A redacted copy would be useful, your next step is to rebut their evidence, so it would be useful to see what it actually is.
There's a lot, and I'm not sure how to upload PDF's, but this is a copy-paste of the main body of their 'evidence' – there are photos of signage taken in 2023 and a contract between the management (not the owners) and UKCP:
On 12/11/2025, a parking event occurred relating to vehicle registration xxxxxxxx The event was recorded by our ANPR cameras at Harbour Exchange because the vehicle was on site over the permitted time of 1 hour.
The parking charge rate was £100.00, reduced to £60.00 if payment was received within fourteen days.
Following the parking event on 12/11/2025, UKPC had reasonable cause to obtain the details of the registered keeper from the DVLA for the purposes of issuing a Parking Charge Notice (PCN) by post- a copy of this PCN is included in this pack.
The PCN was issued on 12/11/2025
An appeal was received from the vehicle's registered keeper on the 10/12/2025, which the appeals department investigated and decided to reject.
Whilst UKPC note the comments, we cannot accept them as evidence when reviewing a parking charge notice. The site is managed by ANPR systems which simply take images of vehicle registration numbers entering and exiting a site; to calculate the total amount of time on site. The vehicle was on site for 1 hour 38 minutes; a sufficient grace period has been provided for this site.
Following the parking event, UKPC had reasonable cause to obtain the details of the registered keeper so that a parking charge notice could be issued by post. A copy of this notice is included in this case summary, dated 18/11/2025. Issued 6 days after the date of the parking event (where a Notice to Driver was not served), the parking charge notice complies fully with paragraph 9 of Schedule 4 of the Protection of Freedoms Act 2012 in permitting the registered keeper to be held liable to pay this unpaid parking charge.
The appellant has stated that the keeper liability warning is not in the prescribed PoFA 2012 format. Section 9(2)(f) states that the notice must warn the keeper that:
“if, after the period of 28 days beginning with the day after that on which the notice is given— (i)the amount of the unpaid parking charges specified under paragraph (d) has not been paid in full, and (ii)the creditor does not know both the name of the driver and a current address for service for the driver, the creditor will (if all the applicable conditions under this Schedule are met) have the right to recover from the keeper so much of that amount as remains unpaid;”
Having reviewed the notice, I am satisfied that it specifies all of this information. Although I appreciate that it may not be stated verbatim, it contains the necessary information nonetheless. The appellant has stated that there isn’t a clear date that the period of parking. Having reviewed the notice, I can see that it specifies the date as 12/11/2025.
The contract between UK Parking Control Ltd and the landowner (or their managing agent) authorising UKPC to provide parking management, and therefore issue parking charges to vehicles breaching the terms of parking, is confidential and we are unable to provide a copy for reasons of commercial sensitivity. We have however provided a redacted copy, with sensitive information covered. The redacted contract confirms our authority in an ongoing agreement. If neither party terminates the contract, as in this case, the contract will continue on a rolling basis.
We have provided the T&C’s in relation to the rolling contract.
Although the BPA Code of Practice outlines what authorisation must set out, we have also shown that beyond checking documentation; there is equipment, signage and on occasion personnel on site to manage the function of enforcement and this cannot happen without the landowner’s authority. I am sure that if the parking operator was not allowed to issue charges on site the landowner would not permit the parking operator to keep its signage on site nor would the landowner allow motorists to park on its land without authorisation.
Any comments, assurances, or representations made by a third party do not override the parking restrictions in place within a car park governed by clearly displayed terms and conditions. Drivers are required to rely on the signage on site, which forms the basis of the parking contract, regardless of any statements made by individuals who are not a party to that contract. Furthermore, the appellant has provided no evidence to demonstrate that they were granted permission to park beyond the maximum permitted stay of one hour. In the absence of such evidence, the vehicle was subject to the standard parking restrictions, which were exceeded.
For the avoidance of doubt, the purpose of entrance signs is solely to advise motorists they are entering into private land and there are parking conditions they must be aware of. Our signage conforms to the guidelines set out within the code, and we are audited regularly by the BPA for those standards; the signs must be provided to make it easy for motorists to find out what the terms and conditions are and that the signs contain the specific parking terms throughout the site, so that drivers are given the chance to read them at the time of parking or leaving their vehicle. Signs must be conspicuous and legible, and written in intelligible language, so that they are easy to see, read and understand. The BPA audits have confirmed that we follow this to their standard.
Please see attached a signage plan showing the signage locations, the entrance signage proof and onsite signage proof. We feel it reasonable to suggest that the driver was advised sufficiently of the terms & conditions of parking on site.
The appellant states that the vehicle was displaying a valid Blue Badge and that the driver is disabled and therefore protected under the Equality Act 2010.
hey further claim that a security guard granted permission to remain on site for longer than the maximum stay as a reasonable adjustment. This assertion is not supported by evidence. The parking charge was issued using Automatic Number Plate Recognition (ANPR) technology, which records vehicle entry and exit times. The ANPR system does not recognise or record the display of Blue Badges, nor does it record any alleged verbal permissions. Furthermore, the appellant has provided no evidence to substantiate the claim that permission was granted by a security guard to remain on site beyond the maximum permitted stay.
In the absence of corroborating evidence, this claim cannot be accepted.
For clarity, although it is not strictly required, evidence has been provided to show that the
vehicle registration mark (VRM) is not listed on the authorised parking system for this site. This confirms that no prior approval or arrangement existed for the vehicle to remain beyond the standard permitted stay.
While UKPC recognises its obligations under the Equality Act 2010, the Act does not provide an automatic exemption from parking terms and conditions, nor does it remove the requirement for motorists to comply with clearly displayed time limits.
Reasonable adjustments must be identifiable, proportionate, and supported by evidence. In this case, the appellant has failed to demonstrate that a reasonable adjustment was requested, agreed, or implemented. As such, the vehicle remained subject to the standard parking terms and conditions, which were exceeded.
Accordingly, the parking charge was correctly issued and does not constitute discriminatory treatment.
UKPC must maintain a consistent approach when issuing and upholding a charge. In this instance, this vehicle had been parked on site in direct breach of the terms and conditions of parking on site as stated on signage. The vehicle was parked in close proximity to UKPC signage, please see all photographic evidence to support this.
UK Parking Control signage complies fully with section 3 of the British Parking Association Code of Practice and we reject the suggestion that it is vague or misleading. Entrance signage advises motorists that terms of parking apply, and that notices within the car park should be checked to identify the full terms and conditions. These notices are placed throughout the car park. It is ultimately the responsibility of the motorist to ensure they identify the terms of parking, and then decide whether to park their vehicle, or leave the site if they are unable to meet those terms.
The parking charges issued by UK Parking Control Limited are based on a contractual agreement between UKPC and the driver, as detailed on the signage displayed in the car park. The signage states the terms and conditions of parking and explains that a parking charge will be payable if the terms are not met by the driver.
We ensure that signage is ample, clear and visible, wholly in line with the British Parking Association Code of Practice. It is settled law that a driver is deemed to have accepted the terms and conditions of parking by the act of parking and leaving a vehicle.
Ultimately, it is fundamentally the responsibility of the motorist to identify the terms of parking when leaving their vehicle on private land. If they feel they are unable to adhere to the terms, they may leave the site before agreeing to those terms.
There are sufficient signs advising drivers that parking over the maximum time permitted may result in a parking charge being issued. MR XXXXXXXXX vehicle was on site over the permitted time of 1 hour; consequently, the parking charge was issued correctly.
A letter was sent to informing him of our decision on the 19/12/2025.
If I can work out where to upload the files properly I will
If I can work out where to upload the files properly I will
A repository such as DropBox or Google Drive works well.
You need to adjust the privacy settings so they're viewable to the public - it's asking me to sign in.
You need to adjust the privacy settings so they're viewable to the public - it's asking me to sign in.
sorry about that, I tried to be clever by shortening the links – they should work now
How does this sound for my planned comments:
I have reviewed the operator’s evidence pack and make the following comments.
1. Keeper liability under the Protection of Freedoms Act 2012
The operator asserts that the Notice to Keeper “complies fully” with Schedule 4 of PoFA but does not demonstrate strict compliance with the mandatory wording required by paragraph 9(2)(f). No explanation or analysis is provided to rebut the appellant’s submission that liability has not been validly transferred from the driver to the keeper. Mere assertion is insufficient where strict compliance is required.
2. Driver not identified
The operator has provided no evidence identifying the driver. The appellant has not admitted to being the driver, and the operator’s evidence does not rebut this point. In the absence of established keeper liability, the charge remains unenforceable.
3. Landowner authority (standing)
The operator relies on a redacted agreement with a managing agent rather than a contract signed by the landowner. No evidence has been provided to demonstrate that the managing agent had authority from the landowner to delegate enforcement rights to the operator. Assertions of authority are not proof, and the chain of authority remains unproven.
4. Permission granted by the landowner’s agent
The operator dismisses permission granted by on-site security as being given by a “third party” but does not address the principles of agency. The security guard controlling access at a barrier was acting on behalf of the landowner or its agent. The operator’s evidence does not rebut that permission was granted or explain why such permission should be disregarded.
5. Equality Act 2010
The operator’s evidence does not meaningfully address the Equality Act 2010. Assertions that ANPR systems cannot recognise Blue Badges or that there is no automatic exemption do not discharge the statutory duty to make reasonable adjustments. No evidence is provided to show that reasonable adjustments were considered or made in this case.
6. Signage
The signage evidence consists of generic photographs from 2023 and plans which do not demonstrate that clear, prominent, and legible signage was in place and visible to a driver before parking at this barrier-controlled site on the material date. This does not rebut the appellant’s signage challenge.
Conclusion
The operator’s evidence does not rebut the appellant’s grounds of appeal. Keeper liability has not been established, driver identity has not been proven, landowner authority remains unsubstantiated, permission by an authorised agent has not been addressed, and Equality Act duties have not been met. The appeal should therefore be allowed.
I think point #3 could be even more explicit - their contract is so redacted as to be almost meaningless - they've completely redacted the name of the landowner, so you've no idea who they claim that is, and whether the entity named is even the owner of the land.
Thank you.
I submitted the comments with the suggestion added – just a matter of waiting now.