Free Traffic Legal Advice

Live cases legal advice => Private parking tickets => Topic started by: bee0821 on May 14, 2025, 01:41:57 pm

Title: Re: Milton Country Park PCN
Post by: bee0821 on August 13, 2025, 03:54:37 pm
Hello

Just wanted to say we've just heard the appeal was allowed. The text of the decision is as follows:

I am allowing this appeal, with my reasoning outlined below: The burden of proof lies with the operator to prove the PCN was issued correctly. The operator issued the PCN based on a lack of payment. The appellant raises the following which has persuaded me to allow then appeal: They say they have not identified the driver and nor is there any legal requirement to do so. They say the operator has failed to identify who was driving at the time and they cannot be held responsible for the actions of an unknown third party In this case the driver has not been identified and therefore, the operator is pursuing the appellant as the hirer for the PCN. The PCN was initially issued to **** and it advised the operator that **** had leased the vehicle. After sending the PCN to **** a representative of the company advised that the appellant **** was the driver of the vehicle. The operator issued a notice to driver to the appellant to pursue their liability as the driver. The appellant responded to the PCN advising they will not be naming the driver on 22 May 2025. The operator emailed the appellant on 9 June 2025 asking for the driver’s details and requesting them under PoFA 2012 and should they not be provided will be pursuing them as the registered keeper. However, both PCNs sent to the appellant were notice to driver’s only, therefore they cannot pursue any other party than the driver. In this case the driver was not identified, as such they cannot pursue any other party than the driver, without using PoFA 2012 and this then leads the PCN to be nul and void. POPLA’s role is to assess if the operator has issued the PCN in accordance with the conditions of the contract. As the operator has not met the strict requirements of PoFA 2012, I am not satisfied that the operator has issued the PCN correctly, and accordingly the appeal is allowed. The appellant has raised other grounds in their appeal, but as I am allowing the appeal, it is not necessary for me to address these.

Thank you very much again for all of your help - I really appreciate it!
Title: Re: Milton Country Park PCN
Post by: bee0821 on July 07, 2025, 09:49:23 am
Thank you very much (again) - I will do as you suggest!
Title: Re: Milton Country Park PCN
Post by: b789 on July 04, 2025, 11:09:59 am
You can just copy and paste the following into the POPLA response webform:

Quote
ParkingEye has failed to address the most fundamental issue: the Protection of Freedoms Act 2012 (PoFA) does not apply at Milton Country Park because the land is not “relevant land”.

Milton Country Park is subject to statutory control under byelaws made under section 41 of the Countryside Act 1968, confirmed by the Secretary of State. Land governed by statutory byelaws is specifically excluded from being “relevant land” under paragraph 3 of Schedule 4 of PoFA. That alone means ParkingEye cannot rely on PoFA to pursue anyone other than the driver.

Since the driver has not been identified, the charge must fail.

Even if the land had been relevant land (which it isn’t), ParkingEye has still failed to comply with the legal requirements to hold a Hirer liable under PoFA. The relevant sections are paragraphs 13 and 14 of Schedule 4. In order to transfer liability to the Hirer, ParkingEye was required to provide copies of the following documents with the Notice to Hirer:

- A statement signed by or on behalf of the vehicle-hire firm to the effect that at the material time the vehicle was hired to a named person under a hire agreement;
- A copy of the hire agreement;
- A copy of a statement of liability signed by the hirer under that hire agreement;
- A copy of the original Notice to Keeper.

They failed to include any of these documents. That is fatal to their case.

Instead, they keep referring to paragraph 9 of Schedule 4, which relates to Notices to Keeper — not Notices to Hirer. This is irrelevant, misleading, and legally wrong. You cannot rely on paragraph 9 to create liability for a Hirer.

To summarise:

- PoFA does not apply because the land is not relevant land.
- Even if it did, ParkingEye has not complied with paragraph 14.
- The driver has not been identified.
- There is no lawful basis to pursue me.

This appeal must be allowed.
Title: Re: Milton Country Park PCN
Post by: jfollows on July 04, 2025, 09:53:55 am
They’re dissimulating, they may have complied with Paragraph 9 of Schedule 4 of PoFA or whatever, but they failed to comply with Paragraph 13 so they can’t transfer liability, you just need to spell this out for the assessor.
Plus, from memory, they deliberately confuse ‘private’ and ‘council’ land, private land can still be subject to bylaws.
That’s at least two points anyway.
Title: Re: Milton Country Park PCN
Post by: bee0821 on July 04, 2025, 09:44:05 am
Sorry, like an idiot I forgot to actually post the evidence from PE:

Case History
31/03/2025   Date of event
System check/manual check identified breach of terms and conditions, prior to DVLA request
02/04/2025   Request queued to DVLA for keeper details
03/04/2025   DVLA response received - Success (Legislation Used: POFA_POPLA - Issued To: Keeper)
03/04/2025   Parking Charge Letter Issued - Letter1 - Ltr01-217
10/04/2025   Parking Charge Letter Issued - Letter1 - Ltr01-217
19/04/2025   Parking Charge Letter Issued - Letter2 - Ltr02-217
10/05/2025   Parking Charge Letter Issued - Letter1 - Ltr01-217
19/05/2025   Parking Charge Letter Issued - Letter2 - Ltr02-217
22/05/2025   Letter Issued - Website Appeal Response
22/05/2025   Website Appeal received for this case and is queued for processing.
09/06/2025   Letter Issued - Driver Details Required From Keeper POFA with FAQ's POFA
11/06/2025   Letter Issued - Website Appeal Response
11/06/2025   Website Appeal received for this case and is queued for processing.
13/06/2025   Letter Issued - GDPR Request - With Appeal
13/06/2025   Letter Issued - Unsuccessful POPLA - Paid Parking Insufficient with FAQ's POFA

Rules and Conditions
This site is a Paid Parking car park as clearly stated on the signage (enclosed). We have included a signage plan showing that there are signs situated at the entrance, exit and throughout the car park displaying the terms and conditions of the site.

All available payment options can be found within the enclosed signage. The full, correct vehicle registration must be inputted when parking payments are made.

Please see below information relating to the payment options on site:

Payment Options: Payment Machine and Evology pay                     
Number of Paid Parking Machine: 1

Authority
We can confirm that the above site is on private land, is not council owned and that we have written authority to operate and issue Parking Charge Notices at this site from the landowner (or landowner’s agent).

It must also be noted that any person who makes a contract in his own name without disclosing the existence of a principal, or who, though disclosing the fact that he is acting as an agent on behalf of a principal, renders himself personally liable on the contract, is entitled to enforce it against the other contracting party. (Fairlie v Fenton (1870) LR 5 Exch 169). It follows that a lawful contract between ourselves and the motorist will be enforceable by us as a party to that contract.

Additional Information
The BPA has provided clarity to both motorists and parking management companies regarding grace periods which can be found in the Private Parking Single Code of Practice.

www.britishparking.co.uk/code-of-practice-and-compliance-monitoring

Parkingeye are fully compliant with the Private Parking Sector Single Code of Practice in relation to Grace Periods.

We ensure that all our signage is clear, ample, and in keeping with the Private Parking Sector Single Code of Practice regulations. The signage at this site demonstrates adequate colour contrast between the text and the backgrounds advised in the Private Parking Sector Single Code of Practice.

This car park has been registered with the British Parking Association and is compliant with the Single Code of Practice.

The signage on site clearly sets out the terms and conditions and states that;

"By parking, waiting or otherwise remaining within this private car park, you agree to comply with the terms of the Parking Contract, including making payment as required and entering your vehicle registration details into the payment machines and/or terminals as directed."

“If you fail to comply with the terms of the Parking Contract, you will become liable to pay the sum specified in this notice (the “Parking Charge”)"

All signs that pertain to the general terms and conditions of parking contain text which explains that, “[…] by entering this private car park, you [each motorist] consent, for the purpose of car park management, to: the capturing of photographs of the vehicle and registration by the ANPR cameras […] and to the processing of this data […]”. In turn, consent is also provided so as to allow us to make a request for registered keeper from the DVLA “where the Parking Contract is not adhered to”. The wording used clearly details that the Parking Contract in question commences when the motorist “enters” the car park and that the data from the ANPR system will be used to enable us to take enforcement action against those who breach the parking terms and conditions in operation.

We operate a grace period on all sites, which gives the motorist time to enter a car park, park, and establish whether or not they wish to be bound by the terms and conditions of parking. These grace periods are sufficient for this purpose and are fully compliant with the Private Parking Sector Single Code of Practice.

You have stated that you do not believe that the Parking Charge amount is a pre-estimation of loss, or that it is extravagant, unfair or unreasonable. In this regard, we rely upon the Supreme Court decision in the matter of Parkingeye v. Beavis [2015] UKSC 67, which was found in Parkingeye’s favour and concerned the value of our Parking Charges.

The Supreme Court considered the Defendant’s submissions that the Parking Charge should be considered to be penal and unfair, but the Justices supported the findings of the lower courts, where the charge was found to be neither ‘extravagant’ nor ‘unconscionable’.

























Initially, we would like to state that we are a leading user of ANPR Technology. We ensure that our cameras, technology and processes are of the highest quality and have built up this expertise with more than 10 years of experience of using ANPR cameras. We ensure that we use the best cameras, and that these are expertly configured.
We have also developed a robust process for handling the data and ensuring the accuracy of the system. We are regularly required to provide data taken from these ANPR cameras for Police investigations.
Once the cameras, signage and other technology are installed at a site, we will test the system extensively before parking charges are issued on site. This involves allowing the site to function normally without parking charges being issued, to ensure that the system is functioning correctly.
The Private Parking Sector Single Code of Practice contains guidelines for the use of ANPR cameras which we fully comply with.
Images recorded by the ANPR (Automatic Number Plate Recognition) systems are time-stamped at source.  The ANPR servers use NTP to regularly verify the accuracy of the local time clock with any adjustments being logged thus ensuring that all images are captured and stamped with an accurate time and date.  Network Time Protocol (NTP) is a widely used standard to accurately synchronise computer time over wide area networks. We firmly believe that these time-stamped images are accurate.
Any time deviance detected on the ANPR servers generates an automatic alert monitored by the Technical Support Team.  If at any stage of the process the ANPR cameras are found to be deviating, parking charges are not issued. There are automated and manual checks to ensure that the cameras are accurate.
It is important to note that cameras and ANPR servers are directly attached as an integrated solution situated on-site therefore ensuring the accuracy of the ANPR read and associated date-timestamp. Transactional data and images are recorded locally before batch transfer to our central systems.
There is no evidence to suggest that a parking charge has been issued incorrectly, and we go to great lengths to ensure that all parking charges are issued correctly. The data taken from the Automatic Number Plate Recognition cameras is sent to us, where it undergoes a checking process of up to 19 stages. This ensures that no errors have been made. There are various other procedures in place to ensure that parking charges are issued correctly, and there is no reason to believe that an error has occurred in this case.

We can confirm that Parkingeye’s use of ANPR cameras is consistent across all the sites on which we operate, and that the data collected is handled in the same manner on each occasion that a motorist is found to be in breach of the terms and conditions of parking in operation.

All signs that pertain to the general terms and conditions of parking contain text which explains that “[…] by entering this private car park, you [each motorist] consent, for the purpose of car park management, to: the capturing of photographs of the vehicle and registration by the ANPR cameras […] and to the processing of this data […]”. In turn, consent is also provided so as to allow Parkingeye to make a request for registered keeper from the DVLA “where the Parking Contract is not adhered to”. The wording used clearly details that the Parking Contract in question commences when the motorist “enters” the car park and that the data from the ANPR system will be used to enable Parkingeye to take enforcement action against those who breach the parking terms and conditions in operation.

As you are aware, we monitor Milton Country Park by the use of ANPR cameras and any motorist wishing to make use of the site must adhere to the terms and conditions displayed on the signage in situ. A parking contract is formed when the motorist enters the site, considers the terms and conditions on the signage, and chooses to remain. A parking charge will thereafter be issued should the terms and conditions of this parking contract be breached and it is our position that a motorist is bound by such a contract provided the terms were sufficiently brought to their attention.

It is our position that the signage in place on site at this location is sufficient for this purpose and that sight of the signs on site, even if their presence was a purported planning breach, would result in the motorist concluding that parking was subject to certain conditions. Motorists would also be placed on notice that breaching the same would reasonably result in enforcement action and we contend that the terms of any such enforcement action are clear.


Please be advised the date of the Parking Event was 31/03/2025 and the Parking Charge Notice was issued on 03/04/2025 , therefore we believe that we have issued the Parking Charge Notice in accordance with Paragraph 9 of Schedule 4 of the Protection of Freedoms Act (2012).

Postage is at the behest of the postal service and therefore any delays are outside of our control.

Please be advised it is the motorist’s responsibility to purchase the correct parking to cover the duration of their stay.

Please find enclosed document showing that on the date of the parking event we had authority to issue and pursue a Parking Charge to this vehicle.
 
Title: Re: Milton Country Park PCN
Post by: bee0821 on July 04, 2025, 09:43:07 am
Hello

Thank you everyone again for your help with this case. We have now heard from POPLA that Parking Eye have submitted their evidence. It looks slightly different - to my untrained eye - to the one in the other case on this forum, so I paste it all here. One notable difference is that it doesn't seem to include this phrase from the other one: "Please be advised, this Parking Charge was not issued under the Protection of Freedoms Act 2012."

In fact at they end they state: "we believe that we have issued the Parking Charge Notice in accordance with Paragraph 9 of Schedule 4 of the Protection of Freedoms Act (2012)."

As before, I'd be very grateful for any help on rebuttal, as I'm not quite sure I understand the ins and outs of reliance on POFA...

Thank you in advance!
Title: Re: Milton Country Park PCN
Post by: bee0821 on June 18, 2025, 04:04:26 pm
Thank you -I'll replace keeper with hirer in all instances then
Title: Re: Milton Country Park PCN
Post by: b789 on June 18, 2025, 03:49:47 pm
Use the appropriate term. If you have leased the vehicle, then you are the Hirer. The lease company is the Keeper.
Title: Re: Milton Country Park PCN
Post by: bee0821 on June 18, 2025, 03:43:09 pm
Thank you both very much. In light of the above, should I replace references to 'keeper' in the POPLA statement with ones to 'hirer? I notice this statement from the other post actually uses both - it refers to 'keeper' in the first para under 1., and then again before the conclusion, but uses 'hirer' in the third para under 1.
Title: Re: Milton Country Park PCN
Post by: jfollows on June 18, 2025, 11:49:11 am

The only thing is I am fairly sure I am not the registered keeper, since the vehicle is a lease, so also not sure if it is correct to say that Parking Eye are seeking to hold me liable as registered keeper? Looking back at their original PCN it doesn't seem to make mention of either keeper or hirer...

As above, all the help on this forum very much appreciated.
It’s a Notice to Hirer, without explicitly saying so, because it says something like “you have been identified as the driver” (untrue, of course) on the rear of the PCN and their later correspondence (Reply #14) refers to you as the hirer.
Title: Re: Milton Country Park PCN
Post by: b789 on June 18, 2025, 11:36:41 am
As it is an identical situation, then yes, just use the same appeal but with your own PCN reference number and any dates etc.
Title: Re: Milton Country Park PCN
Post by: bee0821 on June 18, 2025, 10:40:21 am
Hello

We have now as predicted had the appeal rejected by ParkingEyE. Here is the text of their response:

Dear Sir / Madam,
Thank you for your appeal in relation to the Parking Charge incurred on 31 March 2025 at
16:23, at Milton Country Park, Milton car park.
We have reviewed the details outlined in your appeal and can see that a payment to park
was made on the date of the event. Unfortunately, the tariff purchased was insufficient
and did not cover the entire duration of the stay. The terms and conditions and tariffs are
outlined on the signage which are on display throughout the car park.
We are writing to advise you that your recent appeal has been unsuccessful and that you
have now reached the end of our internal appeals procedure.
If you wish to have your case independently assessed, please be advised, there is an
independent appeals service (POPLA) which is available to motorists who have had an
appeal rejected by a British Parking Association Approved Operator. Contact information
and further information can be found enclosed. See also www.popla.co.uk
By law we are also required to inform you that Ombudsman Services (www.ombudsman-
services.org/) provides an alternative dispute resolution service that would be competent
to deal with your appeal. However, we have not chosen to participate in their alternative
dispute resolution service. As such should you wish to appeal then you must do so to
POPLA, as explained above.
Please note, if the Parking Charge was issued in Scotland/Northern Ireland, only the
driver can appeal to POPLA (Parking on Private Land Appeals).
As a gesture of goodwill, we have extended the discount period for a further 14 days from
the date of this correspondence. If you appeal to POPLA, you will not be able to pay the
discounted amount in settlement of the Parking Charge, and the full value of the charge
will be outstanding. In addition, if your appeal to POPLA is unsuccessful, you will no
longer be able to pay the discounted amount and the full value of the charge will be due.
A payment can be made by telephoning 0330 555 4444, by visiting
www.parkingeye.co.uk/payments or alternatively by posting a cheque/postal order to
Parkingeye Ltd, PO Box 117, Blyth, NE24 9EJ. Please ensure you write your reference
number on the reverse of any cheque/postal order so the payment can be allocated.
If you have received this correspondence via email, please allow 24 hours for our
systems to reflect the discounted value before making a payment via our automated
payment line or website.

I understand the next thing to do is to submit a POPLA appeal. Given the similarity with the other case in this forum (https://www.ftla.uk/private-parking-tickets/pcn-milton-country-park-cambridge/30/) I wondered if a verbatim version of what was submitted there would work - that is:

Grounds of Appeal:
1. No Keeper Liability – PoFA 2012 not applicable to Milton Country Park

2. Driver not identified – No presumption of driver liability

1. No Keeper Liability – PoFA 2012 not applicable
The land in question—Milton Country Park—is subject to statutory control under byelaws made pursuant to Section 41 of the Countryside Act 1968, confirmed by the Secretary of State and in operation since 2 May 1994. As such, the land is not “relevant land” under PoFA Schedule 4. The land is not “relevant land” as defined by paragraph 3 of Schedule 4, and therefore, the registered keeper cannot be held liable if the driver has not been identified.

ParkingEye are attempting to hold me liable as the registered keeper, despite this being a location where keeper liability cannot be established under PoFA.

Since the operator has neither invoked PoFA nor complied with its conditions, and since PoFA could not apply in any event due to the statutory status of the land, there is no lawful basis to hold me liable as Hirer.

2. Driver not identified
At no stage have I identified the driver, nor is there any legal requirement to do so. ParkingEye have failed to demonstrate who was driving the vehicle at the time of the alleged contravention.

As keeper, I cannot be held liable for a charge incurred by an unknown third party at a location not covered by PoFA.

Conclusion
For the reasons above, I respectfully request that POPLA upholds this appeal and instructs ParkingEye to cancel the Parking Charge Notice.

The only thing is I am fairly sure I am not the registered keeper, since the vehicle is a lease, so also not sure if it is correct to say that Parking Eye are seeking to hold me liable as registered keeper? Looking back at their original PCN it doesn't seem to make mention of either keeper or hirer...

As above, all the help on this forum very much appreciated.
Title: Re: Milton Country Park PCN
Post by: b789 on June 13, 2025, 12:33:30 pm
Nothing for you to do... unless you want to give them a hard time. If so, you can respond with the following:

Quote
Dear ParkingEye Privacy Team / Appeals Team

Re: Parking Charge Notice 288486/335086
Date of event: 31 March 2025
Location: Milton Country Park
Hirer: [Your Full Name]
VRM: [Vehicle Registration]

Thank you for your letter.

You state that you rely on performance of a contract and legitimate interests as your lawful bases for processing my data. That position is flawed for the following reasons.

1. While a contract could potentially be formed with a driver, the land in question is governed by statutory byelaws made under section 41 of the Countryside Act 1968. As such, it is not “relevant land” for the purposes of Schedule 4 of the Protection of Freedoms Act 2012. Therefore, even if a contract were formed, you cannot pursue anyone other than the driver, and there is no lawful basis to process the data of a registered keeper or hirer.

2. You did not invoke Schedule 4 of PoFA in your Notice to Hirer. You also failed to include the required documents under paragraph 13(2), namely the hire agreement and the statement of liability. Without these, you have no lawful basis to pursue me as the hirer.

3. You are relying on personal data obtained either from the DVLA or a hire company in order to pursue someone who cannot, in law, be liable. That is a misuse of personal data and a breach of your KADOE contract with the DVLA, as well as a breach of Articles 5 and 6 of the UK GDPR.

4. Your claim to rely on legitimate interests under Article 6(1)(f) also fails the balancing test. You have no enforceable claim against the hirer, and my rights and interests as a data subject outweigh any interest you claim to have in pursuing this charge.

Your processing of my data is therefore unlawful. I now require, under Articles 17 and 18 of the UK GDPR:

• Erasure of all personal data you hold about me relating to this PCN
• Restriction of any further processing

You must either cancel the PCN or issue a POPLA code. If you continue to process my data without a lawful basis, I will submit formal complaints to the DVLA, the Information Commissioner’s Office, and the British Parking Association.

Yours faithfully

[Your Full Name]
Hirer of the vehicle
[Your Address or Email]
Title: Re: Milton Country Park PCN
Post by: bee0821 on June 13, 2025, 11:20:51 am
Hello again. We've received the below from Parking Eye:

Dear,
 
Thank you for your correspondence received in relation to the above referenced Parking Charge. We have been passed this as we note you have raised a data query.
 
Please note, it is Parkingeye’s position that this charge was issued following a contractual breach of the terms and conditions in operation onsite, and that we had reasonable cause to request the Registered Keeper’s details from the DVLA. Please note that our lawful bases for processing data are Performance of a Contract and Legitimate Interests. Parkingeye do not rely on Consent as a legal basis for processing data when issuing and pursuing the payment of outstanding Parking Charges. We are registered with the ICO to collect and process data for the purpose of car park management, which includes dealing with appeals and any subsequent recovery action required.
 
For your clarity, Parkingeye were provided with the details of the hirer on the date of the parking event by the Registered Keeper of the vehicle.
 
We can confirm that your appeal has now been passed back to our dedicated Appeals Team for further consideration.
 
Please note that the UK General Data Protection Regulation provides the following further rights:

•             The right to request from Parkingeye rectification or erasure of your personal data;

•             The right to request from Parkingeye restriction of processing of your personal data;

•             The right to object to the processing of your personal data.

Please note that some of these rights are not absolute and will only apply in certain circumstances. We will review each request we receive in respect of these rights. We do not have to agree with a request but if we refuse, we will still contact the data subject within one month to explain why. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO). For further information, please refer to the ICO website, www.ico.org.uk. You may also seek a judicial remedy.

For further information about your rights as a data subject, plus information about the categories of data we process, data transfers, the legal basis for our processing, and the purposes of processing, please visit: https://www.parkingeye.co.uk/privacy-policy/

 
Yours sincerely,
 
Parkingeye Privacy Team


I assume there's nothing for us to do here as they say they'll pass it back to the appeals team, but just posting for info.

Thanks again all for help on this, I am so impressed that people give up their time to help tackle these bullies.
Title: Re: Milton Country Park PCN
Post by: bee0821 on June 11, 2025, 10:18:48 am
Thank you very much indeed! Hugely enjoyed looking up the reply given in Arkell v Pressdram :)
Title: Re: Milton Country Park PCN
Post by: b789 on June 09, 2025, 07:10:52 pm
I'd respond with the following:

Quote
Dear ParkingEye,

Re: Parking Charge Notice 288486/335086
Vehicle Registration: [Insert VRM]
Date of Event: 31 March 2025

I write in response to your latest letter, which is both inaccurate and legally incoherent.

You now cite Paragraphs 9(2)(b) and 9(2)(f) of Schedule 4 of the Protection of Freedoms Act 2012, which apply solely to Notices to Keeper, not Notices to Hirer. This basic error alone would be embarrassing enough, were it not compounded by your persistent failure to grasp that:

• You did not invoke Schedule 4 in your NtH;
• You did not include copies of the documents required under Paragraph 13(2), such as the hire agreement and statement of liability;
• And most importantly, the site in question — Milton Country Park — is subject to statutory byelaws and is not relevant land as defined under Schedule 4. Therefore, PoFA does not apply at all.

To recap: you have issued a legally defective notice, made a baseless threat of keeper/hirer liability, misquoted legislation, and are now doubling down on your mistake with a recycled, irrelevant template letter that demonstrates either ignorance of the law or wilful misrepresentation.

You now have two options:

1. Cancel this charge immediately, recognising that pursuing it any further is futile; or
2. Issue a POPLA code, where I will refer the assessor to your PoFA failings and the statutory control status of the land, and you can enjoy wasting the POPLA fee.

I refer you, in spirit and with appropriate legal sarcasm, to the response given in Arkell v Pressdram (1971). Should you fail to cancel or issue a code, this matter will be escalated to the DVLA, the ICO, and the BPA with a formal complaint regarding misuse of data and breach of the KADOE contract.

Yours faithfully,

[Your Full Name]
Hirer of the vehicle
Title: Re: Milton Country Park PCN
Post by: bee0821 on June 09, 2025, 02:45:22 pm
Hello

We have now received a reply from Parking Eye. Here it is:

Dear Sir / Madam,
Thank you for your correspondence in relation to the Parking Charge incurred on 31 March 2025 at 16:23, at Milton Country Park, Milton car park.
We are writing to advise you that your recent appeal has been referred for further information.
You have stated that you were not the driver of the vehicle at the date and time of the breach of the terms and conditions of the car park, but you have not indicated who was.
You have already been notified that under section 9(2)(b) of schedule 4 of the Protection of Freedoms Act 2012 that the driver of the motor vehicle is required to pay this parking charge in full. As we do not know the driver’s name or current postal address, if you were not the driver at the time, you should tell us the full name and the current postal address of the driver.
You are warned that if, after 29 days from the Date of Issue, the parking charge has not been paid in full and we do not know both the name and current address of the driver, we have the right to recover any unpaid part of the parking charge from you, the registered keeper. This warning is given to you under paragraph 9(2)(f) of schedule 4 of the Protection of Freedoms Act 2012 and is subject to our complying with the applicable conditions under schedule 4 of that Act.
Please note, if you have made or wish to make an appeal on behalf of the driver, and you do not provide the full name and current postal address of the driver, Parkingeye will be obliged to deal with the representations made in your name.
Parkingeye have placed this charge on hold for 28 days to enable you to provide the evidence requested. If this information is not provided within 28 days, the appeal may well be rejected and a POPLA code provided.
Alternatively, payment can be made by telephoning our offices on 0330 555 4444 or by visiting www.parkingeye.co.uk or by posting a cheque or postal order to ParkingEye Ltd, PO Box 117, Blyth, NE24 9EJ.
Yours faithfully, Parkingeye Team

This is in response to the message I sent them, which you can see in the post above.

It's slightly different to their response to the poster in the other comparable thread, so just wanted to check what the right response should be. Also, I will double check V5C but I don't think I'm the registered keeper (which I'm referred to as in this note) because the car is a lease.

Many thanks in advance for your help.
Title: Re: Milton Country Park PCN
Post by: bee0821 on May 19, 2025, 05:54:51 pm
Thank you very much for all the advice. I will respond to them with the message, and then probably need to ask for more advice when it escalates to POPLA. Really appreciate the help on this forum!
Title: Re: Milton Country Park PCN
Post by: b789 on May 16, 2025, 05:45:05 pm
Just send the initial appeal as you have been advised. There is no point in overthinking this.

ParkingEye will reject the appeal and issue a POPLA code where you can follow the process as advised on the other thread.

ParkingEye not relying on PoFA to hold theKeeper liable. Even if they were, which they aren't, they could not hold the Keeper liable. The driver has not been identified. End of!

The fact that the vehicle is leased/hired snd that they did not issue a PoFA compliant NtH is another factor but it really isn't worth adding that at this stage. As long as the driver remains unidentified, there is nowhere for this to go.
Title: Re: Milton Country Park PCN
Post by: bee0821 on May 16, 2025, 09:14:13 am
Thank you very much May I just check that this as an initial response to Parking Eye:

"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 keeper of the vehicle under Schedule 4 of the Protection of Freedoms Act 2012 ("the Act").

There is no obligation for me to name the driver and I will not be doing so.

For the avoidance of doubt, even if you had attempted to rely on Schedule 4 of the Act, you would have failed to establish liability, as the location in question—Milton Country Park—is subject to statutory control by byelaws. As such, the land is not “relevant land” within the meaning of the Act, and the provisions of Schedule 4 do not apply.

I am therefore unable to assist you further with this matter, and I 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 faithfully,
[Your Name]"

From the other thread is appropriate in my case? And/or ought I to include anything in addition from the points H C Andersen makes above?

Thanks again for your help, much appreciated!
Title: Re: Milton Country Park PCN
Post by: b789 on May 15, 2025, 05:39:17 pm
I refer you to this response in the other thread:

So, you have 33 days from the appeal rejection date to submit your POPLA appeal. Have a search of other POPLA appeals on here and see what you can come up with, based on the information you have been told about in this and the other thread. Don't send anything before you post it here so that we can advise on anything you should add or remove or edit.

Remember, the first thing the assessor will want to determine is whether you, the Keeper can be liable as the drivers identity has not been provided. As this location is covered by byelaws, PoFA does not apply.

If the POPLA assessor cannot determine the drivers identity and PoFA does not apply to land that is covered by statutory byelaws, that should end the matter as far as POPLA is concerned. However, you can throw in the kitchen sink is as a backup, just in case the assessor on the day is one of those doltish types we often see.
Title: Re: Milton Country Park PCN
Post by: bee0821 on May 15, 2025, 02:33:15 pm
That sounds reassuring, thank you very much!

On the other thread (https://www.ftla.uk/private-parking-tickets/pcn-milton-country-park-cambridge) it looks like Parking Eye are rejecting the response:

"Please note, it is Parkingeye’s position that this charge was issued following a contractual breach of the terms and conditions in operation onsite, and that we had reasonable cause to request the Registered Keeper’s details from the DVLA. Please note that our lawful bases for processing data are Performance of a Contract and Legitimate Interests. Parkingeye do not rely on Consent as a legal basis for processing data when issuing and pursuing the payment of outstanding Parking Charges. We are registered with the ICO to collect and process data for the purpose of car park management, which includes dealing with appeals and any subsequent recovery action required.
 
We therefore wish to confirm that we have rejected your request that we remove data from our system and cease processing in this instance at this stage, and can confirm that your appeal has now been passed back to our dedicated Appeals Team for further consideration.
 
Please note you have the right to make a complaint to the ICO in respect of this response, should you wish to do so. You may also seek a judicial remedy.
 
For further information about your rights as a data subject, plus information about the categories of data we process, data transfers, the legal basis for our processing, and the purposes of processing, please visit: https://www.parkingeye.co.uk/privacy-policy/"

They're also rejecting the appeal and referring the poster to POPLA.

Sorry to duplicate things but these cases are nearly identical, hence reposting. Does this response change people's view of this PCN?
Title: Re: Milton Country Park PCN
Post by: H C Andersen on May 15, 2025, 02:25:37 pm
The self-styled Parking Charge Notice is incoherent nonsense.

Pl don't dignify it with a status it does not deserve.

Facts:
The whatever-it-is was posted on Monday 12th May (the 'issue' date is a Saturday) and therefore deemed served Wed. 14th.

The 'Date of event' was 31 March.

Elapsed period: 46 days.

It was served on the addressee because they had been 'identified(by who we don't know)/identified themselves as the driver.'

A Notice to Driver may only be served on the vehicle before it leaves the site.

The ANPR shot shows the vehicle leaving the site.

So, it's not a Notice to Driver.

A Notice to Keeper must be served no later than 14 days after the 'event'.

So, it's not a Notice to Keeper either.

It doesn't carry the wording required by para. 14 Schedule 4 neither does it refer to Hirer, whether preceded by the words 'Notice to' or not.

It wasn't accompanied by the documents mandated under para. 14.

So, it's not a Notice to Hirer.

So, it's a goodness knows what?

The only thing which fits the bill is that the creditor is claiming that the addressee is the driver and in these cases there is no prescribed form of notice, it could be written on the side of a cow (although the postage would be high) and contain whatever words they wanted.
Title: Re: Milton Country Park PCN
Post by: bee0821 on May 15, 2025, 01:12:28 pm
Thank you very much. I've just seen that the poster in the other thread has posted Parking Eye's response, so I might wait to see what people advise about that response.
Title: Re: Milton Country Park PCN
Post by: b789 on May 14, 2025, 07:47:56 pm
Whilst you are not the Keeper, as the Hirer, the exact same principles apply as in the other case. Any appeals must come ONLY from the Hirer and you only reference the Notice to Hirer (NtH) rather than the Notice to Keeper (NtK).

Only you know the identity of the driver and, as the Hirer, you are under no legal obligation to identify the driver to an unregulated private parking company.

You have added advantage that the vehicle is Hired/leased. ParkingEye have failed to comply with all the requirements of PoFA paragraph 14 which means that the Hirer cannot be liable. Also, because the location is not relevant land for the purposes of PoFA, the same condition applies... no Hirer liability.

All you need to do is follow the exact same steps as in the other thread.
Title: Re: Milton Country Park PCN
Post by: bee0821 on May 14, 2025, 03:46:31 pm
No, only the single page letter above
Title: Re: Milton Country Park PCN
Post by: RichardW on May 14, 2025, 03:44:59 pm
Did you receive any other documents with the PCN?
Title: Milton Country Park PCN
Post by: bee0821 on May 14, 2025, 01:41:57 pm
Hello

We're in a situation exactly like the one described here: https://www.ftla.uk/private-parking-tickets/pcn-milton-country-park-cambridge/

£100 PCN at Milton for 30 min overstay (impossible to pay for overstay on exit). As in the above thread, this was a lease car so not registered keeper (we were notified first by lease company and just today received the PCN in the post).

I attach photos of the front and back of the PCN.

I'd be really grateful to know if advice to us would be the same as the advice to the poster above.

Thanks very much in advance for any help.

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