You should send the following Service Complaint to the SRA at contactcentre@sra.org.uk; phillip.archer@sra.org.uk and CC yourself:
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]
Also email the following as a refreshed conduct report for the SRA's "reports" in-box to: reports@sra.org.uk:
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]