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       #Post#: 34372--------------------------------------------------
       PCN addressed to me for somewhere I have never been, car in
       images is not mine - Smart Parking Ltd
   DIR By: strawberrydoll
       Date: August 23, 2024, 11:45 am
       ---------------------------------------------------------
       I have received a PCN of £100 from "Smart Parking Ltd" addressed
       to me and sent to my address for overstaying at a car park in
       Hereford on 19/08/2024. The written reg on the paper is mine,
       but the images they've taken shows a reg that is not mine (but
       is somewhat close) and has a picture of what seems to be a Ford
       SUV which I do not own, mine is an Audi hatchback.
       To be clear, I have never been to the car park in question, they
       seem to have misread the registration (mine is XK69 XXX and the
       reg of the image they've taken is XC59 XXX), so I thought it
       would be as easy as calling them and telling them they have the
       wrong person/car and to please stop contacting me and delete my
       personal details from their system, but the person on the line
       told me I would need to fill out their appeals form online to
       get them to "consider my appeal". The person on the line was
       extremely rude and unhelpful and tried to prod me into just
       paying the fine as the "easiest option for me and would be the
       cheaper £60 option right now" but I refused, is it best to fill
       out all my personal details on their online appeals form or
       should I send them a letter? I could use some advice, thank you
       in advance.
       #Post#: 34376--------------------------------------------------
       Re: PCN addressed to me for somewhere I have never been, car in
       images is not mine - Smart Parking Ltd
   DIR By: DWMB2
       Date: August 23, 2024, 12:04 pm
       ---------------------------------------------------------
       As a general rule, where there is a dispute over money,
       corresponding in writing is generally preferable to by phone, as
       you have a record of exactly what has been discussed.
       I would ordinarily recommend pointing the misread out but as
       this is Smart Parking, the quickest way is probably a template
       appeal. Can you show us the notice you have received?
       It will almost certainly not meet the requirements to hold the
       registered keeper liable, and if you appeal as the registered
       keeper with the below, they will almost certainly cancel the
       charge.
       [indent] Dear Sirs,
       I have received your Parking Charge Notice (Ref: ________) for
       vehicle registration mark ____ ___, in which you allege that the
       driver has incurred a parking charge. I note from your
       correspondence that you are not seeking to hold me liable as the
       registered keeper, under Schedule 4 of the Protection of
       Freedoms Act 2012 ("The Act"). You have chosen not to issue a
       Notice to Keeper in accordance with The Act, and it is now too
       late for you to do so.
       There is no obligation for me to name the driver and I will not
       be doing so. I am therefore unable to help you further with this
       matter, and look forward to your confirmation that the charge
       has been cancelled. If you choose to decline this appeal, you
       must issue a POPLA code.
       Yours,[/indent]
       Do please show us the notice before you appeal, I don't like
       recommending an appeal without double checking it is
       appropriate. You'll need to use a third party site like Imgur to
       upload the notice.
       You could if you wish add a line into that appeal before the
       main point, pointing out that it is not your vehicle and their
       faulty ANPR has led to them accessing your details without
       reasonable cause.
       #Post#: 34390--------------------------------------------------
       Re: PCN addressed to me for somewhere I have never been, car in
       images is not mine - Smart Parking Ltd
   DIR By: b789
       Date: August 23, 2024, 1:10 pm
       ---------------------------------------------------------
       You can also threaten them with a lawsuit for damages as they
       have illegally obtained your personal data in breach of the
       KADOE contract. By failing to perform a manual quality control
       check on the ANPR photographic evidence, they are in breach of
       their AOS Code of Practice which nullifies their KADOE contract.
       Threaten to sue them for £250 for breaching your GDPR and tell
       them you’ll accept £100 if they are prepared to settle within 14
       days of receipt of the letter.
       --- Quote ---
       > Article 12 of the UK GDPR legally requires data controllers to
       store and process personal data accurately: clearly, any data
       controller issuing an invoice to you because it has wrongly
       recorded that you parked in breach of the alleged contract
       between you and the landowner (or, as in this case, an agent of
       the landowner) is processing your personal data unlawfully.
       >
       > The precedents for claiming damages and compensation for such
       unlawful processing are the decisions of the Court of Appeal in
       Zeta Jones & Douglas v Hello! Magazine [2003] EWHC 786 and
       Halliday v Creation Consumer Finance Ltd (CCF) [2013] EWCA Civ
       333, both being binding on all County Courts in England and
       Wales.  In the latter claim, Mr Halliday was awarded
       compensation of £750 at what the Court regarded was the lowest
       level of award, and although this was a claim under Section 13
       of the Data Protection Act 1998, similar provisions - amended to
       take account of a decision by the EU Grand Chamber that the 1998
       Act did not properly implement EU law into UK domestic
       legislation - replaced the old Section 13 provisions with
       Article 12 of the UK GDPR and Section 168 of the Data Protection
       Act 2018.
       >
       > In short, you ought to give 21 days notice (the pre-action
       protocol only really requires 14 days but hey, you can be
       charitable!) to the data controller of your intention to seek
       (say) £100 nominal damages and compensation under Article 12 of
       the UK GDPR and Section 168 of the Data Protection Act 2018 for
       their unlawful processing of your personal data: you could say
       that you will not file your claim with the County Court if they
       confirm in writing that all references to this alleged debt have
       been deleted within (say) 14 days. Clearly mark your letter as a
       "Letter before County Court proceedings".
       >
       > Anyone who is fairly confident can claim as a
       litigant-in-person in Part 27 proceedings in the County Court
       (commonly but wrongly described as "the Small Claims Court").
       Each party is responsible for their own legal costs whether they
       win or lose and the claim for £100 can be issued online for a
       fee of £35 at moneyclaimonline.gov.uk which also gives useful
       advice if you want to have a look at what is involved.  Your
       claim will automatically be listed as being for a total of £135,
       i.e. the successful party gets their Court fees back.
       --- End Quote ---
       #Post#: 34392--------------------------------------------------
       Re: PCN addressed to me for somewhere I have never been, car in
       images is not mine - Smart Parking Ltd
   DIR By: strawberrydoll
       Date: August 23, 2024, 1:18 pm
       ---------------------------------------------------------
       --- Quote from: DWMB2 link ---
       >
       > As a general rule, where there is a dispute over money,
       corresponding in writing is generally preferable to by phone, as
       you have a record of exactly what has been discussed.
       >
       > I would ordinarily recommend pointing the misread out but as
       this is Smart Parking, the quickest way is probably a template
       appeal. Can you show us the notice you have received?
       >
       > It will almost certainly not meet the requirements to hold the
       registered keeper liable, and if you appeal as the registered
       keeper with the below, they will almost certainly cancel the
       charge.
       >
       > [indent] Dear Sirs,
       >
       > I have received your Parking Charge Notice (Ref: ________) for
       vehicle registration mark ____ ___, in which you allege that the
       driver has incurred a parking charge. I note from your
       correspondence that you are not seeking to hold me liable as the
       registered keeper, under Schedule 4 of the Protection of
       Freedoms Act 2012 ("The Act"). You have chosen not to issue a
       Notice to Keeper in accordance with The Act, and it is now too
       late for you to do so.
       >
       > There is no obligation for me to name the driver and I will
       not be doing so. I am therefore unable to help you further with
       this matter, and look forward to your confirmation that the
       charge has been cancelled. If you choose to decline this appeal,
       you must issue a POPLA code.
       >
       > Yours,[/indent]
       >
       > Do please show us the notice before you appeal, I don't like
       recommending an appeal without double checking it is
       appropriate. You'll need to use a third party site like Imgur to
       upload the notice.
       >
       > You could if you wish add a line into that appeal before the
       main point, pointing out that it is not your vehicle and their
       faulty ANPR has led to them accessing your details without
       reasonable cause.
       >
       --- End Quote ---
       Thank you so much for your fast and friendly response! I have
       uploading the letter below- sorry it took me a moment.
  HTML https://i.imgur.com/sLc7jKP.jpeg
  HTML https://i.imgur.com/5YAWiHw.jpeg
       #Post#: 34393--------------------------------------------------
       Re: PCN addressed to me for somewhere I have never been, car in
       images is not mine - Smart Parking Ltd
   DIR By: strawberrydoll
       Date: August 23, 2024, 1:20 pm
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > You can also threaten them with a lawsuit for damages as they
       have illegally obtained your personal data in breach of the
       KADOE contract. By failing to perform a manual quality control
       check on the ANPR photographic evidence, they are in breach of
       their AOS Code of Practice which nullifies their KADOE contract.
       >
       > Threaten to sue them for £250 for breaching your GDPR and tell
       them you’ll accept £100 if they are prepared to settle within 14
       days of receipt of the letter.
       >
       > [quote]Article 12 of the UK GDPR legally requires data
       controllers to store and process personal data accurately:
       clearly, any data controller issuing an invoice to you because
       it has wrongly recorded that you parked in breach of the alleged
       contract between you and the landowner (or, as in this case, an
       agent of the landowner) is processing your personal data
       unlawfully.
       >
       > The precedents for claiming damages and compensation for such
       unlawful processing are the decisions of the Court of Appeal in
       Zeta Jones & Douglas v Hello! Magazine [2003] EWHC 786 and
       Halliday v Creation Consumer Finance Ltd (CCF) [2013] EWCA Civ
       333, both being binding on all County Courts in England and
       Wales.  In the latter claim, Mr Halliday was awarded
       compensation of £750 at what the Court regarded was the lowest
       level of award, and although this was a claim under Section 13
       of the Data Protection Act 1998, similar provisions - amended to
       take account of a decision by the EU Grand Chamber that the 1998
       Act did not properly implement EU law into UK domestic
       legislation - replaced the old Section 13 provisions with
       Article 12 of the UK GDPR and Section 168 of the Data Protection
       Act 2018.
       >
       > In short, you ought to give 21 days notice (the pre-action
       protocol only really requires 14 days but hey, you can be
       charitable!) to the data controller of your intention to seek
       (say) £100 nominal damages and compensation under Article 12 of
       the UK GDPR and Section 168 of the Data Protection Act 2018 for
       their unlawful processing of your personal data: you could say
       that you will not file your claim with the County Court if they
       confirm in writing that all references to this alleged debt have
       been deleted within (say) 14 days. Clearly mark your letter as a
       "Letter before County Court proceedings".
       >
       > Anyone who is fairly confident can claim as a
       litigant-in-person in Part 27 proceedings in the County Court
       (commonly but wrongly described as "the Small Claims Court").
       Each party is responsible for their own legal costs whether they
       win or lose and the claim for £100 can be issued online for a
       fee of £35 at moneyclaimonline.gov.uk which also gives useful
       advice if you want to have a look at what is involved.  Your
       claim will automatically be listed as being for a total of £135,
       i.e. the successful party gets their Court fees back.
       --- End Quote ---
       [/quote]
       Thank you also! Would adding this create any more of an issue?
       It would be nice to be compensated for the stress they've
       caused, but I don't want prolong the issue further and just be
       done with it.
       I appreciate your message very much.
       #Post#: 34395--------------------------------------------------
       Re: PCN addressed to me for somewhere I have never been, car in
       images is not mine - Smart Parking Ltd
   DIR By: DWMB2
       Date: August 23, 2024, 1:33 pm
       ---------------------------------------------------------
       Notice looks as expected.
       Whether you decide to sue them or not is your call, it's your
       personal data and your time.
       Out of interest, how clear are the images of the plate on the
       notice? I'm asking to rule out the possibility that your plates
       have been cloned, which is rare but does happen.
       #Post#: 34396--------------------------------------------------
       Re: PCN addressed to me for somewhere I have never been, car in
       images is not mine - Smart Parking Ltd
   DIR By: strawberrydoll
       Date: August 23, 2024, 1:37 pm
       ---------------------------------------------------------
       --- Quote from: DWMB2 link ---
       >
       > Notice looks as expected.
       >
       > Whether you decide to sue them or not is your call, it's your
       personal data and your time.
       >
       > Out of interest, how clear are the images of the plate on the
       notice? I'm asking to rule out the possibility that your plates
       have been cloned, which is rare but does happen.
       >
       --- End Quote ---
       Thank you.
       The plate is quite clear, I also thought my plates may have been
       cloned when I first saw the letter but it is not mine, it does
       seem to just have been read incorrectly. The "5" is especially
       very clear on their photo, where as on my plate it is a "6".
       #Post#: 34403--------------------------------------------------
       Re: PCN addressed to me for somewhere I have never been, car in
       images is not mine - Smart Parking Ltd
   DIR By: b789
       Date: August 23, 2024, 2:10 pm
       ---------------------------------------------------------
       It is your GDPR that has been breached. You will not be paying a
       penny to (not so) Smart. You have a valid claim for compensation
       and damages for breach of GDPR.
       If you’re happy to simply let Smart off the hook, your choice.
       Personally, I would not be so formal in my appeal and I would
       highlight why they cannot pursue the keeper under any assumption
       they were also the driver.
       --- Quote ---
       > I am the keeper of the vehicle and I dispute your 'parking
       charge'. I deny any liability or contractual agreement and I
       will be making a complaint about your predatory conduct to your
       client landowner.
       >
       > As your Notice to Keeper (NtK) does not fully comply with ALL
       the requirements of PoFA 2012, you are unable to hold the keeper
       of the vehicle liable for the charge. Partial or even
       substantial compliance is not sufficient. There will be no
       admission as to who was driving and no inference or assumptions
       can be drawn. Smart Parking has relied on contract law
       allegations of breach against the driver only.
       >
       > The registered keeper cannot be presumed or inferred to have
       been the driver, nor pursued under some twisted interpretation
       of the law of agency. Your NtK can only hold the driver liable.
       Smart have no hope at POPLA, so you are urged to save us both a
       complete waste of time and cancel the PCN.
       --- End Quote ---
       #Post#: 34411--------------------------------------------------
       Re: PCN addressed to me for somewhere I have never been, car in
       images is not mine - Smart Parking Ltd
   DIR By: DWMB2
       Date: August 23, 2024, 2:45 pm
       ---------------------------------------------------------
       Any appeal that makes mention of the fact they don't bother with
       PoFA will see them cancel.
       #Post#: 34426--------------------------------------------------
       Re: PCN addressed to me for somewhere I have never been, car in
       images is not mine - Smart Parking Ltd
   DIR By: strawberrydoll
       Date: August 23, 2024, 5:25 pm
       ---------------------------------------------------------
       I have to say I feel like I'm out of my depth a little, but why
       not give it a shot? Here's the template I've written
       --- Quote ---
       >
       > Letter before County Court proceedings
       >
       > Dear Sirs,
       > I have received your Parking Charge Notice (Ref: XXXXXXXXX)
       for vehicle registration mark XXXX XXX, in which you allege that
       the driver has incurred a parking charge. I note from your
       correspondence that you are not seeking to hold me liable as the
       registered keeper, under Schedule 4 of the Protection of
       Freedoms Act 2012 ("The Act"). You have chosen not to issue a
       Notice to Keeper in accordance with The Act, and it is now too
       late for you to do so.
       >
       > There is no obligation for me to name the driver and I will
       not be doing so. I am therefore unable to help you further with
       this matter, and look forward to your confirmation that the
       charge has been cancelled. If you choose to decline this appeal,
       you must issue a POPLA code.
       >
       > Furthermore, you have unlawfully obtained my personal data
       from The DVLA which, as a start, is in breach of your KADOE
       contract. I have never entered your car park and by failing to
       perform a manual quality control check on the ANPR photographic
       evidence, you are in breach of their AOS Code of Practice 22.2
       which nullifies your KADOE contract. I intend to submit a record
       of this incident to the Information Commissioner's Office, DVLA
       and KADOE, as you have threatened a parking charge to the
       incorrect address and vehicle, failing to review that the car in
       your photo has the registration mark “XXXX XXX”, a BLUE FORD and
       you have sent your parking charge letter using the personal
       details unlawfully obtained for the registered keeper of the
       mark “XXXX XXX”, a BLACK AUDI, myself.
       >
       > I am seeking £250 nominal damages and compensation under
       Article 12 of the UK GDPR and Section 168 of the Data Protection
       Act 2018 for your unlawful processing of my personal data. I am
       willing to accept a payment of £100 if a) the amount is settled
       within 14 days of the receipt of this letter and b) all of
       personal data and any copies are swiftly and permanently removed
       from your systems within the next 14 days. Please make a valid,
       current cheque payable to [my name] for the above amount. I
       intend to start County Court proceedings if this request is
       ignored, and you may be further liable to Court costs.
       >
       > Yours,
       > [my name]
       >
       --- End Quote ---
       I'll post it out on Monday and keep you both updated. Thanks so
       much for all the help!
       *****************************************************
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