Free Traffic Legal Advice

To whom it may concern,
I am the Registered Keeper of this vehicle. I was not the driver.
Chronology of Events
On 15th August 2025 the driver entered the Swallow Street Car Park at 09:25:46, as captured by an ANPR camera.
After considering the parking terms and charge, and downloading the necessary app to purchase parking, the driver purchased parking. Parking was paid for at 09:34, for four hours, as can be seen from the attached receipt.
The driver left returned to the car and left the car park at 13:36:19.
A Parking Charge Notice was issued on the grounds of ‘the vehicle was parked without a valid pay by phone transaction’.
Grounds for Appeal
The driver paid for parking. The time between arrival and purchasing a parking ticket using the RingGo app is less than 10 minutes, which accounts for the time taken to download the necessary app and make payment for the parking session.
The Single Code of Practice, to which Euro Car Parks is a signatory, details in Annex B that a grace period of at least 10 minutes should be allowed. The period between entry at 09:25 and purchase at 09:34 is within this permitted time.
The ticket expired at 13:34, and the vehicle exited at 13:36. The time between the end parking and leaving the car park is less than two minutes, again which falls within the grace period.
The driver complied with the terms of parking. The charge is therefore invalid and should not have been issued.
Furthermore, I note that your ‘Notice to Keeper’ is not fully compliant with ALL the requirements of Protection of Freedoms Act 2012, you are unable to hold the keeper of the vehicle liable for the charge. Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving, and no inference or assumptions can be drawn.
In light of the above, I respectfully request that this Parking Charge Notice be cancelled.
Please confirm cancellation of the charge, or alternatively provide a POPLA code so that this matter may be referred to independent adjudication.
Yours faithfully,

Grounds for Appeal
Ground 1: The driver paid for parking.
The time between entry to the car park and purchasing a parking ticket using the RingGo app is less than 10 minutes. The Single Code of Practice, to which Euro Car Parks is a signatory, details in Annex B that a grace period of at least 10 minutes should be allowed. The period between entry at 09:25 and purchase at 09:34 is within this permitted time. Given the need to find a space, download an app, register, input card details and purchase a parking session, I would suggest that this grace period is insufficient.
The parking session expired at 13:34, and the vehicle exited at 13:36. The time between the end of the parking and leaving the car park is less than two minutes, again which falls within the grace period. I would note that the time that the driver starts moving the car (i.e. is no longer parked) and the time that the vehicle leave the car park, are not the same and the time taken to move from the parking space and leave the site are not overstaying ‘parking’.
In short, the driver complied with the terms of parking. The charge is therefore invalid and should not have been issued.
Ground 2: The Notice to Keeper is non-compliant with PoFLA.
Furthermore, I note that your ‘Notice to Keeper’ is not fully compliant with ALL the requirements of Protection of Freedoms Act 2012. Partial or even substantial compliance is not sufficient. As the notice is non-compliant, you are unable to hold the keeper of the vehicle liable for the charge. There will be no admission as to who was driving, and no inference or assumptions can be drawn.
In light of the above, I respectfully request that this Parking Charge Notice be cancelled.
Please confirm cancellation of the charge, or alternatively provide a POPLA code so that this matter may be referred to independent adjudication.