Free Traffic Legal Advice

Live cases legal advice => Private parking tickets => Topic started by: strawberrydoll on August 23, 2024, 05:45:50 pm

Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on November 20, 2024, 02:45:00 pm
Sorry this took so long- I lost multiple family members in a short period of time in between all of this, but I am home now. I'm really sorry for the long period of absence.

I am happy to continue on to MCOL and submit a claim if you're all still willing to help, and then move onto the complaint to the DVLA.
Thank you.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on November 06, 2024, 04:17:35 pm
Just to provide an update to my letter of claim- Smart Parking have sent me a response, but only reiterating that my data was deleted.


(https://i.imgur.com/bzj087H.png)
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on October 22, 2024, 08:16:17 pm
Just providing an update with this- Smart Parking have not responded but unfortunately I had a family emergency at the end of September which I'm only just getting back from. I would like to continue and I should be back home around the beginning of November. Sorry for the silence and thank you!
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: b789 on September 19, 2024, 03:55:23 pm
It's all a means to an end. The response to the DVLA is to point out that they ignored the operators unlawful use of the data provided by them. Once the DVLA has been notified of a misuse of data provided by them, simply brushing it off as a "simple ANPR misread" is not satisfactory.

Hopefully, this will result in a complaint to the BPA and perhaps a follow up to see what, if any, sanctions were applied and whether those sanctions were transmitted to the DVLA as required by the KADOE.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: H C Andersen on September 19, 2024, 01:48:24 pm
It seems as if the obligations fall to the 'customer' (the operator). I cannot see that DVLA have any supervisory or inquisitorial role. In any event, IMO their route would be via ATAs i.e. potential withdrawal of KADOE rights would follow an operator's expulsion from ATA membership. 

Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: b789 on September 19, 2024, 11:38:56 am
Sigh...

KADOE contract (https://assets.publishing.service.gov.uk/media/5a81a0c7e5274a2e8ab55036/Annex_A_-_KADOE_Fee_Paying_Contract_V4.pdf)

Just a few clauses that do not let the DVLA "off the hook". The response from the DVLA dismissed the complaint as a minot "misread" by the ANPR and has filed to address the actual failure by Smart to manually check ANPR images against the DVLA supplied data. Smart have misused the data they purchased from the DVLA and appropriate measures should be taken to sanction them, as we know this is not an isolated incident, and also to make sure it can't happen again, preferably by removing Smart's ability to use DVLA data in future.

1. Clause D10.1 (Incidents):
This clause places a clear obligation on the customer (the operator) to notify the DVLA immediately about any data misuse. Why has no action been taken by the DVLA after being informed of the misuse of data supplied by them?

Relevant quote:
The Customer shall notify the DVLA immediately of any losses or misuse of the Data and keep the DVLA informed of any communications about that breach with: the individuals whose Personal Data is affected; the Information Commissioner’s Office; or the media.

2. Clause D9.1 (Audits, Reviews, etc.):
This clause obliges the customer to share with the DVLA the results of audits or reviews concerning data processing activities, ensuring compliance with the contract. Why hasn't the DVLA pursued an audit or review in light of the data misuse by Smart Parking?

Relevant quote:
The Customer shall share with the DVLA the outcome of any other checks, audits or reviews that have been carried out on its activities as a Data Controller that are relevant to the Processing of the Data.

3. Clause D12.1 (Action on Complaint):Why have no steps been taken to address the misuse of data?

Relevant quote:
Where a complaint is received about the Customer or the manner in which its services have been supplied or work has been performed or procedures used or about any other matter connected with the performance of the Customer’s obligations under the Contract or the use of Data, the DVLA may notify the Customer, and where considered appropriate by the DVLA, investigate the complaint.

4. Clause D11.1 (Inspection by the DVLA):
This clause reinforces the DVLA’s right to inspect the Smart’s operations if there are concerns about contract compliance. Why has the DVLA not exercised its right to inspect in light of the complaint about misuse?

Relevant quote:
The DVLA reserves the right to carry out an inspection at any time of the Customer’s compliance with the terms of this Contract.

5. Clause A6.2 (Accredited Trade Association Compliance):
This clause mandates the customer to notify the DVLA about any non-compliance issues or sanctions from the ATA. This one is for after a complaint to the BPA has been filed.

Relevant quote:
The Customer shall notify the DVLA immediately if the Accredited Trade Association finds any non-compliance issues, if any sanctions are applied or points placed on the Customer’s membership licence, or if its membership or Approved Operator status is suspended or ended.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: DWMB2 on September 19, 2024, 10:00:59 am
So that's DVLA off the hook.
I would suggest that if an organisation is handing out 1,400 sets of keeper data each day to a single operator, they ought to properly look into any examples of that data being subsequently misused, once they are brought to DVLA's attention.

That said, I can see the value in your point that an escalated complaint might have more 'teeth' if it can be demonstrated that the matter has been taken up by the BPA, and of course if the OP successfully sues Smart.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: H C Andersen on September 19, 2024, 08:03:37 am
That's not a Stage 2 Complaint IMO.

You acknowledge the following:
While the DVLA may have had reasonable cause to release my data to Smart Parking in the first instance, the key issue here is Smart Parking’s failure to verify that data after receiving it and then unlawfully using it.

So that's DVLA off the hook. How would you expect DVLA to oversee an Approved Operator's subsequent use of data? IMO, this is for their ATA, in this case BPA.

You then demand that DVLA change the law and impose unspecified sanctions on Smart Parking.

The DVLA now has a responsibility to investigate this breach of the KADOE contract and impose appropriate sanctions on Smart Parking for their failure to comply with the requirements for processing the data.

IMO, this responsibility lies with the BPA.

What is it you're trying to achieve..you've written to Smart demanding compensation and ultimately could take them to court therefore, other than venting your spleen at DVLA, what would you hope to achieve at this stage with them? 

If you feel you must write to them, then I suggest you wait until you've concluded your dealings with Smart and then, armed with this info, for example a court judgment, then go back to DVLA.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on September 18, 2024, 06:28:43 pm
Thank you for this, I'll send a step 2 complaint with this wording.

How about responding to Mrs Harris with the following:

Quote
Dear Mrs Harris,

Re: Response to Your Letter Dated 16 September 2024 – Unlawful Acquisition of Personal Data by Smart Parking Ltd

Thank you for your letter dated 16 September 2024, regarding my complaint about the unlawful acquisition of my personal data by Smart Parking Ltd under the KADOE contract. While I appreciate your review of the matter, several critical issues remain unaddressed, and I would like to clarify the core concerns.

1. The Core Issue – Failure in Post-DVLA Data Processing by Smart Parking

The key issue here is not the initial request by Smart Parking for my personal data but their failure to verify that data once they received it from the DVLA. While Smart Parking may have had reasonable cause to request the data due to a misread of the vehicle registration number (VRM) by their ANPR system, the breach and unlawful use of my data occurred when they failed to compare the data they received with the actual vehicle captured in their ANPR images.

After receiving my details, Smart Parking had an obligation under section 21.5a(d) of the British Parking Association (BPA) Code of Practice (CoP) to check that the make, model, and colour of the vehicle in the DVLA data matched the vehicle identified in the ANPR image. This simple, compulsory check would have immediately revealed the mismatch, as the vehicle associated with my personal data was not the vehicle in the ANPR image. Smart Parking's failure to perform this check resulted in the wrongful issuance of a Parking Charge Notice (PCN) to me, of a vehicle I am not the registered keeper of and have never owned or driven.

This failure constitutes a breach of the BPA CoP and the KADOE contract. Had Smart Parking performed the required check, no PCN would have been issued, and I would not have been subjected to the distress and anxiety caused by their unlawful actions.

2. Concerns Over DVLA’s Revenue and Conflict of Interest

Another critical concern is the financial relationship between the DVLA and private parking companies like Smart Parking. In the financial year 2023/2024 alone, Smart Parking submitted 513,696 KADOE requests at £2.50 per request, generating significant revenue for the DVLA. Given this substantial income (from this relatively minor player), there is a concern that the DVLA may be prioritising revenue over its duty to safeguard individuals' personal data and ensure that private parking companies comply with their legal and contractual obligations.

This situation raises the question: Is the DVLA more concerned with protecting its income stream than upholding individuals' rights to privacy and ensuring that their data is only used lawfully? The fact that Smart Parking clearly failed to verify the data they received before issuing the PCN represents a serious breach of the KADOE contract and the BPA Code of Practice.

I would like to know what sanctions the DVLA intends to impose on Smart Parking for this failure. If no meaningful action is taken, this suggests a worrying lack of oversight and protection for the public in favour of protecting the DVLA's revenue sources.

3. Misrepresentation of the Parking Charge Notice (PCN) as a "Penalty"

Finally, I would like to correct an inaccuracy in your response. You referred to the charge issued by Smart Parking Ltd as a "penalty charge notice." This is incorrect. The notice I received was a Parking Charge Notice issued by an unregulated private parking company, not a statutory penalty issued by a public authority. Parking Charge Notices from private parking companies do not carry the same legal weight as penalties issued by local councils or government bodies. This misrepresentation is important and should be corrected in any future correspondence.

Conclusion

While the DVLA may have had reasonable cause to release my data to Smart Parking in the first instance, the key issue here is Smart Parking’s failure to verify that data after receiving it and then unlawfully using it. The DVLA now has a responsibility to investigate this breach of the KADOE contract and impose appropriate sanctions on Smart Parking for their failure to comply with the requirements for processing the data.

I look forward to your response and confirmation that the DVLA will take appropriate action to address this issue and prevent future breaches.

Yours sincerely,
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on September 18, 2024, 06:27:31 pm
cancel Smart Parking Ltd's KADOE contract
In the first 3 quarters of the 23/24 financial year, Smart made 513,696 KADOE requests - DVLA charges £2.50 per request. That's not a money tap they'll be keen to turn off unfortunately. (Source - Excel spreadsheet (https://assets.publishing.service.gov.uk/media/65d71bfa2ab2b3e0f27595aa/kadoe-enquiries-q3-2023-24-v1.ods))

This makes me irrationally (or rather rationally) upset that they have the audacity to respond to me with how they're publicly funded so are unable to help further 🙄
I guess the wording matters, but it did strike a nerve.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on September 18, 2024, 06:23:16 pm
Can you please show us the wording of your complaint to the DVLA.

I used your original letter as a template. I had a friend help me write it because I'm no good with these things 😶

Quote
Unlawful Releasing of Data.

Good Afternoon,

I am writing in relation to your recent releasing of my personal data to “Smart Parking Ltd” under the terms of the KADOE contract, on issuance of a PCN to my registration XK69 XXX from the aforementioned company dated 19th August 2024. I bring to your attention the following points:
Lack of Reasonable Cause: The vehicle captured in the ANPR image sent to me has a registration number XC59 XXX and is of a completely different make and model than my vehicle. I have never owned or driven the vehicle in question, nor have I ever visited the location stated in the PCN. This clearly indicates an error on your part in assessment of reasonable cause to release my personal information to Smart Parking Ltd.
Unlawful Release of Personal Data: Given your failure to enforce your terms or to assess reasonable cause, my data was released unlawfully and a breach of the Data Protection Act 2018 has occurred.
Misuse of Personal Data: As Smart Parking Ltd failed to Adhere to BPA Code of Practice, specifically section 21.5a(d), which mandates manual quality control checks of ANPR images, they have unlawfully processed my data and have sent me a predatory Parking Charge Notice due to your unlawful release of my personal data.
Distress and Anxiety: The actions of the DVLA have caused me significant distress and anxiety and I believe I am entitled to compensation for this.

I now demand that you:
- Immediately cease any further release of my personal data to any third parties, including but not limited to Smart Parking Ltd, as it is clear there is no enforcement of terms related to assessment of reasonable cause to release my data.
- Cancel Smart Parking Ltd’s KADOE contract due to their failure to adhere to BPA Code of Practice 21.5a(d).
- Compensate me for the distress and anxiety, specifically for damages under the Data Protection Act 2018.

Yours faithfully,

Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: b789 on September 18, 2024, 05:49:38 pm
How about responding to Mrs Harris with the following:

Quote
Dear Mrs Harris,

Re: Response to Your Letter Dated 16 September 2024 – Unlawful Acquisition of Personal Data by Smart Parking Ltd

Thank you for your letter dated 16 September 2024, regarding my complaint about the unlawful acquisition of my personal data by Smart Parking Ltd under the KADOE contract. While I appreciate your review of the matter, several critical issues remain unaddressed, and I would like to clarify the core concerns.

1. The Core Issue – Failure in Post-DVLA Data Processing by Smart Parking

The key issue here is not the initial request by Smart Parking for my personal data but their failure to verify that data once they received it from the DVLA. While Smart Parking may have had reasonable cause to request the data due to a misread of the vehicle registration number (VRM) by their ANPR system, the breach and unlawful use of my data occurred when they failed to compare the data they received with the actual vehicle captured in their ANPR images.

After receiving my details, Smart Parking had an obligation under section 21.5a(d) of the British Parking Association (BPA) Code of Practice (CoP) to check that the make, model, and colour of the vehicle in the DVLA data matched the vehicle identified in the ANPR image. This simple, compulsory check would have immediately revealed the mismatch, as the vehicle associated with my personal data was not the vehicle in the ANPR image. Smart Parking's failure to perform this check resulted in the wrongful issuance of a Parking Charge Notice (PCN) to me, of a vehicle I am not the registered keeper of and have never owned or driven.

This failure constitutes a breach of the BPA CoP and the KADOE contract. Had Smart Parking performed the required check, no PCN would have been issued, and I would not have been subjected to the distress and anxiety caused by their unlawful actions.

2. Concerns Over DVLA’s Revenue and Conflict of Interest

Another critical concern is the financial relationship between the DVLA and private parking companies like Smart Parking. In the financial year 2023/2024 alone, Smart Parking submitted 513,696 KADOE requests at £2.50 per request, generating significant revenue for the DVLA. Given this substantial income (from this relatively minor player), there is a concern that the DVLA may be prioritising revenue over its duty to safeguard individuals' personal data and ensure that private parking companies comply with their legal and contractual obligations.

This situation raises the question: Is the DVLA more concerned with protecting its income stream than upholding individuals' rights to privacy and ensuring that their data is only used lawfully? The fact that Smart Parking clearly failed to verify the data they received before issuing the PCN represents a serious breach of the KADOE contract and the BPA Code of Practice.

I would like to know what sanctions the DVLA intends to impose on Smart Parking for this failure. If no meaningful action is taken, this suggests a worrying lack of oversight and protection for the public in favour of protecting the DVLA's revenue sources.

3. Misrepresentation of the Parking Charge Notice (PCN) as a "Penalty"

Finally, I would like to correct an inaccuracy in your response. You referred to the charge issued by Smart Parking Ltd as a "penalty charge notice." This is incorrect. The notice I received was a Parking Charge Notice issued by an unregulated private parking company, not a statutory penalty issued by a public authority. Parking Charge Notices from private parking companies do not carry the same legal weight as penalties issued by local councils or government bodies. This misrepresentation is important and should be corrected in any future correspondence.

Conclusion

While the DVLA may have had reasonable cause to release my data to Smart Parking in the first instance, the key issue here is Smart Parking’s failure to verify that data after receiving it and then unlawfully using it. The DVLA now has a responsibility to investigate this breach of the KADOE contract and impose appropriate sanctions on Smart Parking for their failure to comply with the requirements for processing the data.

I look forward to your response and confirmation that the DVLA will take appropriate action to address this issue and prevent future breaches.

Yours sincerely,
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: b789 on September 18, 2024, 04:35:36 pm
Can you please show us the wording of your complaint to the DVLA.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: DWMB2 on September 18, 2024, 04:28:49 pm
cancel Smart Parking Ltd's KADOE contract
In the first 3 quarters of the 23/24 financial year, Smart made 513,696 KADOE requests - DVLA charges £2.50 per request. That's not a money tap they'll be keen to turn off unfortunately. (Source - Excel spreadsheet (https://assets.publishing.service.gov.uk/media/65d71bfa2ab2b3e0f27595aa/kadoe-enquiries-q3-2023-24-v1.ods))
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on September 18, 2024, 04:09:23 pm
I have sent the letter of claim, looks like they didn't have an email for service so post it is.

In the meantime, I have received a response from the DVLA in response to my complaint. I essentially told them to stop any future sharing of my details with Smart Parking Ltd due to their failure to adhere to the BPA CoP, and to cancel Smart Parking Ltd's KADOE contract and to compensate me for the distress caused by the misuse of my data, which I knew was a long shot.

(https://i.imgur.com/afPr6Gz.png)

(https://i.imgur.com/tQKFQxV.png)

They did write "where any inappropriate use of DVLA data by a company is identified, swift and proportionate action is taken" but seemed to gloss over that in this case.
What a terrible system where anyone can just get my data from the DVLA and do whatever they want with it with no consequences.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on September 12, 2024, 08:14:15 pm
You can attach it to an email as a pdf if you have a valid email address for service. Also, you could print it and sent it by post with a free "proof of posting" certificate from any post office.

If sent by email, it is deemed given the date it is sent. If it sent by first class post, it is deemed given on the second working say after posting.

If you send by email, make sure that you include in the body of the email an instruction to whoever reads the email first that it has attached a legal document that should be passed to the relevant person or legal advisor for the company. The subject should be "IMPORTANT - Letter of Claim".

Understood. Thank you again for the amazing and clear advice! I'll update once again when I send it/get a response.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: b789 on September 12, 2024, 05:00:55 pm
You can attach it to an email as a pdf if you have a valid email address for service. Also, you could print it and sent it by post with a free "proof of posting" certificate from any post office.

If sent by email, it is deemed given the date it is sent. If it sent by first class post, it is deemed given on the second working say after posting.

If you send by email, make sure that you include in the body of the email an instruction to whoever reads the email first that it has attached a legal document that should be passed to the relevant person or legal advisor for the company. The subject should be "IMPORTANT - Letter of Claim".
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on September 12, 2024, 03:51:29 pm
As they have avoided or failed to respond to the third point about compensation in your original complaint and subsequent correspondence, you can now send them a Letter of Claim for compensation for breaching your GDPR under the Data Protection Act 2018. It will be interesting to see their response as, in the words of Lance Corporal Jack Jones (Clive Dunn) in Dad's Army... They don't like it up 'em!"

Something along these lines would do it:

Thank you so much again for your help! I feel like you'd get along with my dad 😂

If I were to send this, would it be via email/pdf again, or post?
I'm going to wait until the weekend once I have a clear head because work has been killing me, then I'll write it out. Appreciate it so much!
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: b789 on September 11, 2024, 05:08:26 pm
As they have avoided or failed to respond to the third point about compensation in your original complaint and subsequent correspondence, you can now send them a Letter of Claim for compensation for breaching your GDPR under the Data Protection Act 2018. It will be interesting to see their response as, in the words of Lance Corporal Jack Jones (Clive Dunn) in Dad's Army... They don't like it up 'em!"

Something along these lines would do it:

Quote
Smart Parking Ltd
Unit 43, Elmdon Trading Estate
Bickenhill Lane
Birmingham, B37 7HE

[Date of sending the letter]

Letter of Claim

Re: Unlawful Acquisition of Personal Data and Compensation Demand

Dear Sirs,

I am writing to formally notify you of my intention to take legal action against Smart Parking Ltd, should this matter not be resolved within 14 days of the date of this letter.

As outlined in my previous correspondence dated [date of your initial letter], your company unlawfully obtained my personal data from the DVLA in connection with Parking Charge Notice (PCN) reference [PCN Reference Number]. The vehicle identified in your ANPR image (registration number XK69XXX) is not mine, and I have never owned or driven the vehicle in question.

You have acknowledged in writing that the PCN was issued in error and confirmed the cancellation of the charge, as well as the deletion of my personal data. However, you failed to address my request for compensation for the distress and anxiety caused by your unlawful actions.

Legal Basis for Claim

Under the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR), individuals are entitled to compensation when their personal data is processed unlawfully and results in distress. By failing to perform the required manual quality control checks under the British Parking Association (BPA) Code of Practice (CoP), section 21.5a, your company had no lawful basis for requesting my personal data from the DVLA. This constitutes a breach of the KADOE contract and the Data Protection Act.

Your failure to comply with these legal obligations caused me significant distress and anxiety, for which I am entitled to compensation.

Demand for Compensation

In light of the distress and anxiety caused, I am seeking compensation in the amount of £300.

If I do not receive a satisfactory response, including the compensation sought, within 14 days, I will issue proceedings against Smart Parking Ltd in the County Court for damages under the Data Protection Act 2018.

This letter serves as a formal Letter of Claim. Please be advised that should you fail to respond or resolve this matter within the specified timeframe, I will take legal action without further notice.

Yours faithfully,
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on September 11, 2024, 04:02:43 pm
I have received the letter

(https://i.imgur.com/cjZJCJa.png)
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on September 05, 2024, 06:51:42 pm
Understood, I do appreciate the help very much. I'll think over it and wait for the letter from them, I'll update this post next week.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: b789 on September 05, 2024, 06:34:18 pm
Don't rush into this. You have to consider it carefully. By making a claim using MCOL, if you are unsuccessful, it will have cost you £35 for a claim of up to £300. Obviously, if you are successful, you will get the £35 back together with the amount that the judge agrees they are liable for.

If you do want to go ahead, you will need to issue an LoC which we can draft for you. Should they not respond or fail to compensate you, then you will have to file the claim on the MCOL website yourself. It is a very straightforward process but does require a bit of an idea of what is involved. The Particulars of Claim (PoC) will have to be carefully crafted and more likely than not will require you to send more detailed PoC within 14 days of the claim as the webform on MCOL has severe limitations.

It is not an issue and we are happy to assist but please remember, we are not lawyers and it is not our £35 that is at risk. If you feel up to it, let us know.

In the meantime, give smart 7 days to send the letter they mention. If they haven't sent anything or it does not answer the question about compensation, then we can proceed with with an LoC.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on September 05, 2024, 06:21:00 pm
It was indeed the one with the three demands, and yes they complied with the first two points and ignored the third point.

Understood, so I just send them a letter of claim with the title Letter before County Court proceedings asking for a fixed amount of compensation for the stress they caused and go from there? Or do I send a letter just claiming without any mention of court? I'm happy to start a claim if it means I get some compensation back for the mini heartattack they caused. Thank you.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: b789 on September 05, 2024, 06:06:41 pm
Which letter did you eventually send them? Was it the complaint one with the three demands, two of which they have complied with but failed to offer any compensation?

You still have the right to sue them for any distress and anxiety this has caused you. It just depends on whether you are up for the fight with our assistance.

I have updated the article on ow and why anyone should sue a PPC for breach of their GDPR and I repeat it below for your consideration:

Quote
Article 5(1)(d) of the UK GDPR legally requires data controllers to store and process personal data accurately. If a data controller, such as a private parking company, unlawfully obtains the keeper's data from the DVLA and issues an invoice based on inaccurate information, claiming you parked in breach of an alleged contract with the landowner (or their agent), this constitutes processing your personal data inaccurately and unlawfully under the UK GDPR.

The precedents for claiming damages and compensation for such unlawful processing of personal data can be found in cases like Halliday v Creation Consumer Finance Ltd [2013] EWCA Civ 333, where the court awarded compensation for distress caused by the inaccurate processing of personal data under the Data Protection Act 1998. Although this case was decided under the old law, similar principles apply under the UK GDPR and the Data Protection Act 2018. Under Article 82 of the UK GDPR and Section 168 of the Data Protection Act 2018, individuals have the right to compensation if they suffer material or non-material damage because of a breach of data protection laws.

Additionally, the case of Vidal-Hall v Google Inc [2015] EWCA Civ 311 confirmed that claimants could recover compensation for distress alone under the Data Protection Act 1998, a principle now similarly recognised under the GDPR. This means that even if you have not suffered tangible financial loss, you may still be entitled to compensation for distress caused by the unlawful processing of your data.

Moreover, in Tetragon Financial Group Limited v Revenue and Customs Commissioners [2020] UKUT 0305 (TCC), the court reiterated the importance of accurate data handling by public bodies. This principle can be applied here, as the DVLA, a public body, must ensure that any data it provides to third parties, such as private parking companies, is used lawfully and accurately. If a private parking company unlawfully obtained your data from the DVLA and processed it inaccurately, you have grounds to seek compensation.

To seek compensation for the unlawful processing of your personal data, you should provide 21 days’ notice (the pre-action protocol typically requires 14 days, but a longer notice can show goodwill) to the data controller, in this case, the private parking company, of your intention to claim damages. You might claim up to £300 for nominal damages under Article 82 of the UK GDPR and Section 168 of the Data Protection Act 2018. This notice should clearly state that you will file a claim with the County Court if they do not confirm in writing that all references to this alleged debt have been deleted within 14 days. Be sure to mark your letter as a "Letter before County Court proceedings."

As a litigant-in-person, you can file your claim under Part 27 proceedings in the County Court (often referred to as the "Small Claims Court"). Each party is responsible for their own legal costs, regardless of the outcome, and the claim can be filed online for a fee of £35 (for a claim up to £300) via the Money Claim Online service (moneyclaimonline.gov.uk (https://www.moneyclaim.gov.uk/web/mcol/welcome)). The successful party can recover their court fees, making the total claim amount £335.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on September 05, 2024, 05:41:28 pm
Thank you both so much for your amazing help!

I sent the letter to their complaints inbox and I have just had the cancellation email from Smart Parking just now which is a massive relief. Sadly they did just gloss over the compensation part. I'll send another email asking to be compensated again in the coming week.

Here's their email.

Quote
Good afternoon

 

Thankyou for your recent communication.

 

We would like to apologise for the error, and I can confirm the PCN has been cancelled. A letter stating so will be sent to you in due course.

 

I can also confirm deletion of your data.

 

Kind Regards,
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: DWMB2 on August 26, 2024, 04:49:02 pm
My suggestion is based more on pragmatism, in case the OP is particularly strapped for time and just needs the charge to go away with as little time required as possible. I don't think a dual-pronged approach, worded well, would create any ambiguity.


As a slightly more general aside, I've never bought into the view that engaging with an appeal process affords legitimacy to the charge being appealed, especially when the purpose of an appeal in this case is to point out why the charge is not legitimate. I've also never seen any cases be negatively affected by any inference that appealing affords legitimacy to a charge.

This being Smart Parking, I think there's a fair chance either of our approaches will lead to the actual charge being cancelled, as we both know Smart have little appetite for all but the most simple cases, so with that in mind, we can probably safely agree to disagree for now.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: b789 on August 26, 2024, 04:31:13 pm
I respectfully disagree. BPA CoP section 23.23 specifically states the following:

Quote
Where you receive a complaint that you consider to
be or include an appeal against the validity of a parking
charge notice, you must also treat it as an appeal for the
purposes of applying the timescales in Clause 23.8, and
should inform the complainant as such unless and until it
is clear that the complaint is not relevant to an appeal or
the complainant informs you that they do not wish it to
be so handled.

It might not be immediately apparent that a complaint
served as such relates to one or more specific parking
charge notices, possibly by way of a clarification that
reveals that an appeal would be worthwhile, hence you
are advised to record and handle complaints as appeals
until they are found conclusively not to be so or patently
refer to matters not relevant to the validity of a parking
charge notice.

The primary concern in this case is the operator's unlawful handling of the keepers data. By focusing solely on a complaint about the misuse of the keepers data under GDPR, it emphasises the most critical issue: the operator’s breach of legal obligations by not manually checking the ANPR images and thereby misidentifying the wrong vehicle.

The operator's breach of the BPA Code of Practice (failure to manually check ANPR images as required under Section 21.5a) and the subsequent unlawful request for the keepers data from the DVLA should be the sole focus. By merging a complaint with an appeal, the main issue of data misuse could be diluted or lost.

Filing an appeal, even when separate from a complaint, could be perceived as engaging with the parking charge's legitimacy. This could inadvertently imply that there is a valid case to answer, which is contrary to the assertion that the vehicle is not the keepers.

An appeal suggests that the alleged parking contravention has some basis for discussion. By appealing, the keeper may inadvertently signal that there is a legitimate issue to address, which could weaken their position that the parking charge is entirely unfounded due to a fundamental identification error.

Maintaining a consistent stance that the parking charge is completely irrelevant to the keeper because the vehicle in question is not theirs is crucial. A separate appeal could create mixed messages or confusion regarding their position.

To remain consistent, it is important to only address the issue of unlawful data handling. If the keeper appeals separately, it could create ambiguity about their position and suggest a willingness to engage with a process that they believe is fundamentally flawed due to the misidentification.

Separating a complaint and an appeal could provide the operator with multiple opportunities to argue their case. They might use any response to an appeal to bolster their procedural stance, rather than focusing on their failure to adhere to the BPA Code of Practice and data protection laws.

A separate appeal could give the operator a chance to frame the situation as a standard parking dispute rather than addressing the core issue of their procedural failures and data misuse. By focusing only on a complaint about unlawful data handling, the keeper forces the operator to directly address their compliance failures rather than deflecting to the merits of a parking charge.

Data protection laws, particularly GDPR, have significant legal weight. Emphasising a complaint based on GDPR breaches is be more powerful and more likely to result in meaningful repercussions for the operator than a standard appeal process.

GDPR violations are taken very seriously and can result in substantial penalties for the offending party. By focusing the keepers efforts on a data protection complaint, thy highlight the operator's severe misconduct and increase the likelihood of regulatory scrutiny and potential sanctions, which may be more effective in resolving the matter than an appeal.

This requires a focused strategy on the operator’s significant breach of data protection laws and procedural failings. By only complaining and not submitting a separate appeal helps to avoid any potential confusion or implication of liability on the keepers part, ensuring that their main concern — unlawful data handling and compliance failures — remains the priority.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: DWMB2 on August 26, 2024, 03:23:25 pm
Quote
Any complaint must be looked at as an appeal according to their CoP, so no need to appeal separately. 
Whilst this is true, if I were erring on the side of caution, I would submit an appeal as well via their portal, just so that the charge is cancelled and the OP can then focus on any complaints they wish to pursue without the actual charge still being in play.

I'm mindful of us not losing sight of that amongst the other (entirely valid) grievances.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: b789 on August 26, 2024, 01:58:38 pm
Any complaint must be looked at as an appeal according to their CoP, so no need to appeal separately. Show us their response. You won’t be able to make an ICO complaint until you’ve received their response to your complaint. However, you certainly should make the ICO complaint, explaining how they’ve obtained your data unlawfully by breaching the KADOE contract.

The DVLA complaint can be submitted immediately. As well as SARing Smart, you should also SAR the DVLA to see which operators and when, obtained your data.

The complaint to Smart should be emailed as a PDF attachment and you should also CC it to yourself as evidence of it having been sent.

If they do cancel the PCN but do not offer compensation for their unlawful access to your data, you can the send them a Letter of Claim for a specified sum for damages under the Data Protection Act 2018. As explained earlier, this is a straight forward process should you want to follow up on and is done online through the Money Claims On Line (MCOL) website. A claim for up to £300 costs £35 and if successful, the fee is also paid back by the defendant.

Whether you follow through with a claim, is up to you. However, simply sending them an LoC gives them a taste of their own medicine and they don’t like it.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on August 26, 2024, 01:14:28 pm
It’s not an appeal. You’ve nothing to appeal. They have obtained your personal data illegally.

Complain by email to their complaints email address. Warn them that they have breached your GDPR and if they refuse to cancel the PCN, you reserve the right to sue them for compensation under the Data Protection Act 2018 for any distress and anxiety this has caused you.

Tell them that you are making a complaint to the ICO and do so.

If they do not cancel, you report them to their ATA, the BPA.

I really don’t understand why you should have to spend time writing to these vermin and, as some have suggested, go out and find a post office so you can see them a complaint. You have nothing to appeal. Your personal data has been obtained illegally.

I suggest you email them a letter along the following lines as a pdf:

Quote
Unlawful Obtaining of Personal Data and Incorrect Issuance of Parking Charge Notice

Dear Sirs,

I am writing in relation to Parking Charge Notice (PCN) reference [PCN Reference Number], issued to my vehicle registration number XK59XXX. I bring to your attention the following points:

1. Incorrect Issuance of PCN: The vehicle captured in your ANPR image has a registration number XK69XXX and is of a completely different make and model than my vehicle. I have never owned or driven the vehicle in question, nor have I ever visited the location stated in the PCN. This clearly indicates an error on your part in reading the ANPR image.

2. Failure to Adhere to BPA Code of Practice: As a member of the British Parking Association (BPA), you are required to comply with the BPA Code of Practice, specifically section 21.5a(d), which mandates manual quality control checks of ANPR images. It is apparent that you failed to perform these checks, leading to the incorrect issuance of the PCN.

3. Unlawful Acquisition of Personal Data: Given your failure to comply with the BPA Code of Practice, you were not entitled to obtain my personal data from the DVLA under the terms of the KADOE contract. Consequently, my personal data has been obtained unlawfully.

4. Distress and Anxiety: The actions of your company have caused me significant distress and anxiety and I believe I am entitled to compensation for this.

I now demand that you:

- Immediately cancel the PCN and confirm in writing that this has been done.

- Delete all personal data you have obtained unlawfully and confirm in writing that this has been done.

- Compensate me for the distress and anxiety caused by your unlawful actions.

If I do not receive a satisfactory response from you within 14 days of the date of this letter, in addition to the formal complaint I have filed with the Information Commissioner's Office, I intend to take legal action in the County Court for damages under the Data Protection Act 2018.

I look forward to your prompt response.

Yours faithfully,

Additionally, you must inform the DVLA of Smart Parking's conduct and their misuse of your personal data. The DVLA has a responsibility to ensure that the data they provide is used lawfully and appropriately.

The DVLA is jointly and severally liable for the misuse of your personal data.

So, you are not appealing. You are complaining and are entitled to compensation.  Send the suggested letter and see what they come back with.

Understood! Thanks for the template. I'll complain and see where it goes then, I'll also be complaining to the ICO and DVLA, as well as the client landowner.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: b789 on August 25, 2024, 08:59:10 pm
Also, SAR them. You need to see everything they hold on you.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: b789 on August 25, 2024, 08:09:54 pm
It’s not an appeal. You’ve nothing to appeal. They have obtained your personal data illegally.

Complain by email to their complaints email address. Warn them that they have breached your GDPR and if they refuse to cancel the PCN, you reserve the right to sue them for compensation under the Data Protection Act 2018 for any distress and anxiety this has caused you.

Tell them that you are making a complaint to the ICO and do so.

If they do not cancel, you report them to their ATA, the BPA.

I really don’t understand why you should have to spend time writing to these vermin and, as some have suggested, go out and find a post office so you can see them a complaint. You have nothing to appeal. Your personal data has been obtained illegally.

I suggest you email them a letter along the following lines as a pdf:

Quote
Unlawful Obtaining of Personal Data and Incorrect Issuance of Parking Charge Notice

Dear Sirs,

I am writing in relation to Parking Charge Notice (PCN) reference [PCN Reference Number], issued to my vehicle registration number XK59XXX. I bring to your attention the following points:

1. Incorrect Issuance of PCN: The vehicle captured in your ANPR image has a registration number XK69XXX and is of a completely different make and model than my vehicle. I have never owned or driven the vehicle in question, nor have I ever visited the location stated in the PCN. This clearly indicates an error on your part in reading the ANPR image.

2. Failure to Adhere to BPA Code of Practice: As a member of the British Parking Association (BPA), you are required to comply with the BPA Code of Practice, specifically section 21.5a(d), which mandates manual quality control checks of ANPR images. It is apparent that you failed to perform these checks, leading to the incorrect issuance of the PCN.

3. Unlawful Acquisition of Personal Data: Given your failure to comply with the BPA Code of Practice, you were not entitled to obtain my personal data from the DVLA under the terms of the KADOE contract. Consequently, my personal data has been obtained unlawfully.

4. Distress and Anxiety: The actions of your company have caused me significant distress and anxiety and I believe I am entitled to compensation for this.

I now demand that you:

- Immediately cancel the PCN and confirm in writing that this has been done.

- Delete all personal data you have obtained unlawfully and confirm in writing that this has been done.

- Compensate me for the distress and anxiety caused by your unlawful actions.

If I do not receive a satisfactory response from you within 14 days of the date of this letter, in addition to the formal complaint I have filed with the Information Commissioner's Office, I intend to take legal action in the County Court for damages under the Data Protection Act 2018.

I look forward to your prompt response.

Yours faithfully,

Additionally, you must inform the DVLA of Smart Parking's conduct and their misuse of your personal data. The DVLA has a responsibility to ensure that the data they provide is used lawfully and appropriately.

The DVLA is jointly and severally liable for the misuse of your personal data.

So, you are not appealing. You are complaining and are entitled to compensation.  Send the suggested letter and see what they come back with.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on August 25, 2024, 06:57:45 pm
Don’t post. Use email.

They do say they don't deal with "appeals" using their usual contact form, and don't seem to have a corporate email as far as I know.
They have an online appeals form, but that obviously doesn't provide me with a record and asks me for personal details and to agree with terms I don't agree to.

Would it be fine to just send both letters to their complaints email? I assume they wouldn't start lecturing me about company policy if I make it clear they have the wrong guy, but that might be a big ask.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: b789 on August 25, 2024, 01:18:57 pm
Don’t post. Use email.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: Dave65 on August 25, 2024, 12:38:18 pm
In Writing post send  1st class with free certificate of posting at a Post Office.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on August 24, 2024, 04:42:20 pm
You write to them separately with a complaint about yourGDPR data breach. If they don’t respond, you can send them a Letter or Claim. Give them a tease of their own medicine.

Understood, I will be sending them seperately on Monday. Thank you again for your help.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: b789 on August 24, 2024, 02:30:31 pm
You write to them separately with a complaint about yourGDPR data breach. If they don’t respond, you can send them a Letter or Claim. Give them a tease of their own medicine.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on August 24, 2024, 01:42:32 pm
You might want to write to them with your proposed resolution before leaping straight in to a Letter before County Court proceedings. The courts expect you to treat court as a last resort, not the first thing you do when you have a dispute.

Thank you again, I've toned it down massively and removed any mention of court.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: DWMB2 on August 23, 2024, 11:37:09 pm
You might want to write to them with your proposed resolution before leaping straight in to a Letter before County Court proceedings. The courts expect you to treat court as a last resort, not the first thing you do when you have a dispute.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on August 23, 2024, 11:25:17 pm
I have to say I feel like I'm out of my depth a little, but why not give it a shot? Here's the template I've written

Quote
Letter before County Court proceedings

Dear Sirs,
I have received your Parking Charge Notice (Ref: XXXXXXXXX) for vehicle registration mark XXXX XXX, in which you allege that the driver has incurred a parking charge. I note from your correspondence that you are not seeking to hold me liable as the registered keeper, under Schedule 4 of the Protection of Freedoms Act 2012 ("The Act"). You have chosen not to issue a Notice to Keeper in accordance with The Act, and it is now too late for you to do so.

There is no obligation for me to name the driver and I will not be doing so. I am therefore unable to help you further with this matter, and look forward to your confirmation that the charge has been cancelled. If you choose to decline this appeal, you must issue a POPLA code.

Furthermore, you have unlawfully obtained my personal data from The DVLA which, as a start, is in breach of your KADOE contract. I have never entered your car park and by failing to perform a manual quality control check on the ANPR photographic evidence, you are in breach of their AOS Code of Practice 22.2 which nullifies your KADOE contract. I intend to submit a record of this incident to the Information Commissioner's Office, DVLA and KADOE, as you have threatened a parking charge to the incorrect address and vehicle, failing to review that the car in your photo has the registration mark “XXXX XXX”, a BLUE FORD and you have sent your parking charge letter using the personal details unlawfully obtained for the registered keeper of the mark “XXXX XXX”, a BLACK AUDI, myself.

I am seeking £250 nominal damages and compensation under Article 12 of the UK GDPR and Section 168 of the Data Protection Act 2018 for your unlawful processing of my personal data. I am willing to accept a payment of £100 if a) the amount is settled within 14 days of the receipt of this letter and b) all of personal data and any copies are swiftly and permanently removed from your systems within the next 14 days. Please make a valid, current cheque payable to [my name] for the above amount. I intend to start County Court proceedings if this request is ignored, and you may be further liable to Court costs.

Yours,
[my name]

I'll post it out on Monday and keep you both updated. Thanks so much for all the help!
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: DWMB2 on August 23, 2024, 08:45:59 pm
Any appeal that makes mention of the fact they don't bother with PoFA will see them cancel.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: b789 on August 23, 2024, 08:10:42 pm
It is your GDPR that has been breached. You will not be paying a penny to (not so) Smart. You have a valid claim for compensation and damages for breach of GDPR.

If you’re happy to simply let Smart off the hook, your choice. Personally, I would not be so formal in my appeal and I would highlight why they cannot pursue the keeper under any assumption they were also the driver.

Quote
I am the keeper of the vehicle and I dispute your 'parking charge'. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.

As your Notice to Keeper (NtK) does not fully comply with ALL the requirements of PoFA 2012, you are unable to hold the keeper of the vehicle liable for the charge. Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving and no inference or assumptions can be drawn. Smart Parking has relied on contract law allegations of breach against the driver only.

The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your NtK can only hold the driver liable. Smart have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on August 23, 2024, 07:37:41 pm
Notice looks as expected.

Whether you decide to sue them or not is your call, it's your personal data and your time.

Out of interest, how clear are the images of the plate on the notice? I'm asking to rule out the possibility that your plates have been cloned, which is rare but does happen.

Thank you.

The plate is quite clear, I also thought my plates may have been cloned when I first saw the letter but it is not mine, it does seem to just have been read incorrectly. The "5" is especially very clear on their photo, where as on my plate it is a "6".
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: DWMB2 on August 23, 2024, 07:33:17 pm
Notice looks as expected.

Whether you decide to sue them or not is your call, it's your personal data and your time.

Out of interest, how clear are the images of the plate on the notice? I'm asking to rule out the possibility that your plates have been cloned, which is rare but does happen.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on August 23, 2024, 07:20:52 pm
You can also threaten them with a lawsuit for damages as they have illegally obtained your personal data in breach of the KADOE contract. By failing to perform a manual quality control check on the ANPR photographic evidence, they are in breach of their AOS Code of Practice which nullifies their KADOE contract.

Threaten to sue them for £250 for breaching your GDPR and tell them you’ll accept £100 if they are prepared to settle within 14 days of receipt of the letter.

Quote
Article 12 of the UK GDPR legally requires data controllers to store and process personal data accurately: clearly, any data controller issuing an invoice to you because it has wrongly recorded that you parked in breach of the alleged contract between you and the landowner (or, as in this case, an agent of the landowner) is processing your personal data unlawfully.

The precedents for claiming damages and compensation for such unlawful processing are the decisions of the Court of Appeal in Zeta Jones & Douglas v Hello! Magazine [2003] EWHC 786 and Halliday v Creation Consumer Finance Ltd (CCF) [2013] EWCA Civ 333, both being binding on all County Courts in England and Wales.  In the latter claim, Mr Halliday was awarded compensation of £750 at what the Court regarded was the lowest level of award, and although this was a claim under Section 13 of the Data Protection Act 1998, similar provisions - amended to take account of a decision by the EU Grand Chamber that the 1998 Act did not properly implement EU law into UK domestic legislation - replaced the old Section 13 provisions with Article 12 of the UK GDPR and Section 168 of the Data Protection Act 2018.

In short, you ought to give 21 days notice (the pre-action protocol only really requires 14 days but hey, you can be charitable!) to the data controller of your intention to seek (say) £100 nominal damages and compensation under Article 12 of the UK GDPR and Section 168 of the Data Protection Act 2018 for their unlawful processing of your personal data: you could say that you will not file your claim with the County Court if they confirm in writing that all references to this alleged debt have been deleted within (say) 14 days. Clearly mark your letter as a "Letter before County Court proceedings".

Anyone who is fairly confident can claim as a litigant-in-person in Part 27 proceedings in the County Court (commonly but wrongly described as "the Small Claims Court").  Each party is responsible for their own legal costs whether they win or lose and the claim for £100 can be issued online for a fee of £35 at moneyclaimonline.gov.uk which also gives useful advice if you want to have a look at what is involved.  Your claim will automatically be listed as being for a total of £135, i.e. the successful party gets their Court fees back.

Thank you also! Would adding this create any more of an issue? It would be nice to be compensated for the stress they've caused, but I don't want prolong the issue further and just be done with it.
I appreciate your message very much.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on August 23, 2024, 07:18:37 pm
As a general rule, where there is a dispute over money, corresponding in writing is generally preferable to by phone, as you have a record of exactly what has been discussed.

I would ordinarily recommend pointing the misread out but as this is Smart Parking, the quickest way is probably a template appeal. Can you show us the notice you have received?

It will almost certainly not meet the requirements to hold the registered keeper liable, and if you appeal as the registered keeper with the below, they will almost certainly cancel the charge.

Dear Sirs,

I have received your Parking Charge Notice (Ref: ________) for vehicle registration mark ____ ___, in which you allege that the driver has incurred a parking charge. I note from your correspondence that you are not seeking to hold me liable as the registered keeper, under Schedule 4 of the Protection of Freedoms Act 2012 ("The Act"). You have chosen not to issue a Notice to Keeper in accordance with The Act, and it is now too late for you to do so.

There is no obligation for me to name the driver and I will not be doing so. I am therefore unable to help you further with this matter, and look forward to your confirmation that the charge has been cancelled. If you choose to decline this appeal, you must issue a POPLA code.

Yours,

Do please show us the notice before you appeal, I don't like recommending an appeal without double checking it is appropriate. You'll need to use a third party site like Imgur to upload the notice.

You could if you wish add a line into that appeal before the main point, pointing out that it is not your vehicle and their faulty ANPR has led to them accessing your details without reasonable cause.

Thank you so much for your fast and friendly response! I have uploading the letter below- sorry it took me a moment.

(https://i.imgur.com/sLc7jKP.jpeg)

(https://i.imgur.com/5YAWiHw.jpeg)
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: b789 on August 23, 2024, 07:10:40 pm
You can also threaten them with a lawsuit for damages as they have illegally obtained your personal data in breach of the KADOE contract. By failing to perform a manual quality control check on the ANPR photographic evidence, they are in breach of their AOS Code of Practice which nullifies their KADOE contract.

Threaten to sue them for £250 for breaching your GDPR and tell them you’ll accept £100 if they are prepared to settle within 14 days of receipt of the letter.

Quote
Article 12 of the UK GDPR legally requires data controllers to store and process personal data accurately: clearly, any data controller issuing an invoice to you because it has wrongly recorded that you parked in breach of the alleged contract between you and the landowner (or, as in this case, an agent of the landowner) is processing your personal data unlawfully.

The precedents for claiming damages and compensation for such unlawful processing are the decisions of the Court of Appeal in Zeta Jones & Douglas v Hello! Magazine [2003] EWHC 786 and Halliday v Creation Consumer Finance Ltd (CCF) [2013] EWCA Civ 333, both being binding on all County Courts in England and Wales.  In the latter claim, Mr Halliday was awarded compensation of £750 at what the Court regarded was the lowest level of award, and although this was a claim under Section 13 of the Data Protection Act 1998, similar provisions - amended to take account of a decision by the EU Grand Chamber that the 1998 Act did not properly implement EU law into UK domestic legislation - replaced the old Section 13 provisions with Article 12 of the UK GDPR and Section 168 of the Data Protection Act 2018.

In short, you ought to give 21 days notice (the pre-action protocol only really requires 14 days but hey, you can be charitable!) to the data controller of your intention to seek (say) £100 nominal damages and compensation under Article 12 of the UK GDPR and Section 168 of the Data Protection Act 2018 for their unlawful processing of your personal data: you could say that you will not file your claim with the County Court if they confirm in writing that all references to this alleged debt have been deleted within (say) 14 days. Clearly mark your letter as a "Letter before County Court proceedings".

Anyone who is fairly confident can claim as a litigant-in-person in Part 27 proceedings in the County Court (commonly but wrongly described as "the Small Claims Court").  Each party is responsible for their own legal costs whether they win or lose and the claim for £100 can be issued online for a fee of £35 at moneyclaimonline.gov.uk which also gives useful advice if you want to have a look at what is involved.  Your claim will automatically be listed as being for a total of £135, i.e. the successful party gets their Court fees back.
Title: Re: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: DWMB2 on August 23, 2024, 06:04:43 pm
As a general rule, where there is a dispute over money, corresponding in writing is generally preferable to by phone, as you have a record of exactly what has been discussed.

I would ordinarily recommend pointing the misread out but as this is Smart Parking, the quickest way is probably a template appeal. Can you show us the notice you have received?

It will almost certainly not meet the requirements to hold the registered keeper liable, and if you appeal as the registered keeper with the below, they will almost certainly cancel the charge.

Dear Sirs,

I have received your Parking Charge Notice (Ref: ________) for vehicle registration mark ____ ___, in which you allege that the driver has incurred a parking charge. I note from your correspondence that you are not seeking to hold me liable as the registered keeper, under Schedule 4 of the Protection of Freedoms Act 2012 ("The Act"). You have chosen not to issue a Notice to Keeper in accordance with The Act, and it is now too late for you to do so.

There is no obligation for me to name the driver and I will not be doing so. I am therefore unable to help you further with this matter, and look forward to your confirmation that the charge has been cancelled. If you choose to decline this appeal, you must issue a POPLA code.

Yours,

Do please show us the notice before you appeal, I don't like recommending an appeal without double checking it is appropriate. You'll need to use a third party site like Imgur to upload the notice.

You could if you wish add a line into that appeal before the main point, pointing out that it is not your vehicle and their faulty ANPR has led to them accessing your details without reasonable cause.
Title: PCN addressed to me for somewhere I have never been, car in images is not mine - Smart Parking Ltd
Post by: strawberrydoll on August 23, 2024, 05:45:50 pm
I have received a PCN of £100 from "Smart Parking Ltd" addressed to me and sent to my address for overstaying at a car park in Hereford on 19/08/2024. The written reg on the paper is mine, but the images they've taken shows a reg that is not mine (but is somewhat close) and has a picture of what seems to be a Ford SUV which I do not own, mine is an Audi hatchback.

To be clear, I have never been to the car park in question, they seem to have misread the registration (mine is XK69 XXX and the reg of the image they've taken is XC59 XXX), so I thought it would be as easy as calling them and telling them they have the wrong person/car and to please stop contacting me and delete my personal details from their system, but the person on the line told me I would need to fill out their appeals form online to get them to "consider my appeal". The person on the line was extremely rude and unhelpful and tried to prod me into just paying the fine as the "easiest option for me and would be the cheaper £60 option right now" but I refused, is it best to fill out all my personal details on their online appeals form or should I send them a letter? I could use some advice, thank you in advance.