Free Traffic Legal Advice

Live cases legal advice => Private parking tickets => Topic started by: Sabab4321 on April 05, 2025, 12:15:09 pm

Title: Re: Smart Parking PCN
Post by: Sabab4321 on August 12, 2025, 05:27:49 pm
Thank you so much
Title: Re: Smart Parking PCN
Post by: b789 on August 12, 2025, 05:22:16 pm
You can safely ignore all debt recovery letters. Debt collectors are powerless to do anything except to try and persuade the low-hanging fruit on the gullible tree to pay up out of ignorance and fear. We don't need to know about useless debt recovery letters and you can shred them and use them as hamster bedding for all anyone cares.

An LoC will give you 30 days to pay, unlike the debt recovery letters which only give you 14 days.
Title: Re: Smart Parking PCN
Post by: jfollows on August 12, 2025, 05:17:04 pm
See Reply #44
Quote
Ignore everything unless it is a Letter of Claim (LoC). Keep the POPLA response as evidence.
Title: Re: Smart Parking PCN
Post by: Sabab4321 on August 12, 2025, 04:26:01 pm
Good afternoon

I just received the letter attached from debt recovery plus on behalf smart parking ltd.

I will appreciate your advice

Thank you
Title: Re: Smart Parking PCN
Post by: Sabab4321 on July 23, 2025, 12:22:29 pm
Thank you very much

I will re read thoroughly and draft a detailed email to my MP

As usual I will keep the forum updated
Title: Re: Smart Parking PCN
Post by: b789 on July 23, 2025, 12:17:20 pm
Sorry, that was my bad. The I mistakenly believed that the Parliamentary and Health Service Ombudsman could investigate concerns about POPLA’s conduct. However, I forgot that POPLA is a private adjudication service, not a public body, and therefore falls outside the Ombudsman’s jurisdiction.

POPLA was created at the request of the UK Government as part of implementing the Protection of Freedoms Act 2012 (PoFA), which outlawed clamping on private land. The Government required an independent appeals service to justify keeper liability under Schedule 4 of PoFA.

In 2012, POPLA was launched and operated by London Councils under a 3-year contract with the British Parking Association (BPA). The BPA funded the service, but London Councils managed it independently. POPLA was meant to mirror statutory tribunals like PATAS and TPT, with legal adjudicators and annual reports.

It was always funded by the private parking sector via the BPA — £27+VAT per appeal.

In 2015, The BPA transferred POPLA’s operation to Ombudsman Services Ltd, a private dispute resolution company. This marked the shift from quasi-public oversight to industry-appointed private control.

POPLA is now industry-funded, industry-appointed, and not subject to statutory oversight. The BPA claims POPLA is “independent”, but it appoints the operator, pays for the service and controls the Code of Practice.

The so-called “Independent Board” overseeing POPLA is appointed by the BPA, with no public transparency or accountability. This system is structurally rigged:

• POPLA pretends to be independent, but is funded and appointed by the very industry it’s meant to regulate.
• The BPA is a trade body, not a regulator — its “oversight” is performative.
• The ICO and DVLA routinely sidestep accountability, especially when it comes to systemic failures rather than isolated data breaches.

And litigation, while winnable, puts the burden on the defendant to clean up a mess that should never have existed.

This isn’t just about one flawed decision — it’s about a deliberately opaque, self-serving framework designed to:

• Give the illusion of fairness
• Funnel motorists into a dead-end process
• Shield operators from real scrutiny

POPLA was created to satisfy the Government’s need for legitimacy under PoFA — but once the public-sector oversight ended, it became a closed loop of industry self-interest.

You could try explaining this to your MP, to raise the structural issue in Parliament, push for statutory oversight of private adjudication services and demand transparency and accountability in unregulated private parking enforcement.

For what it is worth, you could ask them to question the current government as to when they are going to implement the Parking (Code of Practice) Act 2019? In 2019 The Parking (Code of Practice) Act 2019 received Royal Assent. It placed a legal duty on the Secretary of State to create a statutory Code of Practice for private parking operators.

In February 2022 the Government finally published the draft Code of Practice, nearly three years after the Act was passed. This delay was due to consultations and development work with the British Standards Institution (BSI).

In June 2022 the draft Code was withdrawn following legal challenges from parking firms and their trade bodies, the BPA and IPC, who objected to lower charge caps and the ban on debt recovery fees.

In 2023 and 2024 the Government conducted further impact assessments and calls for evidence to address industry concerns. No statutory Code is in force during this time.

However, whilst the Act was introduced to fix exactly the kind of systemic failure we're dealing with here, its implementation has been delayed, diluted, and derailed by the very parking industry through their powerful lobbying. So, whilst the Act was passed in 2019, the Code wasn’t even drafted until 2022.

The parking industry successfully lobbied to block its implementation. As a result, the sector remains self-regulated, with no statutory oversight or binding standards.

This month a new consultation was launched to revive the Code. It closes on 5 September 2025. Please have your say here: Open consultation-​Private parking code of practice​ (https://www.gov.uk/government/consultations/private-parking-code-of-practice)

Title: Re: Smart Parking PCN
Post by: Sabab4321 on July 23, 2025, 10:56:12 am
Good morning all
I sent an email to my MP and the BPA.

BPA acknowledged receiving my email while my MP replied with the email below

Thank you for your email to Stephanie Peacock MP.

 

You would need to submit the complaint to the Parliamentary & Health Service Ombudsman (PHSO) yourself and Stephanie would sign your completed complaint form, if this is something that PHSO could look into.

 

Further details on which complaints the ombudsman can deal with and how to make a complaint can be found here: https://www.ombudsman.org.uk/making-complaint

 

If you require any further information please let us know.


What do you advise

Thank you
Title: Re: Smart Parking PCN
Post by: Sabab4321 on July 22, 2025, 02:48:41 pm
Thank you so much I will write to my MP immediately and keep the house updated
Title: Re: Smart Parking PCN
Post by: b789 on July 22, 2025, 02:46:42 pm
You can also send the following to the BPA, as POPLA operate under BPA oversight, even though (not so) Smart Parking is no longer a BPA member.

Quote
Subject: Notification of POPLA Statutory Breach – Referral to Parliamentary Ombudsman

Dear BPA Complaints Team,

I am writing to formally note a serious adjudication failure by POPLA in relation to appeal reference [insert POPLA reference number].

POPLA has admitted that the Notice to Keeper issued by Smart Parking was delivered outside the 14-day statutory period required under Paragraph 9(5) of Schedule 4 of the Protection of Freedoms Act 2012. Despite this, the assessor upheld the charge, and the complaints handler refused to correct the decision—citing internal process limitations.

This constitutes a clear breach of statutory requirements and a failure of administrative justice. As POPLA operates under BPA oversight, I am placing this on record.

I am referring the matter to my MP for submission to the Parliamentary and Health Service Ombudsman for investigation. No further correspondence is expected from the BPA unless you wish to confirm receipt.

Yours sincerely,

[Your Full Name]

PCN No.: [PCN number]
POPLA Ref. No.: [POPLA reference number]
Title: Re: Smart Parking PCN
Post by: b789 on July 22, 2025, 02:41:17 pm
Ignore everything unless it is a Letter of Claim (LoC). Keep the POPLA response as evidence.

I strongly advise you to contact your MP and show them the failures by POPLA and their weasel excuses. The response is a false dichotomy. A misapplication of law is a procedural error when it results in a decision contrary to statute. POPLA’s refusal to revisit the decision despite acknowledging the breach undermines its claim to impartiality and legal competence.

Find your MP's email (https://members.parliament.uk/findyourmp) and send the following:

Quote
Subject: Request for Referral to Parliamentary Ombudsman – POPLA’s Refusal to Correct Statutory Breach

Dear [MP’s Name],

I am writing to request your assistance in referring a matter to the Parliamentary and Health Service Ombudsman concerning the Parking on Private Land Appeals (POPLA) service, which operates under the oversight of the British Parking Association (BPA).

POPLA recently adjudicated an appeal I submitted regarding a parking charge issued by Smart Parking. The appeal turned on a clear statutory requirement under Paragraph 9(5) of Schedule 4 of the Protection of Freedoms Act 2012 (PoFA), which mandates that a Notice to Keeper (NTK) must be delivered within 14 days of the parking event to establish keeper liability.

The facts were not in dispute:

• The parking event occurred on Sunday, 23 March 2025.
• Day 1 of the relevant period was Monday, 24 March 2025.
• The NTK was posted on Thursday, 3 April 2025.
• Presumed delivery (two working days later) was Monday, 7 April 2025—Day 15, outside the statutory limit.

Despite this, the POPLA assessor upheld the charge, wrongly concluding that PoFA had been complied with. I submitted a formal complaint, and POPLA’s own complaints handler admitted that the NTK was delivered outside the relevant period and therefore did not meet the statutory requirements. However, they refused to overturn the decision, claiming that the error was a “misassessment” rather than a “procedural error”, and that POPLA is a “one-stage process” with no mechanism for correction.

This is a textbook case of administrative injustice:

• A statutory breach was acknowledged.
• The decision was not corrected.
• The complaints process was closed with no recourse.
• The adjudication body continues to uphold legally defective decisions.

POPLA presents itself as an independent appeals service, yet it refuses to apply or enforce statutory law correctly. This undermines public trust and leaves individuals with no remedy when faced with unlawful enforcement.

I am therefore requesting that you refer this matter to the Parliamentary Ombudsman for investigation. I am happy to provide all supporting documentation, including the original appeal, the complaint, and POPLA’s written admission of error.

Thank you for your time and assistance.

Yours sincerely,

[Your Full Name]

[Your Address]
[Your Email]
[Your Phone Number]
Title: Re: Smart Parking PCN
Post by: Sabab4321 on July 22, 2025, 12:52:55 pm
Thank you so much

I will keep the house updated
Title: Re: Smart Parking PCN
Post by: DWMB2 on July 22, 2025, 12:47:32 pm
How failing to count up to 2 working days is not a procedural error is beyond me, but there we go.

In terms of what to do next, keep hold of that response, and wait to see what Smart Parking do next. Come back here if you receive a Letter of Claim from a legal firm representing them. You'll have a very strong defence.
Title: Re: Smart Parking PCN
Post by: jfollows on July 22, 2025, 12:22:15 pm
What a complete joke! Thank you for sharing.

“Apologies, your honour, but I did consider the concept of speed limits properly, but I made a mis-assessment of their application to me, so I can’t be found guilty of speeding.”
Title: Re: Smart Parking PCN
Post by: Sabab4321 on July 22, 2025, 12:11:18 pm
Good morning all

I just received an email from POPLA and below is there response to my appeal

"Thank you for your email, which was passed to me by the POPLA team as I am responsible for responding to complaints.
 
I note from your correspondence that you are unhappy with the decision reached by the assessor in your appeal against Smart Parking - EW.
 
POPLA is an impartial and independent appeals service and we do not act either for the parking operator or the appellant. It is important to explain that POPLA is a one-stage process and we would not change a decision because either party disputes the assessor’s decision. However, we may consider an appeal if there has been a procedural error, for example – if we failed to allow a motorist to comment on a parking operator’s evidence pack.
 
My role as a complaints handler is not to determine if the decision is correct, but to establish if the assessor has failed to follow the correct POPLA process and identify whether a procedural error has occurred.
 
I have summarised your complaint below and will respond accordingly.
 
You are writing to express my utter outrage and disbelief at the appalling standard of adjudication demonstrated by the assessor during the handling of your appeal. You say the handling of a breach under Schedule 4 of the Protection of Freedoms Act (PoFA) 2012 was incoherent. You say the assessor concluded PoFA202 had been met, yet the assessor’s own timeline confirms the PCN was not issued to be delivered within the relevant 14-day period. You say you wish for a review of the decision, an apology, an explanation of the action taken and a commitment to retraining on the statutory requirements of PoFA 2012.
 
Having reviewed your complaint, I have looked at the case including the notice to keeper issued.

As can be seen the date of the event is 23 March 2025.
 
Day 1 of the relevant period is 24 March 2025.
Day 14 of the relevant period is 6 April 2025 and this day fell on a Sunday.
To ensure the PCN was delivered within the 14 day relevant period, the PCN would need to be posted by 2 April 2025 which was a Wednesday.
As the PCN was posted on 3 April 2025  (a Thursday), this would have been considered to be delivered on the second working day after posting, which would have been Monday 7 April 2025. This was day 15 and outside the relevant period.
 You are correct that the assessor has not correctly considered PoFA 2012 requirements and for this I do apologise as the notice did not meet the requirements. With that being said, she has considered PoFA 2012, albeit incorrectly. She has not made a procedural error she has made a mis assessment, and due to this it would not result in us revisiting the decision.
 
I will uphold your complaint and provide the relevant feedback for coaching and decision-making improvement purposes in the application of PoFA 2012.
 
As POPLA is a one-stage process, there is no opportunity for you to appeal the decision. In closing, I am sorry that your experience of using our service has not been positive. We have reached the end of our process, and my response now concludes our complaints procedure. I trust you will appreciate that there will be no further review of your complaint, and it will not be appropriate for us to respond to any further correspondence on this matter.
 
Yours sincerely,
 
Amy Smith
POPLA Complaints Team"


That admitted making a mistake but won't change their decision.

Please what can I do next.

Thank you
Title: Re: Smart Parking PCN
Post by: Sabab4321 on July 07, 2025, 11:19:39 am
Good morning all

I received the email below from POPLA

"Hi,

Thank you for your contact.

We are sorry that you are unhappy with our service and would like to reassure you that we take all complaints seriously.

The information has been escalated to our complaints team and the details will be reviewed.

You should receive a response within 21 days depending on the complexity of the information provided.

Kind Regards,

POPLA Team"

I will keep the house updated once I receive further response from them.

Thank you
Title: Re: Smart Parking PCN
Post by: Sabab4321 on July 02, 2025, 03:01:10 pm
Thank you so much

I will send the email and keep you posted
Title: Re: Smart Parking PCN
Post by: b789 on July 02, 2025, 02:27:34 pm
I would be incandescent about this blatant example of utter incompetence by a supposedly trained POPLA assessor. Whilst POPLA will never change the decision, even when they make a clear mistake, you should make a formal complaint about it which can later be used for any defence should it ever be needed.

Try this email (and always CC yourself) info@popla.co.uk and also CC enquiry@flexibleresolutionservices.co.uk

Quote
Subject: Formal Complaint: Gross Misapplication of PoFA by Assessor Michaela Sutton [POPLA ref number]

Dear POPLA Management,

I am writing to express my utter outrage and disbelief at the appalling standard of adjudication demonstrated by your assessor, Michaela Sutton, in a recent appeal decision. Her handling of a clear-cut statutory breach under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA) was not merely incorrect—it was legally incoherent, procedurally negligent, and frankly, an insult to the intelligence of anyone with even a cursory understanding of the law.

The facts were not in dispute:

• The parking event occurred on Sunday, 23 March 2025.
• Day 1 of the "relevant period" under PoFA began on Monday, 24 March 2025.
• The final day for delivery of the NTK within the "relevant period" was Sunday, 6 April 2025.
• The NTK was issued on Thursday, 3 April 2025, and therefore, presumed delivered was two working days later on Monday, 7 April 2025Day 15 which is NOT within the "relevant period".

Despite this, Michaela Sutton concluded that the operator had complied with PoFA and was entitled to pursue the keeper. This is a flagrant misapplication of Paragraph 9(5) of Schedule 4, which requires delivery (date "given") of the NTK within 14 days—not issuance, not posting, but actual delivery. The assessor’s own timeline confirms that this did not occur.

This is not a grey area. It is not a matter of interpretation. It is a statutory deadline, and it was missed. For an assessor to acknowledge this and still uphold the charge is not just incompetent—it is derelict.

I demand the following:

• A full and immediate review of this decision by a legally qualified adjudicator.
• A formal apology for the distress and wasted time caused by this egregious error.
•  clear explanation of what disciplinary or remedial action will be taken regarding Michaela Sutton’s conduct and competence.
• A commitment that assessors will be retrained on the basic statutory requirements of PoFA, which they are clearly failing to apply.

If POPLA wishes to retain even a shred of credibility as an independent appeals body, it must stop enabling this level of incompetence. Michaela Sutton’s decision is not just wrong—it is indefensible. And if this is the standard you accept, then the entire POPLA process is a sham.

I expect a substantive response, not a generic brush-off.

Yours faithfully,

[your name]
Title: Re: Smart Parking PCN
Post by: jfollows on July 02, 2025, 01:43:54 pm
According to Michaela Sutton
Day 11 is 3 April
Day 13 is 4 April
I think there’s a problem here!

POPLA has made a big error in its calculations, hasn’t it?
Title: Re: Smart Parking PCN
Post by: Sabab4321 on July 02, 2025, 01:33:59 pm
Good afternoon everyone

I just received an update from POPLA, a copy of the unsuccessful appeal is attached.

Your advice on the next step will be appreciated.

Thank you

[attachment deleted by admin]
Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 29, 2025, 04:22:07 pm
Ok I will update the house once I hear from POPLA

Thank you
Title: Re: Smart Parking PCN
Post by: DWMB2 on April 29, 2025, 04:04:47 pm
Half of me would be minded to escalate to the BPA for failure to properly acknowledge your complaint.

The other half of me (which I'm leaning towards) would be minded to wait for POPLA to make a decision. It'll be fun to see how they respond if (as they should) POPLA confirm exactly what you have put to them in your appeal... This also avoids the possibility of the BPA fobbing you off with the same "wait and see what POPLA say" argument.

Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 29, 2025, 04:00:31 pm

Good afternoon


I just received this email from smart parking.

Just keeping the house updated

Thank you


Good Afternoon,

Thank you for your email.
We note the comments made and we would like to make you aware that as you have chosen to appeal further to POPLA, we would advise for you to await an outcome to your POPLA appeal.
We are unable to intervene at this stage.
You will receive an email confirmation when you are able to view this information.


Kind regards,

 

Smart Parking Limited
Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 25, 2025, 05:32:33 pm
I just did as advised

I will surely keep you posted
Title: Re: Smart Parking PCN
Post by: DWMB2 on April 25, 2025, 05:23:17 pm
Be prepared for a wait, POPLA often take over 8 weeks to assess cases.

When you hear back, let us know the outcome!
Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 25, 2025, 05:20:13 pm
Thank you

I will do as advised

Title: Re: Smart Parking PCN
Post by: DWMB2 on April 25, 2025, 05:06:13 pm
Quote
In the Appellants appeal to POPLA the appellant states “Find attached the full appeal document”
;D Just in case you needed evidence that they don't even bother to properly read POPLA appeals before submitting responses.
Title: Re: Smart Parking PCN
Post by: b789 on April 25, 2025, 05:01:19 pm
Just copy and paste this wordy rebuttal into the POPLA webform as your response:

Quote
Rebuttal to Smart Parking Ltd Evidence Pack

The evidence pack provided by Smart Parking Ltd is not relevant to the key point in this appeal. The only matter the assessor needs to consider before looking at any other material is whether Smart Parking Ltd has fully complied with all the requirements of the Protection of Freedoms Act 2012 (PoFA) in order to transfer liability for the parking charge from the driver to the keeper.

As is the keeper's legal right, they have declined to identify the driver. Therefore, unless Smart Parking Ltd can show that their Notice to Keeper was fully compliant with PoFA, the keeper cannot be held liable.

Under paragraph 9(5) of Schedule 4 of PoFA, a Notice to Keeper must be delivered (given) within 14 days beginning with the day after the date of the alleged parking event. The following dates apply in this case:

- The date of the alleged parking event was Sunday 23 March 2025.
- The next day, from which the 14-day period starts, was Monday 24 March 2025.
- The final day of the 14-day period was Sunday 6 April 2025.

Smart Parking Ltd issued the Notice to Keeper on Thursday 3 April 2025. A notice sent by post is considered to be delivered two working days later, under paragraph 9(6) of PoFA. Counting two working days from Thursday 3 April (which excludes Saturday 5 April and Sunday 6 April), the presumed date of delivery is Monday 7 April 2025.

This means the Notice to Keeper was deemed delivered (given) 15 days after the parking event. That is one day outside the 14-day limit (relevant period) required by law. Therefore, Smart Parking Ltd cannot rely on PoFA to transfer liability to the keeper.

Smart Parking Ltd has submitted an evidence pack, but none of it deals with this key issue. They have provided photographs of signage and general terms and conditions, but that is not relevant here. If the operator wishes to hold the keeper liable, they must comply with PoFA. If they do not, they must pursue the driver. As the keeper has not been identified as the driver, and as PoFA cannot apply due to late delivery of the Notice to Keeper, the appeal must be allowed.

To summarise:

- The Notice to Keeper was delivered (given) too late to comply with PoFA.
- The keeper has not been identified as the driver.
- Therefore, the operator cannot hold the keeper liable.

Accordingly, Smart Parking Ltd has no lawful basis to recover the charge from the keeper, and the appeal should be upheld.
Title: Re: Smart Parking PCN
Post by: jfollows on April 25, 2025, 04:52:31 pm
Yes, I can read it.
You left your registration in clear text in one place, although I’m not sure it really matters.
Smart still going on about sending the notice in time, which is just not true.
Exactly as I said in Reply #9 above I think ……….
Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 25, 2025, 04:35:43 pm
I have edited the access

Kindly recheck now please

Thank you
Title: Re: Smart Parking PCN
Post by: DWMB2 on April 25, 2025, 04:28:33 pm
Cheers, but you need to make it public access - at the moment it's restricted.
Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 25, 2025, 04:25:37 pm
Good evening

I have downloaded the evidences and redacted

Here is the link to 

https://drive.google.com/drive/folders/1HPbm5QL7GRHEt0oih9iZH9xf7DLTqwcN?usp=drive_link

Thank you
Title: Re: Smart Parking PCN
Post by: DWMB2 on April 25, 2025, 01:16:13 pm
That didn't take them long!

If you log onto the POPLA portal, a copy of their evidence pack should be available to download. Download it, then host a copy of it on a file-hosting platform such as DropBox or Google Drive, and share the link with us. Make sure to redact any personal details, but leave on relevant details like dates and times.
Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 25, 2025, 01:00:06 pm
Good day

I just received the following from POPLA

Your parking charge appeal against Smart Parking - EW.

Smart Parking - EW has now uploaded its evidence to your appeal. This will be available for you to view by clicking here

Please note: some evidence may not show immediately, if it is not currently available on your account please check back later before contacting us.

You have seven days from the date of this correspondence to provide comments on the evidence uploaded by Smart Parking - EW.

Please note that these comments must relate to the grounds of appeal you submitted when first lodging your appeal with POPLA, we do not accept new grounds of appeal or evidence at this stage

Any comments received after the period of seven days has ended will not be considered and we will progress your appeal for assessment. Therefore, if you have any issues with the evidence uploaded by Smart Parking - EW such as being unable to view it online, please contact POPLA immediately via phone - 0330 1596 126, or email - info@popla.co.uk, so that we can look to rectify this as soon as possible.

After this period has ended, we will aim to issue our decision as quickly as possible. The decision we reach is final and binding. When the decision is reached there is no further option for appeal.

Yours sincerely

POPLA Team
Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 23, 2025, 05:40:12 pm
Good day. I have completed the POPLA appeal and sent an email to SmartParking attaching the correspondence to it too.

Thank you
Title: Re: Smart Parking PCN
Post by: DWMB2 on April 23, 2025, 01:26:15 pm
Please confirm when you have successfully submitted your POPLA appeal.

A suggested wording for your complaint is below. It should be sent to complaints@smartparking.com (complaints@smartparking.com). I would attach to this a copy of the correspondence you have shared with us today.

They will probably fob you off in their response, but the goal here is to ultimately escalate the complaint to the British Parking Association.

Quote
Subject: Formal Complaint, PCN #[REFERENCE]

Dear Sirs,

For the avoidance of doubt, this is not an appeal against a parking charge (one has been submitted separately) but is instead a formal complaint regarding your handling of my case.

I am writing to make a formal complaint about your correspondence in respect of PCN #[REFERENCE], which amounts to a breach of the Private Parking Sector Single Code of Practice (PPSSCoP) and, by virtue of this, your KADOE contract with the DVLA. 

Following receipt of your PCN, I appealed as the registered keeper, pointing out that due to your failure to deliver a Notice to Keeper within the relevant period of 14 days as required by Schedule 4 of the Protection of Freedoms Act (PoFA), you are unable to recover the charge from me as the keeper. You responded with a letter dated [DATE], which is attached, falsely claiming that the notice was issued under PoFA. In the letter you claim:

"the Parking Charge was promptly issued within the 14 days required under POFA 2012"

As you will know, paragraph 9(4) of PoFA is clear that the notice must be given (that is, delivered), within 14 days, not merely issued within 14 days.

By falsely claiming otherwise, you are in breach of the PPSSCoP and the KADOE contract for the following reasons:

1. Breach of the PPSSCoP
Section 8.1.1 of the PPSSCoP states:

8.1.1 The parking operator must not serve a notice or include material on its website which in its design and/or language:
d) state the keeper is liable under the Protection of Freedoms Act 2012 where they cannot be held liable.

In the appeal, I explained that Smart Parking had failed to serve a notice compliant with the requirements of PoFA, having given the notice outside of the relevant period of 14 days. You then responded on [DATE] with the attached letter, claiming the ability to recover the charges from me under PoFA. This is a deliberate misrepresentation, and a breach of 8.1.1 of the PPSSCoP.

As per Annex H of the PPSSCoP, this constitutes at least a Level 1 sanction for non-conformance.

2. Breach of the KADOE Contract
Clause C1.1 of your KADOE Contract with DVLA states:

The Customer shall ensure that signage, terms and conditions of service for parking customers and correspondence with data subjects comply with the Law and with the requirements of the ATA’s Code of Practice or Conduct.

By knowingly and falsely claiming compliance with PoFA, you have failed to comply with the terms of your KADOE contract, bringing into question your suitability to have access to sensitive registered keeper data.

As a result of these serious failings you should:
  • Confirm that the parking charge has been cancelled and that no further action will be taken
  • Explain why your correspondence falsely claims the ability to recover charges under PoFA when you are, or ought to be, fully aware this is not true
  • Issue a formal apology

I expect a response to my complaint within 14 days. Following your response, I reserve the right to escalate this matter to the British Parking Association, and the DVLA.

Yours etc...
Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 23, 2025, 01:21:49 pm
Thank you so much for the redaction

I will keep the house posted
Title: Re: Smart Parking PCN
Post by: DWMB2 on April 23, 2025, 01:17:59 pm
Your next steps are:

Your POPLA appeal can be worded as below. For your reason for appeal on the online portal, simply choose 'Other'. If it asks for your relationship to the vehicle, simply select 'Registered Keeper'. Create your appeal as a PDF document, and attach it to the portal under supporting evidence. In the actual appeal box, just put something along the lines of "Find attached the full appeal document".

Quote
POPLA Appeal
[NAME] (Registered Keeper) (Appellant)
-Vs-
Smart Parking (Operator)
Vehicle Registration Mark:[VRM]
 POPLA Reference Code: [POPLA REFERENCE]
 Parking Charge Notice Number: [PCN REFERENCE]

Case Overview:
I, [NAME], the registered keeper (“I”/“the Appellant”) of the above vehicle (VRM: _______), received a parking charge notice via post from Smart Parking (“the Operator”), which purported to be a Notice to Keeper. I appealed to the Operator, who acknowledged and subsequently rejected my appeal. It is my position that as the registered keeper of the vehicle I have no liability for the parking charge, and that my appeal should therefore be upheld. My appeal is on the following grounds:

1. No keeper liability: the Parking Charge Notice does not comply with the requirements of Schedule 4 of the Protection of Freedoms Act (“PoFA”/“the Act”):
The operator does not not know the identity of the driver and is therefore seeking to recover the charge from me, the registered keeper of the vehicle. In order to be able to recover any unpaid charges from me as the registered keeper, the operator must comply with the requirements outlined in Schedule 4 of the Protection of Freedoms Act 2012. Smart Parking have failed to do so.

They have failed to deliver the notice to keeper within the relevant period of 14 days beginning with the day after that on which the specified period of parking ended, as specified by 9(5) of the Act.

Date of Parking: 23/03/2025
Date of PCN issue: 03/04/2025
Date of presumed service (2 working days after issue, as per 9(6) of the Act): 07/04/2025
Elapsed time period: 15 days

As Smart Parking are unable to rely on the provisions of PoFA to hold me liable as the keeper, and as there is no evidence as to who was driving, I cannot be held liable for the charge, and my appeal should be upheld.

2. Breach of the PPSSCoP - Misrepresentation

The parking charge notice issued by Smart Parking claimed that they would be able to hold me liable as the registered keeper, under the provisions of Schedule 4 of the Protection of Freedoms Act, despite the fact they were aware (or ought to have been aware) that they had not complied with the relevant conditions to do so. Following my appeal pointing this out, Smart Parking doubled down on their stance, claiming that the charge was 'issued within the 14 days required under POFA 2012', despite the fact that PoFA requires the notice to be given (that is, delivered) within 14 days, not merely issued within 14 days.

This repeated misrepresentation is in direct contravention of section 8.1.1 (d) of the Private Parking Sector Single Code of Practice, which states:

8.1.1 The parking operator must not serve a notice or include material on its website which in its design and/or language:
a) implies or would cause the recipient to infer statutory authority where none
exists;
b) deliberately resembles a public authority civil enforcement penalty charge
notice;
c) uses prohibited terminology as set out in Annex E; or
d) state the keeper is liable under the Protection of Freedoms Act 2012 where they cannot be held liable.

For the reasons outlined above, it is clear that as the registered keeper I have no liability for this charge, and I request that my appeal is upheld.
Title: Re: Smart Parking PCN
Post by: DWMB2 on April 23, 2025, 01:04:02 pm
Here's a version where your full name and home address aren't able to be copied and pasted from behind your redactions:

(https://i.imgur.com/NCGqvVT.png)
(https://i.imgur.com/KBTtBHD.png)
Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 23, 2025, 12:56:23 pm
Good day

I just received a letter from smart denying my appeal.

Attached is a copy of the letter
Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 09, 2025, 01:22:12 pm
Ok thank you
Title: Re: Smart Parking PCN
Post by: b789 on April 09, 2025, 12:48:00 pm
Just email it to complaints@smartparking.com and CC yourself.
Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 09, 2025, 12:27:18 pm
I tried to appeal via mobile but the error message attached shows a number to call

Kindly advise on the next step

Thank you

[attachment deleted by admin]
Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 09, 2025, 12:14:30 pm
Good day I tried to appeal this PCN via the website but anytime I enter the vehicle registration number, I keep getting the error attached.

I didn't want to send an email as instructed but telling the house to know if it is the right thing to do

Any advice will be appreciated.

Thank you

[attachment deleted by admin]
Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 05, 2025, 03:13:42 pm
Noted

I will keep you posted

Thank you
Title: Re: Smart Parking PCN
Post by: jfollows on April 05, 2025, 02:55:17 pm
Remember, Smart will reject your appeal “having considered your appeal in detail” and incorrectly state that they comply with PoFA because they posted the notice within 14 days, but will provide a POPLA code, which will need to be used but the basis of the appeal is already here, and POPLA will cancel.

Smart does this because there’s little downside to rejecting valid appeals because plenty of people pay up at that point. They only care about getting your money, and if this requires them to tell untruths in order to get it, they don’t care.
Title: Re: Smart Parking PCN
Post by: DWMB2 on April 05, 2025, 01:22:40 pm
Either of the above will do but the important thing is not to appeal too early!
Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 05, 2025, 01:15:03 pm
Ok thank you so much

I will do as instructed
Title: Re: Smart Parking PCN
Post by: b789 on April 05, 2025, 01:14:06 pm
The Notice to Keeper (NtK) has not been "given" (Delivered) within the PoFA 9(4)(b) relevant period of 14 days. Irrespective of anything else on the NtK, they cannot hold the Keeper liable and they have no idea who the driver is unless the Keeper blabs it inadvertently or otherwise.

Easy one to deal with… as long as the unknown drivers identity is not revealed. There is no legal obligation on the known keeper (the recipient of the Notice to Keeper (NtK)) to reveal the identity of the unknown driver and no inference or assumptions can be made.

The NtK is not compliant with all the requirements of PoFA which means that if the unknown driver is not identified, they cannot transfer liability for the charge from the unknown driver to the known keeper.

Use the following as your appeal. No need to embellish or remove anything from it:

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 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: Smart Parking PCN
Post by: DWMB2 on April 05, 2025, 01:12:21 pm
So they are wrongly claiming the ability to hold you liable as the keeper. You should in due course complain to them about that, which we can advise on.

In the meantime, the first thing to do is appeal. Don't do this until Tuesday 8th April.

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 claim to be able to hold me liable under Schedule 4 of the Protection of Freedoms Act 2012 ("The Act"), but this is not true. You have failed to deliver the notice within the relevant period of 14 days as required by paragraph 9(4) of the Act.

Date of parking: 23/03/25
Date of issue: 03/04/25
Date of presumed service under 9(6) of the Act: 07/04/25
Days elapsed: 15 days

I am appealing as the registered keeper. 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,


If appealing online, be careful there are no drop down/tick boxes that cause you to identify who was driving, and keep a close eye on your spam folder for their response. If they do not respond within 28 days, chase them.

But as above, not until 8th April!
Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 05, 2025, 12:59:49 pm
Here is the back of the letter

Thank you

[attachment deleted by admin]
Title: Re: Smart Parking PCN
Post by: DWMB2 on April 05, 2025, 12:57:50 pm
Can we please see the back of the notice?

As noted above there will be an appeal based on the dates, but for obvious reasons you'll need to wait until after 7th April to do so
Title: Re: Smart Parking PCN
Post by: Sabab4321 on April 05, 2025, 12:57:30 pm
What do you advise since the 14 days expired before getting the letter
Title: Re: Smart Parking PCN
Post by: jfollows on April 05, 2025, 12:46:21 pm
Contravention date: 23 March
Issue date: 3 April
Presumed delivery date: 7 April
14 days after contravention date: 6 April

Check my calculations

Smart will say that it was posted in time, but that’s because they’re stupid or deliberately misrepresent the requirements of PoFA in which the liability can only be transferred from the unknown driver to the known keeper if served on the latter in time. It seems that this notice wasn’t.
Title: Smart Parking PCN
Post by: Sabab4321 on April 05, 2025, 12:15:09 pm
The driver dropped a family at this residential house on the said date and was on a call for around 4 mins before driving away from the parking spot.

The driver never stepped out of the car nor see the parking warning

Attached is the PCN

Kindly assist with this case

Thank you

[attachment deleted by admin]