLFeUuaVlnDLkDQyELM?rlkey=7da7a0vmpt7vk49qdjv73moin&st=58acrojy&dl=0


Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on October 07, 2024, 11:22:15 am
At this point I think Trading Standards need to tell Smart Parking to change their company name, as it is clearly misleading.

@bebu - did you make the point about landowner authority? If so, can you show us what they have provided by way of a contract? Smart used to have serious issues with this, so I'd be interested to see what they've provided.

lol, they should call themselves DAFT PARKING STANDARDS  ;D  :)  :D

Yes, I did mention the landowner argument, I think they just omitted everything and have their arguments mixed up

Here was my argument




Re: Parking ticket TC82751969 ( POPLA Verification Code: 8512324712)
I was issued with a parking ticket for parking at the Anlaby shopping centre for my visit on the 15th July 2024. I have been charged £100. I believe that this ticket was issued unfairly. I am NOT liable for the amount payable. Reasons and evidence below:

1. No legal evidence of land authority
2. There was insufficient signage and not clearly visible
3. Enroute the centre, where I parked at the time, there is a major road, which branches off to the right, notably where I parked there is no clearly visible sign
4. From the spot I parked and my short walk into the gym, (on that day the PCN was issued) there is no clearly visible sign.
5. I drove back to the shopping centre today and at the entrance is a disabled spot with a sign on it, which is not clear, as the sign is placed on a disable spot and not at the entrance of the gym
6. Gross unfairness and affecting my mental health

Even if smart parking, in all fairness is setting up 3 hours parking restrictions where a gym exists. It would be in the public’s interest to ensure the gym “IN QUESTION” notifies its members, in the app, on the gym floor and upon sign up. If it is done in FAIRNESS. After all a gym is not just about hours of working out, it has showers, hour long classes, changing, banter (mental health) etc

Kind regards

 
INTRODUCTION – my reason to visit the gym
I am a member of both Nuffield Fitness gym and JD Gyms in Hull. Of which I have been using Nuffield for almost 14 years now. I am not a member of Pure Gym, but was my first visit on the fateful day
An old friend, told me about Pure Gym in Anlaby ( which I had never been to, neither do I shop in that area) and sent me a free pass, asking to meet up before 5pm.
I had sent him a photo that I was infront of the gym as I arrived early, but he unfortunately arrived late. (Kindly see whatsapp evidence, and there was no parking advisory sign, where I parked as I sent him a photo)
I repeat: There was no sign or warning from both smart parking, neither any put up by Pure gym, (outside their premises, inside or in their app) and they do not have any staff manning the entrance.

POINT OF APPEAL

1. No evidence of landholder authority

The operator is also put to strict proof, by means of contemporaneous and unredacted evidence, of a chain of authority flowing from the landholder of the "relevant land" to the operator. It is not accepted that the operator has adhered to the landholder's definitions, exemptions, grace period, hours of operation, etc. and any instructions to cancel charges due to complaints. There is no evidence that the freeholder authorises this operator to issue parking charges or what the land enforcement boundary and start/expiry dates are, nor whether this operator has standing to enforce such charges in their own name rather than a bare licence to act as an agent ‘on behalf of’ the landowner.

The operator is put to strict proof of full compliance with the BPA Code of Practice. As this operator does not have proprietary interest in the “relevant land” then I require that they produce an unredacted copy of the contract with the landowner. The contract and any 'site agreement' or 'User Manual' setting out details including exemptions - such as any 'genuine customer' or 'genuine resident' exemptions or any site occupier's 'right of veto' charge cancellation rights - is key evidence to define what this operator is authorised to do and any circumstances where the landowner/firms on site in fact have a right to cancellation of a charge. It cannot be assumed, just because an agent is contracted to merely put some signs up and issue Parking Charge Notices, that the agent is also authorised to make contracts with all or any category of visiting drivers and/or to enforce the charge in court in their own name (legal action regarding land use disputes generally being a matter for a landowner only). Witness statements are not sound evidence of the above, often being pre-signed, generic documents not even identifying the case in hand or even the site rules.

A witness statement might in some cases be accepted by POPLA but in this case I suggest it is unlikely to sufficiently evidence the definition of the services provided by each party to the agreement. Nor would it define vital information such as charging days/times, any exemption clauses, grace periods (which I believe may be longer than the bare minimum times set out in the BPA CoP) and basic information such as the land boundary and bays where enforcement applies/does
not apply.

Not forgetting evidence of the various restrictions which the landowner has authorised can give rise to a charge and, of course, how much the landowner authorises this agent to charge (which cannot be assumed to be the sum on a sign because template private parking terms and sums have been known not to match the actual landowner agreement). Paragraph 7 of the BPA Code of Practice defines the mandatory requirements and I put this operator to strict proof of full compliance:
7.2 If the operator wishes to take legal action on any outstanding parking charges, they must ensure that they have the written authority of the landowner (or their appointed agent) prior to legal action being taken.

7.3 The written authorisation must also set out:
(a) the definition of the land on which you may operate, so that the boundaries of the land can be clearly defined
(b) any conditions or restrictions on parking control and enforcement operations, including any restrictions on hours of operation
(c) any conditions or restrictions on the types of vehicles that may, or may not, be subject to parking control and enforcement
(d) who has the responsibility for putting up and maintaining signs
(e) the definition of the services provided by each party to the agreement



No evidence of landholder authority

The operator is also put to strict proof, by means of contemporaneous and unredacted evidence, of a chain of authority flowing from the landholder of the "relevant land" to the operator. It is not accepted that the operator has adhered to the landholder's definitions, exemptions, grace period, hours of operation, etc. and any instructions to cancel charges due to complaints. There is no evidence that the freeholder authorises this operator to issue parking charges or what the land enforcement boundary and start/expiry dates are, nor whether this operator has standing to enforce such charges in their own name rather than a bare licence to act as an agent ‘on behalf of’ the landowner.

The operator is put to strict proof of full compliance with the BPA Code of Practice. As this operator does not have proprietary interest in the “relevant land” then I require that they produce an unredacted copy of the contract with the landowner. The contract and any 'site agreement' or 'User Manual' setting out details including exemptions - such as any 'genuine customer' or 'genuine resident' exemptions or any site occupier's 'right of veto' charge cancellation rights - is key evidence to define what this operator is authorised to do and any circumstances where the landowner/firms on site in fact have a right to cancellation of a charge. It cannot be assumed, just because an agent is contracted to merely put some signs up and issue Parking Charge Notices, that the agent is also authorised to make contracts with all or any category of visiting drivers and/or to enforce the charge in court in their own name (legal action regarding land use disputes generally being a matter for a landowner only). Witness statements are not sound evidence of the above, often being pre-signed, generic documents not even identifying the case in hand or even the site rules.

A witness statement might in some cases be accepted by POPLA but in this case I suggest it is unlikely to sufficiently evidence the definition of the services provided by each party to the agreement. Nor would it define vital information such as charging days/times, any exemption clauses, grace periods (which I believe may be longer than the bare minimum times set out in the BPA CoP) and basic information such as the land boundary and bays where enforcement applies/does
not apply.

Not forgetting evidence of the various restrictions which the landowner has authorised can give rise to a charge and, of course, how much the landowner authorises this agent to charge (which cannot be assumed to be the sum on a sign because template private parking terms and sums have been known not to match the actual landowner agreement). Paragraph 7 of the BPA Code of Practice defines the mandatory requirements and I put this operator to strict proof of full compliance:
7.2 If the operator wishes to take legal action on any outstanding parking charges, they must ensure that they have the written authority of the landowner (or their appointed agent) prior to legal action being taken.

7.3 The written authorisation must also set out:
(a) the definition of the land on which you may operate, so that the boundaries of the land can be clearly defined
(b) any conditions or restrictions on parking control and enforcement operations, including any restrictions on hours of operation
(c) any conditions or restrictions on the types of vehicles that may, or may not, be subject to parking control and enforcement
(d) who has the responsibility for putting up and maintaining signs
(e) the definition of the services provided by each party to the agreement

Above is a google map of direction from my house to the gym. There is no sign as you approach the entrance and insufficient enroute the gym.



2. There was insufficient signage. There was no sign at the entrance of the car park or major areas in the car park, neither is there any at the entrance of the gym

I have attached a whatsapp screenshot, when I arrived the gym and was waiting for my friend, who invited me for a 5 day workout session.

Notably, I had parked infront of the gym and there was no sign at the entrance. I have also attached more photos of the area attesting to this fact. At the end of this document




























3. The reason for my visit: The gym in question ( Pure Gym, in Anlaby Hull) uses automated entries and assistance, as there is no one there to advise you

No one at pure gym picks there phones, replies to emails or replies to their facebook and social media accounts.
4. From the spot I parked and my short walk into the gym, (on that day the PCN was issued) there is no clearly visible sign. This is a statement of fact and honesty
6. Gross unfairness and affecting my mental health
Even though this is not quoted in the “requirements of the BPA CoP” I think its important that we speak out against private companies setting traps for unsuspecting individuals.
I honestly never saw any of the notices/signs and innocently went to the gym, it would have been fair, if they insisted also, that the gym notify their members, rather than set traps for them

See more evidence attached below
Main entrance – No obvious signed


Main Entrance – No Obvious signs
Where I parked, No signs. Kindly note this is the main and only entrance into the gym
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: b789 on October 07, 2024, 11:19:47 am
Where are the photos you took when you went back to the site? The links to them do not work anymore. However, the GCV view from March 2022 show that any signs they claim were there in 2017, were not actually there anymore.

Also, the signs they have shown show that they were "created" in November 2017 but "modified" in May 2017. If that is not evidence of tampering, I don't know what else is.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on October 07, 2024, 11:19:22 am
Yes, its both my vehicle and my argument. But their response is just daft. I went to the gym to work out. YOu can see in my failed summary response, which I even put screenshots of my gym membership ( and the full argyment is below).

1. So where they got the response, that I went shopping and left my 6 months old son is daft

2. I only have a daughter, who lives 2 hours 10 mins, away from me in another city and she is 16

3. I am a male and dont breastfeed as stated by them

Reading the whole things just gives me a headache and at the same time, makes me laugh.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: DWMB2 on October 07, 2024, 11:16:43 am
At this point I think Trading Standards need to tell Smart Parking to change their company name, as it is clearly misleading.

@bebu - did you make the point about landowner authority? If so, can you show us what they have provided by way of a contract? Smart used to have serious issues with this, so I'd be interested to see what they've provided.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: b789 on October 07, 2024, 11:05:41 am
Lovely... I will come back with a suitable retort you can submit to POPLA. Bear with me, this is going to be fun.

Does their "Case Summary - 8512324712" number match your POPLA claim number? Also, does the VRM match your vehicles VRM?
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on October 07, 2024, 10:55:25 am
Hello
I got an email from my POPLA appeal, in which smartsystems are challenging my appeal.

However I think they are mixing up my appeal with another person, as my initial flawed appeal, which they rejected was based on the fact that I was in the gym for the first time. But in their response, they claim, I went to do my weekly shopping and kept my kid in the car

See it here

Although I want to reply asap, I dont want to make mistakes as last time and say something sensible, but outside the legal points. So please advise,

many thanks


https://www.dropbox.com/scl/fi/1opcb9ourplg52u91xgws/popla.png?rlkey=d5ruu4dcwasgbe3qr6vav4zys&dl=0

https://www.dropbox.com/scl/fi/zb9ovpo0ntoy13go1kvym/Case-Summary-8512324712.pdf?rlkey=y2q2s0cgc48xfap3r13hkk5ik&dl=0
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on September 16, 2024, 09:13:47 pm
As I already mentioned, the required entrance signage is in place at the location. However, if parking at the side of the gym, there is no visible signage except the disabled bay notice (at least in March 2022):

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

You also need to remember that POPA will not consider anything that isn't a failure to follow the law or the BPA CoP. So anything about anything that is not to do with the operator and whether the PCN was issued correctly, is a waste of your time and effort. Did the operator follow all their legal and CoP requirements correctly. If they did, then the assessor issuing to reject your appeal.


thank you for your time, help and kind comments. Its very much appreciated

I had parked at the side of the gym, next to the two blue cars, and from that spot, there no way I could have seen that sign, thats why I posted that whatsapp attachment, as I sent it to my friend, saying I was waiting at that spot for him

thank you very much, will submit the first one now and second tomorrow
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: b789 on September 16, 2024, 04:54:01 pm
As I already mentioned, the required entrance signage is in place at the location. However, if parking at the side of the gym, there is no visible signage except the disabled bay notice (at least in March 2022):

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

You also need to remember that POPA will not consider anything that isn't a failure to follow the law or the BPA CoP. So anything about anything that is not to do with the operator and whether the PCN was issued correctly, is a waste of your time and effort. Did the operator follow all their legal and CoP requirements correctly. If they did, then the assessor issuing to reject your appeal.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on September 16, 2024, 04:42:49 pm
Points noted. Will update it shortly

That last photo is the entrance, and when you turn right, you are then in the south entrance of the centre. Which then turns right at the end to the gym
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: DWMB2 on September 16, 2024, 04:28:59 pm
Couple of comments:

Quote
Introduction - my reason to visit the gym
The reason for your visit is irrelevant as to whether or not a contract was formed leading to a parking charge becoming payable. Leave this out.

Quote
Above is a google map of direction from my house to the gym
It's not entirely clear why you have included this. It doesn't really support your point around signage in its current form.

Page 6: You have included a WhatsApp screenshot, but this is too small to be of much use for anything. Your wider photos of the signage at the site may be useful, but the WhatsApp screenshot isn't particularly.

Quote
3. The reason for my visit: The gym in question ( Pure Gym, in Anlaby Hull) uses automated entries and assistance, as there is no one there to advise you No one at pure gym picks there phones, replies to emails or replies to their facebook and social media accounts.
None of this is relevant, I'd leave this out.

Page 8:
(https://i.imgur.com/T3R2XsI.png)

You say this is a photo of the main entrance, but it looks like it is actually a photo of the way out, taken from inside the car park: https://maps.app.goo.gl/zRFAgiCDNHPwCe2aA (https://maps.app.goo.gl/zRFAgiCDNHPwCe2aA). This is the entrance: https://maps.app.goo.gl/BBdcmXhz1ug1iuma7 (https://maps.app.goo.gl/BBdcmXhz1ug1iuma7).
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on September 16, 2024, 03:56:41 pm
I have updated this document - MY APPEAL

https://www.dropbox.com/scl/fi/4i047o9gvvlhf2420juae/PCN-Appeal-pure-gym-analby-2.pdf?rlkey=5dy0lluvruov91sn27f9ump0n&st=tp8d5ylz&dl=0
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on September 16, 2024, 03:30:43 pm

"They" cannot identify the driver unless YOU, the Keeper did so, inadvertently or otherwise. Smart Parking are one of the easiest operators to beat, as long as the driver is not identified by the Keeper. Smart do not issue PoFA compliant PCNs.

So, did you or did you not reveal the identity of the driver when you appealed? Saying things like "I parked..." instead of "The driver parked..." is an example of how to blow the drivers identity inadvertently. Also, when appealing, there is an option to select whether you are appealing as the "driver" or the "keeper" or "other". Which option did you select?

If you have revealed yourself to be the driver, then you cannot rely on their failure to comply with PoFA and you are liable as the driver.

However, looking at GSV images from 2022, the signage appears to be woefully inadequate, or at least it was back then. At the parking are to the side of the gym there is no signage whatsoever. The only visible sign is the in front of the disabled bays.

All the other signs in the car park are small and the wording appears to illegible unless you are standing six inches from the sign. Can you get a close up of the sign so that we can evaluate the wording and whether it is able to form a contract?

I see there is an entrance sign as you drive into the retail park. Have you tried contacting the managing agent for the landowner to ask that they bet the PCN cancelled? You can probably find out who that is by looking at that big advertising plinth by the entrance. Normally, near the bottom, there is information on who either owns or manages the land on there.

If you are interested, have a look at the BPA CoP for the requirements in their signs.

https://www.britishparking.co.uk/write/Documents/AOS/NEW%20Redesigned%20Documents/Version91.2.2024Highlight.pdf

The landowner point should be used but not as the primary point, although, then again, Smart very often do not have valid contracts where they operate.
AS I said, I cant remember what I said in my 1st appeal, as in my naivity, I thought being a gym member would be straightforward, but I like to believe I owned it was me.

Moving forward

I just drove down the centre and realized, driving in. There are

1. A notice when you come in, on the right
2. A notice on the left and right, before you turn into the gym
3. But where I parked, I there are no visible direct notice, as you enter the gym

AS I said earlier, I never noticed anything the 5 days I visited the gym, as the gym is at the end of the shopping centre

SEe attached files here

https://www.dropbox.com/scl/fi/quj76oasaoxyu3ihte8eq/20240916_144849-0.jpg?rlkey=w6otulcp7unile3x963jiveo0&st=v1ldzggs&dl=0

https://www.dropbox.com/scl/fi/e768t078klr2i9sj5xocz/20240916_144929.jpg?rlkey=99kmdfslg1tgnzje0hnzavp4j&st=5htldaef&dl=0


This last photo is where I parked, and the sign, I highlighted with the arrow, has a disabled spot with a PCN warning

https://www.dropbox.com/scl/fi/h5f2nbtjozobss4wrdmit/disabled-sign.jpg?rlkey=hmtv9vsonih4sai5ye8e13rak&st=jddx1jf1&dl=0




Finally about the SHOPPING CENTRE ownership is a charity called

Anlaby Retail Park is owned by The Albert Gubay Charitable Foundation and managed by Workman LLP
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: DWMB2 on September 16, 2024, 01:28:20 pm
The landowner point should be used but not as the primary point, although, then again, Smart very often do not have valid contracts where they operate.
Even if not as the primary point, definitely include this. As b789 notes, there have historically been issues with their contracts, to the point that Smart often used to withdraw at POPLA where this point was raised.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on September 16, 2024, 01:26:02 pm
I believe I have identified myself and blown my cover. I will get back to you with the other questions shortly. As I would take a photo and ask about the other questions

Many thanks
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: b789 on September 16, 2024, 01:09:04 pm
They havnet identified me as of yet, just a letter to which I have acknowledge in my 1st faulty appeal (In which I did say, I was visiting the gym), which has been rejected.

"They" cannot identify the driver unless YOU, the Keeper did so, inadvertently or otherwise. Smart Parking are one of the easiest operators to beat, as long as the driver is not identified by the Keeper. Smart do not issue PoFA compliant PCNs.

So, did you or did you not reveal the identity of the driver when you appealed? Saying things like "I parked..." instead of "The driver parked..." is an example of how to blow the drivers identity inadvertently. Also, when appealing, there is an option to select whether you are appealing as the "driver" or the "keeper" or "other". Which option did you select?

If you have revealed yourself to be the driver, then you cannot rely on their failure to comply with PoFA and you are liable as the driver.

However, looking at GSV images from 2022, the signage appears to be woefully inadequate, or at least it was back then. At the parking are to the side of the gym there is no signage whatsoever. The only visible sign is the in front of the disabled bays.

All the other signs in the car park are small and the wording appears to illegible unless you are standing six inches from the sign. Can you get a close up of the sign so that we can evaluate the wording and whether it is able to form a contract?

I see there is an entrance sign as you drive into the retail park. Have you tried contacting the managing agent for the landowner to ask that they bet the PCN cancelled? You can probably find out who that is by looking at that big advertising plinth by the entrance. Normally, near the bottom, there is information on who either owns or manages the land on there.

If you are interested, have a look at the BPA CoP for the requirements in their signs.

https://www.britishparking.co.uk/write/Documents/AOS/NEW%20Redesigned%20Documents/Version91.2.2024Highlight.pdf

The landowner point should be used but not as the primary point, although, then again, Smart very often do not have valid contracts where they operate.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on September 16, 2024, 12:47:48 pm
POPLA is only interested in whether the PCN was issued correctly on points of law or the BPA CoP.

So, if the driver is still unidentified, was the PCN POFA compliant? If not, the burden of proof is on the operator to prove that the Keeper was the driver.

They havnet identified me as of yet, just a letter to which I have acknowledge in my 1st faulty appeal (In which I did say, I was visiting the gym), which has been rejected.

So I have kind of roped myself in

Do the signs conform to the requirements of the BPA CoP and do they adequately bring to the attention of the driver the charge for breaching the terms?

I had attached a number of photos to my appeal, in which there are no signs, as you approach the shopping center and no clear signs as you drive in. However there are 2 signs as you turn right ( which I would argue is very easy to miss) and a sign by the side of the gym, which if you look in the photos I attached, faces another side and would not be something I would have seen. So I would say no

Also, I did visit the gym 6 days in a row and never noticed any of the signs



If you look at the google road layout, I attached, its a straightforward drive to the gym, virtually an L shaped drive, as the gym ( in question, I visited) is at the corner or the end of the road



Were the signs able to form a contract with the driver?

I would again say no, see the photos I attached. Even leaving the gym, it would be hard to see them



Is there a valid contract flowing from the landowner to the operator?
I dont know, but I dont think so, as its a shopping center and I dont believe SP owns that land



And so on. What the Gym did or did not do is irrelevant.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: DWMB2 on September 16, 2024, 12:30:56 pm
Quote
Moving forward, do you have templates for the other points ?
The other points were questions, which you need to answer. Once you've done so we might then be able to advise.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on September 16, 2024, 12:29:04 pm
I haven't gone through it fully but simply looking at your appeal points, you have about zero chance of POPLA accepting the appeal on mitigation.

Waffling on about what the Gym has or has not done or their staffing levels is of no consequence and will not be considered. POPLA is only interested in whether the PCN was issued correctly on points of law or the BPA CoP.

So, if the driver is still unidentified, was the PCN POFA compliant? If not, the burden of proof is on the operator to prove that the Keeper was the driver.

Do the signs conform to the requirements of the BPA CoP and do they adequately bring to the attention of the driver the charge for breaching the terms?

Were the signs able to form a contract with the driver?

Is there a valid contract flowing from the landowner to the operator?

And so on. What the Gym did or did not do is irrelevant.

I see, I have deleted all the other points, except for no 1. Which you earlier gave me. Moving forward, do you have templates for the other points ?

Do I leave the photos about the signs not being so obvious ?

many thanks
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: b789 on September 16, 2024, 12:03:26 pm
I haven't gone through it fully but simply looking at your appeal points, you have about zero chance of POPLA accepting the appeal on mitigation.

Waffling on about what the Gym has or has not done or their staffing levels is of no consequence and will not be considered. POPLA is only interested in whether the PCN was issued correctly on points of law or the BPA CoP.

So, if the driver is still unidentified, was the PCN POFA compliant? If not, the burden of proof is on the operator to prove that the Keeper was the driver.

Do the signs conform to the requirements of the BPA CoP and do they adequately bring to the attention of the driver the charge for breaching the terms?

Were the signs able to form a contract with the driver?

Is there a valid contract flowing from the landowner to the operator?

And so on. What the Gym did or did not do is irrelevant.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on September 16, 2024, 11:54:13 am
hello
very sorry this is late, I have had some challenges. I have removed personal details and done a draft challenge which I want to submit today, kindly find attached here

I cant upload to this forum as I am told the upload folder is full and I should contact the administrator, however I have uploaded it here to my dropbox account

https://www.dropbox.com/scl/fi/4i047o9gvvlhf2420juae/PCN-Appeal-pure-gym-analby-2.pdf?rlkey=5dy0lluvruov91sn27f9ump0n&st=tp8d5ylz&dl=0


many thanks
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: b789 on August 22, 2024, 03:59:51 pm
POPLA code is actually valid for 33 days. Just bear that in mind if you need a little longer to formulate your appeal.
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on August 22, 2024, 02:53:18 pm
A couple of general tips for POPLA:

  • Be detailed. Lead the assessor through each of your points, as if they have no prior knowledge. Leave as little room for misinterpretation as possible and explain exactly why each point means that your appeal should be upheld and the parking charge cancelled.
  • Don't write your appeal in the online form. Produce it as a PDF that you will upload to the POPLA system. If you're referencing signage, include photos in-line in your appeal
  • Use numbered headings for each of your appeal points to make the appeal easy to follow. Ideally read some other examples, on here and the MSE forum, to get an idea of what a good POPLA appeal looks like.

As this is Smart Parking, I would strongly recommend including a point on landholder authority - in the past, including this has often led to Smart withdrawing from the process, meaning you win. There's an example of how to word such a point below:
No evidence of landholder authority

The operator is also put to strict proof, by means of contemporaneous and unredacted evidence, of a chain of authority flowing from the landholder of the "relevant land" to the operator. It is not accepted that the operator has adhered to the landholder's definitions, exemptions, grace period, hours of operation, etc. and any instructions to cancel charges due to complaints. There is no evidence that the freeholder authorises this operator to issue parking charges or what the land enforcement boundary and start/expiry dates are, nor whether this operator has standing to enforce such charges in their own name rather than a bare licence to act as an agent ‘on behalf of’ the landowner.

The operator is put to strict proof of full compliance with the BPA Code of Practice. As this operator does not have proprietary interest in the “relevant land” then I require that they produce an unredacted copy of the contract with the landowner. The contract and any 'site agreement' or 'User Manual' setting out details including exemptions - such as any 'genuine customer' or 'genuine resident' exemptions or any site occupier's 'right of veto' charge cancellation rights - is key evidence to define what this operator is authorised to do and any circumstances where the landowner/firms on site in fact have a right to cancellation of a charge. It cannot be assumed, just because an agent is contracted to merely put some signs up and issue Parking Charge Notices, that the agent is also authorised to make contracts with all or any category of visiting drivers and/or to enforce the charge in court in their own name (legal action regarding land use disputes generally being a matter for a landowner only). Witness statements are not sound evidence of the above, often being pre-signed, generic documents not even identifying the case in hand or even the site rules.

A witness statement might in some cases be accepted by POPLA but in this case I suggest it is unlikely to sufficiently evidence the definition of the services provided by each party to the agreement. Nor would it define vital information such as charging days/times, any exemption clauses, grace periods (which I believe may be longer than the bare minimum times set out in the BPA CoP) and basic information such as the land boundary and bays where enforcement applies/does
not apply.

Not forgetting evidence of the various restrictions which the landowner has authorised can give rise to a charge and, of course, how much the landowner authorises this agent to charge (which cannot be assumed to be the sum on a sign because template private parking terms and sums have been known not to match the actual landowner agreement). Paragraph 7 of the BPA Code of Practice defines the mandatory requirements and I put this operator to strict proof of full compliance:

7.2 If the operator wishes to take legal action on any outstanding parking charges, they must ensure that they have the written authority of the landowner (or their appointed agent) prior to legal action being taken.

7.3 The written authorisation must also set out:

(a) the definition of the land on which you may operate, so that the boundaries of the land can be clearly defined
(b) any conditions or restrictions on parking control and enforcement operations, including any restrictions on hours of operation
(c) any conditions or restrictions on the types of vehicles that may, or may not, be subject to parking control and enforcement
(d) who has the responsibility for putting up and maintaining signs
(e) the definition of the services provided by each party to the agreement
[/quote]

I see, many thanks, as I would revert with my draft shortly.

I was given 28 days
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: DWMB2 on August 22, 2024, 12:30:10 pm
A couple of general tips for POPLA:


As this is Smart Parking, I would strongly recommend including a point on landholder authority - in the past, including this has often led to Smart withdrawing from the process, meaning you win. There's an example of how to word such a point below:
No evidence of landholder authority

The operator is also put to strict proof, by means of contemporaneous and unredacted evidence, of a chain of authority flowing from the landholder of the "relevant land" to the operator. It is not accepted that the operator has adhered to the landholder's definitions, exemptions, grace period, hours of operation, etc. and any instructions to cancel charges due to complaints. There is no evidence that the freeholder authorises this operator to issue parking charges or what the land enforcement boundary and start/expiry dates are, nor whether this operator has standing to enforce such charges in their own name rather than a bare licence to act as an agent ‘on behalf of’ the landowner.

The operator is put to strict proof of full compliance with the BPA Code of Practice. As this operator does not have proprietary interest in the “relevant land” then I require that they produce an unredacted copy of the contract with the landowner. The contract and any 'site agreement' or 'User Manual' setting out details including exemptions - such as any 'genuine customer' or 'genuine resident' exemptions or any site occupier's 'right of veto' charge cancellation rights - is key evidence to define what this operator is authorised to do and any circumstances where the landowner/firms on site in fact have a right to cancellation of a charge. It cannot be assumed, just because an agent is contracted to merely put some signs up and issue Parking Charge Notices, that the agent is also authorised to make contracts with all or any category of visiting drivers and/or to enforce the charge in court in their own name (legal action regarding land use disputes generally being a matter for a landowner only). Witness statements are not sound evidence of the above, often being pre-signed, generic documents not even identifying the case in hand or even the site rules.

A witness statement might in some cases be accepted by POPLA but in this case I suggest it is unlikely to sufficiently evidence the definition of the services provided by each party to the agreement. Nor would it define vital information such as charging days/times, any exemption clauses, grace periods (which I believe may be longer than the bare minimum times set out in the BPA CoP) and basic information such as the land boundary and bays where enforcement applies/does
not apply.

Not forgetting evidence of the various restrictions which the landowner has authorised can give rise to a charge and, of course, how much the landowner authorises this agent to charge (which cannot be assumed to be the sum on a sign because template private parking terms and sums have been known not to match the actual landowner agreement). Paragraph 7 of the BPA Code of Practice defines the mandatory requirements and I put this operator to strict proof of full compliance:

7.2 If the operator wishes to take legal action on any outstanding parking charges, they must ensure that they have the written authority of the landowner (or their appointed agent) prior to legal action being taken.

7.3 The written authorisation must also set out:

(a) the definition of the land on which you may operate, so that the boundaries of the land can be clearly defined
(b) any conditions or restrictions on parking control and enforcement operations, including any restrictions on hours of operation
(c) any conditions or restrictions on the types of vehicles that may, or may not, be subject to parking control and enforcement
(d) who has the responsibility for putting up and maintaining signs
(e) the definition of the services provided by each party to the agreement
[/quote]
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on August 22, 2024, 08:50:57 am
hello
any advise on what to do next with my independent appeal ? many thanks
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: The Rookie on August 20, 2024, 01:42:13 pm
Apparently, I was there for 5 days in a row, but only got 2. I am not sure, If I stayed below 3 hours in other 3 times, hence future fines are on the way.
ANPR is very unreliable, at our works car park it's about 60% effective.

There will be no fines coming, there may be more invoices.  Only a court can fine you.  If you do get more then use the right appeal!
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on August 20, 2024, 12:26:09 pm
If you have two parking charges then you should have two POPLA codes, as each is appealed separately. Have you appealed both?

Yes I have appealed both, but I only got the above rejection today. I am guessing the 2nd is on the way

Apparently, I was there for 5 days in a row, but only got 2. I am not sure, If I stayed below 3 hours in other 3 times, hence future fines are on the way.

But for now, one rejected, one pending.

tnx
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: DWMB2 on August 20, 2024, 12:20:33 pm
If you have two parking charges then you should have two POPLA codes, as each is appealed separately. Have you appealed both?
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on August 20, 2024, 12:00:32 pm
this ?

POPLA Verification Code: [REMOVED BY MOD]

Apologies, I thought appealing would be a walk in the park, as I was given a free gym 5 day pass, as to be honest, I never saw the 3 hours warning, until I drove back there now

many thanks
Title: Re: 3 hours Parking fine violation while at anlalby gym Hull
Post by: DWMB2 on August 20, 2024, 11:54:02 am
What's done is done, but in future, if you come here before appealing this is preferable - we can get Smart Parking charges cancelled on first appeal, as long as the driver is not revealed. Nevertheless, all is not lost, and you can still probably get this withdrawn at POPLA. Have they provided you with POPLA codes?

To help us to help you, please read the following thread carefully, and provide as much of the information it asks for as you are able to: READ THIS FIRST - Private Parking Charges Forum guide (https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/)
Title: 3 hours Parking fine violation while at anlalby gym Hull
Post by: bebu on August 20, 2024, 11:36:45 am
hello everyone
I moved from London to Hull and signed up to 2 gyms and spend well over 2 hours weekdays at the gym, since I work from home with computers, I hardly move. So need to make up for it


PROBLEM

A friend gave me a gym pass for pure gym in analby in Hull and asked me to meet up with him before 5pm, So I got there about 440pm. Then when he came, we share pleasantries and went in and did our workout. After I finished, I looked around and left

KINDLY NOTE:

No where in the gym does it say we have a max stay of 3 hours
None of the staff are in, after 6pm ish, as its all automated
No where in my welcome email or gym app does it say a max stay

PCN ISSUED

I got 2 tickets saying I am issued a PCN of £100 for overstaying the 3 hours limit, which I appealed to the company www.smartpartking.com, but was rejected.

I just drove to the center now, to see if there were signs displayed and yes there are signs displayed, if you look carefully. But not at the gym or entrance and it could easily be missed


Kindly advise moving forward

as I want to lodge an independent appeal


Kind regards
Ehi