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       #Post#: 34597--------------------------------------------------
       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 26, 2024, 7:58 am
       ---------------------------------------------------------
       Any complaint must be looked at as an appeal according to their
       CoP, so no need to appeal separately. Show us their response.
       You won’t be able to make an ICO complaint until you’ve received
       their response to your complaint. However, you certainly should
       make the ICO complaint, explaining how they’ve obtained your
       data unlawfully by breaching the KADOE contract.
       The DVLA complaint can be submitted immediately. As well as
       SARing Smart, you should also SAR the DVLA to see which
       operators and when, obtained your data.
       The complaint to Smart should be emailed as a PDF attachment and
       you should also CC it to yourself as evidence of it having been
       sent.
       If they do cancel the PCN but do not offer compensation for
       their unlawful access to your data, you can the send them a
       Letter of Claim for a specified sum for damages under the Data
       Protection Act 2018. As explained earlier, this is a straight
       forward process should you want to follow up on and is done
       online through the Money Claims On Line (MCOL) website. A claim
       for up to £300 costs £35 and if successful, the fee is also paid
       back by the defendant.
       Whether you follow through with a claim, is up to you. However,
       simply sending them an LoC gives them a taste of their own
       medicine and they don’t like it.
       #Post#: 34604--------------------------------------------------
       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 26, 2024, 9:23 am
       ---------------------------------------------------------
       --- Quote ---
       > Any complaint must be looked at as an appeal according to
       their CoP, so no need to appeal separately.
       --- End Quote ---
       Whilst this is true, if I were erring on the side of caution, I
       would submit an appeal as well via their portal, just so that
       the charge is cancelled and the OP can then focus on any
       complaints they wish to pursue without the actual charge still
       being in play.
       I'm mindful of us not losing sight of that amongst the other
       (entirely valid) grievances.
       #Post#: 34610--------------------------------------------------
       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 26, 2024, 10:31 am
       ---------------------------------------------------------
       I respectfully disagree. BPA CoP section 23.23 specifically
       states the following:
       --- Quote ---
       > Where you receive a complaint that you consider to
       > be or include an appeal against the validity of a parking
       > charge notice, you must also treat it as an appeal for the
       > purposes of applying the timescales in Clause 23.8, and
       > should inform the complainant as such unless and until it
       > is clear that the complaint is not relevant to an appeal or
       > the complainant informs you that they do not wish it to
       > be so handled.
       >
       > It might not be immediately apparent that a complaint
       > served as such relates to one or more specific parking
       > charge notices, possibly by way of a clarification that
       > reveals that an appeal would be worthwhile, hence you
       > are advised to record and handle complaints as appeals
       > until they are found conclusively not to be so or patently
       > refer to matters not relevant to the validity of a parking
       > charge notice.
       --- End Quote ---
       The primary concern in this case is the operator's unlawful
       handling of the keepers data. By focusing solely on a complaint
       about the misuse of the keepers data under GDPR, it emphasises
       the most critical issue: the operator’s breach of legal
       obligations by not manually checking the ANPR images and thereby
       misidentifying the wrong vehicle.
       The operator's breach of the BPA Code of Practice (failure to
       manually check ANPR images as required under Section 21.5a) and
       the subsequent unlawful request for the keepers data from the
       DVLA should be the sole focus. By merging a complaint with an
       appeal, the main issue of data misuse could be diluted or lost.
       Filing an appeal, even when separate from a complaint, could be
       perceived as engaging with the parking charge's legitimacy. This
       could inadvertently imply that there is a valid case to answer,
       which is contrary to the assertion that the vehicle is not the
       keepers.
       An appeal suggests that the alleged parking contravention has
       some basis for discussion. By appealing, the keeper may
       inadvertently signal that there is a legitimate issue to
       address, which could weaken their position that the parking
       charge is entirely unfounded due to a fundamental identification
       error.
       Maintaining a consistent stance that the parking charge is
       completely irrelevant to the keeper because the vehicle in
       question is not theirs is crucial. A separate appeal could
       create mixed messages or confusion regarding their position.
       To remain consistent, it is important to only address the issue
       of unlawful data handling. If the keeper appeals separately, it
       could create ambiguity about their position and suggest a
       willingness to engage with a process that they believe is
       fundamentally flawed due to the misidentification.
       Separating a complaint and an appeal could provide the operator
       with multiple opportunities to argue their case. They might use
       any response to an appeal to bolster their procedural stance,
       rather than focusing on their failure to adhere to the BPA Code
       of Practice and data protection laws.
       A separate appeal could give the operator a chance to frame the
       situation as a standard parking dispute rather than addressing
       the core issue of their procedural failures and data misuse. By
       focusing only on a complaint about unlawful data handling, the
       keeper forces the operator to directly address their compliance
       failures rather than deflecting to the merits of a parking
       charge.
       Data protection laws, particularly GDPR, have significant legal
       weight. Emphasising a complaint based on GDPR breaches is be
       more powerful and more likely to result in meaningful
       repercussions for the operator than a standard appeal process.
       GDPR violations are taken very seriously and can result in
       substantial penalties for the offending party. By focusing the
       keepers efforts on a data protection complaint, thy highlight
       the operator's severe misconduct and increase the likelihood of
       regulatory scrutiny and potential sanctions, which may be more
       effective in resolving the matter than an appeal.
       This requires a focused strategy on the operator’s significant
       breach of data protection laws and procedural failings. By only
       complaining and not submitting a separate appeal helps to avoid
       any potential confusion or implication of liability on the
       keepers part, ensuring that their main concern — unlawful data
       handling and compliance failures — remains the priority.
       #Post#: 34612--------------------------------------------------
       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 26, 2024, 10:49 am
       ---------------------------------------------------------
       My suggestion is based more on pragmatism, in case the OP is
       particularly strapped for time and just needs the charge to go
       away with as little time required as possible. I don't think a
       dual-pronged approach, worded well, would create any ambiguity.
       - Appeal: The charge issued is entirely illegitimate because
       it's not my vehicle, and should clearly be cancelled
       - Complaint: By failing to manually check the information
       generated by the dodgy ANPR system, you have wrongly processed
       my personal data, for which I want some sort of recourse.
       As a slightly more general aside, I've never bought into the
       view that engaging with an appeal process affords legitimacy to
       the charge being appealed, especially when the purpose of an
       appeal in this case is to point out why the charge is not
       legitimate. I've also never seen any cases be negatively
       affected by any inference that appealing affords legitimacy to a
       charge.
       This being Smart Parking, I think there's a fair chance either
       of our approaches will lead to the actual charge being
       cancelled, as we both know Smart have little appetite for all
       but the most simple cases, so with that in mind, we can probably
       safely agree to disagree for now.
       #Post#: 35798--------------------------------------------------
       Re: PCN addressed to me for somewhere I have never been, car in
       images is not mine - Smart Parking Ltd
   DIR By: strawberrydoll
       Date: September 5, 2024, 11:41 am
       ---------------------------------------------------------
       Thank you both so much for your amazing help!
       I sent the letter to their complaints inbox and I have just had
       the cancellation email from Smart Parking just now which is a
       massive relief. Sadly they did just gloss over the compensation
       part. I'll send another email asking to be compensated again in
       the coming week.
       Here's their email.
       --- Quote ---
       >
       > Good afternoon
       >
       >
       >
       > Thankyou for your recent communication.
       >
       >
       >
       > We would like to apologise for the error, and I can confirm
       the PCN has been cancelled. A letter stating so will be sent to
       you in due course.
       >
       >
       >
       > I can also confirm deletion of your data.
       >
       >
       >
       > Kind Regards,
       >
       --- End Quote ---
       #Post#: 35803--------------------------------------------------
       Re: PCN addressed to me for somewhere I have never been, car in
       images is not mine - Smart Parking Ltd
   DIR By: b789
       Date: September 5, 2024, 12:06 pm
       ---------------------------------------------------------
       Which letter did you eventually send them? Was it the complaint
       one with the three demands, two of which they have complied with
       but failed to offer any compensation?
       You still have the right to sue them for any distress and
       anxiety this has caused you. It just depends on whether you are
       up for the fight with our assistance.
       I have updated the article on ow and why anyone should sue a PPC
       for breach of their GDPR and I repeat it below for your
       consideration:
       --- Quote ---
       > Article 5(1)(d) of the UK GDPR legally requires data
       controllers to store and process personal data accurately. If a
       data controller, such as a private parking company, unlawfully
       obtains the keeper's data from the DVLA and issues an invoice
       based on inaccurate information, claiming you parked in breach
       of an alleged contract with the landowner (or their agent), this
       constitutes processing your personal data inaccurately and
       unlawfully under the UK GDPR.
       >
       > The precedents for claiming damages and compensation for such
       unlawful processing of personal data can be found in cases like
       Halliday v Creation Consumer Finance Ltd [2013] EWCA Civ 333,
       where the court awarded compensation for distress caused by the
       inaccurate processing of personal data under the Data Protection
       Act 1998. Although this case was decided under the old law,
       similar principles apply under the UK GDPR and the Data
       Protection Act 2018. Under Article 82 of the UK GDPR and Section
       168 of the Data Protection Act 2018, individuals have the right
       to compensation if they suffer material or non-material damage
       because of a breach of data protection laws.
       >
       > Additionally, the case of Vidal-Hall v Google Inc [2015] EWCA
       Civ 311 confirmed that claimants could recover compensation for
       distress alone under the Data Protection Act 1998, a principle
       now similarly recognised under the GDPR. This means that even if
       you have not suffered tangible financial loss, you may still be
       entitled to compensation for distress caused by the unlawful
       processing of your data.
       >
       > Moreover, in Tetragon Financial Group Limited v Revenue and
       Customs Commissioners [2020] UKUT 0305 (TCC), the court
       reiterated the importance of accurate data handling by public
       bodies. This principle can be applied here, as the DVLA, a
       public body, must ensure that any data it provides to third
       parties, such as private parking companies, is used lawfully and
       accurately. If a private parking company unlawfully obtained
       your data from the DVLA and processed it inaccurately, you have
       grounds to seek compensation.
       >
       > To seek compensation for the unlawful processing of your
       personal data, you should provide 21 days’ notice (the
       pre-action protocol typically requires 14 days, but a longer
       notice can show goodwill) to the data controller, in this case,
       the private parking company, of your intention to claim damages.
       You might claim up to £300 for nominal damages under Article 82
       of the UK GDPR and Section 168 of the Data Protection Act 2018.
       This notice should clearly state that you will file a claim with
       the County Court if they do not confirm in writing that all
       references to this alleged debt have been deleted within 14
       days. Be sure to mark your letter as a "Letter before County
       Court proceedings."
       >
       > As a litigant-in-person, you can file your claim under Part 27
       proceedings in the County Court (often referred to as the "Small
       Claims Court"). Each party is responsible for their own legal
       costs, regardless of the outcome, and the claim can be filed
       online for a fee of £35 (for a claim up to £300) via the Money
       Claim Online service (moneyclaimonline.gov.uk
  HTML https://www.moneyclaim.gov.uk/web/mcol/welcome).
       The successful
       party can recover their court fees, making the total claim
       amount £335.
       --- End Quote ---
       #Post#: 35808--------------------------------------------------
       Re: PCN addressed to me for somewhere I have never been, car in
       images is not mine - Smart Parking Ltd
   DIR By: strawberrydoll
       Date: September 5, 2024, 12:21 pm
       ---------------------------------------------------------
       It was indeed the one with the three demands, and yes they
       complied with the first two points and ignored the third point.
       Understood, so I just send them a letter of claim with the title
       Letter before County Court proceedings asking for a fixed amount
       of compensation for the stress they caused and go from there? Or
       do I send a letter just claiming without any mention of court?
       I'm happy to start a claim if it means I get some compensation
       back for the mini heartattack they caused. Thank you.
       #Post#: 35812--------------------------------------------------
       Re: PCN addressed to me for somewhere I have never been, car in
       images is not mine - Smart Parking Ltd
   DIR By: b789
       Date: September 5, 2024, 12:34 pm
       ---------------------------------------------------------
       Don't rush into this. You have to consider it carefully. By
       making a claim using MCOL, if you are unsuccessful, it will have
       cost you £35 for a claim of up to £300. Obviously, if you are
       successful, you will get the £35 back together with the amount
       that the judge agrees they are liable for.
       If you do want to go ahead, you will need to issue an LoC which
       we can draft for you. Should they not respond or fail to
       compensate you, then you will have to file the claim on the MCOL
       website yourself. It is a very straightforward process but does
       require a bit of an idea of what is involved. The Particulars of
       Claim (PoC) will have to be carefully crafted and more likely
       than not will require you to send more detailed PoC within 14
       days of the claim as the webform on MCOL has severe limitations.
       It is not an issue and we are happy to assist but please
       remember, we are not lawyers and it is not our £35 that is at
       risk. If you feel up to it, let us know.
       In the meantime, give smart 7 days to send the letter they
       mention. If they haven't sent anything or it does not answer the
       question about compensation, then we can proceed with with an
       LoC.
       #Post#: 35817--------------------------------------------------
       Re: PCN addressed to me for somewhere I have never been, car in
       images is not mine - Smart Parking Ltd
   DIR By: strawberrydoll
       Date: September 5, 2024, 12:51 pm
       ---------------------------------------------------------
       Understood, I do appreciate the help very much. I'll think over
       it and wait for the letter from them, I'll update this post next
       week.
       #Post#: 36452--------------------------------------------------
       Re: PCN addressed to me for somewhere I have never been, car in
       images is not mine - Smart Parking Ltd
   DIR By: strawberrydoll
       Date: September 11, 2024, 10:02 am
       ---------------------------------------------------------
       I have received the letter
  HTML https://i.imgur.com/cjZJCJa.png
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