Free Traffic Legal Advice

Is this the first response you've received? If so, yes I would do as you suggest, but also make clear that it has taken them 5 months to issue a 3 paragraph response that neither properly engages with the issues you raised nor complies with the PAPDC.

You don't want to end up in an endless letter ping-pong, but if you can create a clear paper trail that evidences their shoddy conduct this is advantageous.

As ever feel free to show us a draft.

Yes this was the first response!

Planning to respond with the below, although I realised there is no return address and I'm overseas so may just try sending via email again, cc'ing myself.
_____________________

Dear Sirs,

I acknowledge receipt of your letter dated 26 February 2026.

Your response does not properly engage with the matters raised in my previous correspondence and fails to provide the documents specifically requested pursuant to the Pre-Action Protocol for Debt Claims (PAPDC) and the Practice Direction - Pre-Action Conduct and Protocols (PD-PAC).

1. Continuing Protocol Non-Compliance

In my previous correspondence I requested disclosure of key documents required under PAPDC paragraphs 5.1-5.2 and PD-PAC paragraph 6, in order to enable the parties to properly understand the issues in dispute and to comply with the objectives of the pre-action process.

Your response contains none of the requested material and instead consists of a brief assertion that the Parking Charge Notice was correctly issued. Such a response falls materially short of the obligations imposed upon a creditor under the Protocol.

For the avoidance of doubt, the requested documents remain outstanding.

2. Failure to Meaningfully Engage

It is notable that your organisation has taken approximately five months to produce a response comprising only a few paragraphs which neither addresses the substantive issues raised nor provides the documentation required to allow meaningful engagement with the alleged claim.

This conduct does not comply with either the letter or the spirit of the Pre-Action Protocol for Debt Claims or the Practice Direction on Pre-Action Conduct, both of which require parties to exchange sufficient information and documentation to properly narrow or resolve disputes prior to litigation. Your letter dated 26 February 2026 also fails to provide any address for correspondence. This omission further undermines compliance with the Pre-Action Protocol, which requires parties to provide sufficient information to enable meaningful engagement and response prior to the commencement of proceedings.

3. Requested Documentation

The documents previously requested remain outstanding, including but not limited to:

the original Notice to Keeper and all subsequent notices;

strict proof of the legal basis of liability, including compliance with Schedule 4 of the Protection of Freedoms Act 2012 if keeper liability is alleged;

all ANPR images, photographs and VRM logs relating to the alleged incident;

contemporaneous evidence of signage in situ on the material date together with a site plan showing sign locations and entrance signage;

the unredacted landowner contract or chain of authority establishing your standing to offer parking contracts and pursue litigation at the site;

any payment machine records or audit logs relevant to the alleged period; and

a full breakdown of the sum claimed, including the legal basis for any amount above the core parking charge.

Until these documents are provided, it is not possible to properly assess the basis of your claim or provide a substantive response.

4. Reservation of Rights

We reserve the right to bring to the court’s attention, in any proceedings you may commence, your apparent failure to disclose information that is plainly central to your claim. We will further contend that your unreasonable withholding of such material amounts to a deliberate obstruction of the pre-action protocol. In those circumstances, we will seek appropriate costs sanctions against you.

Further, I expressly reserve the right to rely upon your continued non-compliance with the Pre-Action Protocol when addressing case management directions and any costs issues that may arise should proceedings be issued.

5. Protocol Timing

As previously stated, the 30-day response period under the PAPDC cannot properly commence until a compliant Letter Before Claim supported by the requested documentation has been provided.

Should proceedings be issued without compliance with the Protocol, I will invite the court to consider a stay of proceedings to allow proper compliance, together with any appropriate directions and sanctions.

6. Availability

Please note that I will be overseas until mid-April 2026. During this period I will be able to respond only to email correspondence. Any further communication should therefore be sent electronically.

If you intend to pursue this matter, please provide the requested documentation in a single paginated electronic bundle so that the issues may be properly considered.

Yours faithfully,

Keeper

Update on this one! Received this letter by post



I feel they've not responded adequately to my previous correspondence, so I assume the next step is to respond basically pointing out their non-compliance with the PD-PAC. Anything else at this stage?

OR, no response at all?



THANKS for the continued advice

Plan A is to approach the hospital and get them to cancel it.

Happy to try this although I note that their website states:

Parking charge notices are generated and issued to those who have parked without making payment for the time they have been parked on site. In the event you incorrectly enter your vehicle registration number, this may also result in a ticket.

Should you receive a parking charge you feel is unwarranted or issued in error please appeal. The appeals process is with APCOA Connect and NOT the hospital.

If you have your ticket or proof of payment then your penalty charge notice will be cancelled.

What should the driver approach the hospital with? "So sorry, didn't know, mea culpa, here's proof of my appointments?"

Thanks

Had this one come through and hoped the good folks here could help me as the keeper of the vehicle.

The driver had a self-paying appointment at Nuffield Health Parkside hospital. The driver had been there in the past and enjoyed free parking and received no fine.

The drive attended their appointment and left and then returned some days later for a follow-up.

I then received the following notice as the keeper

https://imgur.com/a/Lh6LRE8 - front

https://imgur.com/a/msIfPX9 - back

EDIT: Didn't know imgur was banned. Herewe go







Upon checking the hospital website it states:

There is no charge for private or self-paying patients.

NHS patients and all hospital visitors are required to pay the following parking fees:

[fees]

How do I pay for parking?
The hospital’s camera-controlled car parking system requires all visitors to enter their vehicle's registration number. Those who have to pay the charge will need to download the APCOA Connect app to make payment. The charging period for the car park is 24 hours a day including weekends and bank holidays.

What should I do now? I'm out of the country so I can't go and check the signage but the driver did not notice it on their visit (although they were going to somewhere they'd been many times before and may not have been looking for signs).

Many thanks as always!

Hello! Hope all are doing well!

Well here we are, nearly a year since the last update and after ignoring several debt collection service letters, I'm now the lucky recipient of a Letter before action from CE.

Letter attached (note that it's dated 04 September but received just a few days ago, probably around the 18th.

They've also included Annex 1 from here https://www.justice.gov.uk/documents/debt-pap.pdf and a Press Summary of two cases: Cavendish Square Holding v Talal El Makdessi and ParkingEye ltd v Beavis as well as some paperwork to fill in if one is unable to pay.

https://www.justice.gov.uk/documents/debt-pap.pdf

Letter: (not sure how to get it to embed?)

https://imgur.com/a/qC1ILkW

POPLA Appeal has come back - unsuccessful (explanation below for those interested) - what should be my next steps?

Many thanks!

Assessor summary of operator case
The operator has issued the PCN because the vehicle was parked on the site and failed to obtain a permit during the notified period.


Assessor summary of your case
The appellant has raised the following grounds of appeal: • The signage on the site does not comply with Section 19.3 and 19.4 of the British Parking Association (BPA) Code of Practice. • The evidence provided by the operator has been tampered with. • The operator has not provided adequate evidence of their authority to issue parking charges at this location. In the comments the appellant has advised the following: • The confirmation of appointment is not a contract. • The images provided by the operator show different timestamps which indicates potential tampering. • The signage does not comply with Section 19.4 of the BPA Code of Practice. The appellant has provided a document detailing their appeal.


Assessor supporting rational for decision
When assessing an appeal POPLA considers if the operator has issued the parking charge notice correctly and if the driver has complied with the terms and conditions for the use of the car park. The operator has provided evidence of the vehicle parked on the site for one hour and 11 minutes on the day in question. The data from the permit system shows that the vehicle had not been registered for a permit on the day of the incident. In this case, it is not clear who the driver of the appellant’s vehicle is, so I must consider the Protection of Freedoms Act (PoFA) 2012, as the operator issued the Parking Charge Notice (PCN) to the keeper of the vehicle. The operator has provided me with a copy of the notice to keeper sent to the appellant. I have reviewed the notice to keeper against the relevant sections of PoFA 2012 and I am satisfied that it is compliant. I will therefore be assessing keeper liability. The appellant has advised that the signage on the site is not compliant. The British Parking Association (BPA) has a Code of Practice which set the standards its parking operators need to comply with. Section 19.3 of the code states that signs must be placed throughout the car park so that drivers have the chance to review the terms and conditions. The code confirms that these signs must be conspicuous and legible and written in intelligible language so that they are easy to see read and understand. The operator has provided multiple images of the signs within the car park and after reviewing these, I am satisfied that there are plenty of signs located within the car park and that these signs meet the requirements of section 19.3 of the Code of Practice.The signage clearly advises that a permit is required to park and failing to obtain one is a breach of the terms. Further to the appellant’s statement that the operator’s evidence has been tampered with I am satisfied that the evidence the operator has provided is correct and has not been tampered with. The fact that there are different timestamps on some of the images does not invalidate the PCN in any way. Section 19.4 of the Code of Practice states that if parking operators intend to use the keeper liability provisions in Schedule 4 of the Protection of Freedoms Act (PoFA) 2012, the signs must give adequate notice of the charge. I have reviewed the signs and I am satisfied that the charge amount is clear as it has been highlighted to draw motorist’s attention to the amount. The appellant has questioned landowner authority .I note the appellant’s comments and I refer to Section 7 of the British Parking Association(BPA) Code of Practice which states in 7 .1 “If you do not own the land on which you are carrying out parking management, you must have the written authorisation of the landowner (or their appointed agent). The written confirmation must be given before you can start operating on the land in question and give you the authority to carry out all the aspects of car park management for the site that you are responsible for. In particular, it must say that the landowner (or their appointed agent) requires you to keep to the Code of Practice and that you have the authority to pursue outstanding parking charges. 7.2 If the operator wishes to take legal action on any outstanding parking charges, they must ensure that they have the written authority of the landowner (or their appointed agent) prior to legal action being taken. 7.3 The written authorisation must also set out: a the definition of the land on which you may operate, so that the boundaries of the land can be clearly defined b any conditions or restrictions on parking control and enforcement operations, including any restrictions on hours of operation c any conditions or restrictions on the types of vehicles that may, or may not, be subject to parking control and enforcement d who has the responsibility for putting up and maintaining signs e the definition of the services provided by each party to the agreement”. The operator has provided a confirmation of appointment document and I am satisfied that the operator has the authority to issue PCN’s on this site. The operator does not need to provide a full copy of the full contract as it may contain commercially sensitive information. The evidence provided in relation to this appeal meets the criteria POPLA requires, and therefore I am satisfied that the operator has sufficient authority at the site on the date of the parking event. After considering the evidence from both parties the vehicle was parked on the site and failed to obtain a permit during the notified period and therefore did not comply with the terms and conditions of the site. Based on the evidence provided, I am satisfied the parking charge has been issued correctly therefore, I must refuse the appeal.

It's just a comment box - can't upload or attach anything so mentioning is the best I can do...

On the landowner front I spoke to the Archdiocese who confirmed that the Parish Priest should be able to do this so I have no idea why he was reluctant. A further email may be in order...