Some more info, I believe her husband attempted to email them explaining he was at work, as far as I know at the moment, this email bounced, which is good.
I've had a look through the forum and found a similar case, I have taken the suggested letter and amended it, if someone could give me the thumbs up if it's appropriate, I would be most grateful.
I will thank you all in advance for the excellent work you guys do, how these companies get away with this ... - they are utter scum.
***************
Here is the amended letter.
I am the registered keeper of the vehicle and am writing to formally appeal the Parking Charge Notice issued in relation to an alleged unpaid stay at Exeter Cathedral on 30th July at 16:36 . Your allegation is based on ANPR images that incorrectly suggest the vehicle was at that location on that day. In fact, the vehicle was parked outside my house at that time. The vehicle was at the location on the 25th July, a single visit that was paid for, for a duration of about 2 hours.
Your Notice is based on ANPR images purporting to show a single continuous stay from 25th July - 30th July, which is factually incorrect. The vehicle made one visit to the site on 25th July and left on the 25th July. Either your system failed to record the visit correctly, or the evidence had been fraudently adjusted.
Such errors are typically caused by your system's failure to reconcile "orphan images" — unpaired entries or exits — which should have been identified during the mandatory manual quality control check required by Section 7.3(d) of the Private Parking Single Code of Practice (Version 1.1, 17 February 2025). That section states:
“Photographic evidence must not be used by a parking operator as the basis for issuing a parking charge unless: images generated by ANPR or CCTV have been subject to a manual quality control check, including the accuracy of the timestamp and the risk of keying errors.”
And Note 1 explicitly refers to:
“...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...”
Your failure to detect this pattern, especially over an alleged stay of 5 days, demonstrates that no such check was carried out, and no due diligence was applied. You had no reasonable cause to request my personal data from the DVLA, and your continued processing of that data — despite clear evidence of a system error — constitutes a breach of Article 5(1)(a), (b), and (f) of the UK GDPR, which require data to be processed lawfully, fairly, and for a specified, legitimate purpose. I won't even start on the KADOE contract breach.
Irrespective of the outcome of this appeal, I am reporting Premier Park Ltd to the DVLA for unlawfully obtaining my keeper data. A further complaint to the Information Commissioner’s Office is being prepared, and I reserve the right to pursue damages under Article 82 UK GDPR for this data misuse.
This appeal is submitted solely by the registered keeper. No admission is made as to the identity of the driver, and no such information will be provided.
You are formally invited to cancel this PCN immediately. Should you choose not to, you must provide a full explanation of how your ANPR system complied with Section 7.3(d) of the PPSCoP, including evidence of the manual quality control check and reconciliation of orphan images.
