3. Parking Charge UK Car Park Management
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Re: Parking Charge UK Car Park Management
« Reply #15 on: »
You are not the RK. You are assisting the RK. The land is not relevant for the purposes of PoFA. The response to the appeal you were advised to tell the Keeper to send, says that you (whoever made the appeal) have been named as the driver and a new PCN will be issued in your (the drivers?) name.

It sounds as though whoever appealed the PCN, didn’t use the wording as advised. We have no idea who actually appealed and whether they did so in the name of the Keeper ot ‘on behalf’ of the Keeper.

This all needs clarifying as it would seem that this simple NtK has been FUBAR’d.
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Re: Parking Charge UK Car Park Management
« Reply #16 on: »
Correct, not hirer or lessee.

I'm not sure what that means, it is puzzling.
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Re: Parking Charge UK Car Park Management
« Reply #17 on: »
I give in. Until we know who is the Keeper (person A), who is the person who made the appeal, if different from person A (person B).

Person A is the Keeper. They may also be the driver but we don’t need to know this and neither does the parking firm.

According to what we’ve been told, there is a person C who has been named as the driver and the parking firm are going to send a notice to them in their name.

All tha should have happened is that person A should have appealed as the Keeper and declined to identify the driver. Had that happened, we would know where we stand and this could easily hav be een dealt with.

Now we only have cryptic answers to questions that I am no longer bothered to answer,
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Re: Parking Charge UK Car Park Management
« Reply #18 on: »
Update for @amuk786 regarding this case. I submitted the following FoI request to the London Borough of Redbridge:

Quote
Dear FOI Team,

Under the Freedom of Information Act 2000, I request the following information regarding parking enforcement at Cranbrook Primary School, The Drive, Ilford, IG1 3PS:

Has the London Borough of Redbridge, or any delegated authority thereof, contracted UK Car Park Management (CPM) to operate parking enforcement services at the above site?

If so, please provide:

• The name of the contracting party or authority.
• The date the contract was initiated.
• The scope and duration of the contract.
• A copy of the contract or agreement (with any necessary redactions).

If CPM was contracted by the school directly, please confirm whether the school had delegated authority from the borough to enter into such an agreement concerning land use and enforcement.

This request concerns the legitimacy of private enforcement activity on land that appears to fall under local authority control. Please treat this as a matter of public interest and procedural accountability.

I look forward to your response within the statutory 20 working days.

Yours faithfully,

B789

They have responded today with the following:

Quote
Dear B789

Freedom of Information Act 2000

Thank you for your request for information received on 31 July 2025

This request is being handled under the Freedom of Information Act 2000

Section 1 of the Freedom of Information Act 2000 provides two distinct but related rights of access to information which impose corresponding duties on public authorities. These are:

• The duty to inform the applicant whether or not information is held by the authority
and, if so,
• The duty to communicate that information to the applicant.

Request

Under the Freedom of Information Act 2000, I request the following information regarding parking enforcement at Cranbrook Primary School, The Drive, Ilford, IG1 3PS:

• Has the London Borough of Redbridge, or any delegated authority thereof, contracted UK Car Park Management (CPM) to operate parking enforcement services at the above site?

If so, please provide:

• The name of the contracting party or authority.
• The date the contract was initiated.
• The scope and duration of the contract.
• A copy of the contract or agreement (with any necessary redactions).

If CPM was contracted by the school directly, please confirm whether the school had delegated authority from the borough to enter into such an agreement concerning land use and enforcement. This request concerns the legitimacy of private enforcement activity on land that appears to fall under local authority control. Please treat this as a matter of public interest and procedural accountability.

I am writing to advise you that, following a search of our paper and electronic records, I have established that the information you requested is not held by London Borough of Redbridge. Please contact Private Parking firm directly for the requested information.

Redbridge did meet s1(1)(a) FOIA in saying “information ... is not held”, but the reply falls short of the duty to advise and assist under s16 and the Section 45 Code. They told me to “contact [the] Private Parking firm,” which is not a public authority for FOIA purposes, instead of identifying/redirecting to the most likely public holder (the school/governing body) or considering a transfer. They also didn’t address obvious council-held points my request covered—e.g., whether Redbridge is the landowner or has granted any delegation to the school regarding parking enforcement—matters the Council should be able to confirm even if it doesn’t hold the CPM contract itself.

So, I am pursuing an internal review and have asked them:

Quote
Subject: Request for Internal Review

Dear FOI Team,

I am writing to request an internal review of your response to my Freedom of Information request regarding the contracting of UK Car Park Management (UKCPM) at Cranbrook Primary School.

Your reply stated that the information I requested is not held by the London Borough of Redbridge and advised me to contact the private parking firm directly. I believe this response is inadequate for the following reasons:

1. Failure to confirm land ownership and delegation
Even if the Council does not hold the UKCPM contract itself, you are still able – and obliged – to confirm whether the land in question is Council-owned or controlled, and if so, whether any delegation has been granted to the school governing body to enter into such arrangements. This is relevant context squarely within the scope of my request.

2. Duty to advise and assist (s16 FOIA)
The Section 45 Code of Practice requires public authorities to advise and assist applicants. Directing me to contact a private company that is not subject to FOIA does not satisfy this duty. You should instead have identified or signposted the correct public body likely to hold the requested information – in this case, the governing body of Cranbrook Primary School – or considered whether a transfer under FOIA was appropriate.

3. Incomplete handling of the request
My request covered not just the specific contract with UKCPM but also any agreements, delegations, or authorisations by the Council concerning parking enforcement at this location. These are matters the Council is in a position to confirm.

I therefore request that the internal review addresses:

• Whether the land at Cranbrook Primary School, including the car park, is owned or controlled by the Council.
• Whether the Council has delegated authority to the school governing body to enter into parking enforcement arrangements.
• Whether the Council holds any records, correspondence, or authorisations relating to the introduction of private parking enforcement at this site.
• Proper signposting or transfer to the public body that does hold the requested contract (likely the school/governing body).

Please ensure this review is conducted in line with the FOIA Code of Practice and completed within 20 working days.

Yours sincerely,

B789

Any update on how you are getting on with the PCN so far? DO NOT pay anything to UKCPM as they are scamming.
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Re: Parking Charge UK Car Park Management
« Reply #19 on: »
Hello

Thank you very much for your patience and due diligence. Much Appreciated.

I have followed the appeal process and have logged the appeal with IAS.

The operator has replied today as follows:

The operator made their Prima Facie Case on 19/09/2025 11:15:07.

The operator reported that...
The appellant was the keeper.
The operator is seeking keeper liability in accordance with PoFA..
ANPR/CCTV was used.
The Notice to Keeper was sent on 31/07/2025.
A response was received from the Notice to Keeper.
The ticket was issued on 28/07/2025.
The Notice to Keeper (ANPR) was sent in accordance with PoFA.
The charge is based in Contract.

The operator made the following comments...
The appellant has been captured by ANPR entering and leaving the car park.

The vehicle was at the car park for 35 minutes, evidence of this can be seen in the attached document '70XXXX26'.

The appellant has parked within the car park and did not register their vehicle.

Signage clearly states "MOTORISTS MUST REGISTER WITH A VALID E-PERMIT OR HAVE A VALID EXEMPTION BY ENTERING THEIR FULL, CORRECT VEHICLE REGISTRATION INTO THE KIOSKS LOCATED WITHIN THE RECEPTION AREAS OR BE REGISTERED VIA SIPPI".

Please be advised, physical permits are not currently in use at this location. Our records indicate that vehicle registration DSXXXLB was not registered on the E-Permit system, however other vehicles are registered on the E-Permit system on the date of contravention. This can be seen in the attached document '70XXXX26'.

The signage is clear within the area and states the terms and conditions for parking. It is the driver's responsibility to ensure they register their vehicle. This is the only way we can determine which vehicles are authorised to be parked within the restricted area.

Please be advised that the appellant has submitted the same evidence within their IAS appeal as was provided in their original online appeal.

You have argued that the site in question is subject to statutory control and thus excluded from the definition of “relevant land” under Schedule 4 of the Protection of Freedoms Act 2012 (POFA).

We must clarify that not all land owned by a local authority is subject to statutory control. In this case, the parking area at Cranbrook Primary School is not governed by a Traffic Regulation Order (TRO), nor is it subject to enforcement under the Road Traffic Regulation Act 1984.

This specific site is managed under a private agreement between the landholder and our client, under which we are authorised to operate a private parking enforcement scheme. Therefore, the land qualifies as “relevant land” under Schedule 4 POFA, and keeper liability may be pursued where the driver is not identified.

The Appellant accepts that they were the registered keeper of this car at the time of this incident but has not been prepared to identify the driver. The provisions of the Protection of Freedoms Act schedule 4 enable the Parking Operator to recover against the keeper if they fail or refuse to name the driver.

We note your concerns under the Data Protection Act 2018 and UK GDPR. As a precaution and in line with our internal protocols, your correspondence and data concerns have been forwarded to our Data Protection Officer, who will review your claims separately.

Please be assured that all personal data is processed in compliance with the UK GDPR, and only for purposes directly related to the enforcement of this charge and legitimate interest in site management.

You have requested a copy of the unredacted landowner agreement. Please note that we are not obligated to share proprietary contractual documents with third parties during the appeals process. However, we can confirm that we have valid, written authorisation to operate on this site, in line with the International Parking Community (IPC) Code of Practice.

The PCN was issued correctly under this authority and in full accordance with industry regulations.

By the appellant parking at the restricted area, they have contractually agreed to pay the parking charge notice.


-------

As they say, in for a penny, in for a hundred pound  ;) -

I have until 26/09/2025 23:59 to respond.

There are two options:

1. Submit a response
2. Refer case to arbitration

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Re: Parking Charge UK Car Park Management
« Reply #20 on: »
Here would be my response with some help from AI:

Re: IAS Appeal – PCN [Reference], Vehicle [Reg], Cranbrook Primary School, IG1 3PS

Dear Adjudicator,

I note the operator’s response. It is submitted that their case remains fundamentally flawed, for the following reasons:

Land Ownership and Statutory Control

The HM Land Registry Title Register (EGL505126) confirms the freehold is owned by The Mayor and Burgesses of the London Borough of Redbridge

summary_of_title_EGL505126_GOV.

Land owned by a local authority is, by definition, subject to statutory control. POFA Sch.4 para.3(c) excludes such land from being “relevant land,” regardless of whether a TRO is currently in place. The operator has misstated the legal test by narrowing it to TROs under the RTRA 1984.

Keeper Liability Cannot Apply

Because the land is not relevant land, the operator cannot transfer liability to the keeper under POFA. Their reliance on Schedule 4 is therefore misconceived.

Failure to Evidence Landowner Authority

The operator relies on a supposed “private agreement” but has refused to produce the unredacted contract. Without documentary proof of authority from the council, their claim cannot be substantiated. Mere assertion is inadequate.

Misuse of Personal Data

The operator’s continued attempt to pursue keeper liability where POFA does not apply amounts to unlawful processing of my data. This is a breach of the Data Protection Act 2018 and UK GDPR.

In conclusion, the operator has failed to discharge their burden of proving that the site is “relevant land” under POFA. The Land Registry evidence conclusively establishes that the land is local authority–owned and thus excluded from POFA. Keeper liability cannot therefore apply, and the PCN must be cancelled.

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Thoughts?
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Re: Parking Charge UK Car Park Management
« Reply #21 on: »
I would expand with much more detail and clearly rebut any points of the appeal they have not responded to or incorrectly stated. Here is an expanded rebuttal to the operators prima facie case you can use:

Quote
This response addresses and rebuts each point in the operator’s prima facie case and shows why the PCN cannot lawfully be enforced.

1.Keeper Liability Cannot Apply

The operator argues that the site is “relevant land” because there is no TRO and the site is managed under a private agreement. That is a misstatement of the law.

Paragraph 3(1)(b) of Schedule 4 excludes “a parking place which is provided or controlled by a traffic authority.” Paragraph 3(2) defines a traffic authority to include a London borough council. Cranbrook Primary School is a community school, not an academy or foundation school. The site is both owned and controlled by the London Borough of Redbridge. The school governing body does not own or control the land independently. Control therefore rests with Redbridge Council, which is a traffic authority. That alone excludes this land from being relevant land.

The operator’s focus on the absence of a TRO under the Road Traffic Regulation Act 1984 is misplaced. PoFA does not say “provided or controlled under RTRA powers.” It says “provided or controlled by a traffic authority.” Parliament could have restricted the scope to RTRA car parks but did not. The statutory test is broader, and it is satisfied here.

Even if paragraph 3(1)(b) were doubted, paragraph 3(1)(c) also applies. It excludes land where parking is “subject to statutory control.” Cranbrook Primary School is subject to statutory governance under the Education Acts and is directly controlled by a London borough exercising statutory powers. Parking on the site is therefore subject to statutory control.

The operator’s claim that a private agreement with the council renders the site relevant land is misconceived. A contract cannot override statute. If the land is excluded under paragraph 3, no private arrangement can change that legal status.

Accordingly, the Cranbrook Primary School car park is not relevant land. Keeper liability under PoFA cannot arise, and the operator’s reliance on Schedule 4 is fundamentally flawed.

2. Failure to engage with IAS appeal points 4 and 5

The operator’s fallback (“the Appellant is the keeper and has not named the driver; PoFA enables recovery”) is nonsensical once the land is shown not to be relevant. Even a perfectly drafted NtK cannot conjure keeper liability where Parliament has excluded it. The operator has not grappled with this point.

Separately, the operator has failed to answer two discrete evidential challenges in my IAS appeal:

Point 4: Reliability and calibration of enforcement mechanism. I required strict proof that the mechanism used (ANPR or manual patrol) is reliable, synchronised, maintained, and calibrated, and that it evidences a period of parking rather than mere site presence within a consideration or grace period as required by the PPSCoP. No maintenance logs, calibration records, clock-sync evidence, or patrol notes have been produced. No evidence of the operator’s consideration/grace-period policy for this site has been disclosed. Assertions are not evidence. In the absence of contemporaneous records, the evidential chain is incomplete and the allegation is not proven.

Point 5: Proof of posting and service timing. I required strict proof that any NtK was posted in time to be “given” within the relevant period. PPSCoP 8.1.2(d) Note 2 requires the operator to retain a record of the date of posting, not merely the date a notice was generated or handed to a mail consolidator. The operator has provided no postal manifest, no proof of handover to Royal Mail, and no evidence of posting dates. A back-office “generated on” timestamp is not proof of posting or delivery. On their own case, they have not discharged the burden of proving service.

Given (i) PoFA is inapplicable because the land is excluded, and (ii) the operator has not rebutted points 4 and 5 with primary evidence, the prima facie case fails on both legal applicability and proof.

3. Landowner authority: proof required, not bare assertions

If the operator genuinely believes that merely asserting the existence of a valid agreement—without evidencing it to the appellant—is sufficient, I would relish watching them try that excuse in an actual courtroom. The IAS’s willingness to entertain such nonsense only reinforces its reputation as a kangaroo court. If this assessor is prepared to accept that a contract exists based solely on secret evidence shown only to the IAS, then congratulations: you’ve just proven why this appeals process is a farce.

The PPSCoP §14 requires evidence, not secrecy. Section 14.1(a)–(j) mandates written confirmation from the landowner covering: the landowner’s identity and a boundary plan; any applicable byelaws; the permission granted and its duration; the parking terms and conditions applied; the method of issuing charges; responsibility for necessary consents; the operator’s obligations under the Code; the documentation the operator must be able to supply on request to authorised bodies detailing the relationship with the landowner; and the operator’s approach to appeals. Note 2 confirms that where byelaws prohibit private charges they take precedence; Note 3 warns that pre-existing rights cannot be overridden by signage. These are core standing documents, not optional extras.

Commercially sensitive pricing can be redacted where justified; however, the authority clauses, boundary plan, byelaw status, scope and duration of permission, operative terms, and method of charge issuance must be disclosed in full. A private “we have authority, trust us” is not compliance with §14 and is not evidence of standing.

If the IAS is content to uphold charges on the basis of undisclosed contracts shown only to the assessor, it merely underlines that this process is not transparent and not credibly independent. The upcoming implementation of the Parking (Code of Practice) Act 2019 cannot come soon enough. When it does, incestuous outfits like the IAS—masquerading as independent while rubber-stamping operator fiction—will finally be consigned to the procedural dustbin where they belong.

Conclusion

For the reasons above—(i) the site is not “relevant land” so PoFA cannot transfer liability, (ii) the operator failed to evidence Points 4 and 5 (reliability/calibration and proof of posting/service), and (iii) standing has not been proven as required by PPSCoP §14—the PCN must be cancelled.
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Re: Parking Charge UK Car Park Management
« Reply #22 on: »
Superb!

Thank you kindly. Will update here in due course.
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Re: Parking Charge UK Car Park Management
« Reply #23 on: »
And here we have the response:

The Independent Appeals Service (IAS) has received a decision from the Independent Adjudicator regarding your recent appeal for the below PCN.

Parking Charge Number (PCN): 7xxxxxx6
Vehicle Registration: DxxxxxxB
Date Issued: 28/07/2025

Appeal Outcome: Dismissed

The Adjudicators comments are as follows:

"The Appellant should understand that the Adjudicator is not in a position to give legal advice to either of the parties but they are entitled to seek their own independent legal advice. The Adjudicator's role is to consider whether or not the parking charge has a basis in law and was properly issued in the circumstances of each individual case. In all Appeals the Adjudicator is bound by the relevant law applicable at the time and is only able to consider legal challenges and not factual mistakes nor extenuating or mitigating circumstances. Throughout this appeal the Operator has had the opportunity consider all points raised and could have conceded the appeal at any stage. The Adjudicator who deals with this Appeal is legally qualified and each case is dealt with according to their understanding of the law as it applies and the legal principles involved. A decision by an Adjudicator is not legally binding on an Appellant who is entitled to seek their own legal advice if they so wish.
The Appellant's vehicle has been recorded as entering this site at 20.02 and leaving at 20.38. No e-permit was held for the vehicle, nor was payment made to remain on site.
The Appellant is liable as the keeper of the vehicle. The operator has satisfied me that they have the relevant contract with the landowner to enforce parking restrictions at this site.
The signage is prominent, clear and unequivocal in its terms.
The Appellant should have seen the signage and should have realised that payment was required to park or registration at the kiosks in reception was required.
Having considered all the relevant issues raised and the evidence submitted, I am satisfied that the operator has established that the Parking Charge was properly issued in accordance with the law.
This appeal therefore has to be dismissed. "

As your appeal has been dismissed, the Independent Adjudicator has found, upon the evidence provided, that the parking charge was lawfully incurred.

As this appeal has not been resolved in your favour, the IAS is unable to intervene further in this matter.

You should contact the operator within 28 days to make payment of the charge.

Should you continue to contest the charge then you should consider obtaining independent legal advice.

Yours Sincerely,
The Independent Appeals Service

Thoughts? Next action?
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Re: Parking Charge UK Car Park Management
« Reply #24 on: »
Not unexpected. As you see, the decision is from an anonymous fetishist who never finished high school and is into bestiality, for all we know. As for the claim that they are "legally qualified", that can be dismissed instantly. They never answered the question about whether the land is "relevant" for the purposes of PoFA and simply stated "The Appellant is liable as the keeper of the vehicle".

They used to claim that all their "adjudicators" were either legally trained as solicitors or barristers. I note that they have now removed that claim after I have persisted in exposing their unverified claims and now they have simply said "legally qualified". If any of that is not evidence of the Kangaroo court nature of the IAS, I don't know what else would be required.

Never mind. That decision is not binding on you and you don't pay anything. You are now likely to get debt recovery letters which you can safely ignore. Debt collectors are powerless to do anything except to try and intimidate the low-hanging fruit on the gullible tree into pain gout of ignorance and fear. For all anyone cares, you can shred those letters and use them as hamster bedding.

Eventually, you will receive a Letter of Claim (LoC). When you do, come back and we will give you the response to send. What you want is a county court claim, because that is the only forum where you would get an impartial decision based in the actual facts from the only truly independent arbiter, a district judge.

However, the odds of this ever getting as far as an actual hearing are slim to none. They will go through the motions in the hope that you are gullible and ignorant enough of the process to give in and just pay up. In the vast majority of these cases, the claim is either struck out or discontinued just before they have to pay the £27 trial fee.

So, come back when you receive an actual LoC. We don't need to know about any useless debt recovery letters.
« Last Edit: October 31, 2025, 02:28:28 pm by b789 »
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Re: Parking Charge UK Car Park Management
« Reply #25 on: »
Understood, thanks.

Is there any point in contacting UK Car Park Management to acknowledge this decision or do you think they will contact me before handing over to a debt collection agency?

Have we missed something in our position of 'relevant land' that the adjucator has seen in the contract that was provided to them to make them think they can win in court?

Is there anything else I can obtain to prove this further without any doubt?

Thanks

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Re: Parking Charge UK Car Park Management
« Reply #26 on: »
Quote from: amuk786 on November 01, 2025, 09:31:59 am
Understood, thanks.

Is there any point in contacting UK Car Park Management to acknowledge this decision or do you think they will contact me before handing over to a debt collection agency?

Have we missed something in our position of 'relevant land' that the adjucator has seen in the contract that was provided to them to make them think they can win in court?

Is there anything else I can obtain to prove this further without any doubt?

You are overthinking this. You are not dealing with a firm that has any sort of "customer ethos". These are ex-clamper scammers. They are hoping you are low-hanging fruit on the gullible tree and can be intimidated into paying up out of ignorance and fear!

You are assuming the "adjudicator" is a real, legally qualified person. They are not. On what planet do you think it is reasonable for any evidence of a valid contract to be withheld has evidence from you? Maybe in North Korea or Russia, they can rely on "evidence" that is withheld, but you are dealing with a kangaroo court.

You are in the midst of a scam and the sooner you understand that, the easier this will become. Don't be naive about this. We deal with this day in and day out.

Why are you worried about this being "handed over to a debt collection agency"? Who gives a toss about a third party with zero power to do anything except to prey on your ignorance and fear? Any debt collector is powerless to do anything. They are not a party to any contract allegedly breached by the driver. Ignore all debt recovery letters. Shred them and use them as hamster bedding for anyone cares. We don't need to know about them and you should stop worrying about them. They cannot do ANYTHING! They will not an cannot affect your credit rating.

If you are so unknowledgeable about how a CCJ works, then have a rad of this:

Do you have any understanding of how someone gets a CCJ? Nothing we advise on here will make anyone get a CCJ.

Quote
A County Court Judgment (CCJ) does not just happen—it follows a clear legal process. If someone gets a Parking Charge Notice (PCN) from a private parking company, here's what happens step by step:

1. Parking Charge Notice (PCN) Issued

• The parking company sends a letter (Notice to Keeper) demanding money.
• This is not a fine—it’s an invoice for an alleged breach of contract.

2. Opportunity to Appeal

• The recipient can appeal to the parking company.
•If rejected, they may be able to appeal to POPLA (if BPA member) or IAS (if IPC member).
• If an appeal is lost or ignored, the parking company demands payment.

3. Debt Collection Letters

• The parking company might send scary letters or pass the case to a debt collector.
• Debt collectors have no power—they just send letters and can be ignored.
• No CCJ happens at this stage.

4. Letter Before Claim (LBC)

• If ignored for long enough, the parking company (or their solicitor) sends a Letter Before Claim (LBC).
• This is a warning that they may start a court case.
• The recipient has 30 days to reply before a claim is filed.
• No CCJ happens at this stage.

5. County Court Claim Issued

• If ignored or unpaid, the parking company may file a claim with the County Court.
• The court sends a Claim Form with details of the claim and how to respond.
• The recipient has 14 days to respond (or 28 days if they acknowledge it).
• No CCJ happens at this stage.

6. Court Process

• If the recipient defends the claim, a judge decides if they owe money.
• If the recipient ignores the claim, the parking company wins by default.
• No CCJ happens yet unless the recipient loses and ignores the court.

7. Judgment & Payment

• If the court rules that money is owed, the recipient has 30 days to pay in full.
• If they pay within 30 days, no CCJ goes on their credit file.
• If they don’t pay within 30 days, the CCJ stays on their credit file for 6 years.

Conclusion

CCJs do not appear out of thin air. They only happen if:

• A parking company takes the case to court.
• The person loses or ignores the case.
• The person fails to pay within 30 days.

If you engage with the process (appeal, defend, or pay on time), no CCJ happens.
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Re: Parking Charge UK Car Park Management
« Reply #27 on: »
Just as an fyi - 1st debt collector letter received 28th November 2025.

No action taken.
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