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       #Post#: 49814--------------------------------------------------
       CN At Leeds Airpot
   DIR By: Faust
       Date: December 14, 2024, 12:14 pm
       ---------------------------------------------------------
       Hi.First of all thanks for previous ticket that I got cancelled
       with help from here. I dind't think I'll ask again for help.
       However, I started new job at Leeds airport working for
       construction site. Sadly I haven't been given clear instruction
       where workers are parked, and I had to stop to ask the workers
       about it.
       Sadly I have received Charge Notice that I have to pay £100
       fine. I heard from other workers that the company are refusing
       to sort this out. Or they say that it will get sorted, but then
       people get new letter for £170 fine.
       I don't want to rely on the company promise that it will get
       sorted, and want to appeal. And I don't think that saying I was
       working there will cancel my CN.
       Any advice  please?
       All photos of this case and photo of CN are attached on google
       drive link below:
  HTML https://drive.google.com/drive/folders/1-0CCxBvIOQFgaeMSjwEUFO5ztth3ApgB?usp=share_link
       Thanks.
       #Post#: 49818--------------------------------------------------
       Re: CN At Leeds Airpot
   DIR By: fraser.mitchell
       Date: December 14, 2024, 1:16 pm
       ---------------------------------------------------------
       You've got a private parking ticket, so you're in the wrong
       forum.
       I have requested that this be moved to the private tickets
       forum.
       #Post#: 49832--------------------------------------------------
       Re: CN At Leeds Airpot
   DIR By: Faust
       Date: December 14, 2024, 3:17 pm
       ---------------------------------------------------------
       --- Quote from: Incandescent link ---
       >
       > You've got a private parking ticket, so you're in the wrong
       forum.
       >
       > I have requested that this be moved to the private tickets
       forum.
       >
       --- End Quote ---
       Thanks, hope to get some help. Haven't appealed as I don't know
       what to write.
       #Post#: 49845--------------------------------------------------
       Re: CN At Leeds Airpot
   DIR By: b789
       Date: December 14, 2024, 5:48 pm
       ---------------------------------------------------------
       You have to understand that you are dealing with a vexatious
       firm of unscrupulous ex-clampers. They have no idea who was
       driving and you must not reveal that information to them.
       As the Registered Keeper, you are under no legal obligation to
       revel the drivers identity to an unregulated private parking
       company. VCS are not allowed to assume or infer that the Keeper
       must also be the driver.
       As the alleged contravention took place on airport land which is
       under statutory control, they cannot rely on PoFA to transfer
       liability from the unknown driver to you, the Keeper.
       Also, they are relying on contract law to say that the driver
       entered a contract with them. However, their signs are unable to
       form a contract because they are forbidding.
       So, you must write to the LBA airport management and complain
       vigorously about the actions of their agent, VCS, in issuing
       you, the Keeper, a Parking Charge Notice (PCN). As they did not
       form a contract with he driver, they have breached the KADOE
       contract with the DVLA and obtained your data unlawfully. That
       is a breach of your GDPR and unless the PCN is cancelled you
       will hold them jointly and severally liable for the action of
       their agent VCS and reserve the right to sue for compensation
       under the Data Protection Act 2018 (DPA).
       I suggest you send that complaint to the LBA CEO. Just remember,
       you are complaining as the Keeper who has received the PCN. No
       "I did this or that". You refer only to the driver in the third
       person "The driver did this or that".
       Before the deadline to appeal expires, if you have not heard
       back from the Airport, you send the follwingto VCS as your
       appeal (only appeal as the Keeper):
       --- Quote ---
       > I am the registered keeper. VCS cannot hold a registered
       keeper liable for any alleged contravention on land that is
       under statutory control. As a matter of fact and law, VCS will
       be well aware that they cannot use the PoFA provisions because
       Leeds Bradford Airport (LBS) is not 'relevant land'.
       >
       > If LBA wanted to hold owners or keepers liable under Airport
       Bylaws, that would be within the landowner's gift and another
       matter entirely. However, not only is that not pleaded, it is
       also not legally possible because VCS is not the Airport owner
       and your 'parking charge' is not and never attempts to be a
       penalty. It is created for VCS's own profit (as opposed to a
       bylaws penalty that goes to the public purse) and VCS 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.
       VCS have no hope at IAS, so you are urged to save us both a
       complete waste of time and cancel the PCN.
       --- End Quote ---
       It will be rejected but you will have put then on notice that
       you are not low-hanging fruit on the gullible tree and will be
       fighting them all the way. They will probably go as far as
       issuing a claim in the county court but you can be sure they
       will not see it through unless they want a spanking from the
       judge for bringing a case that has no hope of ever being
       successful. They are simply hoping that you will fold once they
       threaten litigation.
       #Post#: 49849--------------------------------------------------
       Re: CN At Leeds Airpot
   DIR By: Faust
       Date: December 14, 2024, 6:18 pm
       ---------------------------------------------------------
       Thanks for your help. So the message you have quoted is for
       appeal, is that correct ?
       I’ll need to find the email address to the airport of CEO. Can I
       ask please what should I write in the email to the airport?
       #Post#: 49875--------------------------------------------------
       Re: CN At Leeds Airpot
   DIR By: Faust
       Date: December 15, 2024, 5:51 am
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > You have to understand that you are dealing with a vexatious
       firm of unscrupulous ex-clampers. They have no idea who was
       driving and you must not reveal that information to them.
       >
       > As the Registered Keeper, you are under no legal obligation to
       revel the drivers identity to an unregulated private parking
       company. VCS are not allowed to assume or infer that the Keeper
       must also be the driver.
       >
       > As the alleged contravention took place on airport land which
       is under statutory control, they cannot rely on PoFA to transfer
       liability from the unknown driver to you, the Keeper.
       >
       > Also, they are relying on contract law to say that the driver
       entered a contract with them. However, their signs are unable to
       form a contract because they are forbidding.
       >
       > So, you must write to the LBA airport management and complain
       vigorously about the actions of their agent, VCS, in issuing
       you, the Keeper, a Parking Charge Notice (PCN). As they did not
       form a contract with he driver, they have breached the KADOE
       contract with the DVLA and obtained your data unlawfully. That
       is a breach of your GDPR and unless the PCN is cancelled you
       will hold them jointly and severally liable for the action of
       their agent VCS and reserve the right to sue for compensation
       under the Data Protection Act 2018 (DPA).
       >
       > I suggest you send that complaint to the LBA CEO. Just
       remember, you are complaining as the Keeper who has received the
       PCN. No "I did this or that". You refer only to the driver in
       the third person "The driver did this or that".
       >
       > Before the deadline to appeal expires, if you have not heard
       back from the Airport, you send the follwingto VCS as your
       appeal (only appeal as the Keeper):
       >
       > [quote]I am the registered keeper. VCS cannot hold a
       registered keeper liable for any alleged contravention on land
       that is under statutory control. As a matter of fact and law,
       VCS will be well aware that they cannot use the PoFA provisions
       because Leeds Bradford Airport (LBS) is not 'relevant land'.
       >
       > If LBA wanted to hold owners or keepers liable under Airport
       Bylaws, that would be within the landowner's gift and another
       matter entirely. However, not only is that not pleaded, it is
       also not legally possible because VCS is not the Airport owner
       and your 'parking charge' is not and never attempts to be a
       penalty. It is created for VCS's own profit (as opposed to a
       bylaws penalty that goes to the public purse) and VCS 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.
       VCS have no hope at IAS, so you are urged to save us both a
       complete waste of time and cancel the PCN.
       --- End Quote ---
       It will be rejected but you will have put then on notice that
       you are not low-hanging fruit on the gullible tree and will be
       fighting them all the way. They will probably go as far as
       issuing a claim in the county court but you can be sure they
       will not see it through unless they want a spanking from the
       judge for bringing a case that has no hope of ever being
       successful. They are simply hoping that you will fold once they
       threaten litigation.
       [/quote]
       I have formulated an email address to send to LBA customer care.
       Should I make any amendments ?
       --- Quote ---
       > I am writing to formally lodge a serious complaint regarding
       the actions of your appointed agent, Vehicle Control Services
       (VCS), in relation to a Parking Charge Notice (PCN) that has
       been unlawfully issued to me as the Keeper of the vehicle.
       >
       > VCS has obtained my personal data from the DVLA without lawful
       justification, as no contract was formed between the driver of
       the vehicle and VCS. This action constitutes a clear breach of
       the KADOE contract with the DVLA and, more importantly, a
       violation of my rights under the UK General Data Protection
       Regulation (GDPR).
       >
       > By unlawfully obtaining and processing my personal data, VCS
       has infringed upon the principles of data protection established
       by the Data Protection Act 2018 (DPA). As the principal party
       responsible for the actions of your agent, I hold Leeds Bradford
       Airport (LBA) jointly and severally liable for this breach.
       >
       > I demand the immediate cancellation of the PCN and the
       cessation of any further misuse of my personal data. Failure to
       resolve this matter promptly will leave me with no choice but to
       pursue my rights under the DPA, which may include seeking
       compensation for the misuse of my personal information.
       >
       > Please treat this as a formal complaint and provide a response
       within [X] days. I expect a clear resolution to this matter,
       including confirmation of the cancellation of the PCN and
       details of the corrective measures being taken to prevent
       further breaches.
       >
       > I trust this matter will receive the urgency it warrants.
       Should you require any further information, I am available to
       discuss this at your earliest convenience.
       >
       > Yours sincerely,
       --- End Quote ---
       #Post#: 49887--------------------------------------------------
       Re: CN At Leeds Airpot
   DIR By: b789
       Date: December 15, 2024, 7:32 am
       ---------------------------------------------------------
       I'd suggest you use the following which incorporates the fact
       that the driver was newly employed to work on a construction
       site at the airport:
       --- Quote ---
       > Mr Vincent Holder
       > Chief Executive Officer
       > Leeds Bradford Airport
       > Whitehouse Lane
       > Yeadon
       > Leeds
       > LS19 7TU
       >
       > Subject: Formal Complaint Regarding Unlawful and Unfair
       Parking Charge Notice [PCN number]
       >
       > Dear Mr Hodder,
       >
       > I am writing as the Registered Keeper of a vehicle that has
       been issued a Parking Charge Notice (PCN) by Vehicle Control
       Services Ltd (VCS), acting as your agent at Leeds Bradford
       Airport.
       >
       > The alleged contravention occurred on 5th December 2024, and
       the PCN was subsequently issued to me, the Keeper. I am raising
       a formal complaint on two key grounds: the unfairness of the
       circumstances surrounding this PCN's issuance and the legal and
       procedural concerns about its validity.
       >
       > Unfair Circumstances Surrounding the Issuance of the PCN
       >
       > The driver of the vehicle, who was newly employed to work on a
       construction site at the airport, was unfamiliar with the area
       and had not been given adequate instructions about where workers
       were permitted to park. While attempting to navigate the
       situation, the driver briefly stopped to request directions from
       colleagues.
       >
       > It is deeply unfair for a PCN to have been issued under such
       circumstances. A simple act of seeking assistance, which did not
       obstruct operations or violate any reasonable expectation of
       airport use, should not result in the disproportionate penalty
       of £100 (or an even higher demand if left unresolved). This
       treatment reflects poorly on the airport and its contractors and
       creates unnecessary hardship for individuals who are already
       working to support your operations.
       >
       > Legal and Procedural Issues with the PCN
       >
       > In addition to the unfair nature of this PCN, I have serious
       concerns about its validity under applicable laws and
       regulations:
       >
       > [indent]• No Keeper Liability Under Protection of Freedoms Act
       2012 (PoFA):
       >
       > The alleged contravention occurred on airport land, which is
       under statutory control. Consequently, VCS cannot rely on PoFA
       to transfer liability from the unknown driver to me, the Keeper.
       I cannot lawfully be held liable for this charge.
       >
       > • No Contract Formed with the Driver:
       >
       > VCS’s reliance on contract law is flawed. The signage at the
       site is prohibitive in nature and incapable of forming a binding
       contract with the driver. Therefore, no contractual relationship
       existed between VCS and the driver to justify this charge.
       >
       > • Unlawful Access to Keeper Data:
       >
       > Since there is no lawful basis for holding the Keeper liable,
       VCS has breached its KADOE contract with the DVLA by unlawfully
       accessing my personal data. This represents a clear violation of
       the General Data Protection Regulation (GDPR) and the Data
       Protection Act 2018 (DPA).[/indent]
       >
       > As the landowner and principal, Leeds Bradford Airport is
       responsible for the actions of its agent, VCS. Their conduct,
       particularly under the circumstances outlined above, reflects
       poorly on the airport’s reputation.
       >
       > I request that you:
       >
       > [indent]• Instruct VCS to cancel this PCN immediately and
       confirm this in writing.
       > • Review the practices of VCS to ensure fairness and
       compliance with applicable laws and regulations in the
       future.[/indent]
       >
       > Failure to address this matter adequately will leave me with
       no choice but to escalate my complaint to the Information
       Commissioner’s Office (ICO) and consider pursuing compensation
       under the Data Protection Act 2018 for the unlawful use of my
       personal data.
       >
       > Please confirm receipt of this complaint and provide a
       response within 14 days.
       >
       > Yours sincerely,
       >
       > [Your Full Name]
       --- End Quote ---
       I suggest you send it as a PDF attachment in an email to the
       CEO, Vincent Hodder, at vincent.hodder@lba.co.uk and also CC in
       yourself. Let him or one of his minions sort this out for you.
       #Post#: 49904--------------------------------------------------
       Re: CN At Leeds Airpot
   DIR By: Faust
       Date: December 15, 2024, 8:13 am
       ---------------------------------------------------------
       Thanks, all sent in PDF file. Should I make an appeal as well,
       or should I wait for now ? Don't think I will receive an
       response any time soon, especially with Christmas on the door
       steps.
       #Post#: 49912--------------------------------------------------
       Re: CN At Leeds Airpot
   DIR By: b789
       Date: December 15, 2024, 8:27 am
       ---------------------------------------------------------
       You can make the appeal if you have not had a response by the
       deadline. You have until Tuesday 6th January to submit an
       appeal.
       #Post#: 49942--------------------------------------------------
       Re: CN At Leeds Airpot
   DIR By: Faust
       Date: December 15, 2024, 10:18 am
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > You can make the appeal if you have not had a response by the
       deadline. You have until Tuesday 6th January to submit an
       appeal.
       >
       --- End Quote ---
       Thanks a lot for your help. I will wait a response, and keep
       this topic updated.
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