Free Traffic Legal Advice

Hi All,

Looking for some advice on the wording of my complaint (never had to do one of these before!) towards G24 Ltd in response to a false Contractual Parking Charge Notice I've received at the Reading Gateway Retail Park, Imperial Way, Reading (RG2 0TA).

The Notice states that I have parked overnight at this car park, which is factually incorrect. This car park is the site of a Premier Inn hotel where late evening on 14th November, I dropped off two friends who were staying in Reading, and then on the morning of the 15th November, I picked them up again as we were heading to Heathrow. I have google timeline records to prove that after the times stipulated on the notice, I was not in the car park but actually at my house 5 miles away. I will also go check my dash cam after this and see if it still has a recording from those dates to show me driving away as extra supporting evidence. 

I can only assume I've been charged due to the fact this car park has two separate entrances, one just off Imperial Way and one off the Basingtoke Road. I used both different exits on the Thursday when I dropped off my friends, entering first using the Imperial Way entrance, dropping my friends off outside the front of the hotel, then exiting via the Basingstoke Road entrance to continue to my house south of the town.

Instead the notice alledges that I entered the car park on 14th Nov @21.57.18pm and left it on the 15th Nov 06.54.51pm and that I was parked stationary for the duration of that. I've attached a photo of the notice, as well as screenshots of my timeline showing me away from the hotel at those times.

Any advice on how to structure a complaint would be most welcome.

Many Thanks!
Ben

[ Guests cannot view attachments ]

I have removed your last attachment. It may be wise to remove your name and home address, as well as your vehicle registration mark and PCN number.

Apologies, ill go fix that now and reupload

I doubt that they will give in but, for what it's worth, you could make a formal complaint to G24 with the following:

Quote

Subject: Formal Complaint Regarding Incorrect Parking Charge Notice (PCN Reference: [Insert Reference])

Dear G24 Ltd,

I am writing as the Keeper of the vehicle in relation to Parking Charge Notice (PCN) reference number [Insert Reference], issued concerning alleged parking at Reading Gateway Retail Park, Imperial Way, Reading (RG2 0TA) from 21:57 on 14th November 2024 to 06:54 on 15th November 2024. The assertion that the vehicle remained parked overnight during this period is factually incorrect.

The vehicle in question was used by the driver on two distinct occasions at this location. The driver entered the car park on the evening of 14th November to drop off passengers at the Premier Inn. The vehicle was subsequently driven away from the site. The driver returned to the car park the following morning, 15th November, to collect the same passengers and exited promptly thereafter.

Your ANPR system has failed to record both visits accurately, instead erroneously combining them into a single continuous stay. This is a clear example of “double dipping”, where an ANPR system fails to accurately record all instances of a vehicle entering and leaving controlled land.

Supporting Evidence:

1. Google Timeline Records: Attached are timeline records showing that the vehicle was not on the premises during the alleged overnight parking period.

2. Dash Cam Evidence (if applicable): Additional footage is being retrieved for further corroboration, if necessary.

3. Pattern of Movement: It is likely that the vehicle's use of different access points (Imperial Way and Basingstoke Road) contributed to the ANPR system’s failure to register each movement correctly.

Breach of the Single Code of Practice (Section 7.3):

Your failure to conduct the required manual quality control check of ANPR data before issuing this PCN constitutes a direct breach of Section 7.3 of the Single Code of Practice, which states:

“The manual quality control check for remote ANPR and CCTV systems is particularly important for detecting issues such as 'double dipping', where image camera systems might have failed to accurately record each instance when a vehicle enters and leaves controlled land…”

Had this mandatory check been performed, it would have revealed the error in your system’s data and prevented the issuance of this incorrect PCN. This failure not only contravenes the Single Code of Practice (SCoP) but also raises concerns regarding the lawfulness of your request for the vehicle keeper’s data from the DVLA.

Requested Actions:

1. Immediate Cancellation of the PCN: The incorrect PCN must be cancelled without delay.

2. Deletion of Personal Data: All personal data relating to the Keeper must be deleted from your records, including any information shared with third parties, in accordance with Article 17 of the UK General Data Protection Regulation (GDPR) (Right to Erasure).

3. Written Confirmation: Provide written confirmation of the above actions within 14 days of receipt of this letter.

Consequences of Non-Compliance:

Should you fail to comply with these requests, I will have no hesitation in escalating this matter by:

• Filing complaints with the DVLA and the International Parking Community (IPC) regarding your non-compliance with the Single Code of Practice and misuse of ANPR systems.

• Lodging a formal complaint with the Information Commissioner’s Office (ICO) concerning your unlawful processing of personal data.

• Initiating legal proceedings for compensation under the Data Protection Act 2018, as this error and mishandling of personal data have caused significant distress.

I trust that you will take this opportunity to resolve the matter swiftly. I look forward to your written confirmation of the PCN's cancellation and the deletion of personal data within 14 days of this correspondence.

Yours faithfully,

[Your Full Name]
Registered Keeper of Vehicle [Registration Number]

Thanks for the swift reply! Just checked my dashcam and whilst i don't have footage of me driving away, i do have parking mode clips during that night showing my car in front of my house and not at the hotel. The back of the form says to either appeal via post or by appealyourcharge.co.uk, I assume the above would be ok for using the appeal your charge website?

Keep hold of that footage. Are those clips time-stamped?

They are timestamped and also have coordinates on them.

Save your letter as a PDF file and attach it to an email addressed to info@g24.co.uk. Mark it as a "complaint" not an appeal. Make sure you edit the places in the letter that require editing. You can put the PCN number in the subject field of the email and just state in the body to see the attached formal complaint.

They are required to treat complaints as appeals anyway.

You should make a complaint to the DVLA anyway about G24 having requested your data unlawfully in breach of the KADOE contract. By breaching section 7.3 of the SCoP, having failed to carry out the necessary quality control check of the ANPR images, thus breaching the KADOE contract, you would like to know what sanctions the DVLA intend to take against G24.

Noted thanks, I shall do that now. Regarding contacting the DVLA, do you have a suggested route or email address for contacting them at all?

Save your letter as a PDF file and attach it to an email addressed to info@g24.co.uk. Mark it as a "complaint" not an appeal. Make sure you edit the places in the letter that require editing. You can put the PCN number in the subject field of the email and just state in the body to see the attached formal complaint.

They are required to treat complaints as appeals anyway.

You should make a complaint to the DVLA anyway about G24 having requested your data unlawfully in breach of the KADOE contract. By breaching section 7.3 of the SCoP, having failed to carry out the necessary quality control check of the ANPR images, thus breaching the KADOE contract, you would like to know what sanctions the DVLA intend to take against G24.

Got a generic response this morning from info@g24.co.uk just detailing their appeals process which is to write to their address or use the appealyourcharge.co.uk website. Seems like they have just ignored the fact its a complaint and just gone straight to thinking its an appeal...

If their appeals portal will accept a submission you could submit your complaint via that portal.

Or get back to them and point out that their ATA Code of Practice requires them to respond to complaints, and that 11.2 of that code requires them to treat any complaint that they consider to include an appeal as an appeal.

Ideally you want them to engage with the substance of your message one way or another.

Rereading their email, they do say that "If you wish to make a complaint, please write to the above PO BOX (and then states a address)", Im assuming then that this would cover them from the not responding to a complaint part?

Their appeals process does have a big free text box so I guess I could copy what was written in the attached PDF (as per above in this thread) and put it in that system? Given my evidence is digital, id prefer to use email/submission portal unless it is absolutely necessary or highly advised not to.

Apologies for all the questions, never had to deal with something like this before!