You’re absolutely right to pause before contacting PALS, especially given that APCOA has not invoked the Protection of Freedoms Act (PoFA) in the Notice to Keeper. This means that they cannot hold the Keeper liable, and their only recourse is to pursue the driver. As such, preserving Keeper anonymity is key.
The risk lies in accidentally identifying the Keeper as the driver, which could undermine your ability to argue that no Keeper liability exists under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA), especially since APCOA is not relying on PoFA in this case. But it can be mitigated.
However, the legal risk is very low in practice because APCOA does not litigate. They have a long-standing policy of not pursuing claims through the County Court, even if appeals are exhausted or ignored. Therefore, the worst-case scenario is usually a series of debt collector letters, which the Keeper can safely ignore.
By contacting PALS without care can risk undermining your PoFA defence. But with the right wording, it is possible to make a powerful and safe representation that does not identify the driver. The goal is to raise the issue purely as the Registered Keeper without compromising that legal distinction.
Any contact therefore, should be from the Keeper, and written in the third person. For example:
“The driver was collecting a vulnerable patient following outpatient surgery. The vehicle remained on site for [X] minutes due to mobility difficulties. The Keeper received a PCN despite no parking contract being accepted.”
Any complaint to PALS should be treated as a complaint about patient experience and hardship, not a challenge to APCOA — and copy the Trust CEO if needed, to keep the focus on Trust accountability.
Try something like this:
Dear PALS Team,
I am contacting you as the Registered Keeper of a vehicle that has received a Parking Charge Notice (PCN) issued by APCOA in connection with a visit to Royal Berkshire Hospital on 27th March 2025. The PCN reference number is [INSERT PCN NUMBER].
The driver was at the hospital to assist a vulnerable patient (the driver’s mother), who needed to briefly enter the hospital to collect an item. Due to a lack of available parking on site, the vehicle was driven around and eventually waited in what appeared to be an EV charging bay. The engine remained running and the driver did not leave the vehicle at any point.
The Notice to Keeper was received on 10th April. The images provided are unclear and fail to show when the vehicle exited the site, making it uncertain whether the alleged contravention relates to parking at all, or merely a short period of waiting.
The PCN does not show any defined period of parking — only a single timestamp of 09:49. This makes it difficult to understand the basis of the allegation that the vehicle was parked without payment or a permit.
Given that this visit was entirely for the benefit of a vulnerable patient and no misuse of parking facilities occurred, I would be grateful if the Trust could:
• Confirm whether it supports the issuance of PCNs in cases where the driver remains in the vehicle;
• Consider cancelling this charge on compassionate or discretionary grounds;
• Confirm whether a Trust policy exists for handling complaints about parking enforcement by APCOA.
Please ensure that this correspondence is not shared with APCOA without my express consent.
Kind regards,
[Full Name]
Registered Keeper
[Vehicle Registration]
