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#Post#: 95516--------------------------------------------------
Alliance Parking PCN – No Permit – Caer Street, Swansea
By: calklein Date: October 25, 2025, 6:51 am
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Hello All
I've come here to ask some advice regarding a Trace Debt
Recovery letter received this morning, letter dated 17 Oct 2025.
I am the registered keeper of a vehicle which Alliance Parking
claimed parked without a permit on 02 December 2023.
I have not received any PCN or NtK
The only communication has been the "invoice" from Trace.
I have written to Alliance for a DSAR as I'm hoping to see that
they have confirmation of any letters as I live at the address
the vehicle is registered to and have not received anything from
them relating to this violation from 2023.
Should I also request anything else? Is there another avenue I
should follow or just await the outcome of the DSAR?
Thanks
#Post#: 95570--------------------------------------------------
Re: Alliance Parking PCN – No Permit – Caer Street, Swansea
By: b789 Date: October 25, 2025, 2:49 pm
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You can safely ignore anything and everything from Trace. They
are a powerless debt collector and can only try and intimidate
the low-hanging fruit on the gullible tree into paying out of
ignorance and fear.
Whilst a DSAR is OK, I would have advised you send a formal
complaint about non-receipt of the original Notice to Keeper
(NtK) and put them to strict proof of posting and asking for a
copy of the original. A DSAR will get you a copy but likely
without the required proof of posting. Service of the NtK is a
rebuttable presumption. Whilst it is deemed to have been "given"
two working days after it was issued, by rebutting that
presumption, the burden of proof falls on them to prove posting
or delivery.
You may want to check your V5C registration document. Often, the
reason for not receiving the PCN is because after the last move,
you may have failed to update the address with the DVLA.
Updating a drivers licence does not automatically update the
V5C.
When you receive the copy of the NtK (only the original, not any
reminder, is relevant), show it to us.
#Post#: 95583--------------------------------------------------
Re: Alliance Parking PCN – No Permit – Caer Street, Swansea
By: calklein Date: October 25, 2025, 4:46 pm
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Hi b789
After writing this, I did see some of your other replies and
comments on MSE forums advising to make a complaint (not an
appeal, and to not admit who was the driver) so I have sent an
email complaint to the complaints email and cc’d myself as
proof.
Have asked them for copies of all letters etc with proof of
posting.
Once I have a response I will update here.
Thanks for your reply and information in the other posts.
#Post#: 106364--------------------------------------------------
Re: Alliance Parking PCN – No Permit – Caer Street, Swansea
By: calklein Date: January 18, 2026, 6:13 am
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Sorry to type again on an old post of mine, but there has been a
development
I've now received a letter before claim on this from moorside
legal.
There have been no responses to any of my other emails just the
letter before claim.
Any one know what I should do, it is really worrying me now
#Post#: 106365--------------------------------------------------
Re: Alliance Parking PCN – No Permit – Caer Street, Swansea
By: jfollows Date: January 18, 2026, 6:16 am
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Please show us the original Notice to Keeper.
If you don’t have it, your response to the Letter before Claim
needs to include a requirement for the appropriate
documentation.
See
HTML https://www.ftla.uk/private-parking-tickets/letter-before-claim-moorside-legal/msg103742/#msg103742<br
/>and modify the response contained in it to match your
circumstances.
If you post your proposed response here I expect you’ll get
comments on it.
#Post#: 106369--------------------------------------------------
Re: Alliance Parking PCN – No Permit – Caer Street, Swansea
By: calklein Date: January 18, 2026, 6:27 am
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Hi,
Thanks for your reply.
There was no notice to keeper, it was from December 2023 and
even though I have asked for a copy of the NTK and that never
arrived.
I will draft something and upload it for review :)
Thanks
#Post#: 106372--------------------------------------------------
Re: Alliance Parking PCN – No Permit – Caer Street, Swansea
By: calklein Date: January 18, 2026, 6:47 am
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This is what I gathered is needed ??
Dear Sirs,
Your Letter Before Claim contains insufficient detail of the
claim and fails to provide copies of evidence your client places
reliance upon and thus is in complete contravention of the
Pre-Action Protocol for Debt Claims.
As a firm of supposed solicitors, one would expect you to be
capable of crafting a letter that aligns with paragraphs
3.1(a)–(d), 5.1 and 5.2 of the Protocol, and paragraphs 6(a) and
6(c) of the Practice Direction. These provisions do not exist
for decoration—they exist to facilitate informed discussion and
proportionate resolution. You might wish to reacquaint
yourselves with them.
The Civil Procedure Rules 1998, Pre-Action Conduct and Protocols
(Part 3), stipulate that prior to proceedings, parties should
have exchanged sufficient information to understand each other’s
position. Part 6 helpfully clarifies that this includes
disclosure of key documents relevant to the issues in dispute.
Your template letter mentions a “contract”, yet fails to provide
one. This would appear to undermine the only foundation upon
which your client’s claim allegedly rests. It’s difficult to
engage in meaningful pre-litigation dialogue when your side
declines to furnish the very document it purports to enforce.
I confirm that, once I am in receipt of a Letter Before Claim
that complies with the requirements of para 3.1 (a) of the
Pre-Action Protocol, I shall then seek advice and submit a
formal response within 30 days, as required by the Protocol.
Thus, I require your client to comply with its obligations by
sending me the following information/documents:
1. A copy of the original Notice to Keeper (NtK) that confirms
any PoFA 2012 liability
2. A copy of the contract (or contracts) you allege exists
between your client and the driver, in the form of an actual
photograph of the sign you contend was at the location on the
material date, not a generic stock image
3. The exact wording of the clause (or clauses) of the terms and
conditions of the contract(s) which is (are) relied upon that
you allege to have been breached
4. The written agreement between your client and the landowner,
establishing authority to enforce
5. A breakdown of the charges claimed, identifying whether the
principal sum is claimed as consideration or damages, and
whether the £70 “debt recovery” fee includes VAT
I am clearly entitled to this information under paragraphs 6(a)
and 6(c) of the Practice Direction. I also need it in order to
comply with my own obligations under paragraph 6(b).
If your client does not provide me with this information then I
put you on notice that I will be relying on the cases of Webb
Resolutions Ltd v Waller Needham & Green [2012] EWHC 3529 (Ch),
Daejan Investments Limited v The Park West Club Limited (Part
20) Buxton Associates [2003] EWHC 2872, Charles Church
Developments Ltd v Stent Foundations Limited & Peter Dann
Limited [2007] EWHC 855 in asking the court to impose sanctions
on your client and to order a stay of the proceedings, pursuant
to paragraphs 13, 15(b) and (c) and 16 of the Practice
Direction, as referred to in paragraph 7.2 of the Protocol.
Until your client has complied with its obligations and provided
this information, I am unable to respond properly to the alleged
claim and to consider my position in relation to it, and it is
entirely premature (and a waste of costs and court time) for
your client to issue proceedings. Should your client do so, then
I will seek an immediate stay pursuant to paragraph 15(b) of the
Practice Direction and an order that this information is
provided.
Please note, I will not engage with any web portal; I will only
respond by post.
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