Free Traffic Legal Advice

Yes, there is a route to claim against Horizon, but you should follow the correct order of steps before going anywhere near a court. First, appeal the PCN and make no admission as to who was driving.

Please post up the Notice to Keeper (NtK) with all dates and times visible so we can check for compliance with the Protection of Freedoms Act 2012 (PoFA).

This is a textbook “double dip”. The ANPR system recorded four events (Entry 1 → Exit 1 → Entry 2 → Exit 2) but Horizon incorrectly paired Entry 1 with Exit 2 to fabricate a single long stay. The intermediate Exit 1 and Entry 2 images are orphaned (recorded but not assigned).

The mandatory manual quality control check in PPSCoP 7.3(d) & Note 1 exists to detect exactly this and correctly pair the orphan images into two short visits. Horizon’s failure to do so means they lacked reasonable cause to obtain the keeper’s data from the DVLA, amounting to unlawful processing under the UK GDPR/Data Protection Act 2018.

The PPSCoP is explicit about this in Section 7.3(d) and Note 1:


By failing to pair the “orphan” entry/exit images from each visit, Horizon did not perform the mandatory manual quality control check. That means they had no “reasonable cause” to request your keeper data from the DVLA.

That is a breach of the UK GDPR / Data Protection Act 2018, and you are entitled to claim compensation for misuse of personal data and the distress caused. The normal process would be:


If you have Ring doorbell footage showing the vehicle at home between visits, keep that safe — it’s key evidence that Horizon failed to carry out the required PPSCoP checks before making the DVLA request.

You should send the following appeal and at the same time submit a complaint to the DPO of Horizon. Here is the appeal:

PCN Appeal (to Horizon Parking)

Subject: Appeal – PCN [insert number] – Vehicle Registration [insert VRM]

Dear Sir/Madam,

I am the registered keeper of the above vehicle. I dispute your parking charge and require you to cancel it immediately.

This is a case of “double dip” ANPR error. On 2 August 2025, the vehicle visited the site twice: once in the morning, and again in the afternoon. The ANPR system recorded four events (Entry 1 → Exit 1 → Entry 2 → Exit 2).

You have incorrectly paired Entry 1 with Exit 2, creating the false impression of one continuous stay. The intermediate Exit 1 and Entry 2 images are “orphan” images that were recorded by your system but not assigned.

Section 7.3(d) of the Private Parking Single Code of Practice requires:

“Photographic evidence must not be used… unless images generated by ANPR… have been subject to a manual quality control check…”

Note 1 makes it explicit that this check is particularly important to detect double-dip scenarios and to pair orphan images with the correct vehicle.

Your failure to perform this mandatory check means you had no reasonable cause to request my details from the DVLA. This is a breach of the UK GDPR and the Data Protection Act 2018.

I require you to:

• Cancel the PCN immediately.
• Erase my personal data from your systems, except for a record of this request.
• Confirm in writing within 14 days that you have done so.

If you reject this appeal, you must provide a POPLA code so that I can escalate the matter.

Yours faithfully,

[Name]
Registered Keeper

GDPR / Data Protection Complaint (to Horizon DPO)

Subject: Data Protection Complaint – Unlawful Processing of Keeper Data – PCN [insert number]

Dear Data Protection Officer,

I am the registered keeper of vehicle [insert VRM]. I am making a formal complaint regarding your unlawful processing of my personal data in connection with PCN [insert number].

On 2 August 2025, your ANPR system recorded four images:

Entry 1 → Exit 1 → Entry 2 → Exit 2.

You incorrectly paired Entry 1 with Exit 2, fabricating a single long stay. The intermediate Exit 1 and Entry 2 images are “orphaned” and should have been identified and correctly assigned as part of the mandatory manual quality control check required by Section 7.3(d) and Note 1 of the Private Parking Single Code of Practice.

Had you performed that check, the orphan images would have been correctly paired to show two short visits, and no PCN would have been issued. This means you had no reasonable cause to request my keeper details from the DVLA.

Your DVLA request was therefore unlawful and in breach of:

• UK GDPR Article 5(1)(a) – Lawfulness, fairness, transparency.
• UK GDPR Article 6(1)(f) – No legitimate interest when the data request was based on an ANPR error that should have been eliminated by quality control.
• Data Protection Act 2018 – Section 171 (unlawful obtaining of personal data).

This unlawful processing has caused me distress and wasted my time in dealing with a baseless parking charge. I require:

• Immediate cancellation of the PCN.
• Written confirmation that you have erased my personal data from your systems, except for a record of this complaint.
• A full written apology.
• Compensation for the distress caused by your breach, in accordance with s.168 Data Protection Act 2018.

If you fail to resolve this within 30 days, I will escalate my complaint to the Information Commissioner’s Office (ICO) and reserve my right to pursue a claim in the County Court for damages.

Yours faithfully,

[Name]
Registered Keeper

Thanks for this.

I’m an optimistic soul but even I think they’ll reject my appeal.

I’ll report back when they do.