Subject: Service complaint – mishandling of report RGC-000170461 (Moorside Legal Services Limited)
Dear Sir/Madam,
Re: Service complaint concerning the assessment outcome on RGC-000170461
Please treat this as a service complaint about the handling and assessment of my report regarding Moorside Legal Services Limited (private parking matter for NCP at Gatwick Airport).
Your decision letter characterises my concerns as “legal and/or procedural” and states you “found there had not been a breach of [your] rules”. That conclusion ignores the specific conduct issues I raised and misapplies your own assessment threshold. In short, the assessment did not engage with the evidence or the relevant SRA standards.
The conduct concerns you did not address:1. Misleading assertions to a third party (Code for Firms 1.4): Moorside threatened the registered keeper with court over an event on airport byelaw land (Gatwick). They did so while asserting liability and a £70 add-on as if lawfully recoverable, and while relying on a “Site Enforcement Pack” that actually confirms statutory control (i.e., not “relevant land” under Sch.4 PoFA 2012). That is not a neutral “legal disagreement”; it is misleading conduct to pressure payment from a non-liable party.
2. Systems and controls to comply with legal/procedural obligations (Code for Firms 2.1): Their Letter of Claim was not compliant with the Pre-Action Protocol for Debt Claims (missing PAPDC enclosures and particulars) and they persisted despite the client’s non-response to a Data Rectification Notice and complaint sent on 24 June (no reply by 26 August). Proceeding regardless evidences inadequate systems and supervision.
3. Pattern and harm: Moorside’s follow-up email (3 September) doubled down on the above, refusing to engage with PAPDC duties and continuing to press the keeper. This is not a one-off slip—it's baked into their process.
Your letter suggests I take “legal advice” or let a court decide. Respectfully, that misses the point: I reported regulatory conduct—misleading assertions and disregard of pre-action duties—not a request for the SRA to adjudicate a parking dispute.
What I am asking for:• A service-level review of the assessment on RGC-000170461, addressing the actual conduct concerns above (with reasons).
• Confirmation that the evidence I supplied (LoC, 3 Sept email, NtK, Final Reminder, and the Gatwick North Terminal pack) will be retained as intelligence and actively monitored for pattern.
• If you still decline investigation, please state which SRA Principles/Code provisions you considered and why you concluded no potential breach of (at least) Code for Firms 1.4 and 2.1.
For clarity, I understand the SRA cannot order redress; I am not asking you to. I am asking you to properly assess clear conduct concerns squarely within your remit.
Yours faithfully,
[Your name]
[Address]
[Email]
Subject: Moorside Legal Services Limited – refreshed conduct report (misleading assertions to non-liable keeper; PAPDC disregard) – RGC-000170461
Dear SRA Investigations,
Further to RGC-000170461, please log this refreshed conduct report (same matter) so your records clearly capture the rule-level issues and supporting documents.
Firm reported: Moorside Legal Services Limited
Client: National Car Parks (NCP)
Matter: Private parking charge at Gatwick Airport (byelaw-controlled land). I am the registered keeper; driver not identified.
Conduct issues (not merits of a parking dispute):1. Misleading statements to a third party – Code for Firms 1.4 (integrity; do not mislead):• Moorside threatened keeper liability on airport byelaw land (Gatwick) and presented a £70 add-on as if lawfully due.
• Their own “Site Enforcement Pack – North Terminal” confirms statutory control of the site. On such land, Schedule 4 PoFA keeper liability cannot arise. Pressing the RK regardless is misleading.
2. Failure to maintain effective systems to comply with legal/procedural duties – Code for Firms 2.1:• PAPDC-non-compliant Letter of Claim (missing mandated content and enclosures) followed by a 3 Sept email that still refused to provide the PAPDC paperwork.
• Proceeding despite the client’s non-response to my Data Rectification Notice and formal complaint sent 24 June (no response by 26 August), suggesting inadequate supervision and controls.
3. Pattern risk: The 3 Sept email restates the same positions, indicating a business model problem rather than an isolated lapse.
Key documents available (on request):• My 24 June emails to NCP (formal complaint + Data Rectification Notice).
• Moorside’s Letter of Claim and 3 September email response (with NtK, Final Reminder, and Gatwick North Terminal enforcement pack).
• Evidence of no response by NCP to the complaint/DRN by 26 August.
Rules engaged (illustrative):SRA Code of Conduct for Firms:• 1.4 – act with integrity; do not mislead.
• 2.1 – governance systems to ensure compliance with legal/regulatory obligations (including pre-action protocols and accurate statements of law to third parties).
I appreciate the SRA does not adjudicate civil liability or award redress. This report concerns regulatory conduct only. Please retain and monitor as intelligence for pattern and confirm this has been added to your records under the above reference.
Yours faithfully,
[Your name]
[Address]
[Email]
[Moorside ref / PCN ref / VRM]
---------- Forwarded message ---------
From: Phillip Archer <Phillip.Archer@sra.org.uk>
Date: Tue, Oct 21, 2025 at 4:33 PM
Subject: RGC-000170461 - your report about Moorside Legal Services Limited
Dear xxxxxxxx
Your report about Moorside Legal Services Limited
We have now completed our assessment of your concerns and have decided not to investigate the concerns raised further.
Please see the attached letter for further information.
I appreciate this is not the outcome you were hoping for, however I hope that the attached document helps to explain why we have made this decision. Our file is now closed.
Yours sincerely
Phillip Archer
Investigation Officer
Investigation and Supervision
Solicitors Regulation Authority/Awdurdod Rheoleiddio Cyfreithwyr
T: 0121 758 6998
sra.org.uk
For information on how we handle your personal data, see our privacy notice.
This email is intended for the addressee only. This includes any attachments. Its unauthorised use, further processing, storage or copying is not allowed. If you are not the intended recipient, please let the sender know and then destroy all copies.
Please note the sender is not authorised to conclude any contract on behalf of the Solicitors Regulation Authority by email.
We are the regulator of solicitors and law firms in England and Wales. The Solicitors Regulation Authority Limited is a company limited by guarantee registered in England and Wales. Our registered offices are: The Cube, 199 Wharfside Street, Birmingham, B1 1RN. Our company registration number is: 12608059.
Our decision concerning the report you made to us
Thank you for your report regarding Moorside Legal Services Limited (the firm)
and its involvement regarding a parking charge dispute between you and National
Car Parks (NCP).
You allege that the firm has threatened proceedings against you although the
registered keeper liability is misrepresented. The firm has failed to provide a
proper basis of claim and documents and added misleading fees to the claim.
NCP have also not responded to your concerns about data protection failings,
and the firm has not ensured its client has complied with data rights and
complaint handling.
After considering your report, we have decided we will not be taking any further
action.
Reasons for our decision
When we look into reports made to us, we make a decision on whether to
investigate based on our assessment threshold test. We look at:
• Whether there has been a potential breach of our rules.
• If there has been a breach of our rules, and if so, the nature of the
breach or whether the conduct forms part of a pattern of behaviour.
However, we typically only investigate the most serious allegations.
• Whether there is enough evidence to prove the breach.
In this case, your report did not pass the assessment threshold test because:
• We found there had not been a breach of our rules.
Please note that:
• We do expect solicitors to keep their clients' information confidential.
But data protection concerns (including against the firm’s client) are
usually best reported to the Information Commissioner's Office rather
than to us.
• The firm has acted on behalf of its client (and following their
instructions) in a legal matter for a parking charge notice dispute.
• We cannot tell a solicitor to take specific steps in your legal case or to
stop taking steps in your case.
• We do not have the power to make a solicitor or firm say sorry to you,
pay compensation to you for a mistake or to put things right in other
ways.
• We cannot intervene in legal disagreements, and the concerns you
raised with us is legal and/or procedural in nature, regarding a parking
charge notice dispute. This means it is ultimately for a court or a
Tribunal to determine the outcome. This is not something we, as a
regulator, can assist with and independent legal advice may need to
be sought.
Under our rules, you do not have the right to appeal or review this decision.
We will keep your report on our records
We are grateful for the time you have taken to provide this information to us. The
reports we receive are an important part of our work in regulating law firms and
solicitors.
Although on this occasion we will not be taking further action, we will keep a
record of your report. We may refer to it in the future if we receive any new
reports of similar concerns. This will help us to identify any patterns or trends that
we might need to address.
Thank you again for contacting us.
Yours sincerely
Phillip Archer
Investigation Officer
Investigation & Supervision
Solicitors Regulation Authority
Email: phillip.archer@sra.org.uk
www.sra.org.uk
Information on how we process personal data can be found in our privacy notice.
---------- Forwarded message ---------
From: <noreply@moorsidelegal.co.uk>
Date: Thu, Oct 16, 2025 at 11:42 AM
Subject: Reference: 40044429
We write in relation to the above matter.
Please note that we will not be addressing any further correspondence related to disputes of the same nature, as we have already provided you with a response.
We ask that you make the full payment of £170.00 within 7 days of receipt of this email.
You can make payment in the following ways:
Contact us on 0330 822 9950 (our opening times are Monday- Friday 9:00- 17:00);
portal.moorsidelegal.co.uk - Login to our portal
https://pay.moorside.legal - Quick Pay
If you fail to respond or make payment, we may be instructed by our client to issue legal proceedings against you. This will incur further costs and fees that will be added to the outstanding balance. You may wish to seek independent legal advice.
Yours sincerely,
Moorside Legal
This email may contain confidential and/or privileged information. If you are not the intended recipient (or have received this email in error) please notify the sender immediately and delete this email, together with any copies from your system. Any unauthorised use, copying, disclosure or distribution of the material in this email is strictly forbidden and may be unlawful. Please note that neither Moorside Legal nor the sender accepts any responsibility for viruses, and it is your responsibility to scan any attachments.
Moorside Legal Services Limited trading as Moorside Legal (1506947)
Authorised and regulated by the Solicitors Regulation Authority - SRA ID 8006077
Registered office address: Unit 101, Hollinwood Business Centre Albert Street, Failsworth, Oldham, England, OL8 3QL
© 2023 Moorside Legal Services Limited All Rights Reserved
Subject: Your defective pre-action conduct and pursuit of a non-liable keeper – PCN [REF]
Dear Sirs,
I refer to your email of 3 September 2025 enclosing a copy NtK, Final Reminder and a “Site Enforcement Pack – North Terminal”.
First, record this timeline:• 24 June 2025: I sent NCP (a) a formal complaint and (b) a Data Rectification Notice requiring correction of my address for service and erasure of the former address.
• By 26 August 2025: No response to either.
• Instead, I received your purported Letter of Claim and, on 3 September, your follow-up email.
That failure to respond to a data rights request within one calendar month is a breach of UK GDPR requirements, and no extension was sought or justified. Your client remains in default.
Second, you are pursuing the registered keeper for an event at Gatwick Airport, land subject to statutory byelaws. Airport land is not “relevant land” under Schedule 4 PoFA 2012, so keeper liability cannot arise. The driver has not been identified and will not be. Your “Site Enforcement Pack” does nothing to alter the statutory position; it merely confirms that the site is under statutory control. Continuing to threaten proceedings against the keeper in these circumstances is misconceived.
Third, your Letter of Claim is not compliant with the Pre-Action Protocol for Debt Claims. Among other defects, it failed to provide the required particulars and documents, including the detailed basis of claim and the Information Sheet, Reply Form and Standard Financial Statement. Your 3 September email still fails to remedy these omissions.
Fourth, your justification for the £70 add-on relies on trade association lore, not law. The small claims track routinely treats such add-ons as unrecoverable double recovery, and Beavis does not licence bolt-ons to a core parking sum. If you intend to plead it, put me to strict proof now with a pleaded legal basis and authority—otherwise remove it.
Given the above:
Cease and desist from pursuing the keeper. Confirm in writing within 14 days that the matter is closed.
Alternatively, if you persist, issue a fully compliant Letter of Claim and place the matter on hold while NCP:(a) serves a substantive complaint response, and
(b) confirms compliance with my Data Rectification Notice (address updated; former address erased).
Any proceedings issued now will be met with an application to stay for pre-action non-compliance and a costsrequest for unreasonable conduct.
Finally, I am filing a complaint to the SRA. Your correspondence misstates the legal position on liability and add-ons, refuses to engage with protocol duties, and ignores data protection obligations. If you cannot grasp these basics, pass the file to solicitors who can.
Yours faithfully,
[Full name]
[Current address]
[Email / phone]
[PCN ref | VRM]
Subject: Moorside Legal – Defective pre-action conduct, misleading assertions, and pursuit of non-liable keeper (private parking claim)
Dear SRA,
I wish to report Moorside Legal for conduct falling below the standards in the SRA Code of Conduct for Firms and the Pre-Action Protocol for Debt Claims (PAPDC).
Matter: Private parking claim for an alleged contravention at Gatwick Airport (PCN ref [REF]). I am the registered keeper; the driver has not been identified.
Key concerns:
Keeper liability misrepresented: Gatwick Airport is subject to airport byelaws and is not “relevant land” under Schedule 4 PoFA 2012. Moorside continue to threaten proceedings against the keeper notwithstanding this, and supplied a “Site Enforcement Pack” which merely confirms statutory control.
Non-compliant Letter of Claim: Their LoC omitted the PAPDC-mandated particulars and documents (including the Information Sheet, Reply Form and Standard Financial Statement) and failed to provide a proper basis of claim and document set.
Misleading add-on: They assert an additional £70 based on trade association codes as if that sum were lawfully recoverable.
Data protection failings: On 24 June 2025 I sent NCP a formal complaint and a Data Rectification Notice to correct my address and erase the former address. No response was provided by 26 August 2025. Moorside pressed on with an LoC regardless, rather than ensuring their client complied with data rights and basic complaint handling.
Why this engages SRA standards:
Code for Firms 1.4 (Maintaining trust): Do not mislead clients, the court or others. Their letters and email misstate liability under PoFA and present the £70 add-on as lawfully due.
Code for Firms 2.1 (Compliance and business systems): Ensure effective systems to comply with legal and regulatory requirements, including pre-action protocols and data protection. Their approach disregards PAPDC content requirements and fails to ensure their client addressed data rights before escalation.
Pre-Action compliance: Their LoC and follow-up do not meet PAPDC para 3.1 (content and enclosures) and fall foul of PD-PAC paras 13–16 (sanctions for non-compliance).
Evidence available (and supplied on request):
My emails to NCP dated 24 June 2025 (formal complaint and Data Rectification Notice).
Moorside’s Letter of Claim and their email of 3 September 2025 (with NtK, Final Reminder, and “Site Enforcement Pack”).
Proof of no reply from NCP by 26 August 2025.
Gatwick Byelaws extract and PoFA references confirming non-relevant land status.
I ask the SRA to consider whether Moorside Legal’s conduct breaches Code 1.4 and 2.1, and to take appropriate regulatory action or require remedial steps.
Please acknowledge and let me know if you require the documents referenced above.
Yours faithfully,
[Full name]
[Postal address]
[Email / phone]
On Wed, Sep 3, 2025 at 9:24 AM <noreply@moorsidelegal.co.uk> wrote:
We write in relation to the above matter.
Please see the attatched, and the below.
1. An explanation of the cause of action
Our client has instructed us to collect the outstanding balance of £170.00 in relation to an unpaid Parking Charge Notice.
2. If the claim is for a contractual breach, photographs showing the vehicle was parked in contravention of said contract.
Please see the attached images.
3. Am I to understand that the additional £70 represents what is dressed up as a 'Debt Recovery' fee, and if so, is this net or inclusive of VAT? If the latter, would you kindly explain why I am being asked to pay the operator’s VAT?
The additional charge which has been levied on your Parking Charge of £70 is the amount set out in both the British Parking Association and International Parking Community Codes of Practice as the amount which may be added to a Parking Charge when a Parking Charge remains unpaid and when further recovery is required. Our Client is a member of the International Parking Community which is a government approved Accredited Trade Association (ATA) for Private Parking. Our Client adheres to the ATA’s Code of Practice. The £70 does not represent the cost of recovery but is a reasonable amount in relation to the Parking Charge amount, in order to encourage early payment of the Parking Charge without the need for debt recovery. It is a fair amount set by our Client’s government-approved Accredited Trade Association Code of Practice. There are however also costs incurred by our client in relation to debt recovery services.
3b. With regard to the principal alleged PCN sum: Is this damages, or will it be pleaded as consideration for parking?
By entering and parking the vehicle on our client's private land, you agreed to enter into a contract with our client and to be bound by the terms and conditions of that contract. The terms and conditions were clearly displayed at the entrance and in prominent places within the car park. Due to your failure to comply with the terms and conditions, our client has issued the PCN therefore if we are instructed to issue a claim the reason would be for Unpaid parking charges/ breach of contract.
4. Provide me a copy of the contract with the landowner under which they assert authority to bring the claim, as required by the BPA/IPC Private Parking Single Code of Practice (PPSCoP).
It is unclear why you would need to inspect any agreement between our client and the landowner as you are not party to that agreement, not could it aid your dispute or any potential defence.
The terms and conditions were clearly displayed in and around our client's private premises. When remaining on the premises, all motorists must choose to abide by them. However, on this occasion you failed to do so.
We ask that you make the full payment of £170.00 within 7 days of receipt of this email.
You can make payment in the following ways:
Contact us on 0330 822 9950 (our opening times are Monday- Friday 9:00- 17:00);
portal.moorsidelegal.co.uk - Login to our portal
https://pay.moorside.legal - Quick Pay
Please note that we will not be addressing any further correspondence related to disputes of the same nature, as we have already provided you with a response. However, should you wish to raise a new dispute, we will investigate the matter further and respond accordingly.
If you fail to respond or make payment, we may be instructed by our client to issue legal proceedings against you. This will incur further costs and fees that will be added to the outstanding balance. You may wish to seek independent legal advice.
Yours sincerely,
Moorside Legal
Dear Sirs,
Your so-called “Letter Before Claim” is a masterclass in procedural non-compliance. It reads less like a legal document and more like a payday loan advert—complete with “friendly team” and “flexible payment plans.” Charming, but irrelevant.
Let me be clear: this is not a compliant Letter Before Claim under the Pre-Action Protocol for Debt Claims. It fails to provide:
• The basis of the alleged claim (contract? tort? clairvoyance?)
• Any evidence whatsoever (no NtK, no signage, no landowner authority, no contract terms)
• A breakdown of the sum claimed (is the £170 damages, consideration, or just wishful thinking?)
• Copies of key documents relied upon
Your letter is devoid of substance, legal reasoning, and basic compliance. It does not enable informed dialogue, nor does it satisfy the requirements of paragraphs 3.1(a)–(d), 5.1, or 5.2 of the Protocol. It is procedurally defective and legally meaningless.
Should proceedings be issued on the back of this nonsense, then I put you on notice that I will be relying on the cases of Webb Resolutions Ltd v Waller Needham & Green [2012] EWHC 3529 (Ch), Daejan Investments Limited v The Park West Club Limited (Part 20) Buxton Associates [2003] EWHC 2872, Charles Church Developments Ltd v Stent Foundations Limited & Peter Dann Limited [2007] EWHC 855 in asking the court to impose sanctions on your client and to order a stay of the proceedings, pursuant to paragraphs 13, 15(b) and (c) and 16 of the Practice Direction, as referred to in paragraph 7.2 of the Protocol.
Unless a compliant Letter Before Claim is issued, I will be referring this matter to the Solicitors Regulation Authority (SRA) under Rule 1.4 and Rule 2.1 of the SRA Code of Conduct for Firms, on the basis that your conduct:
• Misrepresents the legal status of the claim
• Fails to uphold proper standards of legal service
• Demonstrates a lack of integrity and competence in pre-action procedure
Should your client issue proceedings based on this defective LoC, I will present it to the court as evidence of unreasonable conduct and procedural non-compliance. I will seek:
• An immediate stay under paragraph 15(b) of the Practice Direction
• A costs order under CPR 27.14(2)(g) for unreasonable behaviour
• Sanctions under paragraphs 13 and 16 of the Practice Direction
If your client wishes to pursue this matter, I suggest they instruct solicitors capable of drafting a compliant Letter of Claim. Until then, I am under no obligation to respond further.
Yours faithfully,
[Your name]
Subject: Formal Complaint and Challenge to Keeper Liability – PCN [Insert Reference Number]
Dear Sir/Madam,
I write as the Registered Keeper of the vehicle with registration number [INSERT REG] in relation to the above-referenced Parking Charge Notice (PCN), which I only recently became aware of following a letter from Trace Debt Recovery sent to my current address.
Upon investigation, I discovered that the original Notice was sent to a former address where I no longer reside. That address remains on the vehicle’s V5C due to an administrative oversight, although my relatives still live there. The notice was only recently retrieved and had been previously overlooked.
Regardless, I note that the location in question — Gatwick Airport — is not classified as “relevant land” under Schedule 4 of the Protection of Freedoms Act 2012. As such, you are unable to rely on PoFA to hold me liable as the Registered Keeper. I will not be naming the driver, and you have no lawful basis to pursue me for this charge.
This letter also constitutes a formal complaint regarding your inappropriate escalation of this matter to a debt recovery agency without first ensuring proper service of the original notice or verifying the legal basis for pursuing the Keeper. I expect this complaint to be handled in accordance with your published complaints procedure.
Separately, I will be submitting a Data Rectification Notice under Article 16 of the UK GDPR to update my address for service and require that you erase the former address from your records under Article 17(1)(d), as it is no longer accurate or necessary for processing.
Please confirm cancellation of this PCN and provide a written response to this complaint within 14 days.
Yours faithfully,
[Your Full Name]
[Current Address]
[Email Address – optional]
[Date]
...the Notice to Keeper (NtK) was not delivered within the relevant period to be able to rely on PoFA 2012 to hold the Keeper liable.The land isn't Relevant Land as per POFA anyway, as Airport Byelaws apply, so it cannot be applied regardless of when the NtK was delivered.
Subject: Formal Complaint and Challenge to Keeper Liability – PCN [Insert Reference Number]
Dear Sir/Madam,
I write as the Registered Keeper of the vehicle with registration number [INSERT REG] in relation to the above-referenced Parking Charge Notice (PCN), which I have only recently become aware of following a letter from a debt recovery agency (Trace) sent to my current address.
Upon investigation, I discovered that the original Notice to Keeper (NtK) was sent to a former address where I no longer reside. This address remains on the vehicle’s V5C due to an administrative oversight, although my relatives still reside there. The NtK was only recently retrieved and had been overlooked.
Having reviewed the NtK, I note that it was not issued within the statutory timeframe required under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA). As such, you have failed to meet the conditions necessary to hold the Registered Keeper liable for the alleged charge. Specifically, the NtK was not delivered within the period prescribed by Paragraph 9(5) of Schedule 4, which requires delivery within 14 days of the alleged contravention where no Notice to Driver was issued.
Accordingly, I reject any attempt to hold me liable as Keeper. You are not entitled to pursue me under PoFA, and I will not be naming the driver. I therefore require that you cancel this PCN immediately and confirm in writing that no further action will be taken.
This letter also serves as a formal complaint regarding your failure to comply with PoFA and your inappropriate escalation to a debt recovery agency without first ensuring proper service of the NtK. I expect this complaint to be handled in accordance with your published complaints procedure.
Separately, I will be submitting a Data Rectification Notice under Article 16 of the UK GDPR to update my address for service and require that you erase the former address from your records under Article 17(1)(d), as it is no longer accurate or necessary for processing.
Please confirm receipt of this complaint and your intended actions within 14 days.
Yours faithfully,
[Your Full Name]
[Current Address]
[Email Address – optional]
[Date]