Since my post, I spoke to staff at the venue and they are adamant they can't/won't do anything. They have a policy of not getting involved.
So - based on research over the past 48 hours here's what I'm planning to submit as an appeal. If anyone has a moment to suggest improvements, or point out any areas where I'm wasting my time, I would appreciate it massively.
Huge credit to user b789, who I hope doesn't mind that I have used part of a previous/unrelated post of theirs as the basis for some of this.
Thank you.
Re: Parking Charge Notice (PCN) No. [PCN Number]
Vehicle Registration No: [VRM]
Issue Date: 19/03/2026
I am appealing as the registered keeper of the vehicle. I am under no legal obligation to provide the driver’s details, and I decline to do so.
Civil Enforcement Ltd (CEL) has failed to comply with the strict requirements of Schedule 4 of the Protection of Freedoms Act 2012 (PoFA), which are necessary to hold the keeper liable. I outline the following points of non-compliance:
1. Failure to comply with PoFA schedule 4 paragraph 2(3):
Paragraph 2(3) further clarifies that 'adequate notice' means signs must clearly specify the parking charge and be positioned in such a way that the charge is brought to the attention of drivers. In this case, CEL did not display sufficient signage to meet this requirement.
2. Failure to comply with PoFA paragraph 9(2)(c):
PoFA paragraph 9(2)(c) requires that the Notice to Keeper describe how the parking charge arose and how the requirement to pay was brought to the attention of the driver. Given that CEL has failed to provide adequate notice as defined in paragraph 2(3), the Notice to Keeper does not comply with this requirement. CEL’s partial or substantial compliance with PoFA is insufficient to establish keeper liability, as full compliance with all PoFA requirements is mandatory.
In any event, CEL’s signage found at the car park is inconsistent and does not comply with the British Parking Association (BPA) Code of Practice in various ways, including but not limited to the following:
• The entrance sign refers to ‘Phone and Pay’, which is how payment by mobile phone USED to be accepted at this car park but has since been replaced by RingGo, while some other signs still refer to the 'Phone and Pay' website;
• The entrance sign displays none of the Group 1 wording found in the ‘Entrance Signs’ Annex of the BPA Code of Practice;
• The size of the text on the entrance sign is too small to meet the requirements found in the ‘Entrance Signs’ Annex of the BPA Code of Practice;
• Signs on the payment machines themselves state “Valid ticket must be clearly displayed in windscreen”, while other signs state the opposite: “There is no need to display a ticket in your windscreen”;
• CEL signs are inconsistent: some state, around halfway down, “Payment must be made within 15 minutes of arrival at the premises”, while another says in the same area of the sign “Payment must be made before leaving the car park”.
Furthermore, should CEL reject my appeal, I will expect them to provide the following evidence to POPLA:
• A detailed layout of the car park showing the location of all signage.
• Proof of the exact location where the vehicle was parked, and how this relates to any signage.
• Evidence that the signage used to display the parking terms and conditions is fully compliant with the BPA Code of Practice.
CEL will be put to strict proof of the vehicle’s parking location and the relationship of that location to any signs passed between the parking space and the Lido.
In light of these clear breaches of PoFA and the inadequate signage, I request that the Parking Charge Notice be cancelled.
