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#Post#: 114807--------------------------------------------------
Civil Enforcement Ltd - no payment - Wycombe Rye Lido
DIR By: wakefield33
Date: March 30, 2026, 6:17 am
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Good morning all--
I am the registered keeper of a vehicle and a few days ago
received from Civil Enforcement a document titled "Parking
Charge Notice (PCN) Notice to Keeper" in respect of the vehicle.
As you will see from uploaded pics of the document, the driver
appears to have been in the car park for 26 minutes. I gather
that the driver was using the car park to wait for a family
member. They don't appear to have been aware that the car park
was subject to ANPR monitoring. No parking was paid for.
The document is dated 19 March 2026 and I first saw it on
Wednesday 25 March 2026. (Having had a busy few days with work,
it was only on the 25th that I checked my post properly so I
don't know the precise date of delivery; in theory it could have
come through my letterbox on any of 20/21/23/24/25 March.)
This morning, Monday 30 March 2026, I visited the car park to
take some photos, four of which have been uploaded. Some
context:
- The first image below, marked 'Phone & Pay or Pay at Machine',
is the first sign drivers see when entering the car park (there
is only one entrance)
- The second image shows that the payment machines state "Valid
ticket must be clearly displayed in windscreen" (there are three
parking machines; two have this wording and the third doesn't
say either way)
- The third and fourth images show two of the large 'Parking'
signs in the car park
A few thoughts...
- The entrance sign refers to 'Phone and Pay', which is what the
car park used to use for payment. Notice that the large signs
still mention that company's website around halfway down the
blue section ( www.phoneandpay.co.uk).
- The entrance sign seems to be almost wholly incompatible with
Annex A (Entrance Signs) in the BPA code of practice. The
entrance sign also fails to display wording referred to in Annex
B, Table B.1: "Entrance Sign to display / Parking tariff
applies".
- There seems to be black-and-white inconsistency between the
wording on the payment machines which states "Valid ticket must
be clearly displayed in windscreen" vs the signs which state
"There is no need to display a ticket in your windscreen".
- The large signs are, themselves, inconsistent. Halfway down
one of them says "Payment must be made within 15 minutes of
arrival at the premises" and the other says "Payment must be
made before leaving the car park".
- The top right section of the large signs states, in relation
to RingGo: "Please see side of machine for T&Cs" - but the sides
of the three payment machines are blank / display no T&Cs.
As registered keeper I plan to submit an appeal to Civil
Enforcement. If anyone has any advice about the most
relevant/irrelevant parts of what I've mentioned, or anything I
may not have thought of, I would be hugely grateful.
Thank you.
HTML https://i.ibb.co/LzTZRpKD/NTK-front-redacted.png
HTML https://i.ibb.co/7thXghgC/NTK-back-redacted.png
HTML https://i.ibb.co/BMKcw5h/Wycombe-Rye-Lido-1-of-4.jpg
HTML https://i.ibb.co/0pz0Zy7s/Wycombe-Rye-Lido-2-of-4.jpg
HTML https://i.ibb.co/qM4j0vnb/Wycombe-Rye-Lido-3-of-4.jpg
HTML https://i.ibb.co/xTjSBNY/Wycombe-Rye-Lido-4-of-4.jpg
#Post#: 115011--------------------------------------------------
Re: Civil Enforcement Ltd - no payment - Wycombe Rye Lido
DIR By: wakefield33
Date: April 1, 2026, 5:57 am
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Since my post, I spoke to staff at the venue and they are
adamant they can't/won't do anything. They have a policy of not
getting involved.
So - based on research over the past 48 hours here's what I'm
planning to submit as an appeal. If anyone has a moment to
suggest improvements, or point out any areas where I'm wasting
my time, I would appreciate it massively.
Huge credit to user b789, who I hope doesn't mind that I have
used part of a previous/unrelated post of theirs as the basis
for some of this.
Thank you.
Re: Parking Charge Notice (PCN) No. [PCN Number]
Vehicle Registration No: [VRM]
Issue Date: 19/03/2026
I am appealing as the registered keeper of the vehicle. I am
under no legal obligation to provide the driver’s details, and I
decline to do so.
Civil Enforcement Ltd (CEL) has failed to comply with the strict
requirements of Schedule 4 of the Protection of Freedoms Act
2012 (PoFA), which are necessary to hold the keeper liable. I
outline the following points of non-compliance:
1. Failure to comply with PoFA schedule 4 paragraph 2(3):
Paragraph 2(3) further clarifies that 'adequate notice' means
signs must clearly specify the parking charge and be positioned
in such a way that the charge is brought to the attention of
drivers. In this case, CEL did not display sufficient signage to
meet this requirement.
2. Failure to comply with PoFA paragraph 9(2)(c):
PoFA paragraph 9(2)(c) requires that the Notice to Keeper
describe how the parking charge arose and how the requirement to
pay was brought to the attention of the driver. Given that CEL
has failed to provide adequate notice as defined in paragraph
2(3), the Notice to Keeper does not comply with this
requirement. CEL’s partial or substantial compliance with PoFA
is insufficient to establish keeper liability, as full
compliance with all PoFA requirements is mandatory.
In any event, CEL’s signage found at the car park is
inconsistent and does not comply with the British Parking
Association (BPA) Code of Practice in various ways, including
but not limited to the following:
• The entrance sign refers to ‘Phone and Pay’, which is how
payment by mobile phone USED to be accepted at this car park but
has since been replaced by RingGo, while some other signs still
refer to the 'Phone and Pay' website;
• The entrance sign displays none of the Group 1 wording found
in the ‘Entrance Signs’ Annex of the BPA Code of Practice;
• The size of the text on the entrance sign is too small to meet
the requirements found in the ‘Entrance Signs’ Annex of the BPA
Code of Practice;
• Signs on the payment machines themselves state “Valid ticket
must be clearly displayed in windscreen”, while other signs
state the opposite: “There is no need to display a ticket in
your windscreen”;
• CEL signs are inconsistent: some state, around halfway down,
“Payment must be made within 15 minutes of arrival at the
premises”, while another says in the same area of the sign
“Payment must be made before leaving the car park”.
Furthermore, should CEL reject my appeal, I will expect them to
provide the following evidence to POPLA:
• A detailed layout of the car park showing the location of all
signage.
• Proof of the exact location where the vehicle was parked, and
how this relates to any signage.
• Evidence that the signage used to display the parking terms
and conditions is fully compliant with the BPA Code of Practice.
CEL will be put to strict proof of the vehicle’s parking
location and the relationship of that location to any signs
passed between the parking space and the Lido.
In light of these clear breaches of PoFA and the inadequate
signage, I request that the Parking Charge Notice be cancelled.
#Post#: 115197--------------------------------------------------
Re: Civil Enforcement Ltd - no payment - Wycombe Rye Lido
DIR By: Charitynjw
Date: April 3, 2026, 9:22 pm
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Wycombe Rye/Holywell Mead is under statutory control via local
byelaws.
This includes the Lido car park.
The Protection of Freedoms Act 2012, Schedule 4, s3(3) & (4)
excludes it from the 'relevant land' definition.
In short, CEL should not be issuing private parking charges
there.
HTML https://www.legislation.gov.uk/ukpga/2012/9/schedule/4
HTML https://www.legislation.gov.uk/ukpga/2012/9/schedule/4
Fusion Lifestyle, who lease the site from Buckinghamshire
Council, has gone into administration. Whether or not that will
affect CEL's contract with them remains to be seen.
#Post#: 115199--------------------------------------------------
Re: Civil Enforcement Ltd - no payment - Wycombe Rye Lido
DIR By: InterCity125
Date: April 4, 2026, 2:04 am
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Do the Byelaws specifically mention parking?
#Post#: 115201--------------------------------------------------
Re: Civil Enforcement Ltd - no payment - Wycombe Rye Lido
DIR By: RichardW
Date: April 4, 2026, 2:23 am
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Appears to be some history on this point with the council!
HTML https://www.whatdotheyknow.com/request/rye_and_mead_byelaws_and_other_r
#Post#: 115203--------------------------------------------------
Re: Civil Enforcement Ltd - no payment - Wycombe Rye Lido
DIR By: Charitynjw
Date: April 4, 2026, 4:05 am
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--- Quote from: RichardW link ---
>
> Appears to be some history on this point with the council!
HTML https://www.whatdotheyknow.com/request/rye_and_mead_byelaws_and_other_r
>
--- End Quote ---
You could say that, yes. :)
#Post#: 115205--------------------------------------------------
Re: Civil Enforcement Ltd - no payment - Wycombe Rye Lido
DIR By: Charitynjw
Date: April 4, 2026, 5:52 am
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--- Quote from: InterCity125 link ---
>
> Do the Byelaws specifically mention parking?
>
--- End Quote ---
I think so, yes.
CEL 'neither confirms or denies'. ;D
Suffice to say, any pcn's for this site, challenged citing
byelaws, quietly disappear.
#Post#: 115221--------------------------------------------------
Re: Civil Enforcement Ltd - no payment - Wycombe Rye Lido
DIR By: InterCity125
Date: April 5, 2026, 1:58 am
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The parking operator is breaching the Code of Practice by
mentioning PoFA liability on land which is not relevant.
This is also a breach of the DVLA KADOE agreement.
They are misusing your personal data.
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