Free Traffic Legal Advice

You will not get anything meaningful from Horizon now. Gladstones have issued a Letter of Claim (LOC), so you respond to Gladstones and you deny any liability.

Do not identify the driver. Respond only as the registered keeper.

State that their client is put to strict proof of a single continuous period of parking for the full duration alleged. Explain that the “evidence” provided (first entry and last exit only) is entirely consistent with a double-dip/missing ANPR capture, i.e. two short visits with the first exit and second entry not recorded, and that ANPR systems are well known to produce that failure mode.

Point out that their client is required to comply with the Private Parking Single Code of Practice (PPSCOP) requirements for ANPR quality control. In particular, PPSCoP clause 7.3(d) requires manual quality control checks, including the risk of errors, and Note 1 expressly highlights the need to detect “double dipping” where the system fails to record each instance of entry/exit. Their client is therefore expected to search for and match all ANPR images for the vehicle for the material date and to locate and correctly attribute any orphan images (unmatched entry/exit captures) before issuing or pursuing a charge.

Require, as part of your LOC response, copies of the evidence and documents relied upon, including:


Make clear that if they proceed without addressing the double-dip issue and without providing the above, that will be unreasonable conduct in pre-action correspondence, and you will draw it to the court’s attention.

The NtK has arrived and it is still not PoFA compliant, so they cannot transfer liability to you as keeper.

This was a windscreen ticket on 28/11/2025. The NtK is dated 30/12/2025. The timing is within the PoFA window for a Notice to Keeper following a Notice to Driver, so you cannot win on service timing.

However, the NtK fails a mandatory PoFA requirement. Schedule 4 paragraph 8(2)(h) requires the Notice to Keeper to identify the creditor. This NtK does not do that. It uses the trading name “Ace Security Services” and then says “We, the Creditor…”, but it does not clearly identify any legal person who is for the time being entitled to recover the unpaid parking charge. A trading name is not a legal person for PoFA purposes. Because PoFA requires strict compliance, the failure to identify the creditor is fatal to keeper liability.

They also state that they requested keeper details from the DVLA because they “do not know both the name of the driver and a current address for service for the driver”. That is irrelevant to keeper liability. The issue is that they have not complied with PoFA, so they have no right to recover anything from you as keeper in any event.

At this stage you should not identify the driver, should not enter into further debate with Ace, and should simply file everything. If they attempt a court claim against you as keeper, the defence is that PoFA keeper liability does not arise because the NtK does not identify the creditor as required by paragraph 8(2)(h), and the claimant is put to strict proof of their legal standing and entitlement to recover the charge.

Separately, a DVLA and ICO complaint is now arguable because you had already written to Ace as the registered keeper and Ace had acknowledged that correspondence, yet they still say they obtained keeper data from the DVLA. Obtaining personal data from the DVLA when they already held your name and address is unnecessary and excessive processing, contrary to the data minimisation principle in Article 5(1)(c) UK GDPR, and it is not necessary for any legitimate interests lawful basis under Article 6(1)(f). This is exactly why you were told in advance not to go to the DVLA.

So the advice now is: do nothing further with Ace, do not name the driver, keep the paperwork, and if you want to apply pressure, proceed with a formal DVLA complaint (with your keeper email date and Ace’s acknowledgement attached) and escalate to the ICO if needed.

You can use this as the core of your DVLA complaint:

I am the registered keeper of vehicle [VRM]. I am making a formal complaint regarding Ace Security Services/Pace Recovery & Storage Ltd obtaining my personal data from the DVLA without reasonable cause.

On [date] I contacted the operator directly as the registered keeper in relation to Charge Notice [PCN number]. In that correspondence I provided my full name and a current address for service (the address shown on the V5C). The operator replied on [date], acknowledging receipt of my email and engaging with my correspondence. The operator therefore already held my keeper identity and serviceable address.

Despite already holding my personal data, the operator subsequently requested and obtained my registered keeper details from the DVLA. Their Notice to Keeper dated 30/12/2025 expressly states that they obtained my details from the DVLA. This DVLA request was unnecessary and excessive because my name and address were already known to the operator and had been acknowledged in writing.

In these circumstances, the operator did not have “reasonable cause” to obtain my data from the DVLA. The stated purpose of requesting keeper data is to identify and contact the registered keeper. That purpose had already been fulfilled before the DVLA request was made.

Obtaining my data from the DVLA when it was not necessary constitutes a breach of the data minimisation principle under Article 5(1)(c) UK GDPR, which requires that personal data be adequate, relevant and limited to what is necessary for the purposes for which it is processed. It is also not “necessary” for any lawful basis under Article 6(1)(f) UK GDPR (legitimate interests), because the operator could already correspond with me as keeper without any DVLA disclosure.

I therefore ask the DVLA to investigate and confirm:

1. The date on which my personal data was disclosed to the operator and under what justification.
2. What reason the operator provided to the DVLA to demonstrate “reasonable cause”, given that they already held my name and address.
3. Whether the operator’s request complied with the KADOE contract requirement that keeper data must only be requested where it is necessary.
4. Whether DVLA considers it lawful for an operator to obtain DVLA keeper data where the keeper has already provided the same information directly and that information has been acknowledged.

I request confirmation of the outcome of the DVLA’s investigation and any action taken.

Evidence enclosed:

– Copy of my email to the operator dated [date/time] providing my keeper details
– Copy of the operator’s reply dated [date/time] acknowledging my correspondence
– Copy of the Notice to Keeper dated 30/12/2025 confirming that my data was obtained from the DVLA

You can use the following as the core of your ICO complaint:

I am the registered keeper of vehicle [VRM]. I am making a complaint about unnecessary and excessive processing of my personal data by Ace Security Services/Pace Recovery & Storage Ltd.

On [date] I contacted the organisation directly as the registered keeper regarding Charge Notice [PCN number]. In that correspondence I provided my full name and a current address for service (the address shown on the V5C). The organisation replied on [date], acknowledging receipt and engaging with my correspondence. They therefore already held my personal data (name and address) sufficient to correspond with me.

Despite already holding my details, the organisation then requested and obtained my registered keeper data from the DVLA. Their Notice to Keeper dated 30/12/2025 states that they obtained my details from the DVLA. This additional acquisition of my personal data from a third party was unnecessary and duplicative.

Obtaining my personal data from the DVLA when it was not necessary breaches the data minimisation principle in Article 5(1)(c) UK GDPR (personal data must be adequate, relevant and limited to what is necessary). It is also not “necessary” for the purposes of any lawful basis under Article 6(1)(f) UK GDPR (legitimate interests), because they already held my name and address and could correspond with me without making any DVLA request.

I have raised the matter with the DVLA as the data source and asked them to investigate whether there was reasonable cause for the disclosure. However, this complaint concerns the organisation’s processing decision to obtain additional personal data from the DVLA despite already holding it.

I ask the ICO to consider whether the organisation has complied with its UK GDPR obligations, in particular:

1. Article 5(1)(c) data minimisation, given the DVLA request was not necessary once my keeper details were already held.
2. Article 5(1)(a) lawfulness and fairness, because obtaining additional data from the DVLA without necessity is not fair or lawful processing.
3. Article 6(1)(f) necessity under legitimate interests, as the additional DVLA data was not necessary to pursue the stated purpose.

Evidence enclosed:

A. My email to the organisation dated [date/time] providing my name and address.
B. The organisation’s reply dated [date/time] acknowledging receipt.
C. The Notice to Keeper dated 30/12/2025 stating that my data was obtained from the DVLA.

Please confirm whether the ICO considers this unnecessary third-party data acquisition to be compliant with UK GDPR, and what steps the organisation should be required to take to prevent repetition.

You should not wait for the managing agent. Submit the keeper appeal to the operator within the deadline (without naming the driver) and run the managing agent complaint for cancellation at the same time.

I thought t this was a DCB Legal issued claim but I see that it is Elms Legal, which is why it was not discontinued. You need to call Reading county court on 0118 987 0500 and confirm that they have paid the £27 trial fee.

We need to see the cover letter that came with that bundle. Jake Burgess invariably states in the cover letter that he may not attend the hearing (he ever does) and that is often his downfall.

Every page is numbered and there are over 40 pages in that bundle from what I can see. Where is their landholder contract that proves standing to operator and issue PCNs at the location?

So, you need to show us everything that came with that bundle/WS, including the cover letter. Also, show us the Particulars of Claim (PoC) as all the previous images have been deleted.

As long as you did NOT select the option identifying as the driver and that is the sum total of your appeal, you will be OK. If you did identify as the driver, then you have wasted the easiest ever way to get this cancelled. As long as the driver is NOT identified, APCOA have no way to transfer liability from the unknown (to them) driver to the known Keeper.

This is the normal appeal that is guaranteed to get the PCN cancelled, whether at Heathrow or any other airport that uses barrier-less (ANPR) entrapment for extorting the drop-off/pick-up fee:

I am the registered keeper. APCOA cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control. As a matter of fact and law, APCOA will be well aware that they cannot use the PoFA provisions because [name of airport] Airport is not 'relevant land'.

If [name of airport] Airport wanted to hold owners or keepers liable under Airport Bylaws, that would be within the landowner's gift and another matter entirely. However, not only is that not pleaded, it is also not legally possible because APCOA is not the Airport owner and your 'parking charge' is not and never attempts to be a penalty. It is created for APCOA’s own profit (as opposed to a bylaws penalty that goes to the public purse) and APCOA 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. APCOA have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.

So, did you identify the driver by selecting anything other than "Keeper" or "Other"?

Whilst the above appeal is guaranteed to get the PCN cancelled, it does not mean that you have to pay a penny to APCOA, because they are benign. They NEVER litigate but it does mean that you have prolonged the process by many many months because, if the driver is identified, they do have the name of the liable party. That means after a POPLA appeal which is unlikely to be successful, the Keeper will start to receive a load of useless debt recovery letters.

Debt collectors are not a party to the contract allegedly breach by the driver and have no standing to sue or do anything except to try and intimidate the low-hanging fruit on the gullible tree into paying out of ignorance and fear. You can safely ignore all debt recovery letters and, as far as anyone's concerned, you can use them as free emergency loo paper or shred them and use them as hamster bedding.

As it is APCOA, the debt collectors will eventually hand the case back to APCOA and they will give up and move on to more gullible victims. So, even if you do nothing else, nothing will come of this in the long run.

So, has the driver been identified?

1) I appealed within the original deadline, and I'm positive I definitely wrote it. I use a grammar app that hates "I's", so maybe it wasn't written in first person. However, I never received any confirmation, so now I'm starting to doubt whether I appealed or not.

2) Can you explain PoFA and NtK?

3) I will go back to the site from the entry to the parking space to get pictures of the journey. not far from me.

4) For the email, whose email is this being sent from, the keeper or the driver (me)? And if I cc myself, doesn't that imply I'm the one driving?

5) What is the Letter of Claim (LoC)? What are the chances, and in which situations am I most likely to receive it?

6) All debt collectors' notices will be ignored.

To answer your questions:

1) Only the SAR response will confirm whether you identified the drive or not. If you're not sure, then we should work on the assumption that the driver is identified but without any further confirmation, just in case.

2) PoFA is the only legislation that allows a private parking operator to hold a registered keeper liable when they do not know who the driver was. That right only exists if the operator strictly complies with every mandatory condition set out in Schedule 4. If any one condition is not met, keeper liability does not arise.

One of those mandatory conditions is paragraph 9(2)(a). Parliament did not draft the Act to say that a Notice to Keeper must state observation times, photo times, or evidence timestamps. It specifically said the notice "MUST specify the period of parking to which the notice relates". That wording is deliberate. Because PoFA allows an operator to pursue someone who may not have been the contracting party, Parliament required clarity and certainty about what parking period is actually being alleged.

This Notice to Keeper does not specify any period of parking. It merely lists “observation time(s)”. It does not say the vehicle was parked between those times, it does not say the vehicle was observed continuously, and it does not say those times represent the start and end of the parking period. Observation times are simply evidential moments when an attendant noted or photographed the vehicle. They are not, and are not described as, a "period of parking". A vehicle could have been parked before observation began and still parked after observation ended, or it may not have been parked throughout at all. That uncertainty is exactly what paragraph 9(2)(a) is designed to prevent.

To comply with PoFA, the operator only needed to clearly state the alleged period of parking on the face of the Notice to Keeper. For example, they could have said: “The period of parking to which this notice relates was from [21:59] to [22:15]”, or “The vehicle was parked in breach of the terms from [21:59] to [22:15]”. Even if those times were based on attendant observations, the notice needed to explicitly identify them as the "period of parking" relied upon.

Because the operator did not do that, and instead relied on undefined “observation times”, the Notice to Keeper fails to meet the strict requirement of PoFA Schedule 4 paragraph 9(2)(a). As PoFA compliance is 100% mandatory, liability cannot be transferred to the Keeper. The operator is therefore limited to pursuing the driver only and must be put to strict proof of driver identity. Which is why the driver must never be identified in private parking invoice cases.

4) Use your own email address. You are writing as the registered keeper.

The keeper is under no legal obligation to identify the driver, and the email address you use does not prove who was driving. It is simply a contact method. As long as you do not write anything that identifies the driver (no “I parked”, “I didn’t see the signs”, “when I returned to the car”, etc.), there is nothing about an email address that turns a keeper into the driver.

CCing yourself does not imply you were the driver either. People CC themselves for record-keeping all the time. It is no different in principle from keeping a copy of a posted letter. It does not evidence driving, it evidences that you sent an email and kept a copy.

The only thing that matters is the wording. Write strictly in the third person: “the driver”, “the vehicle”, “the operator”, “the site”. Do not describe the driver’s actions as your own, and do not use “I” in a way that could be read as “I was driving”. If you keep to that, your email address and CC are irrelevant.

5) A Letter of Claim (LoC) is a formal pre-court letter sent by a parking operator or, more commonly, their bulk litigation solicitors. It states that they intend to issue a county court claim if payment is not made within 30 days (not the usual 14 days in useless debt recovery letters) and should include reply forms and information required under the pre-action protocol. It is not a court claim and it does not affect your credit record. Nothing we advise on will affect your credit record, even if you were one of the 0.1% that were unsuccessful. It is simply the step that comes immediately before a claim might be issued.

In this case, the operator is a relatively new entrant and this is the first PCN I have seen from them. New operators typically follow the same industry model as the established firms, including using bulk litigation solicitors if matters are escalated.

In practice, an LoC is very often just an extension of the debt recovery process rather than a genuine intention to go to trial. The legal language is used to intimidate recipients into paying out of fear or lack of understanding, not because the case is strong.

The reality is that the vast majority of private parking claims never reach a hearing. Many are struck out for procedural or legal defects, or more likely, discontinued once the defendant responds properly and demonstrates an understanding of the process. Of the extremely small number that do reach a hearing, defendants win a significant proportion of them.

The business model is not built around taking cases to trial. It relies on volume. The operator hopes that the recipient will either not respond at all (resulting in a default judgment) or will capitulate and pay. Once it becomes clear that the keeper or defendant is engaged, informed, and prepared to defend, the commercial incentive to pursue the claim usually falls away.

Yes. Email is the preferred method of communication. It is instant and you have proof of sending and receipt. Uses no paper, only electrons.

Thank you for the email exchange. Although the managing agent stated prior to move-in that up to two vehicles could be registered and that there was ‘no visitor parking’, the tenancy itself contains no parking terms at all.

The pre-tenancy emails are inconsistent and internally contradictory: visitors are variously described as permitted provided the vehicle is not left unattended, subject to random in-person checks, and also as liable to ticketing because the agent has ‘little or no control’ over the parking contractor. Those emails do not impose any clear, certain or enforceable restriction on the use of the tenant’s own numbered bay, nor do they evidence any agreed contractual variation of the tenancy. In particular, they do not prohibit an authorised guest from parking in the tenant’s allocated bay, and instead demonstrate an unmanaged, arbitrary enforcement regime operated by a third party without proper oversight.

Letting/Property Management agents in England must belong to a government-approved redress scheme. The two common ones are:

If they’re a letting/managing agent, you can threaten escalation to whichever scheme they are a member of (you can ask them which scheme, or it may be in their email footer/website).

If it’s a block managing agent (not your letting agent), they may also be a member of:


Separate to “ombudsman” style redress, you can also credibly mention escalation to:


You should send the following email to the managing agent and CC yourself with any correspondence:

Subject: Formal Complaint: Parking Charge Notice [PCN NUMBER] Issued to Authorised Visitor in Allocated Bay

Dear [Managing Agent Name],

I am writing to formally notify you that a Parking Charge Notice [PCN NUMBER] has been issued by your parking contractor to an authorised visitor of mine, whose vehicle [VEHICLE REGISTRATION MARK] was parked correctly in my own numbered bay.

As you are aware, my tenancy agreement and welcome pack contain no terms whatsoever relating to parking, permits, visitor restrictions, or third-party enforcement. There is no contractual requirement within my tenancy to display permits, to comply with contractor signage, or to restrict the use of my allocated bay, including by an authorised visitor.

Prior to moving in, I raised parking queries with you and received conflicting and unclear information. Visitors were variously described as permitted provided vehicles were not left unattended, subject to “random” in-person checks, and also as potentially ticketed because you have “little or no control” over the external contractor. At no point was it stated that an authorised visitor could not park in my own numbered bay, nor was any visitor permit or registration mechanism offered.

The issuing of a parking charge to my authorised visitor while parked correctly in my own bay is therefore wholly unreasonable and unsupported by my tenancy. Although the charge has been issued to my visitor, the interference is with my tenancy rights, including my right to quiet enjoyment and my ability to make lawful use of my allocated parking space. Your contractor has no lawful basis to penalise an authorised guest using my bay.

As the party who appointed the contractor, responsibility for their actions rests with you. I require you to immediately instruct your agent to cancel this Parking Charge Notice. If this charge is not cancelled and your contractor continues to pursue my visitor (including by debt recovery or litigation), I will treat that as a matter for which you are jointly responsible as principal, and I will consider taking action against you directly and/or seeking to join you to any proceedings, together with a claim for any resulting loss and distress.

If you do not resolve this matter, I will escalate a formal complaint through your complaints procedure and then to your redress scheme (TPO or PRS as applicable), as well as to the landlord/freeholder.

Please confirm by return that cancellation has been instructed.

Yours sincerely,

[Tenant Name]